MEPC review group tackles practical questions on ballast treatment

Paul Gunton
Paul Gunton
ShipInsight

31 October 2018


Last week’s Marine Environment Protection Committee (MEPC 73) addressed a number of ballast treatment topics, with a Review Group (RG) tasked with addressing a number of documents submitted to the meeting.

Some addressed specific details relating to practical aspects of operating a ballast water management system (BWMS), including a paper submitted by Japan that raised concerns over practical difficulties in confirming that a ballast water management system (BWMS) complied with the BWM Convention’s Regulation D-2 treatment standard when it was installed.

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In October 2016, MEPC 70 had agreed that systems should be validated during commissioning and a guidance note on how this could be done was circulated at MEPC 72 in April this year with comments invited with a view to finalising it during MEPC 73.

Japan’s paper set out difficulties with this, such as the non-availability of suitable test water at many shipyards. As a result, the testing may not identify that the BWMS is not performing correctly and “Japan is seriously concerned whether administrations can legally conclude validation of compliance at commissioning and mandate any replacement or modification to the type-approved system.”

Its recommendation was that mandatory verification be delayed “until data and experience have been gained and reliable sampling methods and procedures have been established.”

In discussion, their request gained little support, with the International Chamber of Shipping saying that “validation of the efficacy of a system at the time of its commissioning in the form of indicative sampling and analysis of treated local waters is essential” to give confidence that systems are working before leaving the yard.

Others made similar remarks and the committee chair Hideaki Saito ruled that the majority view was that commissioning tests be taken as being indicative, rather than detailed, sampling and this was incorporated into the final version of the guidance, which will be issued as a circular.

Another practical concern raised during discussions in the plenary session came from the Institution of Marine Engineering, Science and Technology (IMarEST), which submitted a paper about contingency measures in the event that a ship’s ballast water management arrangements cannot meet the convention’s discharge standards.

It was responding to an invitation at MEPC 72 to comment on guidance that had been developed on contingency measures and how it should be included in ballast water management plans (BWMPs) and IMarEST listed five proposed contingency management plans that could be added to a BWMP. Its paper was referred to the RG which recommended that each member state “may determine the timing for the incorporation of information on contingency measures in the ballast water management plans of ships flying its flag.”

Perhaps the most significant decision made by the RG was to recommend that MEPC approve a draft circular prepared by MEPC’s Sub-Committee on Pollution Prevention and Response in February (PPR 5), titled Guidance on System Design Limitations of ballast water management systems and their monitoring.

The guidance document explains that the System Design Limitations (SDL) approach “provides a process to identify and provide information to the end user on performance expectations for the system.”

One of its objectives is “to provide transparent oversight of [a] manufacturer’s BWMS performance claims that may go beyond the specific criteria in the code” and administrations will oversee the validation of a manufacturer's claimed SDLs and include them on its type-approval certificate. The guidelines run to nine pages, including four containing detailed tables listing potential SDLs and their related self-monitoring parameters.

• MEPC 73 was invited to consider approving two ballast water management systems that use active substances.

Germany submitted the BWMS made by Italy’s Biomarine, BioBallast 1000, for basic approval and Norway sought final approval for the electrochlorination version of the InTank BWMS made by Envirocleanse of the US.

Both had been reviewed in June by the Ballast Water Working Group of the joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), which provides advice to the UN, and it recommended that both approvals be granted, which the committee agreed.

However, GESAMP’s report made some recommendations about both systems. For the BioBallast 1000, it listed a number of recommendations because of risks that it had identified a number of risks associated with it and recommended that they be addressed before the system is submitted for final approval and imposed some operating restrictions during its further development.

For the InTank system, it identified some potential environmental risks and requested some specific tests to be carried out before it could be granted type-approval by an administration.

GESAMP’s full report (along with all other documents submitted to MEPC 73) is available via the IMODOCS website.

Last week’s Marine Environment Protection Committee (MEPC 73) addressed a number of ballast treatment topics, with a Review Group (RG) tasked with addressing a number of documents submitted to the meeting.

Some addressed specific details relating to practical aspects of operating a ballast water management system (BWMS), including a paper submitted by Japan that raised concerns over practical difficulties in confirming that a ballast water management system (BWMS) complied with the BWM Convention’s Regulation D-2 treatment standard when it was installed.

In October 2016, MEPC 70 had agreed that systems should be validated during commissioning and a guidance note on how this could be done was circulated at MEPC 72 in April this year with comments invited with a view to finalising it during MEPC 73.

Japan’s paper set out difficulties with this, such as the non-availability of suitable test water at many shipyards. As a result, the testing may not identify that the BWMS is not performing correctly and “Japan is seriously concerned whether administrations can legally conclude validation of compliance at commissioning and mandate any replacement or modification to the type-approved system.”

Its recommendation was that mandatory verification be delayed “until data and experience have been gained and reliable sampling methods and procedures have been established.”

In discussion, their request gained little support, with the International Chamber of Shipping saying that “validation of the efficacy of a system at the time of its commissioning in the form of indicative sampling [ShipInsight’s emphasis] and analysis of treated local waters is essential” to give confidence that systems are working before leaving the yard.

Others made similar remarks and the committee chair Hideaki Saito ruled that the majority view was that commissioning tests be taken as being indicative, rather than detailed, sampling and this was incorporated into the final version of the guidance, which will be issued as a circular.

Another practical concern raised during discussions in the plenary session came from the Institution of Marine Engineering, Science and Technology (IMarEST), which submitted a paper about contingency measures in the event that a ship’s ballast water management arrangements cannot meet the convention’s discharge standards.

It was responding to an invitation at MEPC 72 to comment on guidance that had been developed on contingency measures and how it should be included in ballast water management plans (BWMPs) and IMarEST listed five proposed contingency management plans that could be added to a BWMP. Its paper was referred to the RG which recommended that each member state “may determine the timing for the incorporation of information on contingency measures in the ballast water management plans of ships flying its flag.”

Perhaps the most significant decision made by the RG was to recommend that MEPC approve a draft circular prepared by MEPC’s Sub-Committee on Pollution Prevention and Response in February (PPR 5), titled Guidance on System Design Limitations of ballast water management systems and their monitoring.

The guidance document explains that the System Design Limitations (SDL) approach “provides a process to identify and provide information to the end user on performance expectations for the system.”

One of its objectives is “to provide transparent oversight of [a] manufacturer’s BWMS performance claims that may go beyond the specific criteria in the code” and administrations will oversee the validation of a manufacturer's claimed SDLs and include them on its type-approval certificate. The guidelines run to nine pages, including four containing detailed tables listing potential SDLs and their related self-monitoring parameters.

MEPC 73 was invited to consider approving two ballast water management systems that use active substances.

Germany submitted the BWMS made by Italy’s Biomarine, BioBallast 1000, for basic approval and Norway sought final approval for the electrochlorination version of the InTank BWMS made by Envirocleanse of the US.

Both had been reviewed in June by the Ballast Water Working Group of the joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), which provides advice to the UN, and it recommended that both approvals be granted, which the committee agreed.

However, GESAMP’s report made some recommendations about both systems. For the BioBallast 1000, it listed a number of recommendations because of risks that it had identified a number of risks associated with it and recommended that they be addressed before the system is submitted for final approval and imposed some operating restrictions during its further development.

For the InTank system, it identified some potential environmental risks and requested some specific tests to be carried out before it could be granted type-approval by an administration.

GESAMP’s full report (along with all other documents submitted to MEPC 73) is available via the IMODOCS website.