In an exclusive interview to SAFETY4SEA, Stelios Kyriacou, CTO (Chief Technology Officer) at ERMA FIRST, provided an overview of the regulatory landscape concerning the implementation of the Ballast Water Management Convention.
r. Kyriacou suggested issues for discussion at next MEPC, highlighting that Experience Building Phase (EBP) should be addressed further in order to stop holding back decisions related to the implementation of the convention and the definition of the inspection and enforcement framework. Among others, Mr. Kyriacou also stressed the need for crew training and in particularly for periodic re-training and qualification of operators on BWTS installed onboard.
SAFETY4SEA: What are the biggest challenges towards the Ballast Water Management Convention implementation from your perspective and your feedback from the market until today?
Stelios Kyriacou: Although the Convention reached the entry into force point on September 2017 in practical terms the regulations have been in state of ‘suspended animation’. The full implementation is still to be achieved and this is because fundamental elements of the regulatory framework remain open and vague. For very good reasons the Experience Building Phase (EBP), has been launched by IMO MEPC and is work in progress. However the pandemic has impacted working schedules and consequently the implementation of the convention that is intrinsically linked to the EBP outcomes has not made any real progress.
Accordingly, there is no progress on Port State Control inspections (PSC) which is a fundamental requirement for the practical enforcement of the ballast water management convention. This and other outstanding decisions cause a significant unrest to ship owners, managers and operators who are still unaware, as are the rest of us, of the PSC inspection framework, actions, sampling and analysis, penalties and the like, that all have an important impact on the users of Ballast Water Treatment Systems (BWTS).
Shipowners have to comply with both the IMO and USCG ballast water regulations that are based on different enforcement schedules and regimes. USCG is already fully implemented where the IMO convention is lacking behind and this phasing difference must be addressed.
S4S: Based on your research, what are the key characteristics that ship operators need to keep in mind when selecting a BWTS?
St.K.: There are numerous Type Approved BWTS available. According to Clarksons the most popular technologies are those that use Filter-Full Flow Electro chlorination and Filter-UV. It is however evident that there is no one system or one treatment technology solution that fits all. Through the EBP it has become clear that in many cases the lack of operation or performance that has been reported by BWTS users can be explained by the lack of understanding of the System Design Limitations (SDL) where a user expects an operational outcome that can’t be delivered by the equipment available. For example, use electro-chlorination on ships trading mostly in fresh water. Although this can be achieved by inclusion of a high salinity water source, this is not always an economic proposition if a ship spends most trading time in rivers and lakes. Also the use of Filter UV systems on ships trading mainly in areas of high water turbidity, imposes high power requirements and operational delays due to UV inability to deliver the appropriate dose at full capacity.
BWTS system designers have argued consistently that selection of an appropriate system must consider the ship specific operational requirements such as trading pattern, frequency of ballasting/de-ballasting, water quality (salinity, temperature, turbidity), process power demand vs available power etc.
The engagement of ships on the spot market demands that a BWTS must be able to provide operational flexibility and minimum SDLs. Every BWTS has a published list of SDLs that are included on the Type Approval certificate as directed by the Ballast Water Code MEPC.300(72). It is therefore highly advisable to evaluate candidate BWTS technologies before making decisions.
S4S: What needs to be further discussed/ clarified at next MEPC with respect to BWMC?
St.K: MEPC needs to give due consideration to the acceleration of EBP as this is holding back decisions related to the implementation of the convention and the definition of the inspection and enforcement framework. There are outstanding issues to be addressed that include the critical actions related to sampling for compliance, approval and certification of Compliance Monitoring Devices (CMDs) including the working practices of PSC inspections to ensure a level playing field.
S4S: Is crew training an issue with respect to BWTS? What do shipowners need to think about the crew and their understanding of these systems and their installation?
St.K.: It is fair to highlight the need for crew training. Every crew change can inevitably contribute to BWTS operational challenges due to variations in the crew competencies and experience in using the specific BWTS. Many aspects of control and monitoring of key parameters are similar yet not identical. Start-up procedures vary by maker and erroneous operation is a likely possibility. It is always worth considering and investing in periodic re-training and qualification of operators as no two systems are identical.
S4S: Do you have any developments/ projects / plans that you would like to share with the rest of the industry?
St.K.: Earlier this year, ERMA FIRST acquired German marine water specialist RWO GmbH. Founded in 1975 and headquartered in Bremen, RWO provides water and wastewater treatment systems for ships, ports and offshore installations and is a market leader in bilge water separation systems. RWO’s product portfolio includes the treatment of drinking and process water, oily waters, ballast, wastewater as well as a comprehensive range of after sales spare parts and services. Over 16,000 ships have been equipped with RWO’s oil water separators since 1975.
In addition, ERMA FIRST completed the purchase of the world’s smallest and easiest to install ballast water treatment system to the international market through its acquisition of US firm oneTANK LLC. This is a small scale innovative, low-cost, IMO Revised G8 Code and United States Coast Guard compliant system. Based on a patented mixing technology developed by the U.S. Geological Survey, the system can be installed in larger vessels’ aft-peak tanks. It is also suitable for use aboard workboats, tugboats, semi-submersibles, fishing vessels and superyachts.
The views presented hereabove are only those of the author and do not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.