IMO MEPC 70 meeting concluded last month with significant decisions regarding the BWM treaty which will enter into force on September 8th, 2017, as it adopted revised G8 Guidelines. Konstantinos Stampedakis, Managing Director, ERMA FIRST explains the differences among the existing G8 Guidelines, the revised as adopted by MEPC 70 and the ETV/ USCG Final Rule to assist ship operators clarify interpretation issues.
Since the ratification of the Ballast Water Management Convention from Finland, September 8th, 2016, a lot of activity related to ballast water has been observed. Among others, the revision of the G8 Guidelines and the B-3 regulation were two subjects that have become the focal point of many discussions, articles and documents.
The G8 Guidelines, describes the methodology a Ballast Water Management System should follow to obtain its statutory Type Approval either from an Administration or an accredited Recognized Organization. Since 2014, at MEPC67, IMO has identified some gray areas on the existing methodology (MEPC 174(58)), thus, it has started its review via a working group. Two years of extensive studies and debates have been concluded on Oct. 21st at the end of the inter-sessional working group. The outcome of this was the adoption of the revised G8 Guidelines from MEPC 70.
The revised guidelines will be applied on BWTS, which start their Type Approval process from Oct. 28th 2018 onwards. With regards to the installation, BWTS which will be installed (i.e. delivered on board a vessel) prior to Oct. 28th 2020, should be certified either with the existing G8 or the revised. The latter allows early movers to use their installed systems as long as they maintain and operate them properly. Installations from Oct. 28th 2020 onwards should be with BWTS certified with the revised guidelines.
ERMA FIRST S.A is of the opinion that the old G8 was a solid approval reference as far as a guideline goes. As for all guidelines, it is the interpretation of the recommendations that determine their strength.
Trying to highlight the differences between the existing, revised G8 and the ETV, we have developed the below comparison table:
|Revised G8 Guideline||Existing G8 Guidelines||ETV/ USCG Final Rule||Harmonization Level|
Testing is to be carried out by an independent facility accepted by the Administration. Facilities should implement a rigorous quality control/quality assurance program that addresses appropriate challenge water, sample collection, ample analysis and method detection limits
|Any laboratories holding the required certificates (ISO) for performing biological and microbiological analysis for the D2 standards could perform such tests. However, a specific Quality Assurance Management Plan (QAMP) had to be approved from the certifying administration prior each testing.||As per Revised G8. Independed Laboratories (ILs) have undertaken this role.||High|
|Testing at temperatures ranging from 0°C to 40°C
The new guideline requires BWMS performance should be checked in the above given temperature range. BWMS unable to demonstrate successful performance across these salinity and/or temperature ranges will be assigned Limiting Operating Conditions on the Type Approval Certificate
|Such temperature range was not specified.||No specific temperature range is mentioned. Instead Testing must include temperate, semi-tropical, or tropical locations and for all BWMS, temperature must be measured either continuously during or at the beginning, middle, and end of the period of ballast water uptake, as appropriate and practicable for the parameters to be measured.
Land-based testing is to consist of five consecutive valid test cycles that show D-2 compliance. Shipboard testing is to reflect actual ballast operations and consist of at least three consecutive valid tests, which show D-2 compliance spanning a period of not less than six months.
|In this guideline no such requirement existed. For Land Based the vendor had to reach five successful tests in two water salinities irrespectively the total tests he had to perform.
For shipboard testing the vendor had to achieve three consecutive successful tests at period not less than 6 months.
|For Land Based at least five consecutive, valid, and successful replicate test cycles per water salinity.
For ship board test 5 consecutive test have be performed in period not less than 6 months.
The number of required ship board tests for USCG is double than revised G8.
|System Design Limitations
An important development is the concept of documenting the critical parameters known as System Design Limitations (SDL). These parameters impact the operation of BWMS (e.g., minimum and maximum flow rates, time between ballast uptake and discharge) and design limits (e.g., water quality expressed by oxidant demand and ultraviolet transmittance).
SDLs are to be identified by the manufacturer, validated during testing and indicated on the Type Approval Certificate.
|No such requirement was existed in the G8 guidelines. However, at MEPC63, IMO Ballast Water Group of experts had made a recommendation to the approving administrations to include such data in the Type Approval certificate.||As per G8. All critical/ limitation operation parameters should be described in the Type Approval Certificate. Ie. The approval certificate will list conditions of approval applicable to the BWMS.
|Challenge level of Total Suspended Solids (TSS)
The revised G8 guideline requires more onerous examination of the effects of TSS on the BWMS’s ability to perform in the waters found in worldwide shipping.
|Existing G8 were requiring up to 50 mg/L TSS. This is considered a normal value for harbour waters but no much attention was given on the type of these particles. TSS in sea water are consisted of Particular Organic Mater (POM) and Mineral Matter (MM). i.e TSS= POM+MM. However, different ratio of those two create different challenges on the BWTS.||This has been thoroughly covered on ETV protocol.||High|
|Definition of viability
The revised G8 guideline has recognized the organisms inactivation concept (killing) but still includes the reproduction ability of the organism as a benchmark.
|The existing G8 guidelines definition of viability does not include the inactivation (render harmless) of the organism.||Only the inactivation (killing) is considered as a benchmark.||Low|
The revised G8 guideline has required that bypass activation should be recorded in BWMS control and monitoring equipment.
|The same was mentioned in the existing guideline.||The same applies on USCG Final Rule.||High|
The revised G8 guidelines identified approval of scale units is very important and due to time constraints further technical discussions were forwarded to PPR4.
|Few information about scaling was mentioned in the existing guideline.||Scaling is thoroughly covered in USCG Final Rule.||High|
BWMS are to be provided with a system that monitors, records and stores sufficient data/parameters to verify correct operation for the past 24 months. Alerts are to indicate when the system is shutdown or when an operational parameter exceeds the approved specification.
|Few information about self- monitoring was mentioned in the existing guideline.||Self- monitoring is thoroughly covered in USCG Final Rule.||High|
The revised G8 guidelines refer to test requirements of IACS UR_E10
|Existing G8 Environmental tests were requiring less testing than the revised guidelines. However, BWTS with Class Type Approvals had to follow the IACS UR_E10. Thus most of the BWTS in the market fulfil this requirement.||USCG Final Rule Component Environmental Testing requires the same testing as per IACS UR_E10 with the only difference on the vibration duration. IACS UR_E10 requires 120 min but USCG Final Rule 240 min.||High|
|Installation Requirements following type approval
The revised G8 guideline specifies the installation requirements primarily for the bypass and its function on board ship.
|No such requirement was mentioned in existing guideline. However, this was covered by classes installation guidelines and the requirements of the International Ballast Water Management Certificate.||Such requirement is covered by USCG Final Rule.||High|
|Installation Survey & Commissioning Procedures
The revised G8 guideline has identified this requirement as post type approval. The responsibility in verifying the proper operation of BWMS following installation and commissioning lies with the flag Administration of the ship. This includes the performance check following commissioning.
|No such requirement was mentioned in existing guideline. However, this was covered by classes installation guidelines and the requirements of the International Ballast Water Management Convention Certificate.||Such requirement is covered by USCG Final Rule.||High|
Studying the above table, we can conclude that the new G8 Guideline is more prescriptive with respect to details of the control and monitoring system, test reporting, test validation and independence. Therefore, the liberation of misinterpretation by the administration is reduced. And this was the only, but important issue, in the existing guidelines.
Another important aspect of the revised guidelines is their harmonization with the USCG guidelines serving the same scope (ETV protocol). The inclusion in the revised guidelines of fresh water testing, or the presentation of the BWTS operation limitation in the Type Approval are few examples of such harmonization. Having said that and considering ERMA FIRST’s completion of USCG testing, we are ready to apply for a new G8 Type Approval when the administrations will be ready for this. The same applies to all BWTS treatment vendors which have or will finalise their USCG testing.
Written by Konstantinos Stampedakis
Chemical and Process Eng. MSc / Managing Director, ERMA FIRST ESK Engineering Solutions S.A
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.
About Konstantinos Stampedakis
Konstantinos is Chemical and Process Engineer, graduate of the University of Surrey. Having completed his post-graduate studies (Master in Science in Water and Environmental Engineering) and having acquired further academic experiences as a temporary academic assistant at the university, he began his career in Thames Water Ltd, in the sector of waste and potable water management. Returning to Greece, he joined ENVIRONMENTAL PROTECTION ENGINEERING S.A. as the Director of Research, Development and Engineering Department.
In 2009, Konstantinos co-founded ERMA FIRST S.A. and he currently holds the position of the Managing Director.
One of his great achievements is the development of a Ballast Water Treatment System which makes use of active substances. The main aim of the project has been to research and develop methodologies and technologies for preventing the introduction of nonindigenous species through ships’ ballast water.
Some of the most important moments in his career were when he was on- site manager on the United Nations Development Program for the Oil Spill Cleanup of three sites between Jadra and Ras Al Saadiyat in Lebanon and on- site manager for the spill response caused from the cruise vessel Sea Diamond wreck.