The countdown to compliance is upon us, and many unanswered questions about ballast water regulation requirements remain, writes DeNora Water Technologies General Manager Dr Stelios Kyriacou
We are all acutely aware of the countdown to compliance. Much has been made of the various types of ballast water treatment systems available: the pros and cons, the deadlines and the costs, both immediate and on-going. But we are yet to be told what is expected of us when it comes to regulatory compliance and ballast water indicative sampling and instrument certification.
Many unanswered questions remain, and the time is ripe for IMO and industry to step forward and debate.
In its MEPC paper Harmful aquatic organisms in ballast water, a summary of currently available ballast water indicative analysis instruments (MEPC 74/4/INF.18), IMarEst has done a fantastic job of exploring the available indicative analysis instruments for ballast water testing. It is now up to IMO to prioritise and decide an industry standard, in order for shipowners, port state control and port authority officers to make an informed decision when it comes to testing and performance monitoring.
From an industry perspective, IMO must decide how sampling is to take place, what the standard parameters should be for accessing samples, who is responsible for completing the sample, and what are the consequences of non-compliance?
At last count, there are at least 12 portable ballast water fast evaluation kits available on the market. Some might even say we are spoilt for choice. They are each a product of extensive research and development based on sound scientific evidence and testing. But if we lined them all up and used them on a control sample, you can bet they would come back with differing results. It is not a simple question of which one has worked and which has not, more which is testing for what? If we were to expand our control sample further, perhaps to include water that has been treated using different methods, it is safe to say we would end up with far more questions than when we began.
As those in the industry will know, treated ballast water is the product of complex biological processes. Differing methods of treatment only add to this complexity. So, a selection of kits based on their own unique methodologies does little to aid standardisation. Furthermore, the language we use to outline and describe the process needs to be consistent and clearly defined. There are significant differences between gathering, sampling, analysing and evaluating. We can gather and test all we like, but it will provide us little insight into analysis and evaluation unless we have clearly defined parameters for sample size and frequency of data collection. Testing for one organism or another has value, but in the realms of science and legislation, it means very little without due process.
Which leads us to the crux of the issue: what is it we are hoping to find, or perhaps more fittingly, rule out?
We could examine phytoplankton cell density, in line with current IMO D2 and USCG discharge standards, but neglect to look for non-photosynthesising zooplankton. Are we safe to assume the presence of non-oxygenating organisms in a ballast tank is not a risk to compliance? There are plenty more iterations that have the potential to cause significant contention, and for shipowners on the front line, it is vital that we take steps towards clarity and a cohesive approach.
Practically speaking, we still need to decide who should be collecting these samples. From where I am standing, the only way we can hope to guarantee true impartiality is through independent assessors, trained in yet-to-be-agreed upon methods of standardisation and practice. Then, of course, we also have to consider the role of port state control officers, as the lynch-pins between the testers and the technical experts assessing the samples. If, hypothetically speaking, a ship fails to meet compliance, due to current rulings surrounding undue delays, will port authorities be mandated to communicate this to the next port en route? And what then? What are the implications for shipowners and their ballast manufacturers?
Here at De Nora, we are of the firm belief that in order for us to move forward, we need some concrete answers to all of the above. I, of course, have my own opinions on best practices – but ultimately, it is up to IMO to provide us with some direction.
We can advise shipowners on the best treatment system for their vessels. We can support them with choosing the right system, in line with the living structure of their vessel, carry out successful installations and offer on-going support for maintenance and up-keep. But we are not able to shed light on sampling and testing processes without sound guidelines.
It is time for debate, join us as we begin the conversation in our webinar. The details and the link to join are below.
Ballast Water Treatment Beyond Certification webinar details
TITLE: Ballast Water Treatment Beyond Certification
DATE: 25 November 2019 3:30 PM - 4:30 PM GMT
PARTICIPANTS: Mark Cameron, chief operating officer at Ardmore Shipping Limited; Carsten Ostenfeldt, managing director, Anglo-Eastern (Germany) GmbH; Philip Roche, partner, Norton Rose Fulbright; Dr Stelios Kyriacou, general manager - ballast water management systems - De Nora Water Technologies; Guillaume Drillet, regional business development manager - marine services; Tim Wilkins, environmental director, Intertanko