Time running out on ballast water compliance

Delay comes at a cost

We have seen a number of owners opting not to install treatment systems because their ships operate consistently in the same region. But in our experience, this is a short-sighted strategy, because the absence of an effective system has a significant impact on vessel value and can also be a constraint on vessel deployment.

Furthermore, the cost of a retrofit can be significantly less than the reduction in a vessel’s value resulting from not having a ballast water installed. This is because of constraints on future employment possibilities.

Therefore, we see that having an effective system installation is a significant priority for buyers. This is clearly evident in the offshore market (OSVs and PSVs, in particular) and is likely to underpin a buoyant retrofit market lasting well past September 2024.

It should also provide guidance for those who claim there is no return on investment for system installations. It is true having a system does not increase revenue-generating capability. But the converse is also true – not having one could result in the loss of a charter contract or a discount in vessel value. In other words, there is a price attached to not having a robust system on board.

Another key aspect which we believe is sometimes overlooked is the need for ship operators to account for ongoing system service and maintenance and, critically, crew training. We are moving from a market in which it was important to have a system installed on board, to one in which it is essential to demonstrate the system operates effectively and is properly managed by the seagoing staff on board.

Support and spares on board

We believe shipowners should rely on support from system manufacturers in terms of training and annual system checks. Although such checks are not required by IMO, they are mandatory under US regulations and should be included in a robust maintenance schedule.

We have found, in practice, that seafarers who need to familiarise themselves with certain types of systems can be supported at the same time as the annual check. They may well be familiar with generic systems, but not with the requirements relating to specific installations.

Our BIO-SEA systems are relatively easy to use, and personnel training is straightforward. We use a network of certified service partners around the world to ensure our clients have access to the best service and support in any location. This approach also safeguards the validity of our OEM original warranty.

We also strongly recommend ship operators keep a stock of spare parts on board. Although this is not a class requirement, why would you not keep spares for a ballast water system in the same way as you would for any other critical system on board?

Cyber risks: a new challenge

Another important recommendation is to ensure the ballast water treatment system’s control software is sufficiently protected against cyber attack. Like any other equipment on board, a ballast water treatment system can be a point of entry for the cyber hacker. If the ballasting system is accessed by criminals, there is a significant risk to ship stability, crew safety and the environment.

It is important to bear in mind a huge number of systems were installed some time ago, well before some of the latest advances in cyber security were made available. Most of these legacy systems are probably not suitable for security upgrades and could be attractive targets for criminals.

Such is the concern, the International Association of Classification Societies recently published two unified requirements relating to the cyber resilience of ships and their equipment. And we are following these and making sure they will be implemented on system installations from 2024. We have recently completed testing new BIO-SEA cyber-secure control software to ensure our cyber framework offers the right level of security and hope to have full class approval in 2023.

There are, of course, many other issues to consider, both for systems already in operation and others that need to be installed in the months ahead. If you are considering a new installation or a system upgrade – and UV/filtration is your technology of choice – talk to us.

Are you considering a UV/filtration BWMS? Ask the experts at the forthcoming Ballast Water Webinar Week, 31 January 2023-02 February 2023. Register your interest here or to take part, contact: Paul Dowling (paul.dowling@rivieramm.com)