SAFETY4SEA: Tell us a few words about BEMA. How did the need for this new Association emerge and what are your plans on the agenda with respect to BWMC?
Mark Riggio: The Ballastwater Equipment Manufacturers’ Association (BEMA) was formed shortly after MEPC 72 when the implementation schedule of the Ballast Water Management Convention was delayed by two years. This delay highlighted the need for the industry to be represented at the IMO and galvanized the manufacturers to action. Concurrently, we heard from the shipping industry that an Association was needed to provide a unified voice, technical support, and to answer the many questions that were being raised by ship owning associations and Flag Administrations at MEPC. It was in this intersection of requests from ship owning associations and Administrations, along with a galvanized base of BWTS manufacturers that BEMA was born.
S4S: What are the biggest challenges towards BWMC implementation up to 2024?
M.R.: One significant challenge facing implementation of the Convention is rebuilding the trust between manufacturers and the shipping industry. As systems have developed over the past decade, many significant improvements have been made in the performance, operability, and capabilities of treatment systems. Some owners with experience based on early-generation systems have a negative perception of their performance. This has created distrust and fear that the systems they will purchase will not work. This fear has delayed implementation and is forcing bottlenecks in the supply network that are not necessary. If there was sufficient trust between ship owners and BWTS manufacturers systems could be purchased and installed in a more deliberate, planned way.
Another significant challenge facing implementation of the Convention is how differing flag and Port State Control will implement the rules. Both BWTS manufacturers and ship owners need consistency to facilitate taking the necessary actions to comply. BEMA fully supports the IMO’s Experience Building Phase (EBP) and looks forward to opportunities to contribute information, and encourages ship owners and Administrations to participate.
S4S: What needs to be further discussed/ clarified at next MEPC with respect to BWMC?
M.R.: BEMA believes that two primary issues will drive the next round of discussion at the IMO: Port State enforcement and contingency measures. Ship owners need to understand what Port States plan to do during their onboard surveys. Questions remain whether system checks will be largely administrative, whether indicative tests will be done to verify system function, or whether full compliance tests will be periodically done.
There is also a critical need for vessels to have adequate plans in place for when systems are either not functioning properly or when water conditions in the port exceed the system design limitations of an installed system. Each of these discussions provides BEMA with a strong platform to provide unbiased, technical viewpoints to the IMO and ultimately provide input to the decision-making process.
S4S: Have you noticed any specific problematic trend with the implementation of the BWMC so far? What is your feedback and your advice to the industry to move forward?
M.R.: BEMA envisions being a source of information that could help answer this type of question technically, but has not yet had an opportunity to assemble such data into a usable format. That said, BEMA currently sees three primary problems inherent with implementing ballast water treatment onboard vessels:
1) Proper time is not invested into the planning and design of the BWTS installation;
2) System installation plans and designs are intended to ease installation of the system for the shipyard, not to ensure that the system is installed in accordance with the manufacturers' instructions to promote proper system function over its lifespan; and
3) Opportunities for integrating the BWTS with the ship’s central automation system are often not thought about during planning.
If this is not addressed during design and installation, it will often leave the crews with significant extra work when using the systems. BEMA’s advice to industry is to coordinate closely with the manufacturer as early as possible in the process and to listen to their experiences and lessons learned. Many issues could be avoided if the manufacturer is seen as a partner to, and a resource for, the overall project team.
S4S: Where do you see the market is going in terms of timeframes and vendors competition in the short term? Should we expect more type approvals within the IMO and/or USCG?
M.R.: We expect to continue to see new Type Approvals both on the IMO and US Coast Guard side as additional technologies, solutions, and vendors come on line. The shipping industry is very diverse and there is a need for many different types of solutions to meet the many different vessel operating profiles. We would expect that as the market matures, there will be some measure of consolidation and contraction, but in the near term we expect that the market is right-sized for the number of active vendors currently serving it.
S4S: Is crew training an issue with respect to BMW? What do shipowners need to think about the crew and their understanding of these systems and their installation?
M.R.: Crew training has been identified by many as a critical issue with respect to BWM and BWTS. As a trade Association, BEMA cannot comment on specific training requirements for specific systems, but we do recommend that ship owners carefully consider the training available, complexity of systems being offered, and the crews on their vessels when selecting a BWTS for installation on their ships.
S4S: A new Act affecting BWM signed into law (VIDA) with implications on EPA VGP as well. What changes should we anticipate with that development? What could be the challenges ahead?
M.R.: The new Vessel Incidental Discharge Act (VIDA), recently signed into law in the United States, harmonizes the complex web of ballast regulations in the U.S. While this is a universally good thing, there are a number of steps before we know exactly how this will affect vessels doing business in the waters of the United States. BEMA is standing ready to offer assistance to the agencies writing these new regulations and harmonizing these requirements into a new set of standards. As with any potential change, the challenges of VIDA lie in the new areas of uncertainty for ship owners. With a potential four-year timeframe between the signing of the law and the publishing of a new standard, though, this uncertainty will have little impact on the BWMC Implementation Schedule.
S4S: What is your key message to industry with respect to BWMC implementation?
M.R.: BEMA has one key message with respect to BWMC implementation: get started. The time for delays, indecision, obfuscation, and denial has ended. More than 80% of the world’s fleet by tonnage flies the flag of an Administration signatory to the Convention. That means for each of these ships, starting in September 2019, when their IOPP renewal is done, they will need to install a BWTS. If that installation is planned to be done during a yard period, which is preferable, then that yard period may occur months before the IOPP due date. For many ships, that yard period will occur this Spring or Summer. If you do not have a plan in place, you are already too late in many cases to adequately plan for your installation. Do not delay. Start planning for your compliance now.
The views presented hereabove are only those of the author and not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.
Mark Riggio is the President of the Ballastwater Equipment Manufacturers’ Association (BEMA). BEMA is an independent trade organization representing vendors, suppliers, and key partners in the ballast water treatment industry by providing coordinated, technical, non-commercial guidance to the market, including the regulating community, ship owners, and the testing community about how ballast water treatment systems work, how they are designed, and what the reasonable expectations are in regard to their performance.
