Ship operators and owners have questioned whether legislators are rushing forward with new goals before finalising existing requirements
Unlike the choice of designer for a main engine for a large vessel, of which there are now only two mainstream options, the vessel owner and operator is faced with a myriad technologies and designs when it comes to choosing a ballast water treatment systems (BWTS). This confusing prospect is compounded by delays to retrofit installations due to Covid-19. Systems also needs to remain in compliance.
There is a large body of advice available to owners and operators on how to choose a BWTS. The first port of call is to scope the requirements and manufacturer. DESMI is one of many suppliers that provides guidance to prospective purchasers. Its latest whitepaper, Ballast Water Management Technologies: A Comparison Between UV Based Systems & Electrochlorination Systems is particularly useful for owners and operators deciding between UV-based treatment systems and electrochlorination systems. It notes that whichever system is considered, most are generally complex and require more components to be installed.
“The most common technologies for BWM are UV-based systems and EC systems
The white paper contains some interesting statistics: as at October 2019, close to 10,000 vessels— nearly 10% of the global vessel fleet—had been fitted with a ballast water management (BWM) system. According to Clarkson’s World Fleet Register, the most common technologies for BWM are ultraviolet (UV)-based systems and electrochlorination (EC) systems.
Breakdown of installed BWMS
Source: Clarkson’s World Fleet Register, Clarkson Research Services.
The choice of system is highly dependent of where the vessel is operating. If the vessel is operating outside US waters, compliance with IMO guidelines is required. The guidelines for type-approval of BWM systems were revised in October 2018. Since the revision, IMO now states that type-approval according to the new BWM system code MEPC.300(72) (also referred to as the revised G8) is mandatory for all BWM systems installed on vessels after 28 October 2020. As an example, CompactClean, a BWM system from DESMI, is type-approved in accordance with IMO’s BWM system code and as such is ready for the revised G8 guidelines.
IMO evaluates UV-based BWM systems by determining whether the treated organisms are viable or non-viable, i.e. are they capable of reproducing. If they cannot re-produce IMO determines that the organisms do not pose a threat of becoming invasive species. The organisms’ ability to reproduce is measured by the most probable number (MPN) method. The USCG evaluates BWM system performance using a test which measures the number of living organisms after treatment (FDA/CMFDA method).
From this binary operating evaluation the decision-making possibilities expand almost exponentially. As Ecochlor’s vice president of business development Andrew Marshall said during Riviera Maritime Media’s Navigating the BWMS system selection maze webinar: “There is no one BWT technology which is optimised for type of vessel operation, for every size of vessel, for every flow rate. Every BWM technology has a sweet spot.”
Sometimes, the owner or operator cannot make the decision for themselves. In the case of newbuildings, the shipyard will only be offered the Maker’s List of available equipment, covering cargo pumps, valves, scrubbers, and ballast water treatment systems.
Capital Ship Management’s director of newbuildings Nikolas Vaporis, commented that an owner has to accept the offered BWMS or face increased costs to have another BWMS fitted. Not choosing a BWMS with which the yard is familiar could result in problems at the fitting out stage at the yard.
Number one concern
The fitting out stage and for older vessels, the retrofit installation of BWTS, has become the number one concern for owners and operators. It adds an extra layer to the decision-making process and means the successful and timely completion of the installation will be reliant on the supply chain of the BWM manufacturer.
Speaking at the Riviera webinar, Overcoming bottlenecks on BWMS retrofit installation and operation, ballast water treatment supplier De Nora Water Technologies’ regional sales manager Dimitrios Tsoulos said that retrofit installations “have been a headache for the industry for many years and it is true that all external stakeholders have highlighted the challenges to the decision makers well in advance from a regulatory perspective. The industry is at a critical moment and there is no or very limited room to manoeuvre.”
These stakeholders all need to have clear lines of communication with each other. In this phase of the development of BWM retrofits, logistics management becomes key. Mr Tsoulos explained that proper planning, having the correct documents in place, overseen by knowledgeable planners, and implemented by experienced partners, was critical to avoiding the kind of bottlenecks the industry fears. “The timely submittal of front-end engineering plans saves valuable time among partners who may not be water experts,” he said. “Please don’t underestimate the importance of the installation commissioning and associated manuals. Those documents are very important, not only for work guidelines and planning, but also to address regulatory compliance issues.”
Mr Tsoulos also flagged up the need for adequate training, which he said should be addressed as a core deliverable, with its scope managed as a high priority item within a retrofit project. He noted too how delays can stem from items with long lead times, such as valves, and how transport should not be overlooked at the planning stage to avoid associated bottlenecks. In the case of De Nora, the company manufactures its core products, reducing some of the stress on the supply chain. He also explained that the BWMS, as a contractual item, cannot be delivered without approval of the board of directors. “The maker must confirm availability and maintain an organisational structure that ensures the services are on time and meet a quality that will allow at least class approval,” he said.
The stress for the owner and operator does not end there. There is the decision on where to install the BWTS. In a poll conducted among those attending the webinar, 36% listed Europe as the preferred geography for BWTS installation. On-voyage installations (fitting the remaining components on the vessel during a voyage) was the choice of nearly a third of respondents to a poll during the webinar (32%) and China and South East Asia was the choice of 28% - the remainder (4%) chose the Middle East.
Of course, the on-voyage installation option has its challenges. It is expensive, requiring the services of a riding crew, which must ensure they have all the tools and parts required to complete the installation. In a Riviera poll, webinar attendees ranked the challenges as follows:
The Covid-19 pandemic has produced a double-whammy for owners and operators: it not only closed shipyards in China, it did so in the year that those suppliers with the 2008 IMO G8-compliant ballast water systems needed to have them re-assessed to the 2016 revised G8. After 28 October 2020, only revised G8 ballast water systems can be installed. This has led to a call for an extension of the deadline. In another Riviera poll, 29% of responders voted to have an extension to the deadline.
“The industry is at a critical moment and there is very limited room to manoeuvre”
In a poll taken during the Overcoming bottlenecks on BWMS retrofit installation and operation webinar, attendees were asked on a scale of 1 to 5 – with 5 being the most probable – to choose how likely they felt an extension would be. Most attendees (42%) chose option 4, that extensions to the deadlines were likely.
That is for IMO to decide, but the organisation has suspended the meeting, MEPC 75, that might have discussed and approved such a decision and it is now unlikely to take place before the deadline has passed.
For the owner and operator the stop-start progress of ballast water treatment legislation at IMO and US Coast Guard level must seem like a nightmare that will never end. But end it must, with the suppliers providing systems that work as advertised; to many observers it is odd that IMO legislated before the technology was proven to be 100% effective and reliable. To this end, IMO introduced an Experience Building Phase (EBP) into the ballast water treatment management guidelines. The aim here is that stakeholders, such as class societies, flag states and administrations feedback, and pool experience in the use of BWTS.
The association representing independent tanker owners, INTERTANKO, has been at the forefront of providing input into the development of real-world legislation. Its environment director Tim Wilkins noted the number of enquiries from his members related to the new ballast water management system code and said with concern that “our members are still having problems with installed systems.”
Mr Wilkins also noted that as most stakeholders are currently in the EBP, there was still time to iron out complications and to influence the direction of the Convention and other regulatory requirement. “Our concern now, is that a pragmatic approach is reflected by the Port State Authorities as delays in the system occur,” he said. During the EBP, owners and operators and the flag administrations are to report to IMO their findings regarding BWTS. According to Mr Wilkins, there has been no feedback.
He also warned of the danger of moving on to the next piece of legislation. There is a growing impetus to address hull fouling. While this is laudable, he noted that the shipping industry as a whole is still battling to resolve the issue with the BWTS. “We are in the middle of the fight. We need to help shipowners and shipyards; we need to help the (ballast water treatment) system designers. Extensions might help to resolve the challenges that emerge in the EBP. It is too early to shift focus to biofouling,” he said.