The deadlines are clear but there is a lack of data on D-2 standard installations, raising concerns about enforcement and flag extensions
“One estimate is that there needs to be 300 ballast water treatment systems (BWTS) fitted each week in the run up to the September 2024 D-2 deadline,” said Exponent International senior manager, marine engineering Duncan H Tanner speaking during the Riviera Maritime Media webinar BMWS 2022 and 2024 deadlines: what every operator needs to know, held in January 2022.
With the global world cargo fleet of around 64,000 vessels (according to Clarkson Research Services (CRS), as at 1 June 2022) that is potentially a lot of BWTS. Bearing in mind BWTS cost US$150,000 upwards before installation costs and more than one may be needed depending on the flow rate required to meet the vessel’s cargo-handling speed, and this becomes a huge requirement and logistics supply challenge.
Could the deadline be avoided due to exemptions? Under IMO rules, exemptions include vessels without ballast water, warships, vessels operating in a single water, vessels with sealed ballast tanks, vessels on a single international voyage granted exemption by the country of origin and the country of destination.
Vessels under 400 gt and floating platforms, FSUs and FPSOs must still comply if on an international voyage. Such vessels shall be required to have an approved ballast water management plan and a record book. But a ballast water management certificate is only required if the flag administration has its own national requirements.
Under the US Coast Guard rules, tankers that do not leave the US Exclusive Economic Zone and are 1,600 gross registered tonnes (or 3,000 gt or less) are exempt, but again, this will only apply to a limited number of vessels.
Mr Tanner asked rhetorically: “Could the lack of available /or suitable BWTS be a reason to delay implementation of the D-2 deadline?” “Possibly not was” his own reply, as the major marine equipment manufacturers are well established in the ballast water treatment field.
There is some evidence that the largest manufacturers are able to meet demand. Speaking to Ballast Water Treatment Technology at Posidonia 2022, Alfa Laval head of PureBallast Peter Sahlén noted his company had installed some 5,000 systems. He added that the aim is to provide 10,000 ballast water management systems (BWMS) by 2025.
Mr Sahlén said this target is based on the impending D-2 standard coming into force on 8 September 2024 and the company’s ability to supply a large quantity of BWTS at relatively short notice. “We have never missed a compliance date,” he said.
Supporting the target is Alfa Laval’s new production line for Alfa Laval PureBallast 3 in Qingdao, China. Mr Sahlén noted Asia is already a key market for Alfa Laval PureBallast 3, the third generation of Alfa Laval’s leading ballast water treatment technology.
The majority of PureBallast 3 installations occur at Asian shipyards and with a large orderbook in some sectors – as the wave of ballast water treatment system retrofits begins to subside in 2024 – Asian shipyards will become even more dominant as the focus shifts to newbuildings. This seems to indicate that the large manufacturers of BWTS are geared up to meet demand.
The impending deadline should be creating a rush retrofit installations for BWMS, but that is not the case, said BWMS provider Optimarin’s chief executive Leiv Kallestad at Posidonia 2022. “We are seeing extensions being granted [by flag] all the time,” he said. “We see it here in Greece and other markets.”
He said a six-month Flag extension is pushing the retrofit installation of D-2 standard BWTS back into 2023 and 2024.
However, the acceleration of commissioning is quite remarkable. Mr Kallestad said Optimarin had doubled the number in 2022 of that in 2021, which itself was double that of 2020. But he noted the impact of the lockdown in Shanghai, which has just eased, and the component shortage, especially of computer chips, which has not.
“We are seeing extensions being granted [by flag] all the time”
In this respect, Optimarin points to its ability to leverage a flexible delivery model for key components for its BWTS, which has been vital to overcoming supply chain challenges amid rising orders.
Optimarin has a dual-supplier strategy in place that has enabled it to maintain efficient system deliveries even though supply capacity has been strained, as demand has rebounded after the lifting of pandemic restrictions
On the other side of the deadline demand equation is the number of vessels already fitted with BWTS. This is a difficult figure to derive.
In September 2021, in a special survey commissioned by Ballast Water Treatment Technology, shipping information and trade data specialist VesselsValue showed only 17% of the current fleet has a BWTS installed.
The data shows that 43% of the VLCC fleet by number has been fitted with a BWTS, which means the remaining 475 VLCCs without BWTS had 1,085 days (at the time of writing) to ensure they have a ticket to trade by installing a BWTS.
A key BWTS issue concerns smaller tanker size ranges. Only 36% of the popular MR2 product tanker fleet have BWTS installed, according to VesselsValue. To meet the regulatory deadline, a further 1,089 MR2 product tankers need to have BWTS retrofit installations over the next 1,085 days. There are challenges in BWTS retrofit installations on smaller vessels where space is at a premium, but there are ways to overcome these challenges, such as a BWTS deckhouse, which is offered by several providers.
Only 3% of the 6,105-strong small clean tankers in the live fleet have BWTS installed. But 200 small clean tankers have been fitted with BWTS, which shows it can be done.
At Posidonia 2022, CRS global head of research, Stephen Gordan, gave another estimate that more than 25,000 vessels on the CRS database have been fitted, or are pending fitment, of a BWTS.
At the same event, Optimarin’s chief executive Leiv Kallestad said its sales to the end of May 2022 were about 25% ahead of the same period last year – another indicator of the acceleration in interest in the fitment of BWTS in the run up to the 2024 deadline.
