Fitting a timeline to success
IMO’s latest Sub-Committee for Bulk Liquids and Gases meeting (BLG17) has set out a procedure for port states to trial biological sampling techniques for ballast water in preparation for the anticipated implementation of the ballast water management convention. The procedures will be used to evaluate methods for determining if there are live organisms in the treated ballast water, but any such sampling and analysis will not be used for criminal sanctions against shipowners or for detaining vessels. It can however be used enforce emergency treatment action, such as is available from the Ballast Responder developed by the US National Park Service and The Glosten Associates.
The two year trial period aims to provide data on sampling and analysis methods and a review mechanism to improve and standardise the sampling protocols. The trials are seen as necessary because many of the methods trialled by scientists have led to variations in readings of several hundred per cent and have therefore not inspired confidence in the enforcement of the convention.
The move to provide for a trial period has been applauded throughout the industry. “There has been a significant polarisation of views between those that carry out the regulatory testing of ballast water systems and those that have an interest in the development of such systems,” says Dr Stelios Kyriacou, technical director of Wärtsilä’s ballast water management systems division. “Lack of clarity regarding the sampling for enforcement has been a major obstacle for ratification of the convention. For example, it is common knowledge that flag states such as Panama and Greece have been hesitant on ratification due to the lack of guidance, robust sampling protocols and port state control tools. The big questions are though, who is going to regulate this and who is going to manage it?”
Dr Kyriacou says that the science underpinning the sampling procedures proposed to date have not really been put to the test. The proposal for a circular on sampling procedures coming from BLG17 is recognition that the issue needs to be evaluated further to provide guidance on, for example, what quantity of water should be sampled and when should the sample be taken. “With such questions answered, we think we already have a good method for extracting the sample itself.”
Should proof that the ballast water treatment system was run appropriately always be enough for port state control without biological testing? For Birgir Nilsen, vice president of business development at Optimarin, when indicative (dip stick) instruments are fully developed and reliable they might have a place in the port state control tool box. These rapid techniques give an indication of compliance, grey zone or gross in-compliance and a decision factor for potential further sampling and testing. “I do not think any port state will hold a shipowner criminally responsible for discharge of organisms that are above the IMO D2 standards who can document that they have used a type approved ballast water treatment system in good faith.”
Mr Nilsen believes there is enough type approved systems on the market and enough capacity to manufacture the required equipment to meet convention requirements. Adding the installation of a treatment system should not add that much extra time and work to a drydocking. Optimarin has worked with several companies already retrofiting their fleets including Gulf Offshore and Saga Forrest Carriers and has installed 50 systems with another 220 ordered.
Intertanko’s environmental manager, Tim Wilkins, is also positive about the trial period for biological sampling, and there is another compromise he is willing to accept in anticipation of the convention entering into force. Intertanko and others made a submission to MEPC 64 to request changes to the conventions G8 guidelines on type approval due to concerns about their stringency. The proposal asked for more detail on performance with respect to salinity, temperature and total suspended solids as well as the need for manufacturers to provide access to the full-scale land-based and shipboard test results.
Instead, they came away with the proposal to amend the certification so that it shows more details about the water quality conditions under which the systems have performed successfully. “So at the end of the day the G8 Guidelines are still imperfect. Even though the best solution is to tighten up the whole approval system and provide the desired confidence in those purchasing the equipment. That said, the transparency amendments should assist in the short term and provide clearer information to the industry,” he says.
“The final issue now in terms of entry into force is the scheduling and implementation dates. If this is resolved successfully through the planned Assembly Resolution currently being drafted by an IMO Correspondence Group which we’re involved in, then I think the key hurdles to implementation are looking a little easier to jump!”
It is this timing that is of primary importance to Jesper S. Jensen, senior vice president, head of Clipper Fleet Management, more so than IMO activities on sampling. “What we are looking for is that the rules are amended so that we can get some realistic timelines for retrofitting the world’s fleet of 68,000 ships. This should happen the day after entry into force. All ships should be treated equally and the allowance should be for five to seven years. In that period it is important that shipowners start to install systems. However, we need some way for this to be controlled otherwise we will have the same situation as now in five years time.”
Clipper Fleet Management manages a fleet of 30 bulk carriers and project vessels, part of Clipper Group’s fleet of close to 200 vessels. Many work the tramp trade so any ballast water system installed would have to be able to handle, Arctic, tropical and freshwater conditions. The system would also need to be suitable for both IMO and US requirements. Clipper has undertaken an extensive investigation into the technologies available and intends to trial systems in the next 24 months, but the risk is that even then, with the short operational experience available industry-wide, after one or two years, repairs will be required. “That is one of the biggest fears for technical managers. They really don’t know what the maintenance costs will be,” says Mr Jensen.
The power consumed by ballast water treatment systems is also a concern for Mr Jensen. Clipper recently received ISO 50001 certification from Lloyd’s Register. This standard specifies requirements for establishing, implementing, maintaining and improving an energy management system. However, Mr Jensen believes that responsible shipowners must accept that trade-offs must be made to protect the environment. A similar situation exists with NOx reduction technologies, he says.
“As a member of Green Marine, a voluntary initiative requiring members to be proactive regarding environmental protection, and as a company working continuously to reduce the impact of our operations on the environment, we are committed to act regarding invasive species transfer protection,” says Daniel Côté environmental advisor for Canadian shipping company Transport Desgagnés. “But we also must be sure that our investments are delivering the desired environmental improvement. We have great concerns about the existing available solutions to deliver it. We want to act but also stay in business.”
Transport Desgagnés operates mix of trades are including many Saint-Lawrence and Great Lakes voyages so the company is looking for treatment systems approved for Saint-Lawrence and Great Lakes very low salinity (less than 1 PSU) and cold waters conditions. “We met the most promising technologies suppliers and up to now no system has been type approved for fresh waters and very cold waters conditions which is of great concerns for us. Being a very small submarket, we then have little impact on technology development. Many ballast water treatment system suppliers have clearly expressed to us that they have no intention of being engaged under the low salinity testing required by the US Coast Guard type approval process. Those who are engaged in the process can’t receive approval before many years and the USCG AMS temporary approval process is seen by us as inadequate and useless,” says Côté.
He continues: “Regulators are pushing shipowners to install infant technologies with unsure results. The industry can’t afford to install technologies that will have to be replaced after a few years on vessels. There is a need to slowdown and question the process.”
According to Christian Robeson, manager of ballast water management for Bureau Veritas: “If anyone says they can tell you for sure what will happen and when, and which technology to adopt, then they either have a direct line to the future or they are trying to sell you something you don’t want to buy. This is a situation where the regulators and the demand from the public have run ahead of available technology. At the moment nothing is clear – not when the rules will enter into force, not the exact standards that will be enforced, nor the technologies which will ultimately prove the best in service. The best advice for shipowners is to investigate carefully, take a range of advice and then evaluate that advice with a lot of care and a degree of scepticism. They do need to act now, or they may be caught in a horrific retrofit backlog, but they also need to act carefully as every ship, route and fleet may have a different answer to the question – what should I fit and when?”
From a scientific perspective, doubts have been raised over the potential for the installation timetable to be extended. Professor Olof Linden of World Maritime University provides training on the implementation of the convention for European flag states and has developed a database of invasive species in the North Sea. Is it too late? Have all the rats of the sea already been distributed? “It is a question that we are thinking of, many of us who are in this business,” he says. “We have the hull fouling issue. That has not been resolved. It is the next problem and in the EU and IMO there are efforts starting now, but with the long time it takes to deal with these kinds of issues, it is difficult to be optimistic.”
