Confidence and Accuracy Critical to Ballast Water Compliance
After more than a decade of discussion and consideration, the 71st session of the Marine Environment Protection Committee (MEPC 71) in July and the entry into force of the Ballast Water Convention (BWC) has provided shipowners with a firm timeline regarding requirements to manage their ballast water, and the installation of an approved ballast water treatment system (BWTS)
The BWC came into force on 8 September 2017, yet the decision to extend the deadline for the retrofitting of existing vessels with BWTS has provided some shipowners with the opportunity to delay compliance with the regulations and avoid the capex requirement until further down the line. Those intending to defer investment risk not only prolonged damage to the environment, but also significant reputational harm which can negatively impact commercial opportunities and reduce the potential market.
The revised BWC introduces two standards for the handling of discharged ballast water to halt the spread of invasive aquatic species. D-1 addresses the ballast water exchange standard and D-2 details the ballast water performance standard using an approved BWTS.
There are now more than 60 approved BWTS on the market, leaving shipowners and operators spoilt for choice. Treatments include: mechanical treatment methods such as filtration and separation; physical treatment methods such as sterilisation by ozone, ultra-violet light, electric currents and heat treatment; chemical treatment methods such as adding biocides to the ballast water to kill organisms; or various combinations of the above.
The D-1 standard requires ships to ensure that ballast water is exchanged far away from the coast where coastal organisms will not survive due to different temperatures and salinity. This can be achieved by several means: emptying the ballast tank and refilling with replacement ballast water equating to at least 95% volumetric exchange; pumping replacement ballast water into a ballast tank and allowing the existing ballast to escape by overflow where at least three times the tank volume is to be pumped through; or filling new ballast water from the top of the tank with simultaneous discharge from the bottom.
The D-2 standard requires that only ballast water with a concentration of less than 10 viable organisms per cubic metre (greater than or equal to 50 micrometres in dimension), or less than 10 viable organisms per millilitre (less than 50 micrometres in dimension) can be discharged in ports and coastal waters.
The Convention applies to all vessels, existing and newbuild, though the timeline for compliance with the BWC varies from vessel to vessel. Ships under construction whose keel was laid on or after 8 September 2017 must conduct ballast water management that at least meets the D-2 standard from the date they are put into service. For existing ships, the date for compliance with the D-2 standard is linked with the renewal of the ship’s International Oil Pollution Prevention Certificate after September 2019.
To date, 66 states have ratified the BWC, representing nearly 75% of the world’s merchant fleet tonnage. Some states are already moving ahead of the regulators, driving enforcement of the BWC ahead of the IMO timeline. Since 21 June 2012, the United States Coast Guard (USCG) ballast water regulations have required vessels that discharge ballast in U.S. waters to either install a treatment system or manage their ballast water in another approved way. In September, the California State Lands Commission issued a letter to clarify the new requirements for vessels arriving at the country’s ports on or after 1 October 2017, making clear its position on compliance with the Convention. In August 2017, the USCG issued a US$5,000 fine to the operator of a vessel for unauthorised ballast water discharge into the Willamette River in Portland. There is a strong likelihood that the level of fines will increase and will vary from state to state, with many anticipating that fines in the tens of thousands of dollars will be more likely.
FastBallast for compliance monitoring of ballast water discharge
Saudi Arabia is another leading global maritime nation that is moving ahead with enforcement of ballast water regulations. This is reinforced by the recent announcement by the world’s largest oil producer, Saudi Aramco, that all vessels calling at its ports will be required to provide a ballast water sample and report. Saudi Aramco is among the highest receivers of ballast water from ships with over 180 million tonnes of ballast water discharged during cargo operations.
Vessel operators and owners must therefore carefully consider both the form and scope of current and future vessel operations to determine how the Convention applies to them and how they can ensure compliance with minimal impact on operations and profitability. Training of personnel to operate a BWTS and interpret the compliance data also must not be overlooked.
A further consideration is the reliability of BWTS. At a recent conference in China, one representative reported unsatisfactory performance based on experience with the BWTS fitted on 36% of its fleet. At the same conference, another speaker noted problems across five main areas – TRO sensors, systems valves, control units, filters and flow meters. This has caused crews to lose confidence in the treatment systems and has induced a fear of additional commercial risk amongst shipowners.
Chelsea Technologies Group (CTG) has direct experience of ballast water management and compliance with the high standards demanded by regulators. CTG’s FastBallast Compliance Monitoring System was identified by Saudi Aramco’s in-house marine biology experts as the most accurate solution in the market for the sampling and testing of ballast water, and will be used to conduct spot checks undertaken by third-party sampling companies.
FastBallast is able to accurately determine the phytoplankton cell density of ballast water to IMO D2 & USCG Discharge Standards (10-50 µm range). It is the only technology that can provide a high degree of accuracy as both an integrated flow through system and as a portable compliance tool, providing the port state control officer the same level of confidence in the results as with laboratory analysis, in-situ and in a much-reduced timeframe. FastBallast’s straightforward sampling and analysis techniques are being successfully applied to negate disputes and reduce the risk of non-compliance worldwide. Additionally, Global Strategic Alliance Saudi Arabia (GSA), CTG’s agent for Saudi Arabia and Bahrain, is working closely with the Saudi Arabian authorities to set FastBallast as the national benchmark for accurate and reliable ballast water sampling.Saudi Aramco and the US Coast Guard have set high standards in environmental sustainability, and are proactively driving change ahead of regulations. It is clear that ballast water monitoring and the issue of compliance is here to stay, and vessel owners and operators should take steps now - both to maintain the asset value of their vessels, and to future-proof their operations and maintain and indeed grow their market share. Shipowners and crews must have confidence in the integrity of the BWTS they have invested in, and the crew should have the training to give them the knowledge and expertise to spot any issues with the compliance data. Failure to do so will prolong damage to the environment and will impact brand and reputation. For shipowners, this will lower profitability and reduce the available share of the market.
Author: Dr Brian Phillips, Managing Director, Chelsea Technologies Group