Ballast water regulations have created a new and complex administrative burden for shipowners, adding uncertainty and frustration for those who thought they would be compliant
BWMS system malfunctions, alongside issues with securing training or maintenance for systems, mean that ballast water compliance is not only measured by paper checklists. Should a ballast water management system (BWMS) not be treating water to the required standard for whatever reason, a shipowner will not meet the regulations.
The implications of non-compliance can be significant. Some jurisdictions, including the US, could impose a custodial penalty on any shipowner that knowingly breaks regulations. Meanwhile, fines can easily climb into the six-figure range. On top of this, ballast water failures will inevitably lead to significant delays for repair work or additional crew training, resulting in major knock-on costs.
Yet shipowners have reported operational issues with BWMS since the first systems were installed on vessels. Owners who have installed a certified BWMS, and who have ensured that a vessel’s paperwork, ballast water plans, and logbooks are fully compliant and up to date, are now discovering just how difficult ballast water treatment can be.
Training is critical, ensuring that crews know how to operate the specific system installed on each vessel. This may enable a crew to rectify a fault before non-compliant water is discharged, or proactively work with authorities to minimise the impact.
“We cannot and should not expect even the best trained crew to be microbiologists”
Clearly there is a limit to the usefulness of training alone. We cannot and should not expect even the best trained crew to be microbiologists, and reports of more complex BWMS failures are acutely concerning. Systems produce data to show that they are operational, but that data is inherently difficult to read, analyse and understand. Similarly, a fault stemming from a filter or from faulty sensors may not provide any warning at all.
Treated and untreated ballast water look very much alike, and it is very hard to visually verify that a BWMS is working as intended without testing it. Moreover, it is very difficult to rectify a fault or change a process without understanding what might have gone wrong. Regularly or continually monitoring the treatment status of ballast water is the only way to have this actionable data to hand.
Data must be actionable
Indicative ballast water testing is the only way to deliver this vital information. This can ensure that systematic BWMS failures are not left unresolved for long periods of time. Indeed, some shipowners have already invested in programmes to have vessels regularly tested in this way.
Given the challenges that complex ballast systems have posed for shipowners, any ongoing testing must be simple to use and understand – a testing system that takes up too much time, requires significant additional training to operate, or produces results that a crew cannot easily action, will not provide value for a shipowner.
Designing an indicative ballast water test with ease of use at its heart is a difficult task. At Chelsea, we developed our FastBallast system to provide clear guidance with this in mind. The system uses a two-stage test, delivering an indicative result in two minutes which can show a clear pass, or trigger a second more detailed test to provide a confident pass or fail within 10 minutes.
Accuracy is key; should a testing system consistently show a large margin of error, a non-compliant system could remain undiagnosed until authorities take enforcement action. FastBallast delivers this accuracy through single turnover active fluorometry, which measures the fluorescence emitted by individual organisms within a water sample. To ensure that cell density values are accurately calculated, this data is then coupled with specialist Standardised Cell Fluorescence analysis to deliver a final figure. This provides a lab-equivalent analysis onboard a vessel.
As ballast water regulations mature, it is widely expected that enforcement testing will soon be implemented in more jurisdictions. Shipowners need to ensure that they are collecting and using all of the information available to make compliance progressively easier. The best way of doing that is to implement regular, accurate compliance monitoring.