Now that more ballast water management systems (BWMS) are in widespread use, it is becoming apparent subtle and sometimes radical changes are needed to type-approved BWMS to ensure optimal operation, but rigid rules are a hindrance, says Simplify Ballast founder Mark Riggio
The evolution of ballast water treatment is continuing and the speed is beginning to eclipse the speed of regulation. Although regulation has driven the ballast water market up until now, 2023 is likely to see a subtle shift where regulation, and even the lack of regulatory guidance, is beginning to create risks of non-compliance for vessel operators.
During MEPC 79 (12-16 December 2022), nine separate papers were submitted to deal with confusion regarding the implementation of the Ballast Water Management Convention.
Four of these papers dealt exclusively with the Ballast Water Record Book.
While the results of these discussions are not known at the time this paper is written, just the simple fact that four separate papers have been issued on a document intended to mirror the 40-year-old Oil Record Book is a sign the simplest actions – recording a ballast event – is still challenging for crews to do in the real world.
IMO’s experience building phase continues, but the data gathering phase ended in 2022 with the last official reporting of data occurring at MEPC 78. This data shows that although systems are generally functional, ships still often do not pass compliance testing, usually due to contamination of organisms in the largest (greater than 50 micron) size class.
All of these points highlight the critical importance of improving the operation of ballast water treatment systems on board. Using a system at or near the boundaries of the system design limitations, particularly in areas or at times where a system can become overwhelmed, creates significant burdens and risks to the vessel when trying to comply with the regulations.
Whether it is a bypass event that causes contamination of the vessel’s piping systems, tanks and discharge sample port or whether it is the multiple, complex, sequential entries in the ballast water record book, each step in managing ballast water is fraught with the potential for mistakes or interpretations for what is acceptable with ship’s crews constantly forced to operate with an unacceptable level of ambiguity.
Ships need clear guidance and assistance with how to expand the operating profiles of their treatment systems. Systems not installed in an optimal way, systems not fitted with appropriate interlocks, safeties or automation, and systems not intended for the operational areas the vessel plans to trade in create more areas of confusion and mistakes.
The boundaries where treatment systems are expected to operate are defined during type-approval testing. This testing is done in an optimal environment, with systems installed on a ship under the careful guidance of the manufacturer. These tests are proof the treatment systems work when installed correctly, operated according to their instructions, and used in areas where it is certified.
During the procurement process, different compromises are made to reduce the overall cost of a system’s installation. These compromises do not show up until after the system is installed and suddenly it becomes apparent a system does not meet the requirements of the vessels on which it has been fitted.
Ballast water conversations going forward will be focused primarily on improving and expanding the operational profiles of installed systems. Whether through incremental improvements, innovations, updates to process design and control, and improved system automation, systems need to have the flexibility to improve the breadth of water they can treat. Unfortunately, the current regulatory scheme does not support this.
Due to the rigid nature of type-approvals, systems are frozen in time when they achieve their approvals. As systems gain experience on board and find new ways to improve, they face a huge financial and regulatory hurdle to implementing these changes.
Even simple operating instructions and graphical improvements to the operating panels designed to improve and streamline operations can cause a system to undergo a complete type-approval review.
Ship operators deserve the best systems the industry can provide. They deserve them to be installed in the best way and they deserve to be able to implement improvements as they come out to help expand the water their system is able to treat.
The regulatory process needs to start to catch up with the pace of technology to make sure that systems are not struggling with how to comply.
