Type approval process for ballast water treatment systems
The continued delay in implementing the schedule is wholly a result of the convention not having been ratified by sufficient states rather than insufficient treatment systems having become commercially available.
To date, more than 50 ballast water treatment systems have been given final type approval and many more are in the process of testing. However, the delay has been useful in that certain problems have been identified with some approved systems and technologies and that has lead to calls for a tightening up of the whole approval process which has now been set in motion.
It has been a long and frustrating wait for several of whom have given up waiting and retired from the fray. But even though most have thought that the coming into force of the convention would lead to a buying spree that would keep system makers, drydocks and engineering companies busy for some years to come, the likelihood of that happening is receding.
To become type approved, systems have to undergo a series of shore based tests followed by a further testing period onboard a ship under normal operational conditions. In addition, systems that use an ‘active substance’ as part of the treatment process must also have that substance approved by the IMO.
Approving an active substance is a two-step process with Basic Approval followed by Final Approval. The Basic Approval is based upon data supplied by the manufacturer to the IMO following laboratory testing. Final Approval requires the substance to be tested under full-scale operation on the system test bed.
What constitutes an active substance has been the subject of much debate. In the early days of system development, some systems that made use of Ultra Violet (UV) irradiation of the ballast water were considered to be making use of an active substance as the UV process produces short-lived hydroxyl radicals in the ballast water. Later, following some challenges to individual governments, this was changed. As a result, some systems employing UV have active substance approval and others do not.
Full details of the procedures for testing and performance standards are laid out in IMO guidelines to the Convention. The process for systems not making use of an active substance is set out in G8 and for those that do, the relevant process is G9. These terms will frequently be met when looking through system literature from manufacturers.
It is fair to say that some systems that have been given type approval have experienced some difficulties when installed on ships operating in different regions or circumstances to those prevailing when the system underwent onboard testing. This has been recognised at the IMO and work is underway to improve the guidelines for testing set out in the IMO circular BWM.2/Circ.28. The IMO has also determined that the type approval certificates for systems should include more information on operational limitations. In addition, the IMO has asked for case studies where treatment systems are not working properly and the fault is attributable to the technology employed rather than poor installation or incorrect usage.
At MEPC 67 in September 2014, the IMO developed a plan of action to conduct a comprehensive review of G8 taking into consideration the associated guidance documents (MEPC.228(65), BWM.2/Circ.28, BWM.2/Circ.33, and BWM.2/Circ.43). This review of G8 is now in progress and is almost finalised.
The review is addressing differences in type approval protocols of member States, issues raised by, and additional data that may become available from, the Study on Implementing D2, and industry concerns outlined in the annex to MEPC 67/2/6 (ICS et al.). Those concerns include testing using fresh, brackish and marine waters with a temperature range from cold to tropical warm; testing water with organisms that challenge the treatment process (eg. low natural mortality or high resistance to disturbance) and with suspended solids; including results of failed tests in the averaged result; and using realistic flow rates.
MEPC67 also accepted the principle of grandfathering by agreeing that ships fitted with existing G8 approved systems should not be penalised.
A revised version of the G8 guideline was presented in October 2016 at MEPC 70 and the same meeting also agreed to continue revision. While there is some truth in the view that constant revision of the guidelines is to take into account experience of operation and advancing technology, many would point out that the degree of freedom previously allowed in the testing and approval process has seriously undermined confidence.
Since changes have been introduced into the type approval process, the status of systems approved under earlier rules has been questioned. At MEPC 70, the IMO recommended application of the revised Guidelines as soon as possible and agreed that BWMS installed on ships on or after 28 October 2020 should be approved taking into account the revised guidelines. Systems installed prior to that date could be approved using the existing guidelines or the revised guidelines.
Under the new 2016 version of the Guidelines, the type approval process contains detailed requirements for land-based, shipboard, and other tests set out in an annex. A ballast water management system which in every respect fulfils the requirements of the Guidelines may be approved by flag states for fitting on board ships. The approval should take the form of a Type Approval Certificate for BWMS, specifying the main particulars of the system and any limiting operating conditions.
It was also agreed that the approval process should be made mandatory and the MEPC instructed the IMO Secretariat to prepare the Code for approval of ballast water management systems as well as draft amendments to the BWM Convention making the Code mandatory, for circulation with a view to adoption following entry into force of the Convention.
What has not been resolved is how port states will police the system. It is all very well for a vessel to have a type-approved system on board that is operated in full accord with the maker’s instructions but that may not stop PSC authorities initiating action against any ship that does meet the D2 discharge standard. Whether or not that will be a major problem will only be determined after the convention comes into effect.
The latest G8 is more prescriptive with respect to some details and requires harmonisation between administrations to assure that administrations are validating limitations the same way. Systems that can be scaled to suit different ship types must now be tested using the system size considered by the maker to be the most vulnerable to scaling. The control and monitoring system has received more focus. Documentation requirements now include detailed functional description and a software change handling log. The changes also mean that systems presented for testing should be commercially ready systems and not prototypes. Testing must also be carried out over a wider range of environmental parameters and the potential for regrowth needs to be determined.
Some have said that the new guidelines will mean that IMO type approval testing is now more rigorous than the USCG process. In addition the shipboard testing requirements and tank holding times may be difficult to achieve during normal operation of the ship as regard both environmental parameters and voyage length.
A new requirement of the guideline that will apply to many systems is that management of hazardous gases produced by or used in treatment systems now needs to be included. This covers monitoring that ensures redundancy and independent shutdown following a failure. The environmental testing to be conducted on the treatment systems electric and electronic components shall now follow testing defined by IACS UR E10, Rev.6, October 2014 instead of an IMO G8 unique test programme.
###Main G8 Guideline changes adopted at MEPC 70
- `Testing Facilities – Testing is to be carried out by an independent facility accepted by the Administration. Facilities should implement a rigorous quality control/quality assurance program that addresses appropriate challenge water, sample collection, sample analysis and method detection limits.`
- `Salinity and Temperature – Testing is to be carried out across a full range of salinities (fresh, brackish and marine) and through a temperature range of 0°C to 40°C (2°C to 40°C for fresh waters).systems unable to demonstrate successful performance across these salinity and/or temperature ranges will be assigned Limiting Operating Conditions on the Type Approval Certificate.`
- `Consecutive Testing – Land-based testing is to consist of five consecutive valid test cycles that show D-2 compliance. Shipboard testing is to reflect actual ballast operations and consist of at least three consecutive valid tests, which show D-2 compliance spanning a period of not less than six months.`
- `System Design Limitations - An important development is the concept of documenting the critical parameters known as System Design Limitations (SDL). These parameters impact the operation of systems (e.g., minimum and maximum flow rates, time between ballast uptake and discharge) and design limits (e.g., water quality expressed by oxidant demand and ultraviolet transmittance).
SDLs are to be identified by the manufacturer, validated during testing and indicated on the Type Approval Certificate.`
- `Bypass Arrangements – systems bypass or override arrangements, provided to protect the safety of the ship and personnel in the event of an emergency, should activate an alarm and be recorded by the control equipment.`
- `Self-monitoring - systems are to be provided with a system that monitors, records and stores sufficient data/parameters to verify correct operation for the past 24 months. Alerts are to indicate when the system is shutdown or when an operational parameter exceeds the approved specification.`
- `Scaling Effects - Mathematical modelling and/or calculations should demonstrate that any scaling of the systems will not affect the functioning and effectiveness on board the ship. Shipboard testing is intended to further validate the scaling and should, preferably, be carried out at the upper limit of the rated capacity of the systems.`
- `Report of Test Results – Reports for land-based and shipboard testing, submitted to the Administration, should include information regarding the test design, methods of analysis and the results of these analyses for each test cycle, including invalid test cycles, system maintenance logs and any observed effects of the system on the ballast system. Shipboard test reports should include information on the total and continuous operating time of the system.`
-` Installation Survey and Commissioning Procedures - Prior to issuance of the International Ballast Water Management Certificate, installation of the system is to be carried out in accordance with the technical installation specification, relevant Type Approval Certificate, and the manufacturer's equipment specification. The workmanship of the installed system, including completion of all agreed commissioning procedures is to be satisfactorily demonstrated.`