Revisions to existing requirements and tanker-related factors prompt class society action
The International Association of Classification Societies (IACS) has set up a working group to consider revising its Unified Requirement (UR) M74, Installation of Ballast Water Management Systems, IACS secretary general Robert Ashdown has told BWTT. “IACS has acknowledged the need for a clear regulatory framework for the safe installation of water ballast treatment units,” he said.
He did not say how the working group will operate, but a source with knowledge of the work told BWTT that two project teams (PTs) have been set up to define “appropriate safety measures” to ensure that ballast water management systems (BWMSs) are installed safely.
Among other things, the revision to UR M74 will address the difficulties of installing BWMSs on board oil and chemical tankers, while fulfilling water ballast segregation requirements, the source said.
BWTT understands that one PT was established in October 2017 and held a three-day workshop in January, with a second planned later this year.
According to BWTT’s source, a report from its first workshop went to IACS’ Machinery Panel, which in turn passed it to the association’s Safety Panel to be used as the starting point for the second project team, which will look at safety issues around BWMS installations.
That second team will assess each technology and, depending on the location where the system is intended to be installed, define appropriate requirements to help shipowners “take advantage of the broad range of technologies available while supporting safe installation on board,” BWTT was told.
IACS “has acknowledged the need for a clear regulatory framework”
For example, when an installation involves a ballast water management system (BWMS) that relies on ozone generation, it might specify that the space where the unit will be installed must be protected from the potential risk of a leakage of ozone or oxygen.
A BWMS’s operating principle might also limit where a unit can be installed on board. In oil and chemical tankers, for example, if the BWMS treats water by injecting inert gas, its inert gas generator’s location would have to meet the same location limitations as an inert gas generator fitted for cargo tank protection.
• Read IACS UR M74 via http://bit.ly/UR-M74
ABS survey finds only 57% of BWMSs are operational
When class society ABS published the findings of a small survey of shipowners last August, it revealed how few ballast water management systems (BWMSs) were working properly. Although it was based on the experience of just 27 owners that had attended an ABS workshop in April, the size of their fleets meant that ABS was able to aggregate information on 220 BWMSs.
It found that just 57% of these systems were operated or were considered operational on demand. “The remaining [43% of] systems were either inoperable or considered problematic,” its report said.
No systems were mentioned by name, although treatment technologies were mentioned, which subsequently prompted feedback from some manufacturers using technologies that had not performed well in ABS’ analysis, ABS senior engineer (advisory services) Evon Li told BWTT. But from its shipowner clients, the most common feedback it receives confirms that they have concerns about BWMS installations, especially “lack of technical support from vendors, lack of training materials or training programmes for the crew, delayed delivery of the spare parts and delay in after-sales service delivery from the BWMS vendor,” Ms Li said.
She also warned of possible changes in US Coast Guard (USCG) policy that may introduce new challenges in aligning compliance between US and IMO regulations. “While IMO has agreed to some limited delays in entry into force of the Ballast Water Management Convention (BWMC), US Coast Guard (USCG) policy is evolving from implementation of its discharge requirements to enforcement.”
To help clients understand their options and obligations for compliance with IMO and USCG regulations, since 2015 ABS has offered a BWMS Technology Evaluation service. This covers pre-selection or shortlisting of suitable BWMS and support for requesting USCG extensions.
• Read ABS’ analysis via http://bit.ly/BWTT-ABSReport
Class societies respond to ballast management concerns
For this report, BWTT contacted the four largest classification societies – DNV GL, ClassNK, ABS and Lloyd’s Register – to understand their views on some key topics that affect ballast water management.
ABS’ comments on its research into its clients’ experience of using ballast water management systems (BWMSs) is reported separately, but from the other three societies’ experience we can observe that the picture is not yet clear. ClassNK, for example, said that clients had reported cases of BWMSs “not functioning properly due to lack of maintenance,” while DNV GL senior principal engineer (environmental protection) Martin Olofsson said that the class society was collecting data on BWMSs from annual surveys on behalf of flag states. But based on six months of operational data since IMO’s Ballast Water Management Convention (BWMC) came into force on 8 September 2017, “we cannot make any conclusions that suggest BWMSs do not work.”
Lloyd’s Register echoed DNV GL’s comments. In remarks prepared jointly by its senior marine consultant (marine and offshore) Yildiz Williams and its senior specialist (marine and offshore) Sahan Abeysekara, it said that whether a system functioned properly could not be assessed without sampling its discharge. “We are looking forward to the [BWMC’s] experience-building phase, when we will have more reliable and comprehensive data.”
Invited to comment on the delayed compliance schedule agreed by the IMO Marine Environment Protection Committee in July last year (MEPC 71), all three societies stressed their impartiality on regulatory matters. But ClassNK observed that the amended timetable “grants shipowners an additional two years to prepare themselves,” and predicted a large number of retrofits from then onwards. ClassNK’s role in that will be “to support shipowners focusing on the operational and installation aspects of the BWMS to ensure successful implementation and compliance with the regulations,” its feedback said.
Despite the delay, there has been no let-up in demand for system approvals, according to Lloyd’s Register. “The demand for installation is proportional to the newbuild market,” it commented, reflecting the convention’s requirement that newbuldings must be equipped with systems.
More important than the MEPC-agreed delay is the impact of the many decisions during 2017 to bring forward renewal dates of ships’ International Oil Pollution Prevention (IOPP) certificates, to which installation dates in the BWMC are linked, said Mr Olofsson. That will create a retrofit bubble in 2022, he suggested: about half of DNV GL’s classed vessels due to fit a BWMS have a due date that year, he said, which amounts to about 2,500 vessels. “If the situation is similar for other classification societies, we may see 10,000 vessels due for a retrofit in 2022,” he said.
ClassNK also referred to postponements to IOPP certificate renewals, predicting continuing renewal surveys up to September 2019 as a result.
Elsewhere in this publication, shipowners are reported as being concerned about ballast water management training, and class societies are providing some support to them. Lloyd’s Register, for example, offers a one-day ballast water management awareness training course, which “provides delegates with a sense of the issues and offers a practical approach along with sharing LR’s operational experience.”
ClassNK arranges technical seminars and training for interested parties. DNV GL provides general courses and seminars. But it also answers questions every day from its clients, via its DATE (Direct Access to Technical Experts) service. Ballast water management questions relate to “everything from compliance dates for a particular vessel, to BW exchange areas, to procedures in the BWM Plan,” Mr Olofsson said.
ClassNK makes new rules for BWMS work
ClassNK has released a new set of technical rules and guidance for shipowners covering BWMS installations. The revised rules “draw upon the knowledge of ClassNK’s in-house experts, incorporate guidance from the International Association of Classification Societies and satisfy Japanese domestic law,” the society told BWTT.
It also said that its 3D laser scanning technology, Peerless, could be useful in BWMS installation planning. It “offers shipowners the opportunity to assess how to retrofit BWMS on their ships quickly,” it said. It avoids time-consuming manual work by taking point data from 3D scanners and converting it into 3D models within one or two days. “These procedures were previously handled manually, taking 10 to 14 days,” the class society said.