Ballast Water Treatment: IMO's Regulation Uncertainty
IMO's Marine Environment Protection Committee (MEPC) is meeting for its 69th session this week. One of the key items on the agenda for BIMCO is the implementation of the International Convention for the Control and Management of Ships' Ballast Water and Sediments. In particular, the finalization of the revision of the guidelines for approval of ballast water treatment systems (G8) which the organization says are not yet adequate for IMO approved ballast water treatment systems to consistently meet the requirements of the Ballast Water Convention.
Lars Robert Pedersen, BIMCO’s Deputy Secretary General, says: “The shipping industry needs reliable ballast water treatment systems that are fit for global use. Presently, IMO approved systems may not always live up to the required standards under real operating conditions on board ships.”
A key part of the MEPC discussion will center on the report of the Correspondence Group established by MEPC 68. The group’s report includes discussion of around 30 proposed changes to G8 wording and therefore how ballast water treatment systems are tested and type approved. A few of the items to be discussed are:
1. Testing being performed using fresh, brackish and marine waters, including Type Approval (TA) Certificate amendments
Key change proposed:
The water salinities referred to in the guidelines should be amended to:
Fresh (salinity < 1 PSU)
Brackish (salinity 10-20 PSU)
Marine (salinity 28-36 PSU)
Additionally, testing wording should be amended to ensure that testing is conducted within each of the three salinity ranges. The group agreed that the type approval certificate should be annotated on the front page to indicate when a system is certified for limited operations.
2. Testing considering the effect of temperature in cold and tropical waters on operational effectiveness and environmental acceptability
An expert the subgroup found that temperature affects treatment system operations, efficacy, chemical degradation rates and organism regrowth rates and that full scale testing at all temperatures may significantly increase costs of system development and reduce availability of approved technologies. The subgroup questioned whether there is an alternative to full scale testing but stated that testing must be robust and reflect real conditions, if possible.
It was concluded by the group that treatment systems should be adequately tested to ensure effective operation at different temperatures using a combination of ship-based, land-based and bench scale tests.
3. Specification of standard test organisms for use in testing
The group considered the need to ensure that test water provided appropriately challenging conditions and the use of standard test organisms as a possible method of ensuring robustness of testing. It was agreed that the use of standard test organisms should not be accepted as the norm. However, other practical and technical issues caused the group to conclude that MEPC should invite Member States and international organizations to provide information and experiences on the issue.
4. Propose definition of "viability" of organisms, taking into account the damage caused to organisms by ballast water management systems making use of UV
Tasked with proposing a definition of the "viability" of organisms, taking into account the damage caused to organisms by treatment systems making use of UV, the group agreed, with the exception of Italy and the United States, that there was a need to amend the existing definition of "viable organisms" (paragraph 3.12).
The group supported the definition that viable organisms are organisms that are reproductively viable (meaning the organism has the ability to successfully generate new individuals in order to perpetuate the species).
However, it was agreed that an alternative approach is required. This could be to retain the existing definition of viable whilst amending G8 to allow for alternative methods that provide an equivalent level of protection to the existing methods of determining viability.
5. Challenge levels set with respect to suspended solids in test water
Although the group, with the exception of Norway, agreed that the challenge levels of Total Suspended Solids (TSS) listed in G8 require amending, the group did not reach consensus on exactly how this should be done.
It was agreed that challenge levels should reflect "conditions normally encountered during operations," and it acknowledged that current challenge levels do not do this. The group was split when it came to agreeing to the introduction of three set TSS levels (high, medium, low) to G8. An alternative to the suggested three levels was to test at a high level of TSS in order to give sufficient confidence in the ability of a treatment system to operate at lower TSS levels. As no conclusion on this issue was drawn, this item was marked for further consideration.
Moving Ahead Despite the Uncertainties
The importance of the Ballast Water Management Convention was highlighted by IMO Secretary-General Kitack Lim in his opening address. However, Lim stated that he does not see shipowners’ concerns as a cause for slowing its implementation.
“It is recognized that installing and operating a ballast water management system comes at a price and shipowners are understandably concerned about incurring such costs, especially in the current difficult economic climate. Also, new technologies need time to mature, which has caused many owners to stand back and wait. However, these concerns should not stop us from implementing the Convention and I would strongly encourage Member Governments to cooperate and establish meaningful measures which would ease the burden for the shipping industry. However, there can be no doubt that we must move to entry into force and implementation of the Ballast Water Management Convention.”
Since the last session of the Committee, the Convention gained five additional ratifications. To date, 49 States with an aggregate of 34.79 percent of the world’s merchant fleet tonnage have acceded to the Convention. The entry into force condition of 35 percent is now tantalizingly close, says Lim, and, with further ratifications in the pipeline, there is every expectation that it will be reached during the current year. This would mean that the Convention will come into force during 2017.
Currently, type approval has been issued for 65 ballast water treatment systems. It’s not yet clear how these certifications will be affected by current MEPC discussions.