Ballast water compliance:
what you need to know
The BWM Convention was recently amended during the 74th International Maritime Organization’s Maritime Environment Protection Committee meeting. The changes will have a significant impact on the industry as the American Bureau of Shipping’s William H Burroughs explains to Andrew Tunnicliffe.
Maritime Organization (IMO) has warned that bio-invasions of the planet’s marine environment continue to increase at “an alarming rate”, with devastating effects on marine life, economies and health around the world.
Much of this is the result of ships’ ballast water, which often carries bacteria, microbes, small invertebrates, eggs, cysts and larvae. In addition to impacting marine life, ballast water has even been linked to outbreaks of cholera around the world.
In 2004, the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, known widely as the BWM Convention, was adopted; it came into force in 2017. It requires ship owners and operators to have a Ballast Water Management Plan (BWMP), carry a certificate, and conduct procedures to comply with set standards. Those requirements have recently been tightened further, with all vessels required to be compliant within five years.
Tell us a little about the revisions to the BWM Convention.
William H Burroughs: Recent significant revisions include the Ballast Water Management System (BWMS) Code, resolution MEPC.300(72), a new mandatory code for conducting BWMS type approval testing, becoming effective 13 October 2019; amendments to regulations E-1.1 and E-1.5 approved by the Committee during MEPC 74which, if adopted, will require biological testing for D-2 compliance during the BWMS commissioning surveys; and finally, a slight modification to the form of the International BWM Certificate (IBWMC).
Biological testing of BWMS installations is considered necessary to validate the installation of the BWMS but is not intended to validate the design of type-approved BWMS that are approved by the Administration. The modifications to the certificate are intended to allow recognised organisations to issue the certificates for vessels that will not comply using a BWMS, but would comply using other methods per the Convention regulations. This will give Port State Control Officers (PSCO) a convenient way to quickly assess the compliance methods for the vessel before a more thorough examination of the vessel’s BWMP.
AT: How much of a challenge will it be for the industry to become fully compliant within the five-year timeframe required?
We estimate approximately 30,000 vessels of 2,000dwt and larger will have BWMS retrofits during their special surveys between 8 Sep 2019 and 8 Sep 2024. That works out to about 500 retrofits per calendar month. Based on the manhours of work required adding these retrofits to the normal out-of-service periods, the industry will likely need a more technically qualified personnel to accomplish this work by the deadline. If any of the stakeholders have not yet ramped up to meet these challenges, the entire five-year implementation plan could be at risk of failure.
AT: What should ship owners and operators be doing now to meet those requirements?
WHB: For each vessel in their fleet, owners and managers should, first and foremost, determine what BWM technologies will work for each of their post-retrofit charter targets and select a BWMS vendor that provides the best effective technology. Equally important, get early contract agreements from their selected vendors to make sure the BWMS will be delivered on time, since missing the retrofit opportunity will prevent the vessel from operating on international charters after the International Oil Pollution and Prevention (IOPP) certificate renewal survey date.
It’s also very important to get an early booking with naval architect and marine engineering firms that have invested time learning how to manage BWMS retrofits. Waiting too long could force owners to use less experienced designers that will take up the work at the last minute to capitalise on this large market opportunity. The design firms that have invested time retrofitting BWMS have significant lessons learned which might not be shared with the shipyard designers and other less experienced firms. Using less experienced designers could delay a BWMS retrofit or cause post-retrofit operating problems throughout the remaining years of the vessel’s lifecycle.
AT: How important is it to review a ship’s specific requirements rather than take a one-size-fits-all approach?
Based on each vessel’s size, generic ballast dependency and post-retrofit charter opportunities, some BWM technologies might be less attractive. Contingency measures such as ballast water exchange (BWE) and ballast water treatment (BWT) during re-ballasting would be time-consuming and add operating costs; if a vessel requires more time to achieve compliance, other vessels with smarter BWMS technology choices might be better able to compete for those charters. Owners that are counting on only BWE as a contingency measure might not be allowed to enter some ports where the administration requires BWT integrated into contingency measures for compliance.
That could cause some vessels with less effective BWM technologies to have additional problems on some voyage routings, based on water quality challenges such as salinity, temperature, and UV transmittance.
AT: What are the dangers of non-compliance or poorly managed retrofitting?
WHB: Each administration will need to evaluate the acceptability of BWE as a contingency measure versus BWT, and provide notices for vessels operating in their waters as soon as possible. Following the Experience Building Phase (EBP), contingency measures might be less forgiving and could cause some vessels with less effective BWM technologies to be less competitive.
PSC interventions could force vessels to abandon certain de-ballasting ports and affect vessels operating in ballasting ports with challenging water quality conditions. The vessels with smarter BWM technology choices could gain charters that other vessels lose due to operating challenges after the EBP.
Since PSC bodies will likely prohibit discharges of non-compliant ballast water, the real threat is loss of charters for vessels with less effective BWM technologies.
AT: What were some of the key takeaways from the global workshop on this issue ABS held earlier this year?
WHB: Proper and early BWM technology choices, selecting reputable designers with early experience on retrofits; proper BWMS vendor selections evaluating market staying power, technical assistance and spare parts availability, and so on; and effective operator training. Getting any of those wrong could doom a vessel to the scrapyards.
Lastly, a couple of important considerations for the retrofit include cleaning ballast tanks during the retrofit. This should be a priority because a BWMS might produce compliant ballast water, but dirty ballast tanks could prevent compliant discharges. Since the BWMS will require biological testing following installation and commissioning, the added challenge is float out water, the small volume of water added to the vessel’s ballast tanks to get the vessel off the blocks. If the float out water is not treated, the vessel will have to flush the tanks in the “same location”, per regulation A-3.5.
Note that, after the B-3 amended date, mixing the unmanaged float out water with treated water would likely cause the vessel to fail biological commissioning testing and, at best, the Administration might allow the vessel to sail with a short-term IBWMC. However, the vessel might be banned from entering another administration’s waters until biological testing is completed, potentially causing a vessel to lose its post-retrofit charter if it is delayed while flushing non-compliant float out water, or dirty ballast tanks, until it can pass commissioning testing.
William Burroughs, Senior Principal Engineer at ABS. Image courtesy of ABS.