Regulations and guidelines on how samples are taken, who can access samples, who test the samples and what those tests include are a concern for the industry
The issues surrounding the sampling and testing of treated ballast water are neatly summed up by Ne Nora general manager Dr Stelios Kyriacou:
“There are still so many outstanding questions when it comes to regulatory compliance and ballast water indicative sampling and monitoring/analysis instrument certification. Shipowners, port state control and port authorities require guidance that has been hitherto absent to make an informed decision when it comes to ballast water testing and performance monitoring. IMO needs to debate and decide how sampling should take place, with pivotal factors including the parameters for accessing samples, agreeing who completes the sampling and, importantly, how the sample evaluation is carried out.”
Dr Kyriacou explains that De Nora believes that “impartiality throughout the process can only be guaranteed by independent assessors, and regulated indicative sampling testing kits with clear, evidenced-based reasoning behind the methodology.”
He notes that while there is a need to debate sampling and indicative analysis methodologies, as well as the science and the interpretation of results, the ballast water treatment industry needs certainty: “When it comes down to it, ballast water sampling needs to be standardised and indicative analysis methods formally approved by IMO. Regulations must be drawn up, adhered to, consistently applied and enforced in order for the efforts to hold water,” he said.
The fear for many manufacturers and stakeholders in the ballast water industry is that history will repeat itself and that there will be years of debate around the subject. Already the timeline is looking somewhat stretched, having been raised at MEPC 67 (October 2014), which called for the development of provisions for indicative and detailed analysis of ballast water to verify compliance with the requirements of the BWM Convention.
At MEPC 68 (May 2015), the committee approved the revised Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention, where available methods for indicative and detailed analysis of ballast water samples are listed.
In October 2018, MEPC 73 approved BWM.2/Circ.70 on Guidance for the commissioning testing of ballast water management systems, which includes procedures on sampling and analysis based on Guidelines for ballast water sampling (G2) and BWM.2/Circ.42/Rev.1. Noting that testing should cover all size classes defined in regulation D-2.
At MEPC 73 it was agreed that testing methods should be used to show a new vessel’s ballast water treatment system is working properly. Sample instrument manufacturer LuminUltra chief executive Pat Whalen said at the time: “We fully support this decision by the committee. This new guidance means that a ballast water treatment system can no longer be certified for operation unless compliance has been validated as part of the commissioning process, which is good news for shipowners and the environment.”
Then there is the question of the type of sampling – direct or indicative. Direct sampling is the actual examination of organisms, which is both expensive and time consuming. The marine engineers’ organisation IMarEST has submitted a paper to MEPC 74 detailing its findings of a review of the available indicative sampling units on the market. This was conducted with the co-operation of the brands, and the table is reproduced below.
IMarEST found there was a wide range of instruments available, which gives owners and operators options of which one to use on board, depending on the trade of the vessel. Some units have short processing times more suitable for vessels that spend only a short period of time in port.