Regulatory understanding & Accurate information; Installation Timeline; Technical Feasibilities; Compliance Maintenance
The various surveys with early adopters of Ballast Water Treatment System (BWTS) have shown that the majority of systems installed to date face operability challenges, either due to installation, operational sequence or even non-marine-grade system selection. Given that Ballast Water Management (BWM) is a shipowner’s lengthy, complex and costly project, shipowners face a myriad of challenges developing a vessel’s or fleet-wide compliance strategy; understanding the limitations to different BWT systems and choosing the right, operable technology; curating a reasonable plan for system installations that takes into considerations the feasibility & practicality, financial resources and timeline.
In this holistic white paper, Giles Candy (Giles Environmental LLC) offers practical recommendations concerning all technical, regulatory and operational considerations that are necessary prerequisites to shipowner’s effective Ballast Water Management (BWM) compliance strategy.
KNOW THE REGULATIONS AND GET ACCURATE INFORMATION: Many buyers say: “filters are required”, “any Administration type approval (TA) is OK”, “a BWTS needs Class TA”. These are wrong and easy to look up in the rules.
The BWT industry has consistently let itself down by making unsupported claims, technical inoperability, competition and otherwise. The media is not helping either. In 2017, a popularly published list of five companies expected to lead the market in 2021 included BWTS which had already been withdrawn from the market. Regulators and manufacturers therefore need to assert more clarity and owners need to be educated and aware – as increasing number of manufacturers and systems are coming into the market. The newly formed Ballast Water Equipment Manufacturers Association (www.BWEMA.org) should become practical sources of independent information to help solve this issue.
Without accurate information, owners are not protected from purchasing a BWTS that ends up defying the fundamentals of water treatment; or one that is over or under qualified for their vessels. Many Technical Departments across shipping lines have invested considerable resources to understand all aspects of the ballast water issue, but many have not. It is a complex issue and the costs to owners of making wrong decisions are going to increase dramatically in the next two or three years.
Thoroughly understanding the regulations, the treatment systems and fleet trading pattern(s) will allow an owner to choose not only the right compliance strategy but also the most economical compliance strategy for their fleet.
TIMING OF BWTS INSTALLATIONS: Most owners have pushed back BWTS installation. This is understandable to reduce costs and challenges today, whilst watching how the industry develops.
However, the implementation delay, codified at MEPC 71, means the slow 2017-2019 retrofit activity will accelerate steadily 2019-2021, by 2022-2024 more than 20 BWTS may have to be installed every day. There is a hard deadline for every ship to comply with the regulations. Retrofit experience is increasing but the amount of work required to properly install a BWTS – which ever type – is not going to decrease. Owners should establish the installation timeline for their fleet and contract or reserve the installation engineering resources potentially even before they have decided which BWTS to purchase. The various steps involved including vessel’s or fleet’s feasibility studies, 3D scanning, technology & system selection, installation drawings, approval, etc., means that from the ordering stage until a system is installed and successfully commissioned, the crew is trained and ready for compliance amid ocean-sailing, the entire process could require a year or more.
Today owners may watch, but soon they should begin making their decisions, structuring practical installation schedules, committing to installers and suppliers. Expecting to comply by purchasing everything at the last minute may not be the wisest – or cheapest – way forward.
VESSEL OPERATIONS AND BWT PRACTICALITIES: The BW discharge standards are very tough and require a high degree of water treatment. Any successful BWTS is a high-performance equipment. How is it possible for a high performance BWTS to operate on a vessel and not add to crew burden? It is not.
So, use a successful BWTS which impacts the operations of your vessels and trading patterns as little as possible.
Examples of impacts. Filters may not be an issue in the Caribbean but a 50 or even 20-micron filter could be a liability in many ports, particularly on large rivers. Fresh or low-UVT waters can impact performance. These and other factors can lead to slow ballasting/deballasting rates. The choice to treat in port or at sea can bring advantages to vessels, in-tank (at sea) BWTS is a new option to be considered.
A vessel and its operations can be impacted far less with the right choice of BWTS.
CONFIDENCE IN COMPLIANCE: Emphasis on compliance has fallen on to the BWTS but in practice, the owner is responsible for compliance. The owner must operate and maintain the BWTS as intended. The owner must make sure the BWTS manufacturer trains the crew and supports the equipment.
Technical compliance – correct documentation, record keeping and available records of treatment operations – will be the first levels of compliance to be tested by PSC. The owner must implement the correct procedures to achieve Technical Compliance.
Biological Compliance – the analysis of ballast discharge, will be more likely if PSC finds an issue with the Technical Compliance. Here again, different system types can give different degrees of confidence. An oxidizer applied four weeks earlier may not carry the same confidence of Biological Compliance as a vessel which treated ballast in the tanks a day or two before to discharge.
Giles Environmental LLC
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