Owners and operators require contingency plans for their BWTS as part of their preparations for the October IMO G8 type-approval deadline
The IMO G8 guidelines define the type-approval process for ballast water treatment systems (BWTS) under IMO legislation. The guidelines, also known as the BWMS Code, were originally formulated in 2005. In spring 2018, an amendment to the International Convention for the Management of Ballast Water and Sediments (the BWM Convention) was adopted, where installations of BWMS on or after 28 October 2020 must be type-approved based on the BWMS Code and not the earlier G8 guidelines (MEPC 174(58)). The guidelines were then revised to bring the G8 guidelines in line with the IMO D-2 performance standard. By revising the guidelines to the firmer D-2 standard, the 2016-revised G8 guidelines have moved closed to US Coast Guard (USCG) requirements, but important differences remain.
The D-2 standard specifies that ships can only discharge ballast water that meets the following criteria: less than 10 viable organisms per cubic metre which are greater than or equal to 50 micrometres in minimum dimension; less than 10 viable organisms per millilitre which are between 10 micrometres and 50 micrometres in minimum dimension; less than one colony-forming unit (cfu) per 100 mililitres of Toxicogenic Vibrio cholerae; less than 250 cfu per 100 millilitres of Escherichia coli; and less than 100 cfu per 100 milliliters of Intestinal Enterococci.
There is a cut-off date after which newbuildings and older vessels cannot be retrofitted with BWTS that only conform to the earlier 2008 G8 standards without being penalised. That date, 28 October 2020, is looming fast. After that date, only ballast water systems conforming to the 2016 G8 guidelines will comply with IMO criteria. To put is another way, after this date BWMS approved in accordance with the earlier G8 guidelines must not be installed on board ships.
The timing is very unfortunate, as the Covid-19 pandemic has exacerbated the challenges involves. Over the years, around 60 to 80 different makes and models of BWMS have come onto the market. Not all have been put forward by manufacturers for type-approval to D-2/revised G8 standards. The revised G8 guidelines are rigorous and as at mid-2020, there is a risk that some BWTS will not be tested or meet the revised guidelines in time. Speaking at Riviera Maritime Media’s Ballast Water Webinar Week, ABS senior principal engineer William Burroughs noted that as at the start of 2020, IMO had six BWMS listed as approved to the revised 2016 G8 at MEPC 74: Alfa Laval PureBallast; DESMI CompactClean; Headway OceanGuard; Hyundai HiBallast; Environcleanse inTank; and Sunrui BalClor.
An additional seven BWMS manufacturers had submitted papers to MEPC 75, which did not take place in London in 2020 due to the coronavirus pandemic. The adoption of revised G8 type-approval continues in the absence of formal MEPC meetings. “We have about 16 that have 2016 G8 or BWMS Code,” said Mr Burroughs. “It is a little problematic in that six systems are awaiting final approval. Some are extensions for freshwater approval for active systems.”
Many owners and operators had scheduled the retrofitting of 2008 G8 BWTS to coincide with scrubber retrofits. The aim was to undertake the two retrofit installations during the Special Survey dry dockings. The vast majority of the dry dockings were scheduled to take place in China.
Unfortunately, nearly all dry dockings in China have been delayed by the outbreak of Covid-19. In this respect, Covid-19 may yet have the biggest impact on the adoption of the revised G8 protocol. In a poll taken during the webinar, attendees were asked, Has Covid-19 impacted your ability to install systems? The vast majority (73%) replied that Covid-19 had done so. On a supplementary question on where the pinch points were in the revised G8 supply chain, the majority (60%) pinpointed the shipyard. Only 20% felt that the manufacturer was a point of issue and another 20% noted that the inability to secure cargoes to re-position the ship to the region of the shipyard was an issue.
Hyde Marine senior market manager, Mark Riggio (who is also the president of the ballast water treatment manufacturers trade body, BEMA) related his company’s experience of Covid-19. The company had been fortunate to debut a remote access system for its BWTS which is helping overcome restrictions on travel. Mr Riggio explained that a dedicated router with a secure IP address is hardwired into the BWTS and communicates with sensors in the system and the ship equipment. The ship has a switch to disengage ship data if required. Once engaged, the router can send BWMS data direct via a cellular installation, or via the ship’s satellite uplink.
“We can troubleshoot and assist crews immediately without waiting for the vessel to reach port,” he said. “We also have remote local access through technical engineers stationed around the world. They have been able to troubleshoot and accomplish emergency repairs and servicing.”
It is also of note that owners and operators are now delaying maintenance. “We have seen postponements of planned maintenance and preventative maintenance,” he said, adding that while there were some initial supply chain issues, these have been resolved and the Hyde Marine plant is operating as before, but with the social distancing protocols in place.
“Where we do think there will be an impact from Covid-19 will be on those BWMS that are struggling with gap testing between G8 and the USCG and the final revised BWM Code testing,” he said. While remote working can be efficient, making those final adjustments and tests will be difficult, in his opinion. He noted one slightly ironic ‘positive’ to come out of the Covid-19 situation –stress testing: “Every manufacturer has their own story from Covid-19. It shows how we will manage the explosive growth through the IOPP renewal phase.”
Mr Riggio commented that Covid-19 is a unique opportunity for those BWMS that can be installed at sea, or at least have some measure of pre-install which will minimise the downtime in the shipyard. “One of the biggest impacts Covid-19 will have involves compacting the repair period for vessels. Vessels in lay up or in storage that can perform in-service or underway installs with be able to dramatically shrink the yard time,” he said.
But not all systems can be fitted at sea and some owners and operators are reliant on having the vessel in dry dock. ABS’ Mr Burroughs noted that owners should pay careful attention to the wording in any documentation. “Please check your contracts,” he said. “If you have ordered a 2008 G8 BWMS and it was going to be delivered in time for installation before the deadline date and that is now delayed due to the pandemic, make sure it is delivered to the ship before the deadline date, or that date is written into the contract. If you do not have those contract dates in the contract, you may have missed the deadline.”
He added: “If the installation slips (to outside the deadline) the flag or administration may grant an extension based on those dates.”
He also had a warning for those owners and operators that are installing 2008 G8 BWMS in deck-top enclosures: “The 2008 G8 BWTS may be fitted into a deck-top enclosure fitted by a third-party. In that case, the dry- or wet-tested BWTS has to be fitted in the enclosure and installed on the vessel by the 28 October 2020 deadline.”
Owners and operators are now turning to class societies to determine if any extensions will be permitted as a consequence of the current pandemic. Will there be an extension of the deadline for D-1, the regulation on deep-sea ballast water exchange? This would seem to be a possibility. IMO has asked flags and administrations to consider flexibility and the D-1 situation is clearly a concern for owners and operators; in a poll conducted during the webinar, attendees were asked if their company had applied for an extension of the D-1 International Ballast Water Certificate – 12% of the attendees had already obtained a certificate and another 8% had started the process. A further 24% intended to apply but had not started the process and a similar percentage had not considered the issue before it was raised during the webinar – 32% of the attendees concluded that they did not need one.
Even for those that had obtained an extension, that is only half the process. “The receiving port has to buy into that plan,” said Mr Burroughs. In that scenario, a vessel whose 2008 G8 BWMS was not fully installed by the 28 October 2020 deadline would perform a partial ballasting and then ballast water exchange in deep water. This may be allowed by the flags or administration, but the important point Mr Burroughs makes it that the captain of the destination port must also give an approval.
He also had some important advice on the legal issues that arise from the revised G8. The shipping industry is in an experience building phase (EBP) which is due to end by mid-2022. However, as noted above, there have been considerable delays in the revised 2016 G8 approvals and it could be said that the EBP has effectively lost a year due to Covid-19. “We will not have gained enough experience, data and information to make the EBP meaningful,” he said. The impact could be onerous for owners and operators when the EBP ends. During EBP the penalties are suspended, but afterwards, “the owner is liable for the performance of the BWTS and Port State Control could detain you. We wish to avoid that,” he said.
Hyde Marine’s Mr Riggio said that each revision of the code allows manufacturers to build on that experience and incorporate new features. “As with any evolutionary process, only the strongest survive,” he said. “The revised G8 allowed purpose-built ballast water filters to be brought in. These were more efficient than the original filters,” he noted.
It is part of the evolutionary process that led to the revision of the G8 standard. The evolutionary process is, in the case of Hyde Marine, the result of hundreds of installations across a variety of different vessels. But the revision of a regulation, be it IMO or USCG, can have a negative impact on the evolutionary process. “The problem is that you need the type approval. Once you have that type of approval your system design is fixed. You can no longer make minor modifications or changes to improve its performance.
“The revised G8 has allowed a number of systems to incorporate these years of training and learning and experience and be able to make that evolutionary next change with their product,” he said.
The gold standard
The path toward the revised G8 standard took place in parallel with USCG type-approval. Many owners and operators still regard the USCG as the ‘Gold Standard’, necessary if a vessel is trading on a long-term basis in US waters. IMO revised G8 is the global standard, effectively covering 90% or more of global ports. Mr Riggio noted that while the USCG has gained a lot of information on the capabilities of the BWMS it has type-approved, those limitations and capabilities are not shared in the certification. This and a disagreement in the science represent fundamental differences in the approach to ballast water management between the US and the rest of the world.
Mr Burroughs had some advice on what to look for when considering a type-approval certificate. He suggested to not only look at the type-approval certificate, especially if it is an active substance system, but to, “Get the applications for basic and final and then root around and find the public domain documentation that was produced at the GESAMP stage.”
Then, he said, have a long conversation with the vendor. He noted that the USCG certification does not really contain enough decision-making information. His takeaway from the discussion on revised G8 was to focus on: “Commissioning, testing and contingency measures. Those are going to be the go/no go challenges for your vessels. Make sure you understand the limitations of your system. If you trade in water where that system will not perform to D-2 standards during ballasting, make sure your contingency measures are explicit and encompass how to remove that non-compliant water authorised by the flag. Make sure you have clear communication with the destination port so that the [captain of the port] has complete confidence that your vessel has compliant water onboard.”
The majority of webinar attendees (65%) reported, via a poll, that they would shop around the next time they purchased a BWTS. Mr Riggio had some advice for those owners and operators: “There is a lot of talk about BWTS not working, but the reality is most of those issues relate to system design limitations and improper usage.”
His takeaway was that the revised G8 marks the next stage in the evolution of ballast water treatment and that systems from 2004 have undergone significant change at each revision of the regulations. “But there is still one link in the process,” he said. “Learn before you buy. Do not take the certificate at face value and buy the cheapest system. You need to work closely with your manufacturer and you need to make sure that your system is going to work with the crews you have on your ship. You need to make sure the system works in the place where your ship operates. If you take that time during the purchasing process, you really will be much happier with your system and you’ll get better life out of your system.”
Riviera will host a series of 45-minute webinars on subjects ranging from maritime propulsion to vessel optimisation, ballast water management, maritime air pollution and maritime leaders among many others commencing 5 May 2020. Find a list of the webinars and register your interest now