The announcement confirming the ratification of the Ballast Water Convention (BWC) last September at IMO MEPC 71 finally provided the shipping industry with some solid timelines around the installation of ballast water treatment systems (BWTS). The decision to extend the deadline for the retrofitting of vessels with BWTS has been well-documented, and there may be many shipowners that breathed a sigh of relief. Yet, a year on, for those shipowners and operators who choose to take advantage of the extended deadline, it’s important to recognise that failing to follow the principle of the Convention may risk reduced commercial opportunities and reputational harm.
The revised BWM Convention introduces two standards for the handling of discharged ballast water:
- D-1 standard requires ships to ensure that 95% of ballast water by volume is exchanged far away from the coast where it will be released.
- D-2 standard requires ballast water management to restrict the amount of viable organisms allowed to be discharged and to limit the discharge of specified indicator microbes harmful to human health.
New ships (keel laid on or after 8 September 2017) must conduct ballast water management that at least meets the D-2 standard from the date they are put into service. For existing ships, the date for compliance with the D-2 standard is linked with the renewal of the ship’s International Oil Pollution Prevention Certificate after September 2019. With many shipowners opting to renew their five-year IOPP on the cusp of entry into force, this can push ship compliance out by up to seven years in some cases.
But it would be a mistake to assume that BWTS has been ‘put on hold’; two of the most powerful nations in world trade and the maritime economy have chosen to enforce strict ballast water regulations ahead of the required IMO compliance timelines. Since 21 June 2012 the United States Coast Guard (USCG) ballast water regulations require vessels that discharge ballast in U.S. waters to either install a treatment system or manage their ballast water in another approved way. In August 2017 the USCG issued a USD 5,000 fine to the operator of a freight vessel for unauthorized ballast water discharge into the Willamette River in Portland.
Saudi Arabia is another nation that is driving forward with enforcing ballast water regulations, in light of the recent announcement by the world’s largest oil producer, Saudi Aramco, that all vessels calling at its ports will be required to provide a ballast water sample and report. Saudi Aramco is among the highest receivers of ballast water from ships with over 180 million tonnes of ballast water discharged during cargo operations. As of 16 August 2017, all vessels using these ports are now required to demonstrate compliance with the Convention, with failure to do so likely to result in fines and detentions.
The fact that two important nations for shipping have moved ahead of regulation poses a quandary for shipowners and operators and created a two-tier environment, posing questions for those entering U.S, and Saudi Arabian ports: accelerate the installation of BWTS to comply, avoid U.S. and Saudi ports, or risk fines and detention?
Delaying capital investment in ballast water treatment systems might be considered a financially attractive option, but this is a short-term view. Shipowners need to carefully consider the long-term implications of not being able to trade with any ports in countries that have enforced the Convention, including raising asset value of their vessel and future-proofing their fleet to meet standards now and in the future.
Installing ballast water treatment systems is a costly undertaking, and confidence in the reliability and integrity of the monitoring systems is critical. False readings could lead to delays with port state control, fines and potential reputational damage.
To ensure ships are monitoring accurately and ensure total compliance with regulations, Saudi Aramco conducted a detailed technical review by comparing monitoring systems, resulting in the selection of Chelsea Technology Group’s (CTG) FastBallast Compliance Monitoring System as their choice, CTG’s testing devices will be used to conduct spot checks on sampling undertaken by third-party sampling companies.
FastBallast is capable of operating in a flow-through mode, while providing a high degree of accuracy with a representative report on discharge compliance. It is capable of determining the phytoplankton cell density of ballast water to IMO D2 & USCG Discharge Standards (10 to 50 µm range), with a higher degree of confidence than laboratory analysis.
Together with Global Strategic Alliance Saudi Arabia (GSA), its agent for Saudi Arabia and Bahrain, Chelsea Technologies has provided expert consultancy and guidance to Saudi Aramco’s in-house experts on the testing and sampling standards and processes that should be put in place. In addition, GSA is closely working with the Saudi Arabia authorities to utilise FastBallast as the national benchmark for ballast water sampling.
Saudi Aramco and the US Coast Guard have set high environmental standards and are driving change ahead of regulations. Shipowners and operators will come under ever increasing scrutiny from customers and regulators. Those who take a proactive, long-term view regarding compliance will realise the commercial benefits, whilst those who don’t will be left behind. The industry needs to continue to invest in ballast water treatment systems and monitoring in order to keep pace with the leaders and maintain access to global markets.
By Dr. Brian Phillips, Managing Director, Chelsea Technologies Group
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only
Dr Brian Phillips is the Managing Director of Chelsea Technologies Group. The company specialises in optical, acoustic and physical sensors measuring temperature, conductivity, hydrocarbons, fluorescence, water clarity and primary productivity.