1,000 days to go: MEPC 77, The Shanghai Test and BWMS decision time

Today marks 1,000 days until the final date of the D-2 standard implementation – 8 September 2024. The standard includes specific details on the number of organisms per cubic meter of water, and the minimum dimensions of these organisms. But the bottom line for shipowners and operators: there are just under 33 months to ensure your ballast water management system (BWMS) provides effective, long-term, reliable treatment of invasive aquatic species.

While 1,000 days may feel like a long time, when you factor in all the variables and potential delays, it will sneak up on you. For example, there is likely to be a huge demand for retrofitting systems that will result in bottlenecks at shipyards and subsequently higher costs and delays. It also takes time to weigh up the options and make these complex, business-critical purchasing decisions.

MEPC 77: challenging water conditions

Another MEPC meeting has been and gone. One of the key outcomes of the meeting was an agreement to progress work on guidance for ships that need to conduct ballast water management in ports with challenging water with the view to finalisation at MEPC 78. Taken at face value, this outcome means official guidance has been punted down the road. However, in practice, IMO has reinforced the status quo, meaning shipowners and operators must treat the water in sediment-rich areas to the best of their BWMS’s ability. To put in another way, at this stage, there will be no blanket exceptions or bypassing of systems for ships operating in challenging water conditions.

The desire for blanket exemptions highlights the challenges shipowners and operators face if they purchase a poorly performing BWMS and/or filter. But there really is no basis for blanket exceptions. To allow low-quality systems which can be bypassed in less-than-ideal conditions is contrary to the environmental aims of the Ballast Water Management Convention, and it is highly unlikely to ever happen. Therefore, there are essentially two options.

Option one, risk that you can succeed with running a low-quality filter and ineffective system, asking to use contingency measures on a case-by-case basis. This is not a long-term solution and has high opportunity costs. You will waste time, and therefore money, negotiating with the port on current water quality and whether you are compliant or not. This option also has high opex costs. There remains a high risk that you will not comply with regulations resulting in fines, damage to your reputation and the eventual need to install an effective system at additional cost. Additionally, using contingency measures may result in contamination of your tanks and piping, increasing the risk of downstream compliance testing failures long after leaving a challenging port.

Option two, rather than seeking concessions for a low-quality system, ensure that you are buying a BWMS and filter designed for the vessel’s route and operating profile. There is sufficient technology and equipment available on the market today to meet the operational challenges posed by challenging water conditions. With this option, capex costs may be marginally higher but opex costs are much lower. Plus, operational delays and disruption are minimised, maximising trading time and maintaining your competitive advantage. So, how do you know if a BWMS and its filter will be effective in even the toughest water conditions?