Document was submitted to the IMO including major concerns over BWMS
Concerns over the IMO’s Ballast Water Convention (BWM) have been expressed by leading shipping organisations to the IMO ahead of this October’s MEPC 64 meeting.
A document was submitted to the IMO endorsed by Liberia, the Marshall Islands, Panama, BIMCO, INTERTANKO, CLIA, INTERCARGO, InterManager, IPTA, NACE and WSC.
As has been raised at previous MEPC meetings, there are a number of issues that are affecting ratification and implementation of the BWM Convention that need to be addressed by the MEPC and the IMO member states to ensure proper and effective implementation of the convention.
The major concerns of the authors are as follows:
1) Need for revision of the Guidelines for approval of ballast water management systems (G8) to improve transparency and ensure appropriate robustness of ballast water management systems (BWMS).
2) Availability of BWMS and sufficient facilities to install BWMS.
3) Survey and certification requirements for ships constructed prior to entry into force of the BWM Convention.
4) sampling and analysis procedures for port State control purposes.
In June 2012, there were 23 type approved BWMS on the market; 25 BWMS have been approved in total with two BWMS having been withdrawn from the market by their manufacturers. All the Type Approved systems have been approved using the ‘Guidelines (G8)’ and have been released onto the market with the intention of installation on board specific ship types and sizes.
In many cases it is apparent that the type approval certificate and its enclosures are insufficient in detail to provide a clear picture of whether a system may be adequate to meet the needs of the vessel being considered and its particular trade routes, the group said.
The problem stems from the lack of limits provided in the type approval certificate and its enclosures even though this is an aspect specified within the ‘Guidelines (G8)’. In some examples the approval documentation may imply that the BWMS has no practical and operational limitations. However, the fact that no limitations are provided does not mean limitations do not exist.
For example, several certificates have been provided based on theoretical extrapolation of the system’s maximum treatment rated capacity (TRC), as opposed to actual physical tests. The co-sponsors said that they believed approval should be based on actual tests.
The certification documentation frequently fails to include the capacity of shipboard testing that was used when the D-2 standards were attained. In one such example, the certification was supplemented by a four page analysis of the ship board test in terms of the discharge standard, but failed to include the treatment volumes for the test system. The accompanying certification had a range of treatment from 60-6,000 cu m per hour.
An owner may well express some scepticism at a system that has undertaken shipboard testing at 60 cu m per hour yet has a maximum TRC of 6,000 cu m per hour. Approval should be given based on system tests at maximum capacity.
Additional questions arose as to limitations of a BWMS to meet the D-2 discharge standard under many other operational conditions. For example, problems have already been experienced in relation to the operability of certain system types in brackish or freshwater, eg electro-chlorination and electrolysis; in turbid or high-sediment-load waters in the case of UV systems, and; systems using filtration in sediment-rich, muddy waters that may reduce the efficiency (treatment volume and rate), or increase maintenance requirements of the filters.
It is clear that an owner is not able to make a decision based purely on the certification and its enclosures. However, resolution MEPC.174(58) states that the type approval certificate should specify any limiting conditions of the BWMS usage necessary to ensure its proper performance.
The co-sponsors proposed that the form of the certificate, as well as its enclosures, should be revised and standardised with the aim of improving the transparency and detail of information being provided to ensure the overall veracity of the certification and the certification process.
The document then continued to detail why, in the co-sponsors’ opinion, in some cases the approval process does not always ensure that the equipment is fit for purpose, ie is robust enough for shipboard installation and operation
Source: Round Table Associations
