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.
“Covid-19 may yet have the biggest impact on the adoption of the revised G8 protocol”
That date, 28 October 2020, is nearly upon us. 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 involved. 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 ballast water 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 an 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.”
“Vessels that can perform in-service or underway installs will dramatically shrink yard time”
However, some owners and operators are now delaying maintenance. “We have seen postponements of planned maintenance and preventative maintenance,” Mr Riggio said, adding that while there were some initial supply chain issues, these have been resolved and the Hyde Marine plant is operating as usual, but with 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 and Mr Riggio 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 offers 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 will 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.”