Vessel operators’ BWMS installation and testing obligations

There is still a lot of confusion concerning the purpose of the different sorts of commissioning that take place in the ballast water management system industry and one of the aims of the Vessel operators’ new and continuing BWMS installation and testing obligations webinar* that took place 31 January 2023 was to dispel some of the myths.

Three experts, Atlantium Technologies chief technical officer Ytzhak (Itzik) Rozenberg, ERMA FIRST ESK Engineering Solutions chief scientific officer and president Ballast Water Equipment Manufacturers Association Dr Efi Tsolaki, and BAWAT chief executive Marcus Hummer, were recruited to answer questions on the issue of commissioning.

The Vessel operators’ new and continuing BWMS installation and testing obligations webinar was sponsored by Purestream by Atlantium, and Bawat.

Dr Tsolaki provided the table (see main image) which explained the different commissioning processes that take place. The order of commissioning testing is that the first takes place after the installation of the ballast water treatment system when the provider will undertake commissioning to ensure the installation is as per its instructions.

Then the classification society will check, through its commissioning process, that the ballast water management system (BWMS) is in line with regulations required by the flag state.

The vessel owner engages a third party for commissioning testing that the BWMS satisfies IMO D-2 discharge standards.

To this list could be added a precommissioning stage of the type-approval process for IMO or US Coast Guard certification, and in a poll, one third of the webinar delegates agreed in whole or part to the statement: “A BWMS that has IMO and USCG type-approval guarantees the system will pass biological tests” (see polls).

Mr Rozenberg pointed out being able to install or retrofit install a ballast water system on a vessel and have it functioning to the required standard depends on the robustness of the design solution.

“The ballast water management system is an add-on to the existing (ballast) system,” he said. In the case of the Purestream by Atlantium system, the robustness of the system is built-in at the design stage with each UV lamp having its own sensor.

Once a type-approved BWMS is installed on a vessel and has undergone all the commissioning testing, then a certificate of compliance is issued, but as Dr Tsolaki pointed out, remaining in compliance is down to the vessel operator and crew to maintain the BWMS, “Crew training is a key issue and very important for the vessel to be compliant throughout the lifecycle of the vessel.”

Mr Hummer was keen that delegates understand the root purpose of the Convention, “It is crucial to understand and remember when we speak about compliance, the ballast water convention is that discharge convention, it is not an equipment convention,” he said.

He added, “Just because you have bought a type of proof ballast water system and installed it, does not mean you are in compliance. Compliance means the discharge ballast water from your vessel is in use in compliance with discharge bacteria on zooplankton, phytoplankton and bacteria.”

He noted commissioning testing is raising some common issues. One is that vessel owners believe they can undertake the commissioning testing. This is not allowed, said Mr Hummer, it has to be an independent body and that excludes the BWMS provider.

There are also practical considerations, “Your sampling point must be compliant and should be communicated to the testing company before they enter your vessels to make sure they can draw water from it.”

In the case of the BAWAT system, the sampling point is on the exit of the system and as this a one-pass system using heat. “It does not matter what the quality of the water in the tanks, or in the sea, or whether the water is seawater, fresh water, dirty water, clean water - heat always works,” said Mr Hummer, “A BAWAT system has never failed a biological compliance test.”

*A full report on the webinar will appear in the supplement Ballast Water Treatment Technology 2023.