The ballast water headache and LNG carriersTaken from: LNG World Shipping Editor's Viewpoint 19 March 2012
Although implementation of the Ballast Water Convention is imminent, the regime is far from the finished article and the industry is far from ready.
The global shipping community has been faced with an onslaught of new environmental protection measures over the past decade and one of the most difficult sets of requirements to define, configure and implement has been the proposed ballast water management regime.
The slow pace of ratification of the International Convention for the Control and Management of Ships' Ballast Water and Sediments (the BWM Convention), which was adopted by IMO in 2004, reflects the magnitude of the technical challenges facing seafarers, shipowners, equipment suppliers, class societies and regulatory authorities as they attempt to implement the agreed provisions.
The BWM Convention is due to enter into force one year after it has been ratified by 30 member states comprising 35 per cent of the world tonnage. As of 1 March 2012 some 33 countries representing just over 26 per cent of the world's tonnage had done so.
With entry into force imminent, shipowners are under increasing pressure to comply with the agreed requirements. Acceptance of the regime by some leading maritime nations and the unilateral adoption of ballast water regulations in other countries are rapidly reducing the amount of time the shipping community has available for embracing the complex operational and documentary procedures and the novel treatment systems that are called for.
The new convention was developed to control the bio-ecological threat to the marine environment caused by invasive alien species in ships’ ballast. Recognising that ships differ in type, size and configuration, the BWM Convention initially allows for two standards of ballast water management - the Ballast Water Exchange Standard (BWE) - which is only acceptable until January 2014 or 2016, depending on the ship’s ballast capacity - and the Ballast Water Performance Standard (BWP) where ballast water must be treated prior to discharge.
The greatest of the BWM challenges facing a shipowner is the choice of the most appropriate ballast water treatment (BWT) system for a particular vessel. The decision is not made any easier by the fact that BWT technologies are at a relatively early stage of development, the equipment is expensive and question marks remain over the ability of available systems to achieve the necessary performance standard when specified for larger ships with ballast capacities over 5,000m3. The impact of the BWT system on other ship systems and performance monitoring also needs to be borne in mind.
For LNG and LPG carriers and oil tankers, the close alignment of berthside ballasting with cargo transfer operations is critical due to the limited working envelope of the jetty-mounted marine loading arms. Tied to a strict port turnaround schedule, the ship’s master has to be confident that the BWT system will function as specified. The shipowner needs to be assured that the BWT system will perform as specified and not put the vessel at risk of a port state detention.
The brave announcement in recent weeks by Wilhelmsen Technical Solutions (WTS) that it was withdrawing its BWT system from the market, even though the system had attained type approval in 2010 as per the IMO’s guidelines, has highlighted the deep uncertainties about the efficacy of the proposed BWM regime. Despite the approval it had achieved WTS admitted that that it did not believe that its system would provide an effective and fully compliant solution with the provisions as they currently stand.
Against this background the draft BWM Convention is still the subject of debate at IMO. A Ballast Water Review Group is considering whether the agreed type approval procedures for BWT systems may have to be revised and will advise its parent Marine Environment Protection Committee (MEPC) on the outcome. Other outstanding issues include the need to finalise the BWM regime’s port state control procedures, essential for uniform implementation, and a requirement for better alignment between the BWT type approval guidelines and the draft IMO guidelines on compliance testing and sampling.
An estimated 57,000 ships, representing a market worth US$34 billion to equipment suppliers, will be impacted by a BWM Convention which is not yet the finished article. The other question that comes to mind is, has the horse already bolted? Has a busy global shipping industry that has operated without a BWM Convention until now already distributed all the invasive species that there are to be distributed?