Britannia P&I Club issues guidance on how to comply with regulations regarding ballast water management, in order to avoid fines and pollution.
Britannia reminds that the company’s Safety Management System (SMS) should also include procedures on ballasting operations to ensure it is carefully planned and executed. According to Britannia, planning considerations for the ballast process should include:
- Training and familiarising the crew with the onboard ballast system, the line setup, ballast water treatment system and associated equipment.
- Ensuring efficient ballast tank management, including regular inspection of tank-fitted alarms and sounding equipment. This will help prevent the accumulation of sediment or debris that could be of an invasive species.
- Assessing the suitability and quality of the water to be taken on as ballast. If possible, the ballasting required may be achieved by internal transfer of the ballast water already carried on board.
- Determining the amount of ballast water required for stability and trim during the different phases of the cargo operation and voyage. This includes ensuring that vent closures are open for the tanks being ballasted.
- Producing a ballast water plan, which stipulates the required ballast amount and sequence of tanks to be filled and emptied. Also taking into consideration any pump limitations and planning ballasting at a safe rate.
- Considering free surface effects as a result of tanks that are not pressed.
- Obtaining a loading/discharge sequence prior to the cargo operation. If the provided sequence plan raises any stability or hull stress concerns which cannot be compensated by the use of ballast, this should be brought to the attention of the terminal immediately for rectification.
- Ensuring all ballast tank level measuring gauges are working and provide reliable soundings. For manual sounding, suitable sounding intervals and reporting should be agreed.
- If operating in Arctic areas, ensuring the sounding pipes and tank level gauges are not affected by the extreme cold weather.
- Maintaining and updating ballast water management records as required.
- Considering nearby vessels. This is important for bunkering purposes so the de-ballasting does not cause damage or impact its safety.
- Considering the locations of shore installations to ensure de-ballasting operations do not cause damage, particularly to electrical items.
- Taking care when ballasting in shallow waters as it can cause ballast pump strainers to choke and sediment deposits to gather inside tanks.
Monitoring
The ballast operation should be monitored throughout by a duly qualified deck officer, with the deck crew using a reliable means of communications, Britannia highlights. The P&I Club also recommends that:
- To avoid potential fines, ballast tanks should not be allowed to overflow through airpipes. If manual soundings are conducted, these should be carried out at agreed intervals and be reported to the officer in charge of the ballast operation.
- During de-ballasting, frequent ‘over the side’ visual observations of the discharged ballast water should be carried out to determine if there are any signs of contamination. If it does, the ballast operation should be stopped immediately and the root cause investigated.
- The officer in charge of the ballast operation should be familiar with all fitted alarms and react promptly if they are activated. They should also be aware of any alarm not being activated as expected.
- Some vessels may be installed with a gas sampling system in its ballast tanks. While this system may provide an warning about ballast water contamination then it cannot solely be relied on for this purpose.
- Depending on the model it may be required to be disconnected when a ballast tank is full. Also, sufficient headspace within the ballast tank will be required for a dangerous atmosphere to develop and for the system to provide a warning of this.
Therefore, Britannia supports that familiarisation with the ballast system and monitoring the operation by applying good ballast management practice remains vital. Similarly, ensuring accurate ballast tank management, including regular inspection and maintenance, is also important.
Ballast tank maintenance
Britannia states that as part of a vessel’s Planned Maintenance System (PMS), a robust maintenance schedule for the ballast tanks, including cleaning, inspection and repairs should be implemented.
Regular inspections are advised by the Club that should include thorough visual examinations, non-destructive testing techniques, such as ultrasonic testing or magnetic particle inspection, and thickness measurements of the tank walls. Ideally, photographs should be taken and kept as a record of visual inspections.
Checking manhole covers to ensure that sealing arrangements are free of debris, the gasket is in satisfactory condition and all nuts and bolts are in place and correctly cross-tightened. Britannia also advises:
- Periodic hydrostatic testing of ballast tanks surrounding the cargo holds should also be considered as part of a vessel’s planned maintenance system and conducted at suitable intervals when the holds are cargo free.
- Ensuring the surface is properly prepared before applying any protective coatings or treatments to the ballast tanks. This includes cleaning, removing rust and scale.
- Applying appropriate protective coatings to prevent corrosion. These coatings should have corrosion resistant and be able to withstand the harsh marine environment.
- Monitoring and maintaining cathodic protection systems to ensure their effectiveness. This may include periodically measuring the current and potential differences to assess the performance of the system and maintaining and replacing corroded anodes as per the manufacturers’ instructions.
- Regularly monitoring the quality of the water inside the ballast tanks to identify any potential sources of contamination. This includes testing for pollutants, chemicals and biological organisms that could lead to cross-contamination or damage to the ballast tanks. Also being aware of any unusual odour from the ballast tank venting system or sounding pipe
- Promptly addressing any structural damage to the ballast tanks. This includes repairing any cracks, dents, or structural weaknesses that may affect the integrity of the tanks and notifying the vessels’ classification society to determine further repair requirements
- Where there is a sign or suspicion of a ballast tanks integrity being compromised, ensuring it is not used before an investigation and any required repairs have been conducted. This also applies to adjacent tanks or compartments that may be affected by potential structural damage.
It should also be noted that any inspection or work inside a ballast tank should be governed by Members’ entry into enclosed space procedures and Permit to Work system, implementing the provisions stipulated by IMO’s Resolution A.1050(27) ‘Revised recommendations for entering enclosed spaces aboard ships’, Britannia reminds.