Ballast Water Essay

Ballast Water Essay

The proper control and management of ballast water from ships is now a major environmental challenge not only to the International Maritime Organization but also for the shipping industry worldwide. This problematic issue has led some countries to consider actions at the national level to establish regulations and criteria for the discharge of ballast water in areas under its jurisdiction. In this way, the IMO adopted in 2004 the “International Convention for the Control and Management of Ship´s Ballast Water and Sediments” and several guidelines and resolutions. As the Convention previously mentioned has not yet entered into force, several states have taken unilateral action to prevent, minimize and ultimately eliminate the risks of the introduction to the marine environment of harmful aquatic organisms and pathogens from ballast water.

Consequently, in 1998 the Argentine maritime authority approved Order No. 7-98 entitled “Prevention of pollution by aquatic organisms in the ballast water of ships bound for Argentine ports in the estuary of the River Plate”, which requires ships from overseas bound for Argentine ports in the estuary to discharge, change or treat their ballast water before entering a zone in which polluting activities are prohibited, which is located at the exterior limit of the River Plate. Even though Argentina is an IMO member state, for political reasons it has not signed the IMO Convention for Ballast Water. However, Argentina follows the IMO recommendations to create its own regulations in a standardized way, in order to avoid the negative impacts that ballast water discharge involves.

This paper will analyze Argentina´s national regulations and procedures for dealing with ballast water and determine the similarities and differences with the IMO recommendations. In addition, before analyzing this specific aspect, it is necessary to introduce the ballast water issue. First, the ballast water definition and its brief history. Second, this paper will describe the problems that ballast water implies. Third, the IMO responses in concordance with the international cooperation, regarding ballast water management and the assistance to developing countries, like Argentina, to reduce the entry of invasive species. Finally, this research will compare the Argentine legal framework with the international one; to be concluded with some suggestions and recommendations to improve this significant environmental problem.

What is Ballast Water? To understand the problems that ballast water imply, it is necessary to know the meaning of “ballast water”. According to the IMO Convention, “ballast water means water with its suspended matter taken on board a ship to control trim, list, draught, stability or stresses of the ship”.

Ships are designed and constructed to sail carrying cargo such as oil, minerals, containers and so on. Consequently, if the ship travels without charge from one port and goes to the next port, the ballast must be on board to allow the vessel to operate efficiently and with safety. This includes keeping the ship at a depth sufficient to guarantee efficient operation of the propeller and rudder, and to avoid stress and strain on the hull, mainly in heavy seas, that could cause it to break or to sink the ship. Thousands of years ago, when ships began to be built, they carried solid ballast, such as rocks, sand or metal. However, since 1880, ships have used water as ballast, mainly because it is more affordable, it is much easier to load and unload and is, therefore, more effective and economical than the ballast solid (“Ballast Water Defined”, n.d.).

As the figure 1 shows, when a ship is freed from its cargo, it is filled with water ballast. The water is distributed into the ballast tanks in the vessel. These tanks are strategically located depend on the vessel structure. They are usually located along the side and bottom of the hull. Ballast water is extracted through sea water intakes located in the side or vessel bottom, with the aid of feeding pumps for ballast or gravity. The seawater intakes are covered with grills or filters that prevent large foreign objects from entering the ship’s ballast tanks. However, many species are able to pass through the ship´s water intake and pumps (“The Issue”, n.d.).

Figure 1 – Cross section of ships showing ballast tanks and ballast water cycle

Note: Globallast Partnerships

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The ballast water sediments are closely associated with ballast water. When ships charge ballast water, they also receive the solid material contained in the water. When this material enters into the ballast water tank, it sits in the bottom of the tank as “sediment” and the problem is that it can carry a variety of invasive species.

Consequently, approximately 7,000 diverse invasive species could be transported into the ballast water tanks around the world. Many of these species may not survive during the ships´ voyage. In the same way, other species are able to survive but when they are discharged in a place with different environmental conditions, they may die. However, several of the invasive species not only are able to survive but also find favourable conditions in the new environment to reproduce and to be a competitor or depredator of native species (“The Issue”, n.d.).

Invasive Species
There are many problems in the ballast water discharge due to invasive species that are introduced in a new environment. These invasive species could be defined as species that have been introduced, intentionally or accidentally in a place, area or region where not found naturally. Other synonyms that are used to refer to invasive species are “non-native species”, “non-indigenous species” or “invasive alien species” (IAS) (“Invasive species”, n.d.). Furthermore, according to the IMO BW Convention, the invasive species are defined as:

Aquatic organisms or pathogens which, if introduced into the sea including estuaries, or into fresh water courses, may create hazards to the environment, human health, property or resources, impair biological diversity or interfere with other legitimate uses of such areas.

The problem involving invasive species is that after they have been introduced into a new geographic area, they are established and spread, which causes or may cause, damage to the environment, economies or the health of human beings (“Invasive species”, n.d.).

Invasion Process
The invasive process has three main steps: Introduction, establishment and propagation.

1 – Introduction of the species: The species is introduced successfully in a new geographical area, intentionally or accidentally. This means that the species survives the voyage and is able to live in that area because the environmental conditions such as light, temperature, salinity, nutrients, among others, are adequate.

2 – Establishment and reproduction of introduced species: Survivors persist and reproduce successfully, establishing a self-sustaining foundational population.

3 – Propagation: The established population begins to spread, sometimes after a stationary period (or stationary stage) that could be for years and even decades. Then an explosive growth stage begins, this moment is when the new species becomes invasive (“Invasive species”, n.d.).

Negative impacts
The introduction of invasive species and their spread is recognized as a devastating issue in the affected environment because the damage that species cause to the local biodiversity could be irremediable. In this way, these complications in the environment imply also a negative impact in the economy of the affected area and to human health that is impaired by the invasive species´ effects. In addition, all these negative impacts that invasive species produce in the environment, the economy and the human health are interrelated and influence each other (“Ballast Water Management”, n.d.).

Ecological/ Environmental
Negative ecological impacts happen when invasive species alter the local biodiversity of the area and/or ecological processes. While the initial impact may be insignificant and therefore, not detected; over time, as the population increases, also the severity of the effects increases. The most significant ecological impacts that invasive species cause in the environment are (“The Ballast”, 2002, p.8):

Competing with native species for space and food.

Preying upon native species.

Altering habitat.

Altering environmental conditions.

Altering the food web and the overall ecosystem.

Displacing native species, reducing native biodiversity and even causing local extinctions.

Invasive species can produce huge economic losses to society, whether in the form of direct economic impacts, such as loss of marine food production, or secondary economic impacts associated with the health of humans or ecological impact. For example, it is estimated that in the U.S., the cost associated with the control of invasive species is enormous. To clear Zebra Mussels were cost between US$750 and US$1 billion between 1989 and 2000. In general, the economic impacts include (“The Ballast”, 2002, p.10):

Reductions in fisheries production (including collapse of the fishery) due to competition, predation or displacement of the fishery species by the invading species or through environmental changes caused by the invading species.

Impacts on aquaculture (including closure of fish-farms), especially from introduced harmful algae blooms.

Physical impacts on coastal infrastructure, facilities and industry, especially by fouling species.

Reduction in the economy and efficiency of shipping due to fouling species.

Impacts and even closure of recreational and tourism beaches and other coastal amenity sites due to invasive species (e.g. physical fouling of beaches and severe odors from harmful algae blooms).

Secondary economic impacts from human health impacts of introduced pathogens and toxic species, including increased monitoring, testing, diagnostic and treatment costs, and loss of social productivity due to illness and even death in affected persons.

Secondary economic impacts from ecological impacts and bio-diversity loss.

The costs of responding to the problem, including research and development, monitoring, education, communication, regulation, compliance, management, mitigation and control costs.

Human health
Because of the continued transfers of ballast water, chances are high that ships carry microorganisms on a large scale. For instance, there is evidence that cholera epidemics can be directly related to the discharge of ballast water. While “Vibrio cholera” and other pathogens are normal elements of coastal waters, they are not usually present in concentrations high enough to cause health problems for humans. However, with the increase in global trade and vessels transiting between international ports, the transfer of microbes could well be the worst threat related to the discharge of ballast water. A clear example is the cholera epidemic that happened in Peru in 1991 because of ballast water discharge, affecting more than a million people and killing more than ten thousand.

Another problem in the human health that ballast water implies is that ships could carry in the ballast tanks not only bacteria and viruses, but also a “range of species of microalgae, including toxic species that may form harmful algae blooms or ‘red tides'” (“The Ballast”, 2002, p.13). This kind of algae causes shellfish poisoning, which can produce sever illness and death in humans.

The invasive species introduced by ballast water have affected Argentine waters causing many negative impacts. For instance, since 1991, the Golden Mussel (Limnoperna fortunei) entered to Argentina through the River Plate into the ballast water tanks of Asian ships (Crosier, Molloy, n.d.). One of the complications that golden mussel causes is the damage in water intakes and water treatment plants, in which it is adhered. Consequently, the pipes are clogged, the water flow moves slowly and filters are clogged (macro-fouling) (Figure 2 and 3). Other disorders associated with the presence of this invasive bivalve are the rapidly changing in communities of organisms living on the bottom of water bodies (called benthic) and the displacement of indigenous species of mollusks.

Figure 1 and 2 – Golden Mussel

Note: Para Nauticos

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Furthermore, the Golden Mussel produces changes in the food chains of the environment, such as change of diet of “vogue” in the River Plate. In this case, this fish chooses the golden mussel as their main food, altering the normal ecosystem characteristics. On the other hand, the arrival of the invasive bivalve has economic negative effects that can be quantified by the value of the damage it causes, plus the costs of prevention and control tasks (Mirasso, n.d.).

As a result of the Golden Mussel invasion in the River Plate, there are several negative impacts, such as in the human health, taking into account that the water consumed by people is that one that be affected by the Golden Mussel in the treatment plant. Moreover, other negative effects are ecological (because the environmental changes) and economics (due to the procedures used it to solve the problems that the bivalve produces).

Since late 1980, the IMO has been actively engaged in trying to find a solution to the problem of ballast water. Initially, the IMO developed and published a set of guidelines in 1991, which were replaced in 1997 with Resolution A.868 (20) called “Guidelines for the control and management of ship´s ballast water to minimize the transfer of harmful aquatic organisms and pathogens”. Subsequently, IMO began working on an international legal instrument that resulted in the adoption by consensus of the “International Convention for the Control and Management of Ballast Water and Sediments” in the Diplomatic Conference that was held at the IMO headquarters in London on February 13, 2004. This Convention will enter into force 12 months after ratification by 30 States, representing 35 per cent of world merchant shipping tonnage. The last IMO report of August 31, 2011 shows that 35 States have ratified the Convention, representing 27.95% of world merchant shipping tonnage (“Ballast Water Management”, n.d.; “Status of Conventions, 2012).

Basically, the BWM Convention will require all ships to implement a Ballast Water and Sediments Management Plan; all ships will have to carry a Ballast Water Record Book and will be required to carry out standard ballast water management procedures. In addition, Parties to the Convention are given the option to take additional measures which are subject to criteria set out in the Convention and to IMO guidelines. These guidelines were created by the IMO Member States between 2005 and 2008 to facilitate the uniform implementation of the ballast water process. The mentioned guidelines are the following (“BWM Guidelines”, n.d.):

Guidelines for sediment reception facilities (G1) (resolution MEPC.152(55))

Guidelines for ballast water sampling (G2) (resolution MEPC.173(58))

Guidelines for ballast water management equivalent compliance (G3) (resolution MEPC.123(53))

Guidelines for ballast water management and development of ballast water management plans (G4) (resolution MEPC.127(53))

Guidelines for ballast water reception facilities (G5) (resolution MEPC.153(55))

Guidelines for ballast water exchange (G6) (resolution MEPC.124(53))

Guidelines for risk assessment under regulation A-4 of the BWM Convention (G7) (resolution MEPC.162(56))

Guidelines for approval of ballast water management systems (G8) (resolution MEPC.174(58))

Procedure for approval of ballast water management systems that make use of Active Substances (G9) (resolution MEPC.169(57))

Guidelines for approval and oversight of prototype ballast water treatment technology programmes (G10) (resolution MEPC.140(54))

Guidelines for ballast water exchange design and construction standards (G11) (resolution MEPC.149(55))

Guidelines on design and construction to facilitate sediment control on ships (G12) (resolution MEPC.150(55))

Guidelines for additional measures regarding ballast water management including emergency situations (G13) (resolution MEPC.161(56))

Guidelines on designation of areas for ballast water exchange (G14) (resolution MEPC.151(55))

Guidelines for ballast water exchange in the Antarctic treaty area (resolution MEPC.163(56))

However, the most relevant IMO recommendation regarding ballast water is the before mentioned Resolution A.868 (20) “Guidelines for the control and management of ship´s ballast water to minimize the transfer of harmful aquatic organisms and pathogens”. This Resolution was adopted on 27 November 1997 not as a solution to the ballast water issue but as a tool to minimize the risks caused by invasive species. Also, it asked countries to cooperate with this issue, applying the resolution itself and any other necessary measures.

First, the Resolution A.868 (20) establishes several indications both to port States and ships. Beginning with the port States, they should inform the IMO of specific requirements that they have such as regulations, specific zones, standards and exemptions, in order that IMO can distribute this information and in this way, the ships could obtain each country´s requirements prior to their arrival at port. Other information that the port States should pass on to IMO is the results of inspections and analyses of samples of ballast water tanks. In addition, the port States should have adequate reception and treatment facilities in their ports for safe disposal of ballast tank sediments.

Second, according to the Resolution, the ships should have a specific ballast water management plan including safe and effective procedures during the charge and discharge of ballast water. All ships should record each discharge, mention at least dates; geographical location; ship´s tanks and cargo holds; ballast water temperature and salinity; amount of ballast water loaded or discharged. Additionally, the ships should follow precautionary practices such as avoiding taking ballast water in darkness, shallow water or where propellers may stir up sediments. Also, they should avoid unnecessary discharge of ballast water. The ballast water exchange process could be done in deep water, in open ocean, as far as possible from shore or where the port State authorizes. In case of using pumping systems, the water should be pumped through the tank at least three times.

Third, the Resolution takes into account future considerations in relation to ballast water exchange. This means that the measures could be revised and adjusted according to new technologies or developments. In addition, this document has two appendices. Appendix 1 is the “Ballast Water Reporting Form” to be provided by ships to port State Authority upon request. Appendix 2 is the “Guidance of safety aspects of Ballast Water Exchange at sea”. This appendix mentions the safety measures (stability, weather conditions, and stress on the hull, among others) and two recognized methods: “Sequential method”, in which ballast tanks are pumped out and refilled with clean water; and “Flow-through method”, in which ballast tanks are simultaneously filled and discharged by pumping in clean water.

Finally, the Resolution establishes the necessity of crew training and familiarization regarding the ballast water management plan, ballast water methods, pumping system and recording the information required concerning ballast water loading and discharge. This point is very important because conscience and compromise about the ballast water risk, not only from the crew members but also from the port States, are the first steps to minimize the introduction of invasive species.

The IMO not only carries its own efforts to solve the ballast water problem, but also it has been supporting the international cooperation among countries in order to achieve a common solution, and to help developed countries to implement the necessary measures to avoid invasive species and to implement the Ballast Water Convention. In this way, one of the most important programs under the IMO auspices is the “GloBallast Patnership” that it will be developed in more detail in the next section.

International cooperation is essential to prevent the transferences of invasive species. This means that it is necessary joint cooperation among states, the maritime community, shipping companies and non-governmental organizations, in order “to prevent, reduce and control human caused pollution of the marine environment, including the intentional or accidental introduction of harmful or alien species to a particular part of the marine environment.” (“Ballast Water Management”, n.d.).

In this way, since 2000 the IMO has been working with United Nations Development Programme (UNDP) and the Global Environment Facility (GEF) to deal with the introduction of invasive species from ships´ ballast water in new environments. In order to confront this issue with an international effort, these organizations initiated the “Global Programme of Ballast Water Management” to avoid obstacles to the effective implementation of control measures and ballast water management in developing countries (GloBallast Partnership). This is a comprehensive technical cooperation program for help developing countries to (“GloBallast”, n.d.):

• Reduce the transfer of harmful organisms from ballast water of ships.

• Implement the IMO guidelines on ballast water.

• Prepare for the implementation of the Ballast Water Convention of IMO (which was still in negotiations at that time).

• Develop mechanisms for sustainability and reforms at national level.

• Promote regional coordination and cooperation.

• Develop new technologies and exchange of information among government’s measures.

The GloBallast Partnership is divided into phases. The first phase was initiated in 2000 and finished in 2004. The second phase was initiated in 2007 and continuous running during this year. This second phase aims to build on the progress achieved in the original project. It will focus on national policy, legal and institutional reforms in developing countries with particular emphasis on integrated management. The approach includes:

• Build on the achievements and use the skills and knowledge acquired in the first phase;

• Repeat best practices and technical activities to promote national policy reforms.

• Support countries particularly vulnerable and high environmental sensitivity in their efforts to adopt legal reforms and to implement the Convention on Ballast Water Management.

• Promote collaboration with industry to facilitate the successful transfer of new technologies from developed to developing countries (“GloBallast Partnerships”, n.d.).

Consequently, Argentina participated in the GloBallast Partnership Program and this year the Argentine Coast Guard was designated as the focal point to represent Argentina to International Organizations in this Program. In order to assist with other nations in the world particularly vulnerable countries regarding the introduction of invasive species and pathogens through ballast water of ships, to fortify political and legal aspects (“Environmental Protection”, 2012).

The BWM Convention was opened to signature from 01 June 2004 to 31 May 2005. Eight countries including Argentina signed the instrument subject to ratification. Until now Argentina has not ratified the Convention because it still remains in the Congress to analyze. However, this situation does not mean that Argentina does not support the fight against invasive species incoming from the ships´ ballast water. On the contrary, Argentina was a pioneer in this issue. In 1998 the Argentine maritime authority approved Ordinance No. 7-98 entitled “Prevention of pollution by aquatic organisms in the ballast water of ships bound for Argentine ports in the estuary of the River Plate”, which obliges ships from overseas bound for Argentine ports in the estuary to discharge, change or treat their ballast water before entering a zone in which polluting activities are prohibited, which is located at the outer limit of the River Plate. On December 1999, this national regulation was submitted to the IMO through MEPC 44/4/2, in order to be distributed among the states. In the same way, Ordinance No. 12-98 entitled “Special Protection Areas on the Argentine Coast” was submitted to the IMO. This Ordinance established twelve special protection areas, where among other prohibitions, it is forbidden to discharge ballast water, even if treated in some way, unless it has been exchanged for water taken within 150 miles from the outer limit of the area concerned.

Both regulations were made by the Environmental Protection Department of the Argentine Coast Guard (Prefectura Naval Argentina). This Department is in charge of all the issues related to environmental protection. Within this Department is found the Scientific Research Division that works with specialists such as biologists, and this group is continuously conducting research about ballast water and the impact in the environment. In this way, they confirmed with several studies that three species of freshwater bivalves that have been found in the River Plate (Corbicula fluminea, Corbicula largillierti, and Linmoperna fortune, known as “Golden Mussel”) originating from the estuaries of south-east Asia, and that they had entered via the discharge from ships from that region, to which bulk cereals had been exported from Argentina.

Considering that the River Plate is the gateway of the export/import activity of Argentina, it was necessary that this national regulation be applicable and mandatory both for national ships and foreign flagged ships. This last consideration was possible because Argentina submitted the Ordinance to IMO and then it was distributed among the states.

Several of the Ordinance requirements are similar to the IMO Resolution A. 868 (20), because it was made based on this last one. For instance, as the Resolution, the Ordinance has a final annex including “Guidance on Safety Aspects of Ballast Water Exchange at Sea” and “Crew Training and Familiarization”. Other similarity appears in the ship-shore communication and the methods admitted by both regulations. However, some requirements are specific to the Ordinance, such as sealing ballast tanks or pumping control valves and the exigency of salinity levels. Furthermore, the Ordinance does not have many requirements included in the Resolution, such as the port states procedures or the “Ballast Water Reporting Form”.

The Ordinance No. 7-98 “Prevention of pollution by aquatic organisms in the ballast water of ships bound for Argentine ports in the estuary of the River Plate” establishes that all ships that navigate along the River Plate shall exchange ballast water avoiding the prohibited zone of polluting actions located in front of the external limit of the River Plate. Another requirement is the radio electric communication that ships must make with the Vessel Traffic Services of the River Plate (CONRASE) informing them of the ballast water exchange or ballast retention on board. In case of exchange, they must indicate position, amount of water discharged, exchanged or retained on board and method applied for the ballast water exchange.

According to this Ordinance, the methods admitted by Argentine Coast Guard are: “Total deballasting and reballasting” (like the “Sequential Method” indicated in the Resolution A. 868 (20)), “Flow-through” (the same as in the IMO Resolution) and “Overflow” (it is similar to the flow-through” method, but pumping water for a time and making it overflow from the top of tank). In case of considering new methods, these should be approved by the IMO. Some methods admitted as a complement are: Filtering systems, oxidizing and non-oxidizing biocides, thermal techniques, electric pulses and plasma pulses, ultraviolet treatment, acoustic systems, magnetic field, deoxidation, biological techniques and anti-adherent coatings.

Furthermore, the Ordinance allows Coast Guard members to seal ballast tanks and pumps to control valves of ships, to be sure that they would not discharge the water on the way to Argentine Ports. Also the officers may take samples of the contents of ballast tanks, pipes and pumps to control the presence of invasive species and water salinity. In case that the water salinity is below 30mg/cm3, the ship would be not be allowed to enter into the River Plate because this water quality means that the ship exchanged ballast water very near the River Plate without taking into account the requirements of the Ordinance.

Finally, Argentina tries to arrive at a ballast water solution with its own national regulations. However, this is not enough because, since the adoption of the Ordinance No.7-98, many cases of new invasive species have happened, not only in the River Plate but also in the Argentine south where it does not exists any particular regulation, referent to ballast water. For example, the “Golden Mussel” (Limnoperna fortunei) that entered through the River Plate, affecting this complete zone until Brazil or the “Wakame” seaweed (Undaria pinnatifida) that invaded “Puerto Madryn” (a southern Argentine province) causing economic losses because this place is a touristic beach where people make activities like scuba diving but since this seaweed has invaded this place it is impossible to practice this activity. This is a shortcoming in the Argentine regulation because the Ordinance No.7-98 only contemplates the River Plate but not the others ports of entry at the country, mainly in southern Argentina. On the other hand, the Argentine regulation does not contain any reference to the International Convention for the Control and Management of Ships´ Ballast Water and Sediments because both instruments are not contemporary; the Ordinance was made six years previously.

The introduction of invasive species is a ballast water problem that involves the majority of the countries in which the trade is made by ships. Nowadays, most of the ships in the world fleet effectively carry ballast water and, therefore, would need to manage ballast water as part of their operations. The ecological, economic and human health impacts of invasive species are significantly severe for each country or region affected. Ballast water transfers and aquatic invasive species are perhaps the biggest environmental challenge facing the global shipping industry this century. For this reason, the problem of ballast water and invasive species must be addressed on an international basis involving cooperation between all countries and the shipping and port industries because the ships are involved in the international trade around the world; the port states are linked to receive and to control those ships and actions by individual countries could have a limited effectiveness (“The Ballast”, 2002).

In the Argentine case, the national rules are not enough because do not cover the complete jurisdictional water. This means that the places where the ballast water is managed are the River Plate and the Special Areas defined by Argentine Coast Guard. On the other hand, to solve this territorial problem and considering that the main Argentine legal instrument (Ordinance No.7-98) dates from 1998, maybe is time that the competent areas should update the requirements based on the Ballast Water Convention and the IMO Guidelines.

Furthermore, it is widely recognized that international cooperation and regional are crucial to advance the prevention and the fight against the introduction and spread of harmful aquatic organisms and pathogens through ballast water ships. For this reason, Argentina being part of the international cooperation through the participation in the GloBallast Partnership, where one of the objectives is share information among developed and developing countries about effective new methods and national policies to fight against invasive species.

Regarding the Ballast Water Convention as does not entered into force and in the particularly Argentine case that does not ratified the Convention, it is very difficult to implement a plan of ballast water management that would facilitate the safe implementation of the management system of ballast water in the ships, ensuring that procedures are carried out and which teams used are structured, logical, effective and safe. This means that the sooner should been implement the international instrument in order to have an environmental benefit because when be more delayed the impacts would be irreversible. Taking into account that once an exotic species is established, it is almost impossible to eradicate. Thus, the Convention implementation is essential to control new species introductions.

Consequently, despite the ecological risks, economic and health effects represented by the use of ballast water is absolutely essential for the safe and effective operation of shipping. Since at present there is no practical verified way to neutralize ballast water, the goal should be to ensure that the balance between the legitimate interests and opposed in the marine environment is correct and to avoid unnecessary adverse environmental consequences in the future through international cooperation, managed by the International Maritime Organization.

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