There is no question that trade volumes have been badly affected by the coronavirus as China appears to have gone into shutdown beyond the traditional New Year celebrations. Exactly how things pan out regarding quarantine regimes imposed on ships coming from China is anyone’s guess. If the epidemic burns out quickly it will just have been a blip but if it – and the responses to it – continue for much longer things will begin to badly affect shipping in many ways.
Perhaps it is because the 2020 global sulphur cap has been occupying minds so much in recent months that attention over the last two weeks has been focussed on the possible impact of factory closures, lack or workers and more caused by the virus on installing scrubber systems but another problem seems to have been largely overlooked and that must be solved within the next eight months.
After an unexpected - but welcome - two-year delay to the requirement for ships built before 2017 to fit a ballast treatment system ended on 8 September last year, all the ships affected have been required to install a system by the renewal date of their IOPP certificate. Almost certainly most of the ships were scheduled to have that done during a regular drydocking and since China and other Asian countries are where most drydockings take place, the work would have been done there.
If, as has been reported, scrubber installations are being affected by the coronavirus and associated precautions, then the same must be true for regular drydock work and ballast treatment retrofits. Any ship which was planning to drydock but which cannot be accommodated due to congestion or temporary closure will in the first instance be obliged to look for alternatives. Some owners may already be doing this in anticipation of a problem or because they do not want to expose crew and superintendents to risk of exposure to the disease.
If the owner is successful well and good but if not it is a possibility that the flag state might extend the documents for a short period subject to the vessel drydocking before that extension expires. If no drydock capacity can be found then the vessel could be prevented from trading because certificates are out of date. Such a ship could be declared unseaworthy for contractual purposes and will be at risk of falling foul of PSC regulations.
As things stand, not having a scrubber installed will not prevent a ship from operating as it can use a compliant fuel instead. However, not having a ballast system installed if one is required is a different question. Possibly PSC officials will be sympathetic and not detain the vessel but that cannot be taken for granted.
There is a further problem with regard to ballast treatment systems that compounds the problem of delayed installation. Some of the systems due to be retrofitted from now until the 28 of October could be versions that were type-approved under the original 2004 Ballast Convention G8 guidelines. After 28 October it will not be permitted to install a system that has not been type approved to the new 2016 G8 standards contained in MEPC 279(70) but it will be permitted to operate with an older system installed before that date.
There are more than 60 IMO type approved ballast treatment systems but very few of the systems have been approved to the revised G8 standard. Although the new standard is referred to as the 2016 standard, the IMO did allow administrations to continue to issue type-approvals to the old standard until 28 October 2018. The first system to be type approved to the 2016 guidelines was the Alfa Laval PureBallast 3.2 model. Since then only a handful of other systems have been approved with another eight so far listed as being announced at MEPC 75 later this year. That would mean that only around one in four currently type approved systems can be legitimately installed after 28 October this year.
It is very likely that many of the ballast treatment systems due for installation between now and 28 October will have the older type approval and if there is any likelihood of delay after that date, the shipowner concerned should seriously consider their options.