The IMO has taken a step back from the implementation of the ballast water management convention. Led by David Tongue, director of regulatory affairs at the International Chamber of Shipping, and supported by the key states of Panama, Bahamas and Singapore, a successful move has been made to force IMO to reconsider proposed guidelines for how port state control will check that ballast water is fit for discharge.
The convention sets numerical limits on the number of live organisms that can be discharged in an attempt to limit the transfer of invasive species between regions. It means that onboard ballast water treatment systems, rather than ballast water exchange, will be required for sea-going vessels of more than 400 gross tonnes.
Tongue objected to the use of indicative sampling which only provides a rough estimate of the number of live organisms. According to Tongue, it was only ever meant for environmental protection purposes, not enforcement, as it is vulnerable to bias especially when a large number of potential methods could be used and the assessment made does not match type approval criteria. Ship operators who have installed and run a treatment system face regulatory uncertainty as a result.
To gain type approval, systems undergo land and sea trials as defined by the convention’s G8 guidelines, and many in the industry, including Tongue, believe they are inadequate as they do not require enough variation in water quality parameters such as salinity, temperature and sediment load. “We would certainly like to see a revision to the G8 guidelines to make those guidelines much more robust and more relevant to worldwide water conditions,” says Tongue.
G8 is not mandatory and Tongue would also like to see this changed to ensure what he calls a 'robust and equal application' of type approval across the world. “I’m certainly concerned that the test species are maybe not all in compliance with the size requirements. I believe they [some testing houses] are using surrogates that are much smaller in size which of course means they have a much more ready fatality.”
Whether or not approvals will need to be re-granted after any potential changes at IMO is a topic of conjecture at this stage.
Ratification of the convention is no longer expected this year, although many countries are still proceeding with preparations. Australia is one example and once the convention enters into force Australia will recognise IMO’s type approval process and accept discharge from ballast water treatment systems. Prior to this, applications will be considered on a case by case basis.
Australia is also developing tools and verification procedures for compliance checking including a Treatment System Particulars (TSP) document that details the specific functions of each different type-approved system. This will give biosecurity officers the information they need to verify that the crew are familiar with the operation of the system and that it has been operated in accordance with the manufacturer’s instructions and the ship’s ballast water management plan.
Ballast Treatment Technologies
A Hamworthy ballast water system
According to manufacturer Hamworthy, treatment technologies are polarising around two main types: filtration with UV and filtration with electro-chlorination. UV is considered by many to be more suited to small to medium capacity applications (< 1,500m3/hr), says Hamworthy, as it is generally less complex and more space efficient. The company offers both types of systems in their Aquarius range.
Hyde Marine's system
PG Marine of Norway handles manufacturer Hyde Marine’s offshore support vessel (OSV) sales worldwide and they have already secured orders for 60 ship sets of the UV-based system as well as two fleet agreements. “The ultimate challenge for an OSV is the obvious lack of space,” says PG Marine’s CEO, Roy Norum. “Physical engineering on board is as equally important as having a piece of equipment that can be flexibly split, built in clusters, lines, L-shape or even stacked.” PG Marine uses 2-D and 3-D modelling to assist owners and naval architects with such designs.
“OSVs are bespoke vessels. This creates another challenge as even the largest fleets, like Bourbon and Tidewater consist of a myriad of different designs, versions, generations and ship types. This means that serialisation and standardisation is extremely difficult. With fleets in the range of 300-400 vessels each, the challenge in our experience is far more of a logistic nature, than of a price-per-unit issue. Equipment cost is in the range of US$200-250,000 for OSVs,” he says.
Five of the nine projects that ship repair and ballast water specialist Goltens Green Technologies (GGT) has undertaken so far involved installing Norway-based Optimarin’s UV-based system on offshore supply vessels owned by GulfMark Offshore. Optimarin claims the system is simple and has no negative (corrosion-related) effects on ballast water tanks. The equipment is also flexible, making it highly suitable for retrofitting small to medium sized vessels.
Severn Trent de Nora's ballast water system
However, manufacturer Severn Trent de Nora offers their electro-chlorination system for the workboat market and secured their first order in Norway this year with a contract from Greenway Shipping. They will supply four ship sets of their Balpure system for oceangoing heavy deck cargo barges. Trym Gade Lintoft, marketing director at Greenway, says they chose Balpure because of its technical features and Severn Trent de Nora’s long history of water treatment in the marine industry. “Despite the fact many new ballast water treatment systems have been recently introduced, we wanted to work with an established organisation that provided a first class, fully operational system resistant to the harsh marine environment.”
The market’s relative immaturity has led to uncertainty among shipowners, says Jurrien Baretta, business development manager at GGT. Many have opted to wait rather than incur an unnecessary expense before the convention is ratified. However, the cost will be far greater for those who wait. “At this stage it is a matter of when, not if, the convention will be ratified. So it is better to start now. Shipowners who do so get cheaper prices not only for the system but also for the associated engineering and installation,” she says.
GGT is expecting activity to ramp up in 2016 with a last minute rush to come the year after. This would not be a good situation for anyone, says Baretta, as it would lead to a bottleneck, causing system prices to rise and downtime for vessels. “In order avoid a bottleneck in 2017, we are aiming to make agreements with entire fleets. Fleet arrangements allow both parties to better plan ballast water treatment installations over a five-year period and take advantage of economies of scale. There is a misconception about the time it takes to install a system, so shipowners need to understand that now is the time to start planning.”
IMO has agreed that certificates of compliance with the convention can be issued prior to its entry into force to assist with the phase in of the requirements.