Regional training on sampling and analysis of ballast water

Cartagena, Colombia, 31 July-1 August 2014

Organized by

GEF-UNDP-IMO GloBallast Partnerships,

Dirección General Marítima -DIMAR, Colombia

and

Comisión Permanente del Pacífico Sur -CPPS

Project Number: (XB/0102-02-18-02-2270 and XB/0102-01-03-02-2270)

Hosted by

DIMAR

DELIVERY REPORT

Prepared by

Dr. Matej David Consult d.o.o.

.

Dr. Stephan Gollasch, GoConsult

Ms. Aicha Cherif, IMO-GloBallast Representative

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Disclaimer

The designation employed and the presentation of the material in this report and in the papers contained in the annexes thereto do not imply the expression of any opinion whatsoever on the part of the Secretariat of the International Maritime Organization concerning the legal status of any country, territory, city or area, or of its authorities, or concerning the delimitation of its frontiers or boundaries.

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Table of Contents

Table of Contents ............................................................................................................... 3

Summary Sheet .................................................................................................................. 4

Introduction ......................................................................................................................... 5

Objectives ........................................................................................................................... 6

Venue, Dates, Roles and Participants................................................................................. 6

Venues and dates ............................................................................................................... 6

Roles .................................................................................................................................. 7

Cost .................................................................................................................................... 7

Activities and Proceedings .................................................................................................. 7

Opening Ceremony............................................................................................................. 7

Proceedings ....................................................................................................................... 8

30 July afternoon ................................................................................................................ 8

31 July morning ................................................................................................................ 12

1 August 2014 .................................................................................................................. 18

Achievements and Conclusions ........................................................................................ 21

Recommendations ............................................................................................................ 22

Follow-up Action ............................................................................................................... 22

Annex 1 ............................................................................................................................ 24

Annex 2 ............................................................................................................................ 25

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Summary Sheet

Title of the Workshop: Regional training on sampling and analysis of ballast water Host: DIMAR Venue: Hotel Capilla del Mar, Bocagrande, Cra. 1, No. 8-12, Cartagena

de Indias Date: 30 July to 1 August 2014 Type: Regional training Organised by: GEF-UNDP-IMO GloBallast Partnerships Supported by: Dirección General Marítima (DIMAR)

Comisión Permanente del Pacífico Sur (CPPS) No of Participants: 43 participants Summary: The IMO GloBallast Partnerships provided this successful

training workshop to assist one of their Lead Partnering Countries to be trained on compliance with the BWMC with specific emphasis on sampling an analysis of ballast water. The workshop lasted two days and a half and gathered 43 participants from a range of organisations and sectors linked to shipping and the marine environment in the six countries of the South Pacific region. This report gives details of the training together with recommendations on future workshop delivery.

Key Words: Ballast water management, sampling, analysis, harmful aquatic

organisms, marine ecosystems, national strategies, compliance monitoring and enforcement, port state control.

Report ref: IMO Consultancy Contracts references: 4500019068 and

4500019083 Project Number: XB/0102-02-18-02-2270 and XB/0102-01-03-02-2270 Co-ordinators: Ms. Aicha Cherif - IMO/GloBallast

Ms. Luz Angela Castro, DIMAR Ms. Maryluz Cañon Paez, DIMAR Mr. Hector Huerta, CPPS

Consultants: Dr. Matej David, Dr. Matej David Consult d.o.o. and Dr. Stephan Gollasch, GoConsult

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Introduction 1 A regional training course on Sampling and analysis of ballast water was conducted in Cartagena, Colombia from 30 July to 1 August 2014. The training was organised by the GEF-UNDP-IMO GloBallast Project in cooperation with Colombia as Lead Partnering Country (LPC) in the GloBallast Project and the Permanent Commission for the South Pacific (CPPS), as the Regional Coordinating Organization in the region. 2 Shipping is a global industry transporting billions of tonnes of ballast water around the world annually. Ballast water is carried by ships to help maintain stability and is discharged during the loading of cargo. With up to 10,000 species in transit with the global shipping fleet, there is little doubt that ballast water has the potential to cause widespread human health, environmental and economic damage as a result of the introduction of the harmful and invasive species that reside in it. 3 Making ballast water safer is not only an environmental aspiration, but, once ratified, the 2004 IMO Ballast Water Management Convention (BWMC) will (after 12 months) require the shipping industry to comply with regulations. The BWMC introduces two standards, D-1 (ballast water exchange standard) and D-2 (ballast water performance standard), in a sequential implementation:

- The current D-1 Ballast Water Exchange (BWE) Standard - requires ships to exchange a minimum of 95% ballast water volume;

- The D-2 Ballast Water Performance Standard requires that the discharged

ballast waters have organism concentrations below specified limits. These are: 1. less than 10 viable organisms per cubic metre greater than or equal to

50 micrometres in minimum dimension; 2. less than 10 viable organisms per millilitre less than 50 micrometres in

minimum dimension and greater than or equal to 10 micrometres in minimum dimension.

3. Indicator microbe concentrations shall not exceed: i toxicogenic Vibrio cholerae (O1 and O139) with less than 1 colony forming unit (cfu) per 100 millilitres or less than 1 cfu per 1 gram (wet weight) zooplankton samples; ii Escherichia coli less than 250 cfu per 100 millilitres; iii intestinal Enterococci less than 100 cfu per 100 millilitres.

4 The D-1 and D-2 ballast water discharge standards will only be successful at minimizing the risk of invasive species if BWE is carried out appropriately, or if Ballast Water Management Systems (BWMS) operate effectively and reliably, and if ship owners and operators comply with the BWMC. 5 Once a system of ballast water management has been established, based on IMO and national requirements, it is necessary to have an accompanying mechanism to monitor compliance with that system and to provide for its enforcement. This mechanism is known as Compliance Monitoring and Enforcement (CME). CME is an essential component of the overall ballast water management regime, or National Strategic Framework, and is designed to:

- assess whether or not a ship has met the IMO and Port State’s BWM requirements; and

- when necessary, enforce those requirements.

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6 The BWM Convention recognises the essential role of a CME system to any ballast water management regime (for example, in Article 9 on inspections). Furthermore, the BWMC provides considerable guidance as to what kinds of records should be maintained to facilitate the CME function, as well as on the application of the provisions, level of penalties, inspections, verification of records, violations etc. 7 One way of assessing compliance with BWM requirements is to sample ballast water. Sampling can also be done:

- for scientific research to assess the biology and chemistry of ballast water; - to document potentially harmful or other organisms carried in ballast water for

risk assessments; and - for compliance monitoring, i.e. to assess compliance with ballast water

management requirements which is the focus of this document. 8 Sampling is a scientific process. Taking representative sampling is difficult, requires experts, equipment and methodology that is not within the expertise of the PSCO. Differences in organisms' diversity, size and behaviour, as well as differences in ship construction including the different availability of sampling points further enhance the complexity of the ballast water sampling process. 9 After the regional training course on Compliance Monitoring and Enforcement (CME) of the BWM Convention held in Chile in 2012, the LPCs in that region have requested the assistance of the Project to be trained on ballast water sampling and analysis in accordance with the BWM Convention and Guidelines (G2) and the guidance contained in BWM/Circ.42. Objectives 10 The objective of this training workshop was to provide knowledge on the different steps and measures needed to conduct sampling and analysis of ballast water. 11 This was the second in a series of hands-on training on sampling based on the Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines, BWM.2/Circ.42 with a practical demonstration on board a ship to take samples from the ballast tanks, label them and analyse them. Two consultants were contracted for this practical training. Their contribution included theoretical lectures and the practical shipboard sampling exercise and laboratory analysis. Venue, Dates, Roles and Participants Venues and dates

• 29 July 2014 morning: Preliminary visit to the ship to prepare for the sampling on board. Visit to the Centro de Investigaciones Oceanográficas e Hidrográficas del Caribe (CIOH) by Dr. Stephan Gollasch and Dr. Matej David.

• 30 July 2014 afternoon and 31 July morning: Hotel Capilla del Mar, Cartagena for the Opening ceremony, welcome speeches and presentations by IMO-GloBallast representative and lectures by Dr. Matej David and Dr. Stephan Gollasch.

• 31 July afternoon: Shipboard sampling demonstration took place with 30 Participants and other participants joined via live streaming on the Chemical/Oil Products tanker Cartagena Sun (IMO 7402623, Flag Colombia, Built 1976, GT 4,269, positioned at anchor in the port of Cartagena),

• 1 August morning: Hotel Capilla del Mar, Cartagena, Lectures by Dr. Stephan Gollasch • 1 August afternoon: Analysis of samples by Dr. Stephan Gollasch and Dr. Matej David

in the bar of the Hotel Capilla del Mar converted into laboratory for the event. Closing ceremony and distribution of certificates

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Roles 12 DIMAR invited and paid for the consultants’ travel to Cartagena and paid for the venue, the live streaming of the event and the local participants’ travel and stay. IMO/GloBallast funded the travel of 2 participants each from Argentina, Chile, Ecuador, Peru and Panama and the CPPS representatives and recruited the consultants, Dr. Matej David and Dr. Stephan Gollasch. CPPS paid for the participation of one participant each from the countries of the region and coordinated all the participants’ travel and logistical details. Participants 13 There were 43 participants from a range of different sectors of the marine industry of the six countries of the South pacific region. Annex 2 gives a full list of the participants many of whom are delegates from Government Agencies charged with the responsibility of implementation of BWM Convention. Cost 14 Funds for this activity were provided through the GloBallast Partnerships Project, DIMAR and CPPS. Activities and Proceedings Opening Ceremony 15 The training was officially opened on Wednesday 30 July at 2pm by Contralmirante Ernesto Duran, Director General Marítimo, DIMAR who had made the trip from Bogota for the event. He thanked IMO, GloBallast and CPPS for providing assistance to Colombia on ballast water management and for organising the training on sampling in Cartagena. 16 The IMO-GloBallast representative, Ms. Aicha Cherif delivered the opening speech congratulating Colombia for organising this training and making all arrangements to allow the participants on board a ship for a practical demonstration of what the consultants’ lectures would be about. She acknowledged the encouraging progress in terms of BWM in the CPPS region and the hard work by Chile, Colombia and Argentina to achieve all the milestones pledged when they committed to being a Lead Partnering Country in the GEF-UNDP-IMO GloBallast Project. 17 She also reminded participants that IMO's theme for World Maritime Day this year is "IMO conventions: effective implementation". All the effort required to create an instrument that can be universally adopted may be meaningless if that instrument does not quickly become part of the international legal framework.

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Proceedings

30 July afternoon

Dr. Matej David, delivering the first lecture on BW sampling under the BWM Convention Current status of the BWM Convention and developments at IMO in terms of PSC and Sampling presented by IMO/GloBallast Representative, Ms. Aicha Cherif. 18 The presentation was on the latest updates at IMO regarding the extended application timeframe as per Resolution A.1088 (28), the Guidance on Sampling (BWM/Circ.42) and the draft PSC guidelines recently discussed at III Sub-Committee in July (Document III 1/8). The circular contains the current state-of-the-art science with respect to sampling and analysis of ballast water and includes provisions for further improvement and standardization in light of future development of the sampling and analysis techniques. The trial period will start once the Convention enters into force and the goal at the end of the trial period is to have a set of accepted procedures that can be used for sampling and analysing ballast water in a globally consistent way. 19 The consultants then introduced themselves, detailing their background and their studies and findings on on-board sampling. Then Dr. Matej David asked the participants to briefly describe their national BWM requirements: Argentina

• Ballast water releases originating from freshwater ports are especially critical; • BW Sampling occurs; • No sanctions at economical level; • BWE requirements >50 NM from nearest land so that the salinity is above 30 PSU.

Brazil

• BWE >200 NM from nearest land and 200 m water depth, if this is impossible accept also 50 NM from nearest land;

• BWMP required;

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• BWRF properly filled in; • Economic sanctions apply for non-compliance; • Ships also have to do BWE on domestic voyages e.g. on voyages between north and

south Brazilian ports. Chile

• A domestic resolution issued by the maritime regulation agency is in place and is based on Assembly Resolution A.868(20);

• BWE >200 NM from nearest land and 200 m water depth, when impossible never do BWE within 12 NM limit;

• High sanctions are established to those who introduce non-indigenous species; and • BWS is in place as pilot project in one region, in other regions CME is based upon

paperwork verification checks. Colombia

• BWM requirements are outlined in Resolution 0477 from September 2012. It contains the same elements as in Assembly Resolution A.868(20) and as in BWM Convention; and

• BWE >50 NM from nearest land. Ecuador

• Pilot BWS project planned in one petrol port; • BWE >50 NM from nearest land; • Check if BWE was conducted at minimum distances from land as required; • No country-wide BWS, BWS for salinity only, if ballast water is of near shore origin the

vessel is send away to >50 NM from nearest land to do BWE.

Peru • BWE >12 NM from nearest land; • BWS for salinity and pathogens in different ports; and sanctions apply.

20 In summary, all countries require BWE for ships in international voyages and Brazil also for domestic shipping under certain circumstances. As limit for BWE most countries follow the recommendations of the IMO BWE Guidelines (BWE in >200 m water depth and >200 NM from nearest land, if not possible >50 NM from nearest land). Ballast Water sampling under the BWM Convention presented by Dr. Matej David 21 The need for compliance control sampling with BWM requirements as set out in the BWM Convention and the G2 Guidelines was the subject of this presentation to provide basic guidance for a port State control inspection to verify compliance with the requirements of the BWM Convention. BWS may be conducted in a two tier approach. Tier 1 is the initial inspection which is focussed on checks of a valid certificate, consultation of the ballast water record book and ensuring that an officer has been nominated for ballast water management on board the ship and to be responsible for the BWMS, and that the officer has been trained and knows how to operate it. BWS according to G2 may be performed, but the sampling and sample analysis should not result in an undue delay and should neither prevent ballast water discharge before the BWS results become available. Should no valid certificate be available, or clear grounds exists for doubts in the ballast water compliance condition, or BWMS does not correspond to the certificate, or the crew being unfamiliar with BWM procedures, this leads to Tier 2, the detailed inspection. Tier 2 is dependent on the conditions of Article 9 of the Convention. The consequence is, as stated in Article 9.3 of the BWM Convention: "In the circumstances given in paragraph 2 of this Article, the Party carrying out the inspection shall take such steps as will ensure that the ship shall not discharge ballast water until it can do so without presenting a threat of harm to the environment, human health, property or resources."

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22 In cases when indicative BWS has shown a “high” organism load (clear grounds) and the detailed sampling inspection in a previous port documents failed compliance, Article 10.3 of the BWM Convention applies: "If the sampling described in Article 9.1(c) leads to a result, or supports information received from another port or offshore terminal, indicating that the ship poses a threat to the environment, human health, property or resources, the Party in whose waters the ship is operating shall prohibit such ship from discharging ballast water until the threat is removed." However, what can be done with such a vessel? Options include no discharge (resulting in a problem with the cargo operation), ballast water discharge to a port reception facility (or from tank to tank avoiding ballast water discharge if possible) and ballast water operation in a designated discharge/contingency area. If none of these options are available how can such vessel prove again to be compliant? 23 Different BWS approaches were developed for the indicative and in detail D-2 compliance checks. Indicative test (G2 Guidelines, 6.3):

• Prior to testing for compliance with the D-2 standard, it is recommended that, as a first step, an indicative analysis of ballast water discharge may be undertaken to establish whether a ship is potentially compliant or non-compliant.

• Such a test could help the Party identify immediate mitigation measures, within their existing powers, to avoid any additional impact from a possible non-compliant ballast water discharge from the ship.

For the detailed test (G2 Guidelines, 6.2):

• The sampling protocol should result in samples that are representative of the whole discharge of ballast water from any single tank or any combination of tanks being discharged;

• The sampling protocol should take account of the potential for a suspended sediment load in the discharge to affect sample results;

• The sampling protocol should provide for samples to be taken at appropriate discharge points;

• The quantity and quality of samples taken should be sufficient to demonstrate whether the ballast water being discharged meets with the relevant standard;

• Sampling should be undertaken in a safe and practical manner; • Samples should be concentrated to a manageable size; • Samples should be taken, sealed and stored to ensure that they can be used to test

for compliance; • Samples should be fully analysed within the test method holding time limit using an

accredited laboratory; and • Samples should be transported, handled and stored with the consideration of a

chain of custody. 24 One of the biggest challenges in BWS is to take a sample which is representative of the whole ballast water discharge. Clear guidance is needed how to do BWS for CME and IMO is currently working towards the preparation of such a document. Open questions and issues include: How to sample for D-1? How to sample for D-2? What is a representative sample? What should be the sample volume? How many samples to take? Where to take samples? When to take samples? Which sampling gear to use? 25 IMO agreed on a trial period of BWS and analysis in accordance with the BWM Convention and Guidelines G2. This 2-3 year trial period will be used for gaining experience, reviewing, improving and standardizing the BWS Circular as well as to list sample analysis protocols, methodologies and approaches for the D-1 and D-2 standards compliance tests.

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D-1 and D-2 Ballast Water Sampling for Compliance Monitoring and Enforcement recommendations presented by Dr. Matej David 26 This lecture consisted of an introduction to the D-1 Exchange Standard and the D-2 Performance Standard together with the suitable compliance control sampling methods and approaches to address both the D-1 standard and the indicative and detailed sampling for the D-2 standard. 27 For compliance with the D-1 standard a BWE efficiency of at least 95 % volumetric exchange should be reached and the BWE should be performed >200 NM from nearest land and in water depths of at least 200 m. Should this be impossible then conduct BWE >50 NM from nearest land and in water depths of at least 200 m. For D-1 compliance it is recommended to check the water salinity. The world ocean salinity is above 30 PSU which means that should the vessel have conducted BWE as required, the ballast water salinity should be above 30 PSU. Only small quantities like >50 ml of water are needed to do this measurement. However, our studies have shown the water salinity inside a ballast tank is not homogenous when we measured the salinity in-tank from different depths and in-line during different times of a ballast water discharge. We therefore recommend for compliance checks with D-1 to take more than one sample with ~10 minute delay to identify if the salinity is changing through the time of discharge. It is important to take the sample as soon as possible after the ballast water discharge has started to prevent possible discharges of non-compliant ballast water. 28 Compliance checks with the D-2 standard require to check for viable organism densities per size class, i.e. <10 organisms of >50 µm/m³, <10 organisms of <50 and > 10µm/ml and the presence of colony forming indicator microbes (Escherichia coli <250 cfu/100 ml, Enterococci <100 cfu/100 ml, Vibrio cholerae <1/100 ml). This may be done in an indicative and in a detailed analysis. 29 Indicative sampling for compliance with the D-2 standard is recommended prior to detailed sampling to avoid any additional impact from possible non-compliant ballast water and in case tanks have direct discharge to the environment. For this analysis the consultant recommended to use in-tank sampling points to avoid discharge of ballast water and also as no in-line sampling points may be installed on a vessel. The sampling is also possible in-line after ballast water discharge was started, the indication will still be faster than a detailed test. 30 Two principles apply. Principle 1: To prevent possible non-compliant ballast water discharge only one group of organisms is enough to indicate/identify non-compliance! Considering the three organism groups addressed in the D-2 standard, phytoplankton indicative analysis tools (PAM based) are practical for on board use and need low water quantities, zooplankton sample may be concentrated on board and brought to a laboratory for fast analysis, but no indicative analysis tool for bacteria is known. In Principle 2 the indicative test may be followed/expanded to become a detailed test. It may also be considered to sample indicatively as it would be the first part of the detailed test and to include all groups of organisms. 31 For the detailed D-2 compliance control sample representativeness is a key feature and refers to organism diversity, concentration and viability and requires a biological, statistical and shipping related compromise. Representativeness can be seen as of the whole discharge of ballast water from any single tank or any combination of tanks. 32 Sample representativeness is related to the sampling point, sample timing (sampling start and end) and duration, number of samples and sample volume. According to their studies, the consultants recommend the following:

• Sample in-line (at discharge) as this represents discharge of organisms to the environment and D-2 is a discharge standard. To enable such a sampling, a sampling point needs to be installed on board;

• In-tank sampling represents the organism potentially to be discharged (organisms may remain in the tank with remaining water) therefore it is difficult to prove

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compliance with the discharge standard (need to reveal very high organism numbers – e.g. 1000 organisms sampled from a tank of 100 m3);

• For in-line sampling use a sampling bin for sampling larger water volumes and water discharge from that bin needs to be provided on the vessel;

• Do not start sampling during the first 5 minutes after start of the ballast water discharge and do not sample in the last 5 minutes before end of discharge because at these times high patchiness of organisms occurs and more sediment is present in that sampling periods which may negatively affect organisms survival in the sample and also the sample processing;

• A sampling duration of ca. 10 minutes is recommended because longer sampling times negatively affect the survival of organisms >50, hence a sample is underestimating the “real” organisms concentration; and shorter sampling times are still representative for organisms in the group <50 and >10 µm;

• Two or more instantaneous samples should be taken because the averaged biological content of two random samples has shown to be representative, alternatively a sample may be taken over the entire discharge time as appropriate;

• If more than one ballast water source is on the vessel, than at least one sample should be taken from each ballast source as sampling needs to be representative of whole discharge;

• We suggested sample quantities which showed best results and the concentrated sample is easy to carry o For organisms >50; 300 – 500 litres of sample, concentrated to ca. 5 litres for

transport and concentrated further to 100 ml for analysis; o For organisms <50 and >10; 5 – 6 litres of continuous drip sample during

sampling, subsample of ca. 100 ml for transport; o For bacteria; 1 litre separated from the continuous drip sample for transport.

33 The presentation continued to describe in detail different sampling tools which may be applied according to the in-line and in-tank sampling access points. Lastly personal protective equipment was described. 31 July morning Vessel and tank selection for ballast water sampling for compliance monitoring and enforcement presented by Dr. Matej David 34 Considering limited time and resources, without a system to select vessels, the “critical” / “high risk” possibly non-compliant vessels may not be checked, instead “low risk” vessels could be checked which may not be needed. The level of risk posed is a triggering element and the BWM Convention has triggering elements in Article 9. Other triggering elements include, e.g., information about non-compliance from previous port(s) the vessel called. A DSS may support PSC decision making in this complex process. 35 Risk Assessment is needed to be applied to each vessel arrival and this should be based upon the origin of the ballast water to be discharged (donor port/area?) and the presence of HAOP in the donor port. RA principles are data reliability, environmental compatibility of the ballast water source area with the ballast water recipient area and the presence of HAOP in the ballast water donor area. Low risk is assessed when very high environmental incompatibility occurs and when no HAOP are present. In cases when high environmental compatibility occurs and HAOP are present, different levels of risk are triggered by different HAOP profiles, e.g., human pathogens, target species, harmful algae. Triggering elements may become available before a vessel arrives and when a vessel is already in a port resulting in a two tiered approach. 36 Tier 1: the vessel is randomly selected under a regular BWM verification process, the vessel is selected for PSC inspection under a separate process or the vessel is not trustworthy or has a false reporting history. Tier 2 refers to BWM Convention triggering elements when

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the vessel is in a port, which includes no valid certificate, the condition of the vessel or equipment does not correspond with BWMS certificate, the master and crew are not familiar with BWM procedures or have not implemented these, Port State Authority received notification that vessel was found non-compliant with the D-2 standard in a previous port, or any ballast water intended for discharge was identified as high or extreme risk. 37 Discharge of ballast water should not be allowed when a valid certificate is missing, the condition of the vessel or equipment does not correspond with BWMS certificate, the master and crew are not familiar with BWM procedures or have not implemented these or when high or extreme risk is posed by the ballast water intended to be discharged. 38 After the vessel to be checked is selected, the tank(s) to be sampled should be identified. The consultants recommend to consider the following tank selection principles:

• ballast water to be discharged originates from different sources and also with different uptake dates (different holding times on board);

• ballast water from all different sources need to be tested, but this is time consuming; • have a tank prioritization result possibly prior any discharge, tank(s) to be sampled

first should be selected; • the same RA principles to select tanks may be used as for vessel selection for CME;

and • when a vessel has more ballast tanks with the same level of risk / same ballast

water origin, give priority to those with shorter in-tank holding time. • The tank selection criteria RA may consider the following elements, but may not be

limited to: • the environmental compatibility of the ballast water donor area with the ballast water

recipient area; • the potential presence of harmful aquatic organisms and pathogens in the ballast

water donor area; • if appropriate, the presence of target species in the ballast water donor area; and • the in-tank holding time. • The tank priority criteria follow the principle that the higher the risk identified, the

higher is the priority. Give priority to: • tank(s) from another biogeographical area with higher environmental compatibility

with the discharge area; • tanks with a ballast water origin area where HAOP or target species are present; • tanks with shorter in-tank holding time; • tanks to be discharged first.

39 For in-tank sampling accessibility, the ease of the sampling access point may be used as an additional criterion to identify the tank to be sampled, considering also that ballast water in some tanks may not be accessible at all for in-tank sampling. For in-line sampling the tank(s) which is(are) currently being discharged when PSC comes on board may be sampled first to enable stopping of ballast water discharge if needed and not to wait until the “targeted tank” is ready to be discharged. 40 It is concluded that a system is needed for the selection of vessels and tanks for CME for the purpose of the BWM Convention and that it is important to have a regional PSC approach implemented (e.g. MoU). RA is an important tool to support the CME process and that DSS for targeting vessels eases the PSC decision process.

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Ballast water sample handling and transfer to the laboratory presented by Dr. Stephan Gollasch 41 The presentation addressed ballast water sample labelling, transfer to the laboratory and handling and gave very practical recommendations as follows:

• The label should be placed on the bottle and not on the bottle lid to avoid confusion should more than one bottle be opened at the same time for analysis.

• The label should contain the date, start/end time of the sampling event, the D-2 organism group addressed by the sample, the sampling point used, the water volume sampled and whether or not preservative were used.

• The label should be secured with transparent tape so that it cannot fall off or the sampling bottle(s) could be placed in separate bags so that if a label fell of the label and sample bottle can be found in the same bag.

• After sampling the samples should be transported to the laboratory as soon as possible that at best the sample processing should be completed within 6 hours after sampling.

• Styrofoam boxes with cooling / heating elements should be used for sample transport

• The sample transport should occur in controlled temperature conditions and the temperature be documented with temperature loggers. For sample shipment a temperature slightly cooler than the ambient sampling temperature is recommended.

• The sample shipment should be documented with a chain of custody form, to record sampling event details, the purpose of the sample shipment, sample types and number of samples. All personal involved in the sample shipment should sign the form as the samples are handed over.

• After the sample has arrived in the laboratory it should be split to generate separate samples for the analysis of the three D-2 organism groups (if this was not yet done on board). For bacteria analysis a 1 L bottle should be filled and handed over the sample processing team. For phytoplankton analysis 2 x 100 ml bottles should be filled, one to enable a living phytoplankton analysis and another with preservatives as a back-up. For zooplankton analysis the plankton net cod-end, which was stored in a bucket, should be emptied into a filter (30 µm mesh). A wash bottle filled with the filtered water is to be used to empty the material collected on the 30 µm filter into a jar. The bottle and jar should be forwarded to the microscopist for immediate sample processing.

31 July 2014 afternoon Practical demonstration on board the Chemical/oil tanker Cartagena Sun: Sampling for D-1 on a ship in the Port of Cartagena, in tank sampling, performed by Dr. Matej David and Dr. Stephan Gollasch. Dr. Matej David started with asking the ship’s Captain to see the ship’s BWRB and the BWMP. As planned with the Captain two days prior, hatch 3E was opened over starboard side of the ship.

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Cartagena Sun's Capt. Buenaventura Parra

A direct measure of salinity for D-1 without extracting a sample from the tank

Samples were taken from the tank via sounding pipe using a water column sampler The sampler is lowered down into tank until the bottom is reached and then pulled back up. While it is being lowered down the tank, the ballast water enters through the hole on the upper side.

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Another way is to use the point-source sampler. It is lowered down the sounding pipe to the desired point of sampling and then the valve is opened by pulling the second rope which needs to be connected to the valve.

Measuring salinity using a simple refractometer

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A hand pump was also used A hose was lowered through the sounding pipe to the desired depth and the water was pumped into a bucket.

For organisms greater than or equal to 50 micrometres in minimum dimension a plankton net is suggested for in-tank sampling which can easily be lowered through a manhole

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Other samples were taken from a ballast water discharge line for a detailed D-2 test at discharge:

o A bin was used to place the net in water during sampling, o A valve was placed at the discharge point to manipulate the water level in the sampling

bin, o Hoses were connected from the sampling point to the flow meter, which gets the

water into the plankton net as well as from the sampling bin to the discharge point. 1 August 2014 Sample analysis procedures or techniques used to test for compliance with D-1 presented by Dr. Stephan Gollasch 42 Compliance methods to evaluate whether or not the D-1 standard was met need to document if the BWE was carried out in coastal or offshore waters. This may be done by documenting tracers of human activity (presence of e.g. Nitrogen or Phosphorous may indicate nearshore BWE (river run-off in urban areas)), presence of colored dissolved organic matter (CDOM), findings of coastal species (e.g. harpacticoid copepods, barnacles), high sediment load in the sample or by salinity measurements. For salinity measurements it is assumed that if the salinity is below 30 psu it is unlikely that it was exchanged at sea in offshore areas. The weaknesses of the first three mentioned approaches were described and salinity checks were recommended as best compromise. However, BWE in coastal/port areas in high-salinity environments (above 30 psu) will result in compliance salinity measurements, but the water does not originate from offshore areas (non-compliance with D-1). Further, BWE in designated ballast water exchange areas (within 50 nm from nearest land) may result in lower salinity than the offshore water due to e.g. substantial freshwater influence by river run offs. Here the BWE would be compliant, but salinity measurements alone would show non-

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compliance. Therefore, the place where BWE was conducted must be known to draw CME conclusions. Sample analysis procedures or techniques used to test for compliance with D-2, indicative and detailed sample processing, introduction of sample analysis methodspresented by Dr. Stephan Gollasch 43 Compliance with the D-2 standard can be evaluated indicatively and in a detailed sample processing approach. Several organism detection technologies were presented also outlining their strengths and weaknesses. The difficulties in organism detection include that almost all types of organisms are found in ballast water with the dominant groups being crustaceans, mollusks, worms and phytoplankton. Living fishes were also found with a body length of up to 15 cm. Ballast water biota also include critical species such as human pathogens and harmful/toxic alga. The organism detection tools in addition need to be capable to identify the minimum dimension of organisms to sort them into the two D-2 size categories and to identify if the organisms found are living or dead (viability analysis). Other aspects to consider when aiming to identify the most suitable organism detection technologies are the time needed to a result, the required expertise of the sample analyst, the portability of tools to possibly enable their use on board direct after sampling and the capital and running costs. 44 For the indicative analysis, the consultants recommended to use for the organisms <50 and ≥10 µm in minimum dimension pulse-amplitude modulated (PAM) fluorometry. This portable tool identifies living phytoplankton by measuring the algal response to a light stimulus. The measured PAM signal allows a semi-quantitative evaluation of living algae in a sample, but does not provide direct algal cell counts. This tool is easy to operate so that a measurement by PSC directly after sampling on board is enabled and the result is available in a few minutes. For the organisms ≥50 µm in minimum dimension, the consultants use a stereomicroscope to indicatively analyse the sample. However, this method is not portable and requires biological expertise and sample processing in a laboratory so that this cannot be done by PSC on board. For bacteria, the consultants still haven’t fund an indicative method which gives colony forming unit estimations in less than 6 hours. Therefore it was concluded that for an indicative analysis the phytoplankton PAM test is most suitable because it can be done on board directly after sampling and it delivers results in ca. 2 minutes. 45 However, a new indicative method was developed, and is available since very recently, which uses the content of AdenosinTriPhosphate (ATP) in a sample and transfers this measurement into calculated organism counts. As ATP occurs in all species and by using filtration this method could possibly identify all D-2 organisms. The consultants mentioned that they have not yet seen validation results of this method and have not tested this method or considered it in depth. 46 For the detailed analysis, the consultants recommended to use for the organisms <50 and ≥10 µm in minimum dimension a viability stain and an epifluorescence microscope to analyse phytoplankton. The working principle of the stain Fluorescein DiAcetate (FDA) was described and its applicability was critically reviewed. Zooplankton in this size class may be analyzed with a standard bright field microscope and the viability could be tested by gently poking intact, non-moving organisms. For the organisms ≥50 µm in minimum dimension we propose to use a stereomicroscope with the organism poking method. For bacteria several standard methods are available to document colony forming units and with selective bacteria growth media the number per water volume can be determined. However, the incubation time is up to 2 days. 47 All detailed sample analysis methods require a laboratory environment and high level biological expertise for sample processing. It was therefore concluded that these methods are not suitable for PSC use on board a vessel. It is recommended that either the sample taken by PSC is transported to the laboratory as soon as possible after sampling or that a van may be equipped with the above mentioned sample analysis tools as a mobile laboratory. This van

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may be driven to the pier where the vessel is sampled so that longer sample transport times can be avoided.

Morning theory by Dr. Gollasch on tools for D-1 compliance and indicative as well as detailed D-2 analysis methods

Collecting fresh plankton samples from the pier

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Participants performing microscope analysis typical of that required for analysis of>50µµµµm plankton fraction for compliance testing for IMO D-2 supervised by Dr. Stephan Gollasch in the improvised laboratory.

Achievements and Conclusions 48 The event was attended by a wide range of people from the marine industry in the region. Representatives were present from the maritime administration, academic institutes, Port State representatives, shipping organisations and shipping companies. To be able to address such a wide range of interested parties, including government cabinets’ representatives from six countries, is an achievement in itself. There was much debate and questioning throughout which always makes for a highly educational event that puts into local context the points being addressed in the lectures. 49 Lectures are a very good way to impart large amounts of information on sampling and analysis for the various components of the ballast water management convention. However,

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there is no substitute for some hands-on ship-board work and laboratory processing to reinforce the theory. 50 The practical sampling gave an indication of what would need to be done that ballast water could be sampled from a ballast tank. 51 The demonstrations shown that there are available methods and tools for ballast water sampling (e.g., ballast water samplers, hand pump, plumbing, flow-metres and nets with the correct mesh size of 50µm diagonal dimension) and sample analysis (e.g., small size/portable salinity meters and fluorometers, different microscopes) to be used for compliance monitoring with the ballast water management standards in regulations D-1 and D-2 (indicative and detailed) of the BWMC..

52 In the interactive sessions on day 2 and day 3, the participants raised many practical issues with regard to the implementation of the Convention and the consultants were able to satisfactorily answer their queries. Recommendations 53 The IMO has published guidelines on sampling and analysis of ballast water on ships (BWM.2/Circ.42 - Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2) – distributed to delegates in English and Spanish as part of this training). This is a common sense guide and has been assembled by the experts in this field. This would be the recommended starting point for anyone who needs to sample and analyse ballast water for D-1 and/or D-2 compliance purposes. 54 IMO agreed on a trial period of BWS and analysis in accordance with the BWM Convention and Guidelines G2. This 2 - 3 year trial period will be used gaining experience, reviewing, improving and standardizing the BWS Circular as well as to list sample analysis protocols, methodologies and approaches for the D-1 and D-2 standards compliance tests. 55 It was concluded that:

• BWS for CME is a complex process; • Different CME approaches and tools are available; • Organisms are patchy distributed in tanks what influences BWS results; • Very important is to choose the right approach and tools for the purpose of sampling

(D-1, D-2, indicative, detailed analysis); • New CME methods and tools may be developing; • New CME methods and tools need to be tested and validated first before use for

CME; and • A harmonised sampling approach is needed, to avoid that the ballast water of a

vessel is proven compliant in one port, but would not be proven compliant in another port just because of different sampling methods or approaches used.

Follow-up Action 56 Training of this type in developing countries is essential for the IMO Ballast Water Convention to be fully implemented around the world. This training focused on sampling and analysis of ballast water for D-1 and D-2 with some practical demonstrations on sampling and analysis of water from a ballast tank. 57 To facilitate the implementation of international commitments and best practice for the BWM Convention and to support the development of realistic policies, measures and targets, priority actions were discussed, crucial in terms of time and feasibility of implementation. Major shipping ports are often the first places where biological invasions happen. Port Biological Baseline Surveys and a regional-level risk assessment should be used to identify the priority ports for detailed risk assessment.

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58 The following areas were agreed as important for this purpose:

• Communication, raising public awareness and training • Port baseline surveys and monitoring for harmful aquatic organisms and pathogens

in major ports in the region • National action plans and risk assessment tools to support BWMC implementation • Database on harmful aquatic organisms and pathogens • Database on ballast water reporting forms.

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Annex 1 Regional training on sampling and analysis of ballast water

Cartagena, Colombia, 31 July-1 August 2014 Programme

Day 1 – Wednesday 30 July afternoon

14:00-14:20 Opening Ceremony, Welcome Addresses by Contralmirante Ernesto Duran González and Ms. Aicha Cherif

14:20-14:50 Current status of the BWM Convention and developments at IMO in terms of PSC and Sampling

• IMO/GloBallast Representative: Ms. Aicha Cherif

14:50-15:00 Presentation of consultants and their work

• IMO-GloBallast Consultants: Dr. Matej David and Dr. Stephan Gollasch

15:00-15:45 Ballast water sampling under the BWM Convention

• IMO-GloBallast Consultants: Dr. Matej David and Dr. Stephan Gollasch

15:45-16:15

Ballast water sampling (BWS) recommendations for compliance monitoring and enforcement (CME) under the BWM Convention (ballast water exchange standard (D-1), ballast water performance standard (D-2), indicative and detailed sampling, in-tank and at discharge sampling, introduction of sampling gear, representativeness, sample volumes, timing, number of samples

• IMO-GloBallast Consultants: Dr. Matej David and Dr. Stephan Gollasch 16:15-16:45 Coffee Break

16:45-17:30 Ballast water sampling recommendations for compliance control under the BWM Convention - continues

• IMO-GloBallast Consultants: Dr. Matej David and Dr. Stephan Gollasch

Day 2: Thursday 31 July 2014 Theme: BW Sampling - Summary

09:00-09:45 Selecting vessels and tanks for BWS for CME

• IMO-GloBallast Consultants: Dr. Matej David and Dr. Stephan Gollasch

09:45-10:15 Ballast water sample handling and transfer to the laboratory

• IMO-GloBallast Consultants: Dr. Stephan Gollasch and Dr. Matej David 10:15-10:45 Coffee break

10:45-12:00 Ballast water management in Brazil

• Dr. Flavio da Costa Fernandes 12:00-13:00 Lunch break BW Sampling - Practical Part

13:00-18:00 Drive to the port for sampling D-1 and D-2 on a ship in the Port of Cartagena, in tank sampling, in-line sampling, sample storage and transport and return to venue, sample storage overnight in the lab

Day 3: Friday 1 August 2014 Theme: BW Sample Analysis - Theory

09:00-09:30 Sample analysis procedures or techniques used to test for compliance with D-1

• IMO-GloBallast Consultants: Dr. Stephan Gollasch and Dr. Matej David

09:30-10:30 Sample analysis procedures or techniques used to test for compliance with D-2, indicative and detailed sample processing, introduction of sample analysis methods

• IMO-GloBallast Consultants: Dr. Stephan Gollasch and Dr. Matej David 10:30-11:00 Coffee break 11:00-12:00 Practical sample analysis for D-1 and D-2 in the laboratory 12:00-13:30 Lunch break 13:30-15:30 Practical sample analysis for D-1 and D-2, continued 15:30-16:00 Coffee break 16:00-17:00 Summary, recommended sampling kit and sample processing methods 17:00 Closing ceremony and certificates

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Annex 2

Regional training on sampling and analysis of ballast water Cartagena, Colombia, 31 July-1 August 2014

List of participants

ARGENTINA

Nombre Julio Cesar Pereyra Institución Prefectura Naval Argentina Departamento Departamento de Investigación y Sumarios

Dirección Protección Marítima y Puertos Punto Focal Nacional Argentina

Cargo Prefecto Mayor Dirección Av. Madero 235 6to. Piso Oficina 12

Ciudad Autónoma de Buenos Aires Teléfono 5411 43187600 ext. 2619 Móvil 54 9 11 50010197 Email jpereyra@prefecturanaval.gov.ar julpereyra@yahoo.com.ar

Nombre Jorge Alejandro Cuello Institución Prefectura Naval Argentina Departamento Departamento Técnico de la Navegación. Cargo Jefe División Técnica Naval Dirección Av. Madero 235 6to. Piso Oficina 12

Ciudad Autónoma de Buenos Aires Teléfono 5411 43187600 Anexo 2158 Email jcuello@prefecturanaval.gov.ar

Nombre Natalia Florencia Aprigliano Institución Prefectura Naval Argentina Departamento Dirección de Protección Ambiental Cargo Oficial Principal- División Investigación Científica Dirección Av. Eduardo Madero 235 Teléfono 541143183500 Email natyapris@gmail.com

CHILE

Nombre Rodrigo Eduardo Guzmán Barros Institución Ministerio de Relaciones Exteriores Departamento Dirección de Medio Ambiente y Asuntos Marítimos Cargo Jefe Departamento de Asuntos Marítimos Dirección Teatinos 180, Santiago Teléfono 56-2 2827-4384 Email rguzman@minrel.gov,cl

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Nombre Rodrigo Andrés Zambrano Irribarra Institución DIRECTEMAR Departamento Dirección de Intereses Marítimos y Medio Ambiente Acuático Cargo Jefe División Preservación del Medio Ambiente Acuático Dirección Subida Cementerio Nº 300 Playa Ancha, Valparaíso Teléfono 56-32 2208340 Email rzambrano@directemar.cl rzambrano@dgtm.cl

Nombre Javier Eduardo Monsalves Henríquez Institución DIRECTEMAR Departamento Gobernación Marítima de Talcahuano Cargo Encargado de Medio Ambiente y Combate a la Contaminación Dirección Almirante Villarroel 107, Talcahuano, Chile Teléfono 56-41 2266108 Email jmonsalves@directemar.cl

COLOMBIA

Nombre Luz Ángela Castro S. Institución Dirección General Marítima, DIMAR Departamento Protección Medio Marítimo, Ministerio de Defensa Cargo Coordinadora Nacional del Proyecto GloBallast Dirección Carrera 54 Nº 26-50, Bogotá Teléfono 220-0490 ext. 2368 Email lcastro@dimar.mil.co luzangelacastro@yahoo.com

Nombre Mary Luz Cañon Institución Dirección General Marítima, DIMAR Departamento Protección Medio Marítimo, Ministerio de Defensa Cargo Responsable Protección del Medio Marino Dirección Carrera 54 Nº 26-50, Bogotá Teléfono 220-0490 ext. 2368 Email lMcanonpaez@dimar.mil.co

ECUADOR

Nombre Jacqueline Concepción Espinoza Bustamante Institución Ministerio de Transporte y Obras Públicas Departamento Convenios Internacionales Cargo Coordinadora Dirección Av. de la Marina, Puerto Marítimo - Zona bancaria Teléfono 00593-4-2592080 Ext. 82124 Móvil 00593-983021539 Email jcespinoza@mtop.gob.ec

Nombre Richard Patricio Villacís Mendoza Institución Ministerio de Transporte y Obras Públicas Departamento Departamento de contaminación Cargo Jefe Dirección Vía Puerto Marítimo de Esmeraldas Teléfono 00593-62722262 Móvil 00593-997104178 Email rvillacis61@hotmail.com

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Nombre Bilme Roberto De La Cruz Buris Institución Ministerio de Transporte y Obras Públicas Departamento Unidad de Asesoría Jurídica Cargo Coordinador Jurídico-MTOP-SPTMF Dirección Puerto Marítimo Zona Bancaria (Modulo 16 y 17) Teléfono 593 2 592080 Móvil 593 9 90608394 Email rdelacruz@mtop.gob.ec

PANAMÁ

Nombre Jack William Barnett Montenegro Institución Autoridad Marítima de Panamá Departamento Dirección General de Marina Mercante Cargo Tecnico en Cumplimiento de Convenios y Normas Marítimas

Punto Focal del Programa GloBallast Dirección Avenida Omar Torrijos Herrera, Edificio Pan Canal Plaza, piso

3ro Teléfono Móvil Email Jack.barnett@amp.gob.pa

Nombre José Ramón Macias Richa Institución Autoridad Marítima de Panamá Departamento Dirección General de Marina Mercante Cargo Jefe del Departamento de Navegación y Seguridad Marítima Dirección Teléfono Móvil Email

Nombre Alexis Omar Peña Castro Institución Autoridad de los Recursos Acuáticos de Panamá Departamento Investigación y Desarrollo Cargo Biólogo Ambiental Dirección Avenida Justino Arosemena, Calle 45 Bella Vista, Edif. La

Riviera Teléfono 507 511 6036 Móvil 507 6214 1354 Email alexisp1084@gmail.com

PERÚ

Nombre Rita Esther Orozco Moreyra Institución Instituto del Mar del Perú, IMARPE Departamento Área Funcional de Investigaciones Marino Costeras Cargo Coordinadora de la Red de Monitoreo Ambiental Dirección Esquina Gamarra y Gral Valle s/n Chucuito Callao Teléfono (511) 2088650 Anexo 845- 846 Móvil (511) 993380659 Email ritaoro@imarpe.gob.pe

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Nombre Javier Velázquez Maratuech Institución Autoridad Marítima Nacional Departamento Dirección General de Capitanías y Guardacostas DICAPI Cargo Dirección Teléfono Móvil Email

Other national participants from Colombia

Sr Dimar o Sr GRUCOG Bogota German Escobar Responsable Area seguridad Integral

Marítima Mary Luz Cañon Paez Asesor de defensa Dimar Diego Bolivar Líder Proceso PMM Buenaventura Jhon Quiceno Líder Proceso PMMTumaco Nilson Rueda Líder Proceso PMMBarranquilla Luis Manuel Carrillo Bermúdez Líder Proceso PMMSanta Marta Eugenio Henao González Líder Proceso PMMRiohacha Jhon Fredy Agamez Líder Proceso PMMTurbo William Alfonso Monroy García Líder Proceso PMMCoveñas Mauricio Restrepo. Líder Proceso PMMPuerto Bolivar Jimmy Yusti Robles OSEPBarranquilla Omar Penagos OSERP Barranquilla Juan Caceres Inspector de Bandera Coveñas Marco Rueda OSERP Tumaco Jenny Parada Biologa Tumaco Johana Arregoces Biologa CIOH Diana Quintana Microbiologa CIOH Anderson de la Hoz Capitania Puerto Cartagena CP5 Pablo Trujillo Imagen corporativa, dimar Gustavo Arazola OSERP CARTAGENA

Tomas Parra OSERP CARTAGENA

Julian Alejandro salgado Comisión Colombiana del Oceano (CCO)

Fredy Castrillón Centro Control Contaminacion del Pacifico CCCP

Grupo de Tarea Nacional Jesús Eduardo Orduz Rodríguez Cerrejon Marta Patricia Roa Dirección de Infraestructura Min Transporte Jenny Bowie WilchesJenny Parada Tercer Secretario de Relaciones Exteriores

Carlos Peña Empresa de Petróleos (ECOPETROL)

Pedro Alfonso Rincón Porto Empresa de Petroleos (ECOPETROL)

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CONSULTANTS

Nombre Stephan Gollash Institución GoConsult Cargo Consultor – OMI Dirección Grosse Brunnenstrasse 61

22763 Hamburg, Germany Teléfono Móvil Email

Nombre Matej David Institución Dr. Matej David Consult s.p. Cargo Consultor – OMI Dirección Korte 13 e

6310 Izola, Slovenia Teléfono Móvil Email

IMO-GLOBALLAST

Nombre Aicha Cherif Institución GloBallast Partnerships

International Maritime Organization Cargo Project Officer Dirección 4 Albert Embankment,

London SE1 7SR United Kingdom

Teléfono Tel: +44 207 4634215 Móvil Email acherif@imo.org Skype aicha.cherif5

RAC REMPEITC/Caribe

Nombre Vassilis Tsigourakos Institución RAC/REMPEITC – Caribe Cargo IMO Consultant Dirección Seru Mahuma z/n

Aviation & Meteorology Building, Curaçao Teléfono +5999 839 3719 Móvil Email vtsigourakos@cep.unep.org

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COMISION PERMANENTE DEL PACIFICO SUR - CPPS

Nombre Julián Augusto Reina Moreno Institución Comisión Permanente del Pacífico Sur Cargo Secretario General de la CPPS

Secretario Ejecutivo del Plan de Acción Dirección Av. Carlos Julio Arosemena, Edificio Classic 2do piso Teléfono 593 4 2221202 ext 101 Móvil 593 9 85042797 Email jreyna@cpps-int.org

Nombre Héctor Eduardo Huerta Rodríguez Institución Comisión Permanente del Pacífico Sur Departamento Oficina del Plan de Acción para la Protección del Medio Marino y

Áreas Costeras del Pacífico Sudeste Cargo Coordinador Técnico Regional del Plan de Acción Dirección Av. Carlos Julio Arosemena, Edificio Classic 2do piso Teléfono 593 4 2221202 ext 114 Móvil 593 9 92735705 Email hhuerta@cpps-int.org

Nombre Verónica Ávila Pazmiño Institución Comisión Permanente del Pacífico Sur Departamento Oficina del Plan de Acción para la Protección del Medio Marino y

Áreas Costeras del Pacífico Sudeste Cargo Secretaria de la Oficina del Plan de Accion - CPPS Dirección Av. Carlos Julio Arosemena, Edificio Classic 2do piso Teléfono 593 4 2221202 ext 116 Móvil 593 9 96601997 Email vavila@cpps-int.org oficinaplandeaccion@cpps-int.org

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