Checks show that compliance is improving but reveal concerns over sampling port installations
Sample tests show that compliance with ballast water management standards has improved in recent years, according to SGS Group global business development manager Vladimiro Bonamin. Speaking in September 2017, he said that, based on several hundred sampling events worldwide over a number of years, more than 90% had been compliant with the relevant standards. But over the previous 12 months, he said, compliance had been “very, very close to 100%.”
Mr Bonamin was addressing the International BWM Technology and Standardization Forum, organised by the Shipbuilding Information Center of China (SICC) and BIMCO, where he told delegates that most of these tests had been carried out for shipowners or manufacturers seeking information about their systems’ performance, although about 150 of them were carried out to issue official test reports.
His experience spanned both IMO and the US, divided almost entirely between between electrochlorination- and UV-based systems. Other technologies were “very rare,” he said.
Although his test results were encouraging, he described some difficulties in carrying out the tests themselves. In some cases, the crew do not know where the sampling port is, he said. And there have been occasions when treatment has been started only shortly before SGS testers have boarded. “It is necessary to wait at least 10 minutes after the system is switched on to start to see good numbers,” he advised.
Where SGS has found non-compliance, it is often related to the residual chemicals needed for some systems. In particular, there have been instances where the system has no neutraliser, either because too much was being used or the total residual oxidant sensor was not in calibration.
Mr Bonamin also spoke of concerns about sample ports. “Sometimes they are very difficult to reach,” he told the conference. They can also be badly sited in the pipework, he said, illustrating his point with a photograph showing a sampling valve positioned no more than 30 cm before a 90° bend. “The hydrodynamics are completely wrong,” he said.
The Institute of Marine Engineering, Science and Technology (IMarEST) shares his concerns. Although vessel owners acted with good intentions, “many ships have been outfitted with sample ports that are in compliance with [IMO Ballast Water Management Convention (BWMC)] Guidelines G2. However, the current guidelines are not specific and as a result there are many variations of sample ports installed. This variety may challenge efficient and practical port state control inspections,” it said in a submission to the fourth meeting of IMO’s Sub-Committee on Pollution Prevention and Response (PPR 4).
Its paper included a proposal to standardise sampling ports and explained that, although the BWMC guidelines “provide methods to calculate a sample probe size, they do not provide guidance on the sampling port connection size.” This has resulted in a range of different sized sampling probes and, in some cases, “a flange is presented without a sample probe,” IMarEST’s submission said.
Its proposal was well received, IMarEST’s Ballast Water Expert Group (BWEG) co-chair Kevin Reynolds told BWTT. As mentioned elsewhere in this publication, ISO is developing an international standard for sample ports and it will take account of some elements of IMarEST’s paper, he said.
Although PPR4 took place in January 2017, the topic is still a concern now. BWEG’s other co-chair, Marcie Merksamer, told BWTT in April that this topic “is an area of continued focus” and that the BWEG may include this in its work programme.
SGS’s ballast water sampling experience
US VGP-related tests
650 sampling events on 300 vessels; 90% compliant. 60% chemical; 40% UV
13 tests; 12 compliant
Non-compliance is often a consequence of improper handling of the treatment system. US VGP non-compliance can be due to exceedance of biological or chemical limitations
Source: SGS paper to the International BWM Technology and Standardization Forum, September 2017
Port states encourage testing using portable kits
As part of IMO’s experience-building phase of implementing its Ballast Water Management Convention (BWMC), ships visiting some ports are being subjected to ballast water checks, although no action is being taken in the event of a deficiency being found.
At the time of writing, in late April, BWTT is aware of one state that is conducting these tests, Saudi Arabia, and another that is exploring doing so, Canada. But up to six more are understood to be conducting tests.
Canada’s Great Lakes Laboratory for Fisheries and Aquatic Sciences, in Burlington, Ontario, is assessing a number of kits, although exact details have not been made public. French test kit maker aqua-tools revealed in March that its B-Qua equipment had been added to the programme, which is being conducted by the same scientist who conducted a 2015 study to test the efficiency of various ballast water testing methods on board the research vessel Meteor on behalf of Germany’s Federal Maritime and Hydrographic Agency.
The Canadian laboratory plans to carry out ballast water sampling and testing on up to 20 ships during 2018, to assess which tool or tools might provide the best rapid assessment of ballast water compliance, aqua-tools said.
Aqua-tools is also involved in testing programmes in Saudi Arabia. It supplied the first of 30 of its Rapid ATP ballast water monitoring systems last August to Swiss testing and certification organisation, SGS Group, which has agreements to inspect and monitor treated ballast waters of vessels arriving in those countries.
At that time, SGS Group global business development manager Vladimiro Bonamin told BWTT that the company had worked with seven PSC authorities on a project basis, but said the locations of the other six states were covered by confidentiality agreements.
As for Saudi Arabia, though, he said that SGS was one of four inspection companies to have been approved as ballast water test providers to the shipping community. “Ships are now obligated, by local regulations, to sample and perform the indicative test while de-ballasting in Saudi Aramco-controlled ports, using one of the four approved companies,” he said.
SGS and LuminUltra of Canada were involved in developing the test equipment alongside aqua-tools, the manufacturer’s statement said.
Another company providing testing services in Saudi Arabia is Global Strategic Alliance (GSA), which uses Chelsea Technologies’ FastBallast portable ballast water analyser. In a statement last August, Chelsea Technolgies said that its FastBallast was selected “following a detailed technical review conducted by Saudi Aramco’s in-house marine biology experts, who identified FastBallast as the most accurate solution in the market for the indicative sampling of ballast water.”
It quoted Chelsea Technologies managing director Brian Phillips, who looked forward to “working together with Saudi Aramco to ensure that all third-party ballast water sampling meets the high standards of compliance now required of all vessels calling at Saudi Aramco ports and terminals from international waters.”
In an exclusive interview with BWTT, GSA co-founders Adnan Bahamdein and Rajeev Ramachandran stressed that the tests it is conducting are indicative tests and are not the equivalent of a full port state control check. And “there are no penalties,” Mr Bahamdein said. Saudi Aramco’s main goal is data collection, he explained, to understand how many failures there are and where those ships come from. All failures are reported to Saudi Aramco, and “no vessel that has failed has ever failed again,” Mr Bahamdein said.
Saudi Arabia shares sampling data
Saudi Arabia shared some initial findings from its onboard sampling initiative in a paper submitted to the fifth meeting of IMO’s Sub-Committee on Pollution Prevention and Response (PPR5) in February. Although the paper was dated 1 December 2017 – less than four months after it started requiring sampling on 16 August 2017 – its figures were based on water samples from more than 500 ships.
It reported that over 90% of indicative samples from ships that conducted ballast water exchange passed the D-2 standard and were found to have a low count of viable organisms remaining in discharged ballast water.
But “a considerable number of ships that have installed IMO-approved ballast water management systems [BWMSs] and conducted treatment before discharge were observed to have failed D-2 standards testing for samples taken,” it added.
It also found that several ships that have installed type-approved BWMSs “have expressed, in writing, concerns regarding operational constraints, and hence opted to conduct ballast water exchange instead.”
Based on its experience, Saudi Arabia urged more IMO members to conduct indicative sampling initiatives. It proposed a standard for indicative sampling that required sampling to be done by “a competent and certified person,” and for there to be a “clear chain of custody” for the records.
The submission was welcomed by other IMO members and shipping organisations at the meeting, but some were concerned by the number of treatment systems that were found not to meet the D-2 standard.