For the sake of clarity, we are not involved in those new efforts to establish such an association.
Mouawad Consulting is generally supportive of such an action, and we took the same initiative some 4 years ago with no success. However, we caution of some pitfalls and shortcomings that we would like to highlight through this article.
1 - Membership
The membership to this association should firstly be restricted to those companies actually delivering Ballast Water Management Systems (BWMS). Expanding it to all sorts of components, services and testing bodies will water it out and make it toothless (for example by becoming so large that conflicting interests might occur within the group).
All active manufacturers should be invited; by active we mean the makers that are still realistically offering a BWMS. Companies with Basic Approval issued in 2008 and nothing else, companies that are considering to build a BWMS or companies that have stopped producing a BWMS should not be invited.
A list of basic requirements to join the club could include companies:
- With a BWMS that has IMO or USCG Type Approval
- With a BWMS that is undergoing IMO or USCG Type Approval (on probation for a period of 2 years subject to extension until the BWMS has achieved Type Approval)
- With an approved BWMS solution such as reception facility, etc.
Asian makers must NOT be excluded. In order for this to be taken seriously by various stakeholders, active recruitment of the Asian makers must take place. This is important for this club to be more than just frustrated Western companies that want the BWM Convention to be applied strictly to sell equipment.
A list of the companies that we at Mouawad Consulting consider to be active can be found on our BWMS Cube at www.bwm.no free of charge. Contacting all those makers actively (i.e. not just sending an email) is essential for the credibility of this group as a start.
Membership must cost money.
- The cost must be enough for the club to be run professionally
- The cost must be hinder for non-serious BWMS manufacturers to become members
- The cost must NOT stop serious BWMS manufacturers from becoming members
The advantage of the above bullet points is that the club would be working for matters of concern to makers of BWMS, and avoid recruitment of service providers (components, consultants etc.) that would regard this as a selling arena for their services.
2 - Lessons learned from similar initiatives
GlobalTestNet is NOT an example to follow. While the testing facilities all went into this association with massive support from the IMO´s GloBallast, and despite the support of a very active chair in the person of Dr. Drillet, they failed to become a leading voice for testing standards for BWMS.
International Association of Class Societies (IACS) is an example to weary of and learn from at the same time:
- IACS managed to be the de-facto voice of class societies worldwide and a major player in the maritime industry. This is a goal the new club must have as a vision.
- IACS manages their chairmanship per member every 6 months, with a professional organisation seated in London. This is a good practice.
- IACS has become in the recent years another NGO supporting ship owners interests, instead of being an unbiased third party with technical competence in the marine industry. As such, the new club should avoid becoming an opponent to ship owners, but rather a club working for the common interests of the BWMS manufacturers. The former does not contradict the latter.
- IACS has gone and is still undergoing many scrutinies from anti-trust authorities that forced it to open up to a larger number of class societies. Legal issues should be as such clear across the globe, especially in the US, EU, Korea, Japan and China.
Lobbying to become an Observer at the IMO is very demanding. The club should focus on other core issues such as finding common grounds in standards before seeking such major step.
3 - Message to other stakeholders
Class societies, consultants, filter makers, UV lamps makers, TRO sensors makers, shipyards, installation companies and others are all encouraged to find each other and try to organise. Especially the handful of filter makers out there would be a very effective group to start with. But such an organisation cannot be within the confines of a club that should primarily be focused on manufacturers of BWMS.
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.
About Jad Mouawad
Jad Mouawad (M.Sc. Marine Engineering) founded Mouawad Consulting AS in September 2013 in Norway after previously heading the Environmental Protection section at Det Norske Veritas (currently DNV GL). Mouawad Consulting AS currently delivers Type Approval advisory services for manufacturers of BWMS and retrofit services for ships. We are working with more than 120 companies, including ship owners, manufacturers of BWMS, class societies, governments, and shipyards. Mr. Mouawad is part of the Norwegian delegations on ballast water to the PPR and MEPC. He is regularly called upon as an expert in ballast water matters at international conferences and meetings.