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 that will provide confidence that type approved treatment systems are 'fit for purpose'. The Convention 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 and conditions of water normally encountered in world trade and any limitations discovered should be clearly identified. The current, recently revised, recommendatory procedures permit a treatment 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 of the system.
The type approval Guidelines also need to be consistently applied and the legislation should be amended to achieve this without the possibility of a test facility amending stipulated procedures and so weakening the testing appraisal. For ease of reference the proposed amendments for enhancing the (G8) Guidelines originally given in MEPC 64/2/17 are reproduced below, together with a rationale, as the basic outline for this much needed amendment.
1. Testing should be performed using fresh, brackish and marine waters - the present requirement is for testing to be performed with two test waters with a salinity differential of at least 10 PSU. In effect this means that testing in fresh water can be avoided. It is now generally recognized that certain fresh water organisms (specifically copepods) can be more resistant to some treatment processes now commonly applied in BWMS than marine water organisms and therefore the full range of salinities, which are commonly encountered during normal ship trading, should be represented to provide assurance that the 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 on operational effectiveness and environmental acceptability. One BWMS has been withdrawn from the market due to residual toxicity in cold water, which was not detected during the TA testing conducted with temperate water. The possibility of residual toxicity following a chemical treatment in cold waters cannot be discounted and therefore should be checked. The efficacy of operation in both cold and tropical waters should also be verified.
3. Standard test organisms that challenge the treatment process should be specified for use in testing. It is a serious concern that some test facilities may select organisms with either a high natural mortality or low resistance to disturbance for convenience due to the test site location; it is essential that the treatment efficacy is sufficiently challenged to provide a real life operating scenario.
4. Suspended solids in test water should provide a more realistic challenge than at present. Levels of clay silt and the content of total suspended solids (TTS) in the test water should be increased. It has been found in practice that some filtration systems forming an integral part of the BWMS cannot cope with conditions prevalent in a number of areas, particularly where heavily contaminated river estuaries are the port location; as many BWMS inherently rely on the efficiency of the filtration for efficacy of treatment, the filtration phase needs to be realistically challenged under conditions reflecting the worst case real life scenarios that may be encountered.
5. The TA testing should not allow discounting test runs in the full-scale testing that do not meet the D-2 standard, nor should the results of test runs be "averaged". If a system under test fails the treatment efficacy requirements at any time, then it should not be granted TA. This is a root cause of concern as the present allowances provide an opportunity for systems that cannot reliably maintain the D-2 efficacy requirements to gain TA. This should also apply to test runs that fail the efficacy criteria that are discounted due to not meeting the control water validity criteria.
6. TA testing should realistically represent the flow rates the system is approved for. In addition 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 such as 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 described above, it would be unfair to penalize shipowners that in good faith have already purchased or installed type approved BWMS or to require them to remove and replace their existing type approved systems. Vessels that are equipped with G8 based IMO type approved systems by a specified 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 the vessel, whichever is shorter.
It is considered that successful implementation of the Ballast Water Management Convention, 2004, depends upon confidence in the availability of Type approved treatment systems that operate effectively and consistently under all normally encountered operating conditions. This can only be assured by the introduction of an enhanced and consistently applied Type Approval testing regime.
The Committee is invited to consider the problems identified and the proposed solution and to decide as appropriate.
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