Few weeks ago, there were a couple of test facilities that stopped testing BWT. For example, the Maritime Environment Resource Center (MERC) from the US said they stopped the testing because there are so many flaws and regulations designed to minimize the risk of ballast water introductions of invasive species, that they don’t believe in this. DHI from Singapore stopped testing because they said the requirement for a prescribed density of organisms measuring 10-50ɥ was difficult in Singaporean waters. Continuing, Global TestNet were concerned that there will be decreased capacity to process certification testing.

All these statements are leading to further confusion on BWT considering the pragmatic evaluation in type approval testing that has already observed. For instance, the Golden Bear Research Center stated that “Organism reduction demonstrates that ballast water treatment effectiveness is fantastically high”.

"The requirement for 5 consecutive successful results in BWMS type approval testing fundamentally changes the relationship between a method's precision and its effectiveness in ensuring compliance with regulations. Confidence is strengthened because the 5-test, "one strike and you're out" requirement" added the Dalhousie University.

What I want to point out is that even if you have the IMO testing, the new G8 testing, the USCG testing, the certification is not and will not be a proof of compliance. It is a little bit like you are buying a car and it is tested with certain fuel consumption and it give you 5 litres per 100 km and then you start driving it and it normally consumes about 60 km and this is because you are driving it differently than the test conditions. BWT is the same thing: there will be possible alternative testing for BWT in real life and you have to know what kind of system you are installing on a vessel.

Also I don’t think that BWTS makers want to do any additional testing, because it is expensive and time consuming. We are currently going through the USCG testing and revised G8 testing, we are removing limitations on certifications and holding times, we are adding any filter options and we are doing system updates. All these things need further testing.

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According to estimates, the BWT companies and the system makers have spent about 2 billion dollars on this BWT since 2004 only which is a lot of money. When we look at the total figures, in 2017, the BWT market was about 380 million USD, mainly in the European market. In 2018, 342 million USD are expected. In 2019, we will start seeing the first retrofitting installations and, moving further, in 2020 and 2021 we expect the biggest number of vessels installed with BWT; approximately 6,900 vessels.

But when the BWT market started, people were talking about market size at 40 billion dollars and everybody who started this business was thinking about “How much money we will make?” But now when the market is 13,2 billion USD, and we have spent more that 2 billion on testing and development equipment, I think we will see a lot of consolidation. Many makers will disappear because they don’t have the financial backbone to support their systems or be competitive on the market.

We have waited for a long time; IMO Convention was adopted in 2004 and entered into force in 2017 and the expecting BWT market kick-offs in 2019. So, when you think an average profit generated by many sold systems to be between 10-20% on a 13-billion-USD market, it is clear that many companies will not be able to be profitable. We saw the auctions going back even though they had the USCG type approval.

Moving further, USCG Guidelines that came into force on 14 Feb 2018, foresee that in case of an inoperable BWT system (at situ), the Captain of the Port needs to be immediately informed. The COTP may approve one of the “other” approved BWM practices like BWE to be used instead.

According to the USCG Guidelines, the following are not counted as ”inoperable system”:

  • Lack of consumables does not meet the ”stops of operating properly” clause.
  • Ships with inoperable BWT system due to BWT system makers bankruptcy and non-availability of spare parts or chemicals will not receive special consideration.

 

The views expressed in this article are solely those of the author and do not necessarily represent those of SAFETY4SEA and are for information sharing and discussion  purposes only.

View Juha Kiukas’s presentation on BWTS during the last GREEN4SEA Conference herebelow


Juha Kiukas is a Marine Naval Architect with over 20 years of experience in various marine markets. As the European Sales Director at Trojan Marinex, he leads the tactical implementation of sales and market integration strategies. Trojan Marinex is part of the Trojan Technologies group of businesses. Direct access to 40 years of industry-defining water treatment expertise has enabled them to create a suite of ballast water treatment systems unlike any other. These systems are purpose built for the marine environment and provide filtration + UV in a single, compact unit.