ICS, BIMCO, Intercargo, Intertanko, WSC made submission to IMO MEPC 66
ICS, BIMCO, Intercargo, Intertanko, WSC have jointly made a submission to upcoming IMO Maritime Environment Protection Committee (IMO MEPC 66) to amend the Guidelines for approval of ballast water management systems in order to ensure success of the BWM Convention. The MEPC 66 will be held in IMO headquarters from 31 March 2014 to 4 April 2014.
The authors suggest that the only way to satisfactorily address concerns regardinf the BWM Convention is to amend the G8 Guidelines to provide a robust and consistently applied testing protocol thatwill provide confidence that type approved treatment systems are 'fit for purpose'. TheConvention provides a procedure for making changes to the guidelines in Regulation D-5
It is recommended that treatment systems should be subject to testing in all types andconditions of water normally encountered in world trade and any limitations discovered shouldbe clearly identified. The current, recently revised, recommendatory procedures permit atreatment system to be tested only in high and medium salinity temperate water with the type approval certificate stating this; this does not provide any indication of the actual limitations ofthe system.
The type approval Guidelines also need to be consistently applied and thelegislation should be amended to achieve this without the possibility of a test facility amendingstipulated procedures and so weakening the testing appraisal. For ease of reference theproposed amendments for enhancing the (G8) Guidelines originally given in MEPC 64/2/17 arereproduced below, together with a rationale, as the basic outline for this much neededamendment.
1. Testing should be performed using fresh, brackish and marine waters - the presentrequirement is for testing to be performed with two test waters with a salinity differential ofat least 10 PSU. In effect this means that testing in fresh water can be avoided. It is nowgenerally recognized that certain fresh water organisms (specifically copepods) can bemore resistant to some treatment processes now commonly applied in BWMS than marinewater organisms and therefore the full range of salinities, which are commonlyencountered during normal ship trading, should be represented to provide assurance thatthe system will continue to work correctly in waters of all salinities.
2. Testing should also consider the effect of temperature in cold and tropical waters onoperational effectiveness and environmental acceptability. One BWMS has beenwithdrawn from the market due to residual toxicity in cold water, which was not detectedduring the TA testing conducted with temperate water. The possibility of residual toxicityfollowing a chemical treatment in cold waters cannot be discounted and therefore shouldbe checked. The efficacy of operation in both cold and tropical waters should also beverified.
3. Standard test organisms that challenge the treatment process should be specified foruse in testing. It is a serious concern that some test facilities may select organisms witheither a high natural mortality or low resistance to disturbance for convenience due to thetest site location; it is essential that the treatment efficacy is sufficiently challenged toprovide a real life operating scenario.
4. Suspended solids in test water should provide a more realistic challenge than atpresent. Levels of clay silt and the content of total suspended solids (TTS) in the testwater should be increased. It has been found in practice that some filtration systemsforming an integral part of the BWMS cannot cope with conditions prevalent in a numberof areas, particularly where heavily contaminated river estuaries are the port location; asmany BWMS inherently rely on the efficiency of the filtration for efficacy of treatment, thefiltration phase needs to be realistically challenged under conditions reflecting the worstcase real life scenarios that may be encountered.
5. The TA testing should not allow discounting test runs in the full-scale testing that do notmeet the D-2 standard, nor should the results of test runs be "averaged". If a systemunder test fails the treatment efficacy requirements at any time, then it should not begranted TA. This is a root cause of concern as the present allowances provide anopportunity for systems that cannot reliably maintain the D-2 efficacy requirements to gainTA. This should also apply to test runs that fail the efficacy criteria that are discounted dueto not meeting the control water validity criteria.
6. TA testing should realistically represent the flow rates the system is approved for. Inaddition the continued effectiveness during low ballast water flow rates should be verified as a BWMS will be required to operate effectively at both full flow and reduced flow suchas when topping up ballast tanks and fine adjusting the ballast condition en-route.
If the Committee agrees to amend the G8 Guidelines or the Convention as describedabove, it would be unfair to penalize shipowners that in good faith have already purchased orinstalled type approved BWMS or to require them to remove and replace their existing typeapproved systems. Vessels that are equipped with G8 based IMO type approved systems by aspecified date (date to be determined) could be deemed to have IMO type approved systems,even after new testing protocols have been adopted, for the remaining life of the system or thevessel, whichever is shorter.
It is considered that successful implementation of the Ballast Water ManagementConvention, 2004, depends upon confidence in the availability of Type approved treatmentsystems that operate effectively and consistently under all normally encountered operatingconditions. This can only be assured by the introduction of an enhanced and consistentlyapplied Type Approval testing regime.
The Committee is invited to consider the problems identified and the proposed solutionand to decide as appropriate.