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BEWARE BALLAST BOOBY TRAPS

BEWARE BALLAST BOOBY TRAPS

Sunday, January 10, 2021 

Shipowners who have invested in Ballast Water Management Systems (BWMS) rightly expect that they’ll deliver reliable, simple regulatory compliance. These systems often represent millions of dollars’ worth of capex and come with International Maritime Organization (IMO) or US Coast Guard (USCG) certifications that validate their effectiveness.

However, shipowners have consistently found it difficult to ensure that their system treats water to the correct standard and many have found themselves noncompliant and out of pocket, despite diligently following the manufacturer’s best practice recommendations. This is not an acceptable risk. Having a non-compliant IMO or USCG BWMS means that you are subject to fines and sanctions that can effectively render you unable to trade. In the US, failure to comply to the USCG standard brings with it fines of $35,000 per day and criminal liability for those who “knowingly” violate the law.

As things stand today, there is no IMO requirement for a BWMS to be tested upon installation and, in my experience, it’s all too common for errors to creep in during the installation process. These errors may render a BWMS incapable of treating ballast water at all, or reduce its effectiveness to the extent that it does not meet the IMO’s D-2 minimum standard. Indeed, some estimate that more than a fifth of BWMS do not treat water to the required standard upon their installation.

If a BWMS does not work as designed when it is delivered on board, it will represent a compliance risk throughout its lifecycle. A shipowner might only discover that a ship’s system has never worked correctly when a regulator takes enforcement action, leaving them with sizeable fines, legal liability and numerous additional off-hire costs. Fortunately, it’s looking likely that this reality will change at the 75th session of the Marine Environment Protection Committee (MEPC 75), when it’s widely anticipated that new commissioning testing rules will be adopted.

These commissioning testing standards — expected to come into force in 2021 — would harmonise regulation for signatories of the Ballast Water Management Convention and see every BWMS installation tested before delivery, with failed tests triggering diagnostic and repair work until the system passes. This process relies entirely on fast and accurate indicative testing, which can deliver this practical assurance to shipowners and other key stakeholders.

BEYOND INSTALLATION

Thorough and practical commissioning test standards will have a real impact for shipowners, and represent a vital step in reducing unreasonable risks. However, this does not guarantee operational compliance, and a significant number of issues will persist.

Last year, the American Bureau of Shipping (ABS) released its “Best practices for Operations of Ballast Water Management Systems” report, which included a significant survey of shipowners. Some 59% of respondents reported operational problems with their BWMS, and 6% reported completely inoperable systems. There are more than 100 BWMS models on the market, with each operated differently.

This understandably creates challenges with training and human factors, especially as crew move between ships and encounter new systems. Some units from the same manufacturer that seem visually similar are operated differently, while they are unlikely to provide useable data to show if they are being operated incorrectly. There is no requirement for seafarers or shipowners to monitor the complex data produced by a BWMS, while the information measured may look normal, despite non-compliance. In some cases, issues with filters, electrodes, or other components can cause a system to stop treating ballast water to the acceptable level without providing any indication.

As a system ages, these issues become exponentially more likely. As the regulations mature further, compliance will be fully enforced. Robust compliance testing standards will be adopted by the IMO and the USCG, and those who are not operationally compliant will face enforcement actions — potentially even if they have followed current best practice to the letter.

CONTINUOUS TESTING

Shipowners need to be confident that their vessels are compliant with regulations and the only consistently reliable way to do that is with the right tools and technology. Similarly, it is important that ships are not accidentally transporting invasive species in inadequately treated ballast water for the regulations to have the ecological effect they were designed to. The only way to provide these tools is through the data provided by ongoing indicative monitoring. This should be the fundamental cornerstone of any shipowner’s approach to ballast water management, as well as the approach regulators take going forwards. Ongoing monitoring processes could take several forms.

One method, which is already being adopted by some, entails contracting out regular indicative testing at ports to a third party. This approach cuts the risk of a long-term undiscovered BWMS failure and usually enables diagnostic and corrective action to be taken in the event of a fault before a shipowner is liable for sanction. However, the most effective way to minimise this data-driven risk is to install on-board indicative ballast water monitoring systems.

These can continually provide real time, accurate data at any point. This provides fast information that can stop a noncompliant discharge, enable the rapid diagnosis of issues while at sea, and help seafarers work efficiently with Port State Control to find alternative arrangements for ballast water discharges if necessary. These ongoing monitoring solutions will only provide value if shipowners and regulators are certain that indicative tests can meet their needs. They must be fast, accurate, reliable, practical and simple enough to use that they do not require any additional training.

These market needs are what drove the development of Chelsea Technologies’ FastBallast system, which uses an integrated, sophisticated measurement technique within a convenient, portable, and user-friendly instrument to deliver a high degree of accuracy. The technical and regulatory challenge posed by ballast water management has caused unforeseen issues across the industry,and opened up unfair hidden risks for shipowners who follow the rules to the letter. The changes to commissioning testing regulations expected at MEPC 75 represent a real step forwards in tackling these risks, but the only way to achieve the operational certainty that the industry needs is to continue testing on an ongoing basis after commissioning.

This article was written before MEPC 75.

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