In approximately 1000 days all vessels must comply with the D-2 standard, as per the BWM Convention. ERMA FIRST chief technical officer Dr Stelios Kyriacou discusses the issues surrounding the implementation of these standards
Over four years ago, the ground-breaking Ballast Water Management Convention (BWM Convention) was finally ratified by IMO. The legislation provided a pathway for all ships to install and operate treatment systems to manage ballast water discharges which minimise the transfer of aquatic invasive species.
Following the ratification of the BWM Convention, it was considered appropriate to initiate the Experience Building Phase (EBP) to gather experience-based information from Ballast Water Treatment Systems (BWTS) installations operated in real-life situations. The EBP was to use data and information gathered during inspections of systems operated on board ships globally to review the Convention and contribute valuable information to shape its implementation.
However four years on, the EBP is yet to be completed and its progress remains inadequate. The paper MEPC.77/4/7 presented by shipowner groups ICS, BIMCO et al, charts the nature of the problem. At MEPC 73 (Autumn 2018) and MEPC 74 (Spring 2019) no EBP data were submitted. MEPC 75 was postponed to MEPC 76, where four states submitted data. In fact, EBP data submissions to date are very few, as reported in MEPC.77/4/5, and data has been supplied by just five Flag states and relates to some 169 ships in total.
It is very understandable why shipowner groups in their paper MEPC.77/4/7 propose the extension of the EBP to at least autumn 2024. Covid-19 restrictions have caused big delays to the entire EBP process and continue to do so. Getting inspectors on and off ships has been severely curtailed and the data gathered has been limited. IMO has contracted the World Maritime University to gather data, coordinate the analysis of the data, and develop an analysis report. It is now a matter of awaiting the EBP report to evaluate what the data reveals and how these findings can be further used to support the implementation of the convention. But is there really enough data to conduct sound analysis?
A small number of proactive Flag states have already contributed data, having carried out their own investigations, and have provided feedback related to their findings following sampling of ships operating within their jurisdiction (see Singapore MEPC.75/INF.11 and Australia MEPC.76/INF.56). Their findings have underlined the need to review the post-delivery functionality of installations following equipment electro-mechanical commissioning and have further revealed the adverse effects of not having selected the most appropriate ballast water treatment technology for a ship. With over 70 different companies providing systems aboard and with over 10,000 ships equipped with BWMS, the EBP data submitted to date is statistically insignificant.
There have also been inconsistencies with the way in which samples have been taken. Although there is an ISO Working Group looking at sampling device standardisation, it is still reported that there are different sampling methods used. There needs to be a robust framework dealing with sampling for compliance. Today, several devices are employed for fast compliance evaluation, but such Compliance Monitoring Devices (CMDs) must be subject to third-party verification and approval to ensure there is a scientific and statistically sound basis for their use and an ISO standard is currently in preparation.
Manufacturer data?
One important source of data for the EBP has been overlooked. The manufacturers, represented by the Ballast Water Equipment Manufacturers Association (BEMA), submitted members’ data, but there was no mechanism for this information to be accepted. The collective findings of manufacturers are a huge data sample and one which should not be ignored. My firm, ERMA FIRST, has installed upwards of 3,000 systems on 2,600 ships and we have contributed to the BEMA data submission as we believe in sharing our operational experience with the regulatory authorities.
“Is there really enough data to conduct sound analysis?”
We are seeing ship managers and their crews growing in confidence at their ability to manage BWTS well. There is little doubt that the operational experience, as systems are operated regularly, is substantially contributing to the development of a more complete picture linked to practical, real-life operation. The industry has gained an improved understanding of the factors that affect BWTS operability. Installation design, quality of project execution and selection of appropriate BWTS are all emerging as factors that have a bearing on system operability. Early identification of operational issues has been possible through commissioning testing of installations. Such testing has been implemented due to the early adoption of such requirements by a small number of Flag states (Australia, Cyprus, Greece, Panama, Singapore). As of 1 June 2022, however, this requirement enters into force and every newly-installed system should be subject to commissioning testing per BWM.2/Circ.70, as mandated in the Ballast Water Code MEPC.300(72) and before the issuance of the ship-specific International Ballast Water Management Certificate.
Universal inspection standards
But the biggest shortcoming has been the lack of universal guidelines for the humble port state control (PSC) inspector. No one wants to see a patchwork of different controls around the world. A BWMS is very different to the many other systems and processes under the inspector’s purview. A system can be spread across a ship and involves processes which are not common to any other type of equipment aboard. With approximately 70 Type Approved BWMS available, utilising different principles of water treatment and comprising multiple and different components, it is questionable if effective PSC inspections can be undertaken. I would dare say that many PSC officers are still uneasy in undertaking BWMS inspections as it is likely they are not confident with their understanding of BWTS operation.
“There needs to be a robust framework dealing with sampling for compliance”
The PSC inspection system is still lagging behind the implementation of the BWM Convention. There is an urgent need for IMO to focus on the development of appropriate guidelines for inspections. Flag states have a collective responsibility to devise a framework and training system for inspectors that ensures a global, level playing field. Without this, BWM Convention implementation and enforcement is impossible.
2022 market impact?
With the 2023 D-2 Standard deadline for retrofits fast approaching, 2021 has been a busy year for equipment manufacturers and yards. Whilst there have been reports that some manufacturers have faced supply chain issues and difficulties securing components for their systems, I am pleased to report that ERMA FIRST has a robust and well-managed supply chain and maintains a well-stocked facility. We do not anticipate any delivery delays from our side in 2022. However, some owners are concerned that the quality of retrofits will dip in 2022 due to bottlenecks and pressure. Our advice is: plan in advance, select a BWMS that meets the ship’s requirements and review the system design limitations. Contract an experienced yard, select a proficient engineering firm and competent installers. No project will be successful without proper planning.
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