BALLAST WATER: MEPC 81 STRUGGLES TO DELIVER CLARITY

When it comes to systems’ effectiveness, of major concern is the fact that replacement parts are not up to snuff. Though a system’s OEM might be one of the relatively few to survive a decade’s consolidation, and may have already had both IMO and USCG type-approval for some time, and shipowners are finding that the companies providing replacement hardware – bulbs, filters, piping – are changing constantly. Another vexed question is, like Theseus’ ship – how many replacement parts can be fitted to a system before it is no longer the one originally type-approved?

A submission to this year’s IMO meeting of the environmental protection committee (MEPC81) by the Ballast Water Equipment Manufacturers Association (BEMA), asks the IMO for a resolution to this. Namely, it is hoped that the IMO will, like the US Coast Guard (USCG) type approval procedure, require a ‘bill of materials’ (BOM), to specify which filters, pumps and valves are appropriate for a given system.

“…A change in component availability, discontinued or obsolete components, an improved component, or an installation-specific required component,” can lead to some challenging situations, the document indicates.

One is that that OEMs – as represented in the submission – are left scratching their heads as to why their systems being found non-compliant. Solving this problem, BEMA says, would eliminate some of this guesswork and provide a solid basis for continual development. BEMA also said that changing the rules would add capacity for continuous improvement of installed systems.

“BWMS manufacturers may seek to improve their equipment based on operational experience gained and/or industry demands, such as ways to address ballast water management in ports with challenging water quality (CWQ) or improving energy efficiency,” it said.

If adopted, perhaps this will begin to address a problem that has been plaguing the industry for some time – that no matter how good their designs, and how successfully they managed to pass type-approval testing, there is apparently zero guarantee of future performance, or future compliance.

At the outcome of MEPC81, this remained an open question. “Due to limited time to discuss all the necessary changes, amendments… were not concluded,” said LR in its MEPC 81 post-match analysis, adding that “…a more permanent solution to be developed as part of the BWM Convention review.

“As such it is anticipated that this will be worked on intersessionally, and further concrete proposals were invited to be submitted to MEPC 82, with a view to finalisation of the guidance,” LR said.

Although the IMO granted final type-approval for two additional BWM systems – Techcross’ ECS Hychlor 2.0, and NK’s Blueballast II Plus NK-03 at MEPC 80, and basic approval for Erma First’s Flow BWMS at MEPC 81 – even those ballast water systems with the highest type-approval standards available today are proving, on occasion, to be ineffective.

Bridge over troubled waters

‘Ports with challenging water quality’ came under discussion at MEPC 81, where the IMO adopted new guidance to assist shipowners in keeping their systems functional. It is by now well-understood that UV Irradiation systems encounter issues with light penetration in brackish water, requiring a 

good deal more power to perform correctly. This is a common issue in the Great Lakes, and in ports that are some way upriver.

But in February, the result of an Australian study conducted over several years, showed that out of 39 ships calling at the Ports of Gladstone, Dampier, Walcott and Newcastle, more than a third – some 36% – were non-compliant with the IMO D-2 performance standard. In discouraging news for proponents of electro-chlorination (EC) the preferred solution for larger vessels as well as the alternative usually considered for UV systems, almost all those involved in the Australian sample used active substances, making for a rather poor indictment of the industry as a whole.

The non-compliant organisms tended toward the large, the study found. “All observed non-compliances were found in the largest size class of organisms in the discharge standard,” the study determined – the ≥50μm size bracket. “This outcome shows, as other studies have, that organisms in the ≥50 μm size class are more prone than other size classes to present a risk of non-compliance in treated ballast water.”

On top of this, some 5% of the samples didn’t comply with standards based on total residual oxidant (TRO), suggesting that not only did the systems perform badly in the role for which they were designed, but polluted the marine environment beyond acceptable levels to boot. “The range of concentrations released across the various BWMS that utilise active substances could be of potential environmental concern,” the study determined, given the number of volume of active substances released into the environment.

However, on a positive note, the study noted that a degree of improvement had been observed since 2021, with both biological and chemical non-compliance incidences showing an incremental decrease in the years since.

The IMO issued new guidance at MEPC 81 for dealing with challenging water quality, including recommendations for maintaining effective operation, steps for identifying when a system is not operating correctly, and how to make record of and communicate with local authorities in the event of a non-compliance issue.

A people problem

Another factor in non-compliance could be crew familiarity, Optimarin has suggested. Not only are poorly-trained crews more likely to be unsuccessful in compliance with the rules; but, according to Optimarin, could even be a factor in the sector’s reliance on spare parts.

“We see that a lot of start-up issues with new systems could be avoided simply by including crew training in the planning phase,” said Optimarin system engineer Øystein Myhrvold. “It is also an ongoing process to ensure crew have the knowledge they need during service visits to minimise the need for maintenance.”

Tests on two different vessels with identical equipment, but two different standards of training, demonstrated intriguing results. “By providing training for the crew, we saw consumption of spare parts and other wares could be reduced significantly, thereby saving money,” said Optimarin service manager Arne Lund. “If the operator understands the system and knows how its components work, this makes it possible to anticipate and quickly resolve issues so the BWTS can run effectively with low maintenance costs over many years.”

By way of a solution, Optimarin is offering online courses and even simulator training to help bring crew up to speed. The scheme, OptiLearn, adds to familiarisation training conducted at the time systems are installed.

In apparent acknowledgement of this need, the IMO noted that as part of an upcoming review of the STCW code, seafarers should be given new familiarisation training for compliance with the BWM Convention. If Optimarin is correct, this training should pay for itself in the long run, by lengthening the life of equipment, as well as reducing off-hire costs from non-compliance.

Tabled at MEPC 81 was a submission requesting that IMO de-mystify the rules surrounding the use of an onboard back-up ballast water system. If a portable system is carried and used as a back-up in the case the installed system failed, is it to be considered a newly installed system once it is commissioned?

Following disputes between ship operators and port state control authorities on the issue, IMarEST submitted a document to IMO to consider this question. “[The] industry has developed a variety of innovative solutions and technologies to assist ships in cases when a contingency measure is needed,” it said.

It has become commonplace for ballast water OEMs to release containerised versions of their systems, with Damen and Bawat being the standout examples. Carried on the deck of a ship, ballast lines would need to be connected to these systems, bypassing existing piping. This approach is hardly optimal from the point of view of power consumption, since it requires that large volumes of seawater be pumped up onto the deck during ballasting or deballasting operations. But with the systems installed below decks seeing such high failure rates, it is hardly surprising that some shipowners are willing to pay for such an option, in a pinch.

“These scenarios may include an installed BWMS becoming temporarily inoperable, a ship encountering challenging water quality (CWQ), ballasting operations in emergency situations, or use on ships that cannot practically install a BWMS permanently,” IMarEst added. However, it criticised a “lack of clarity in the existing regulations and lack of relevant guidance,” from IMO. Portable BWMS systems “…have been considered as permanently installed by some flag States and/or recognized organisations.”

The lack of regulatory clarity over whether a back-up system constituted a separate installation, then, was holding back more widespread adoption, IMarEST said. “The demand for these contingency measure options is currently low, influenced by the regulatory gap that exists and which creates uncertainty for shipowners about the acceptability of their use.”

Unfortunately, it appears they will have to wait until MEPC 82, or even 83, for clarity.

New momentum

But it may be that BWM systems are about to take on a welcome new degree of urgency. A paper submitted to the scientific journal New microbes and new infections reveals that ships’ ballast water might be contributing to the transmission of new antimicrobial resistant (AMR) bacteria – or what is known is superbugs.

“…It is plausible that clinically relevant bacterial pathogens and their genetic determinants, emerging in a specific country, could be also silently introduced to other countries through [shipping’s] transoceanic pathway,” the paper, entitled Critical-priority resistant bacteria hidden in ship ballast water: A challenge for global epidemiological surveillance, read.

Indeed, this may have already happened, the paper asserts. An AMR-strain of E-Coli, originally found in Brazil in 2016 where it has infected humans and plants, has since spread to Europe and Asia, “being early identified in Brazil in bivalves used as marine sentinels of anthropogenic pollution of ecosystems associated with the largest international Latin America seaport.”

Although speculative in nature, the paper “draw[s] attention to the need for epidemiological genomic investigation for tracking [World Health Organisation] critical priority bacteria in BW.”

“Therefore, the global scientific community and environmental authorities should work towards developing strategies to monitor and strengthen the surveillance of AMR through transoceanic activities,” the authors determine.

If it is true, the spread of AMRs in ballast water is already posing a threat to animals and humans on land, and could play a role in future pandemics. This alarming development may be what is needed to finally push the ballast water management convention over the line.