Given that September 2019 signalled the final five years of the retrofit programme for ballast water systems for ships constructed prior to September 2017, things were not expected to be as turbulent as they have turned out in the first few months of 2018.
As well as the retrofit bandwagon beginning to roll, the industry is also in the experience building phase decreed by the IMO for examining how the battle against invasive species and the role of ballast treatment is unfolding. For shipowners the worst fear is in having a system that doesn’t perform as promised with consequent delays at ports.
In part the shipping industry has not really helped itself with some owners having installed systems perhaps in anticipation of an earlier coming into force that was later delayed, but who have not actually employed the systems in operation. Some will likely never have even been properly commissioned and crew not trained in their use and maintenance.
That last point will be finally addressed later this year on 28 October when the 2016 G8 guidelines become a mandatory standard for type-approval and no system that has not been tested to them can be fitted. With this comes a new requirement in 2021 for the system to be commissioned and tested immediately after installation. Furthermore, since there will then be a requirement to use the system in operation, any shortcomings should be quickly established.
So early on in the experience building phase, there is as yet very little in the way of reliable data on the operation of systems, but this will increase in time, a point made by Jad Mouawad during the ShipInsight Conference at the end of February. However, since it will be 2024 before all ships in service that are required to be fitted with systems will have done so, Mouawad also believes that it will be 2029 before sufficient data is collected to determine if ballast treatment is really effective and being performed properly.
The issue of type approval was something that was also discussed at the ShipInsight conference raised primarily because of the temporary suspension of the type-approval granted by South Korea to Panasia’s Glo-En Patrol system. Much has been said about the type approval process but one thing that is not fully appreciated is that type-approval by a classification society does not automatically mean that a system is approved for installation on every ship.
The fact that type-approval under the IMO system has no relevance for ships trading to the US and that only systems approved by the US Coast Guard are recognised as meeting the US ballast treatment rules is probably quite well understood. Much less so is the fact that every flag state has the right to recognise or not, type-approvals granted by other flag states.
While most flag states do accept recognition by another state such cannot be taken for granted and before installation an owner would be wise to seek confirmation from flag. Highlighting this was the recent announcement by Alfa Laval that its PureBallast 3.0 system which has been type-approved by European and USCG authorities for some time has only just been granted recognition by the Chinese government.
The Panasia case allegedly turns on the fact that some components of the original tested system have been replaced with alternatives bearing the Panasia name but sourced from third parties other than those used during original type approval process. Panasia is confident that the temporary suspension of type-approval will be overturned and expects this to be done by the end of March.
The case does though raise some interesting questions. Virtually all systems rely on parts sourced from sub-contractors and to maintain type approval, the sae parts must be used for both new systems and for repairs. Switching to an alternative either because the original part is no longer made or because a better or cheaper alternative is available is fraught with problems. Does such an alternative void the type approval, is further testing necessary and how would shipowners know if a component has been substituted?
Another aspect of the ballast water treatment system market that has been raised is how many OEMs can the market sustain once the retrofit programme is near completion. Most observes feel that the field will slim down to just 10 – 15 OEMs in a fairly short period. This week may have seen the start of that process with the co-operation agreement between Optimarin and Sunrui entered into in early March. This is not yet close to a merger but such arrangements do sometimes end in that process.
If the process accelerates the likely survivors will probably eb found among those makers that have both IMO new G8 and US type-approval. There are few enough of them – 26 systems with US approval as at 4 March and less that 20 with IMO approval. It will not be impossible for latecomers to take a market share but time is not on their side.