BWM Convention in brief
The BWM Convention was concluded in 2004 and it was expected that it would be ratified within a five years’ time frame; a time schedule based on 2007 to 2010, but it took a lot of time. The reason why the convention was not ratified was shipowners’ lack of confidence in the BWMC testing guidelines limited support for ratification. But, in 2014, the ICS said the industry proposed “minimum issues to be addressed for a revision of the G8 testing guidelines”. A working group was established and developed the new robust 2016 G8 testing guidelines and the BWMC entered into force 8th September 2017.
What is the Revised 2016 G8 Guidelines?
Starting from the testing facility independency, operators may not like the manufacturers to decide how to fix the equipment, but the equipment should be operated independently from the manufacturer. International Organisations are very keen on that; the system should be suitable for worldwide operation meaning that it should be working in cool water, in low salinity and it should be very clear what the system design limitations are. It is of essence to have made a good assessment on the system capabilities; for this reason there is need of consecutive design test cycles. When it comes to the minimum holding time, the system should be tested within five days but in the revised G8 and if the operator needs a no hold time, they need to state it at the performance claim in order to be tested at no hold time. There is also some clarification about service and commissioning procedures.
Last year, in February, Pure Ballast received the BWMS certification in compliance with the revised 2016 G8. They were the first one to be able to be certified according to the revised G8. Installations from 28th October 2020 and onwards should have revised 2016 G8 certification. Thus, the revised 2016 G8 certificate gives vessel owners peace of mind in planning future-proof fleet retrofit installations.
USCG type approval
USCG ballast water management regulations entered into force 21st June 2012 and Alfa Laval began testing in October 2012. However, applications from Alfa Laval and two other UV suppliers were rejected in 14th December 2015. After that Alfa Laval started retesting and became the second supplier to be type approved by the USCG in December 2016. Now, there are six type-approved systems.
Moreover, we had a problem with this prescribed USCG method called CMFDA and in order to get that working we had to apply 72 hours hold time.
The US Administration is working to verify the MPN test method, and is going to do the verification during the spring of 2018, which will be a solution for the UV problem. However, some vessel owners have expressed concern over the 72h holding time required to make the USCG CMFDA method work.
USCG policy for inoperable BWMS
As far as the USCG’s policy regarding inoperable BWMS is concerned, we can conclude that USCG, other organizations, and IMO, are moving from type approving to compliance, and USCG notes the following:
- Lack of consumables, training or operational experience will not be accepted going forward;
- An inoperable BWMS must be reported and the USCG can accept a ballast water exchange 200 nm from shore;
- Submission of a repair plan is suggested;
- The BWMS must be repaired before the vessel returns to the USA after sailing in foreign waters;
- Regular operation of the BWMS is recommended even if the vessel is not bound for the USA, in order to give the crew operational experience.
Above text is an edited article of Peter Sahlén’s presentation during the 2018 GREEN4SEA Conference
You may view his video presentation herebelow
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.
In 2012 Peter Sahlén joined the Research & Development team for the Alfa Laval PureBallast product – a Ballast Water Management System (BWMS). Peter Sahlén was originally responsible for project management, technical and commercial evaluation and qualification of some key components, e.g. filter. In early 2014 Peter was assigned the position as Research & Development manager for the Alfa Laval PureBallast BWMS. Peter is in this position responsible for the development and maintenance of the PureBallast products and its compliance with class, IMO and any domestic (USCG) legislations. Peter has since 2014 participated in the United Nations/IMO’s Marine and Environmental Protection Committee (MEPC) meetings and the ballast water correspondence groups / meetings. One of the more important tasks in this forums has been the development of the new revised IMO 2016 G8 Guidelines for type approval testing, to now be followed by the experience building phase.