GREEN4SEA: What do the decisions made during MEPC 71 actually mean for the BWMC? What are the biggest challenges towards BWMC implementation?
Jad Mouawad: The most important aspect to consider here is that the BWMC was not delayed. It is the implementation schedule of the D-2 standard of the BWMC that has been pushed forward 2 years, but all ships must be certified for exchange as of 8 September 2017 in order to be allowed to trade internationally. This fact that exchange will start is a huge and impressive leap towards protecting the environment that must not be undermined.
Other decisions by MEPC 71 like making the Type Approval Guideline a mandatory code and discussing contingency measures mean that the IMO is moving towards practical implementation challenges of the BWMC, and not just high level policy making. I believe those discussions were much more interesting and important for the industry than the discussion on dates, which was over and done months before the meeting took place.
G4S: What are the implications of the BWM new dates for both the shipowners and the vendors? What could be done to harmonize the contrasting effect of this postponement?
J.M.: All in all, I believe the new proposal allows for more time for ship owners to make decisions, and at the same time for vendors to obtain necessary USCG Type Approvals and hopefully 2016 G8 Guidelines (to be called Code for Approval of BWMS). The implications to the vendors are quite dramatic in some cases where cash flow is crucial, while it is less evident for companies that can ride the next 2 years without so much income.
The only way I recommend moving forward is for ship owners to start planning for the retrofits, make agreements with vendors and not sit down and relax yet another 2 years before rushing to comply at the last moment.
G4S: Some environmental NGOs support that this two-year postponement is bad news for the marine environment. What is your view on this statement, considering that some existing vessels will have until 2024 to fully comply?
J.M.: As I mentioned in the first question, I don´t think there is a good understanding of the provisions of the BWMC. We will start protecting the environment as of 8 September 2017 through exchange. And then gradually implement the more stringent standard. In my opinion, this is a very good start for protection of the marine environment. We have to combine environmental protection with trade and welfare challenges in order to make this work. Ships must sail and trade, the environment must be protected. We cannot do one without the other and so we have to come to a good way forward, which I believe we do now.
G4S: Do you foresee any emerging problems with the implementation of the BWMC? What is your advice?
J.M.: Yes!! Many. The major issue I observe right now is the inability of ships to get the systems they have onboard to work properly. Not because of type approval, or because of the systems proper (like some shipping NGOs falsely claim), but because of a combination of design flaws, non-usage, lack of proper training, maintenance and wrong installation at retrofit or new build stage. We cannot have it so that we have to send specialist consultants to brand new ships to fix a brand-new system installed, because the crew don´t know how to do it. It is not sustainable and this must be taken very seriously by all parties. The only way around that problem is for Port State Control to take it very easy in the first years of implementation, allowing ships and vendors to learn more about the operation of the BWMS onboard those ships.
G4S: 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?
J.M: We expect a sharp rise in USCG and IMO TA BWMS within 2018. We know this for a fact due to the large number of contracts we have consulting for type approvals.
We don´t expect this number to increase much more in 2019 onward but we do see a trend of coming up with new solutions and improving existing ones. I see a major advantage for the Korean and Chinese makers due to their strong presence in the New Building and Retrofit market, respectively. Although I see many other makers in other countries coming up with really good and innovative solutions that will be interesting to follow, like the BAWAT BWMS in Denmark and GenSys BWCS in Germany.
G4S: What is your key message to industry with respect to BWMC implementation?
J.M.: I recommend ship owners, as always, to go ahead and test a system or two before purchasing something for their entire fleet. Hire a consultant if you don´t have the expertise in-house, but by all means avoid purchasing a BWMS without really knowing if it meets the requirements of the ship or not. It is much more difficult for us to fix those issues, than coming in early and making the right choices from the beginning. We will shortly launch a free of charge service online at www.bwm.no, to help ship owners make the right choices of makers. At least use that before deciding. For those with BWMS installed, follow up and make effort to make them work, and ask the managers to start running them (even if you have to pay for the extra fuel).
Vendors should make serious efforts to finish their USCG type approval, but most importantly, they must work hard and fast to get the 2016 G8 Guidelines approval (to be called Code for Approval of BWMS). When components are failing (read: TRO meters), efforts must be made to find good solutions for those so that ships are not hampered in their trade.
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
Jad Mouawad (M.Sc. Marine Engineering) founded Mouawad Consulting AS in September 2013 in Norway after previously heading the Environmental Protection section at Det Norske Veritas (currently DNV GL). Mouawad Consulting AS currently delivers Type Approval advisory services for manufacturers of BWMS and retrofit services for ships. We are working with more than 120 companies, including ship owners, manufacturers of BWMS, class societies, governments, and shipyards. Mr. Mouawad is part of the Norwegian delegations on ballast water to the PPR and MEPC. He is regularly called upon as an expert in ballast water matters at international conferences and meetings.