Vessels with Ballast Water Treatment Systems installed and planned to sail to US waters, need to comply with both regulations.

  • US EPA VGP 2013
  • IMO BWM.2/Circ.70

Vessels sailing in US waters must comply with the US maritime regulations (EPA VGP 2013), just for the simple reason that the US is not a signatory of the Ballast Water Management (BWM) Convention.

In order to comply with the regulations, the discharge water from BWTS need to be tested in order to confirm Biological Efficacy, and that the system is operated in accordance with the standards and requirements.

By performing the discharge water testing the specialist ( can check the mechanical, physical, chemical and biological process of the BWTS, and compliance with regulations, It is recommended that the Sampling and Testing is performed by a independent test facility, accredited and certified to perform the tests required. See for more info.

24Marine will verify that your BWMS is operated in accordance with performance and standards at discharge as per USCG  and IMO.

Different type of systems (Chlorine, Ozone, Electrolytic, Ultraviolet, Pasteurization, etc) require different type of tests, sampling and check procedures.

When the test are performed by land based facility (Accredited Laboratory) it is really important to hire a specialist (trained) water sampling specialist, in order to collect, filed test, preserve, transport, document and deliver the samples to the lab following the standards. If the Sampling procedures are not followed by standards the sample can be declared as not valid.

Cargo Tanks – Drone Inspection

Drones and UAV offer a very real solution for the inspection of confined areas, such as tanks / cargo holds. Traditional inspection of these tanks is a laborious, expensive and poses many potential risks. The use of a drone revolutionises the time  needed and the the safety of cargo tanks and cargo holds inspection.

By performing tanks  and cargo holds inspections using drones the specialist ( can check the the real time conditions of places that are not accesible by normal human conditions.

A drone can be quickly deployed to capture images and video to allow asset inspectors to view all internal spaces. This includes fitting pipes, wall and bulkheads junctions, welding, structural members, without the need for workers to spend time in a highly hazardous environment,  workinng at high.

Industry statistics shows that 98% of the costs are related to HSE and preparation, only 2% to the inspection itself. By removing the need for staging, scaffolding, downtime and the time is taken for humans to enter confined spaces leads to a cost reduction that amounts to hundreds of thousands of dollars

Traditional cargo tank inspection takes days to implement. Tank inspections carried out by a drone can take as little as two hours per tank. or cargo hold.

WHAT IS IHM (Inventory of Hazardous Material)?

IHM is a list that provides ship-specific information on the actual hazardous materials present on board, their location, and approximate quantities onboard vessels.

The purpose of an IHM survey is to provide ship owners, managing agents, crews, engineers, and workers with a management report of all the hazardous materials which, are on-board the vessel.

The main materials that the IHM survey covers:

  • Asbestos
  • PCB’s
  • TBT’s
  • ODS.
  • PCT
  • PBB
  • lead in paint.

The IHM has the following parts:

  • PART I: Materials contained in ship structure or equipment
  • PART II: Operationally generated wastes, and
  • PART III: Stores

The IHM Part I shall be prepared and certified for new ships and ships in operation and shall be maintained and kept up to date during the operational life of the ship, while the IHM Part II & III are only required to be prepared when the ship is decided to be sent for recycling. For the preparation of IHM Part I, hazardous materials set out in appendix 1 and 2 of the HKC or Annex I and II of the EU SRR shall be investigated.
The picture below shows part I, part II and part III.

IHM Part I for new ships should be developed at the design and construction stage based on suppliers’ declarations on the hazardous material content of the products. The determination of hazardous materials present on board existing ships should, as far as practicable, be conducted as prescribed for new ships. Alternatively, in the case where documentation is not available, samples shall be taken from the ships to investigate the hazardous materials.
For new ships, all the hazardous materials listed in Appendix 1 & 2 or Annex I & II shall be investigated, while for ships in operation Appendix 1 / Annex I is a must, and Appendix 2 / Annex II is to be investigated as far as practicable.

There are two main legislations with respect to ship recycling in the market, one is IMO Hong Kong Convention (HKC) SR/CONF/45 and the other one is the EU Ship Recycling Regulation (EU SRR) EC No 1257/2013. HKC has in total of 6 guidelines and MEPC.269(68) is the guidelines for the development of the inventory of hazardous materials (IHM) under IMO.

The Hong Kong Convention:

It will enter into force 24 months after the date on which the following conditions are met:

  1. Signed by at least 15 states;
  2. The combined merchant fleets of the signatory states are not less than 40% of the GT of the world’s merchant shipping,
  3. The combined maximum annual ship recycling volume of the signatory states, during the preceding 10 years, is not less than 3% of the GT of the combined merchant shipping of the same states.

The entry into force conditions of HKC is not met yet (Aug 2020) and its compliance is on a voluntary basis.
HKC will apply to ships, operating in the marine environment, which is equal to or above 500 GT. Navy ships and domestic ships are excluded from the scope.

According to the EU Ship Recycling Regulations:

  1. New ships flying a flag of an EU member state, shall be delivered with a valid IHM which is certified;
  2. End-of-life ships going for recycling shall have a valid IHM certified and shall be sent to one of the recycling facilities in the EU List of approved ship recycling facilities.
  3. Existing ships flying the flag of an EU member state and third-party ships visiting EU ports and anchorages, from 31 December 2020, shall have a valid IHM on-board, which is certified.

“New ship” means a ship for which either:

  • the building contract is placed on or after the date of application of this Regulation;
  • in the absence of a building contract, the keel is laid or the ship is at a similar stage of construction six months after the date of application of this Regulation or thereafter; or
  • the delivery takes place thirty months after the date of application of this Regulation or thereafter.

Cargohold Condition Survey with Virtual Reality

Every vessel or offshore installation, no matter the size and type, has a high potential accident opportunity. While the seaman, surveyors, contractors may be experts in one area, they may not be fully aware of the dangers and potential accidents that can happen onboard.

We in 24marine strongly believe that virtual reality can contribute to decrease the number of preventable accidents and bring a new dimension of details on the survey reporting systems. It has the potential to document conditions, detect failures, perform tests, and save lives in the long-term.

In the video below 24marine team conducted a Virtual Reality Survey on a Cargo Hold, using Enterprise Level Drones and Virtual Reality post-processing referring the spaces to the vessel drawings.  To navigate virtually inside the cargo hold, please click on this link

Cargohold inspection with Virtual Reality by

The virtual replication of the surveys spaces allows decision makers to assess the survey areas, in details and without risking any life, a part of introducing big savings on scaffolding, equipment and preparation time. Below a summary of benefits of using virtual reality in cargo hold and confined spaces onboard ships:

  1. Increase quality.
    Virtual reality offers a common spatial experience that leads to better decision-making. Because there are almost no misinterpretations.
  2. Save time and money.
    By allowing a better pre-planning stage, as drones and virtual reality crew and sets are reduced compared with other techniques as scaffolding, ropes crews, cherry-pickers.
  3. Improve survey review.
    The inspected area gets recorded in real time (real life), can be analyzed and re-analyzed as many times as required.
  4. Reduce downtime.
    Surveys performed by drones and Virtual Reality, reduced the impact of surveys times on vessels busy and tied schedules.

Fish Census by ROV

The motion capabilities by ROVs provides new possibilities in surveying methodology not capable by other deep-water (>30 m) or video-based survey techniques. ROV-based sampling strategies often reflected the aims of the study, which could be classified into six major types (Study at the University of Tasmania, Australia

  1. Surveys in natural habitats,
  2. Surveys on artificial structures,
  3. Surveys in marine protected areas
  4. Opportunistic/exploratory surveys without the use of transects,
  5. Studies that evaluate the effectiveness of ROVs, and
  6. Studies that compare ROVs with other survey methods

ROV can make fish react in different ways, (attraction or avoidance). Studies suggest that most species (68%) behaved neutrally towards the vehicles. But the other 32% Responses to ROV are related to the following factors:

  1. Fish species
  2. Size-specific
  3. ROV Illumination
  4. Thrusters sound emission
  5. Speed of the vehicle
Fish Census by ROV

During Fish Census apart from the Size and Number the most important factor to check is fish health.

  • Regular observation allows farmers to monitor welfare for fish, feeding processes, water conditions and fish behavior.
  • Healthy fishes are profitable farms.
  • Finding symptoms early by monitoring fish behavior, can reduce big losses.
  • Infectious diseases are one of the biggest causes of Loss.

ROV surveys allow for systematic inspection of the sampling area. It is potentially useful where rapid assessments of species diversity within a complex habitat are required.

For more information please go to, and for many articles check

Case Study: Deadly Fall Into Water While Rigging Accommodation Ladder


An inbound container vessel had just picked up the pilot. Two crew were on the upper deck preparing the port accommodation ladder prior to mustering at their mooring stations. Although they had brought two life vests on deck with them, these floatation devices stayed on the deck as they went about their work.

The hoist winch was tested by lowering the accommodation ladder approximately 1 metre and then slightly raising it. It was then lowered approximately 3 metres to allow a crew member to walk under the davit frame. A crew member stepped on to the upper platform and proceeded to the lower end where he rigged a section of collapsible handrails. He then went to the lower platform to make the rails secure while another crew member secured the safety ropes around the upper platform.

Suddenly, a loud bang was heard followed by a whirring sound as the ladder fell rapidly towards the sea. The lower ladder broke away and fell into the water, taking the attending crew member with it. The upper
section of the ladder was left hanging vertically down from its upper platform hinges with the hoist wire dangling from the davit.

A crew member alerted the bridge via VHF radio and then ran aft to look for the victim over the stern. A tug was close by, but there was no sign of the victim. The vessel was in the relatively confined waters of the port and making between 5 and 6 knots through the water. One of the attending tugs and the pilot boat were assigned to look for the victim, as the vessel was constrained by the restricted water. The victim was spotted about half a metre below the surface of the water and recovered by the pilot boat crew some 10 to 15 minutes after the event, but there were no signs of life.

The subsequent autopsy determined the cause of death to be ‘drowning with blunt force injuries’. The victim had suffered blunt force injuries to his head, neck, chest, back, abdomen and legs, resulting in a broken right femur, fractured ribs, multiple bruising and abrasions. These injuries were not considered to be fatal.

Lessons learned

  • Accommodation ladder failures, although rare, are certainly not unheard of and numerous lives have been lost as a result. Risks involved in rigging and securing accommodation ladders should be duly accounted for.
  • As in several of the MARS reports in this issue, the attending crew did not take basic precautions such as using fall protection and donning a PFD. The lack of these precautions cannot be solely attributed to the crew. The company and vessel leadership must also bear responsibility.
  • The failure in this case to release the lifebuoys and smoke floats once the victim was in the water was particularly significant. It denied the ships involved in the search a visible reference, and also potentially denied the victim the buoyancy he required to remain afloat.