NEWS ANALYSIS
Water works
regulations to the IMO’s Marine Environment Protection Committee. Te flag states of Liberia, the Marshall Islands and
A
Panama are concerned about a number of possible difficulties following the ratification of the BWTS regulations. Included in their list of possible problems is the:
number of organisations have outlined their concerns regarding the ratification and implementation of the ballast water treatment
standards in turbid or high sediment conditions while filtration systems may find that their efficiency is reduced in sediment-rich and muddy waters. “It is clear that an owner is not able to make a decision
• need for revision of the Guidelines for approval of ballast water management systems (G8) to improve
• availability of BWMS and sufficient facilities to install BWTS
• sampling and analysis procedures for port state control purposes.
Convention and, And their concerns are shared by a number of industry
organisations, including: BIMCO, the oil tanker owners’ association Intertanko, the Cruise Lines International Association (CLIA), the cargo owners’ association Intercargo, the ship managers’ association InterManager, the International Product Tankers Association (IPTA), the corrosion foundation NACE and liner shipping representatives the World Shipping Council (WSC). Te co-sponsors of the MEPC submission say that as of
June 2012 there 23 type approved BWTS on the market. However, the group says: “In many cases it is apparent that the Type Approval Certificate and its enclosures are insufficient in detail to provide a clear picture of whether a system may be adequate to meet the needs of the vessel being considered and its particular trade routes. Te problem stems from the lack of limits provided in the Type Approval Certificate and its enclosures even though this is an aspect specified within the “Guidelines (G8)”. In some examples the approval documentation may imply that the BWTS has no practical and operational limitations. However, the fact that no limitations are provided does not mean limitations do not exist.” According to the group type approval certificates have
been “provided based on theoretical extrapolation of the system’s maximum treatment rated capacity [TRC] as opposed to actual physical testes.” In addition the co-sponsors believe that electro-
chlorination and electrolysis systems may not meet the standards in certain conditions, that is brackish or freshwater, while UV systems could fail to meet the
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transparency and ensure appropriate robustness of ballast water treatment systems (BWTS)
• survey and certification requirements for ships constructed prior to entry into force of the BWM
based purely on the Type Approval Certification and its enclosures. However, resolution MEPC.174(58) states that the Type Approval Certificate should specify any limiting conditions of the BWTS usage necessary to ensure its proper performance. Te co-sponsors propose that the form of the Type Approval Certificate as well as its enclosures should be revised and standardised with the aim of improving the transparency and detail of information being provided to ensure the overall veracity of the certification and the certification process,” say the co-sponsors. According to the flag states and owner’s
organisations a number of issues are emerging that show that the approval process is failing to ensure that the ballast water treatment equipment is fit for purpose. Tat is that the equipment is “robust enough for ship board installation and operation”. In effect the co-sponsors say that resolution MEPC.174(58) will approve a system that meets the D-2 standards, but it does not approve a system that is operating in an “actual maritime environment”. Te proposals set out in their paper “are seen as
a first step in assessing BWTS in a more credible and effective manner. If the MEPC should decide that there is a need to revise the “Guidelines (G8)”, which the co-sponsors believe is the case, then the Committee would also need to discuss what to do about systems that have already been approved under the current Guidelines (G8)”. Owners also have other concerns, including the
problems surrounding the fitting of BWTS to all ships within 12 months of the regulation becoming live. In addition sample testing methods are considered to be a potential problem where, the co-sponsors say, some properly maintained and type approved systems could fail during sample testing. “Te manner in which the sampling and port state
control procedures are being interpreted at present would suggest that there is also a lack of confidence by some administrations in the original approval process. Tis would indicate uncertainty in the ability of the approval process using “Guidelines (G8)” to fulfil its obligations in ensuring compliant systems are installed and operated on board ships.” As a result of the continued uncertainties surrounding compliance and enforcement
the
co-sponsors claim there are “significant barriers to implementation” of the ballast water regulations.
The Naval Architect September 2012
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