Representatives of the leading worldwide Associations of Shipbuilders, Classification Societies and Shipowners met in Busan, Korea for their annual Tripartite meeting hosted by the Korean Register of Shipping and KOSHIPA, the national shipbuilders association.
The meeting was united in expressing its serious concern with the obstacles that all three parties face as the Ballast Water Management Convention moves closer to ratification, eight years after its text was adopted. It was always going to be challenging to fit ballast water treatment equipment to all of the world’s 70,000 ships.
New technologies needed to be explored and developed to treat the volume of water required by ocean going ships as ballast. However the slow pace of ratification by IMO member States has negated the carefully staged implementation program that was a feature of the original Convention. Now that the fixed timeline for implementation has passed without entry into force it means that, as soon as the Ballast Water Management Convention does meet its ratification criteria, thousands of ships will need to be fitted in a very short time.
Whilst strenuous efforts were made by industry, this will put unattainable demands on ship repair facilities, engineering capabilities and on the relatively small number of manufacturers that have developed suitable treatment equipment.
The meeting also expressed serious concerns about Type-Approval requirements. Having now gained some experience with the current requirements, Tripartite participants expressed the clear opinion that many serious shortcomings now need urgent attention. If nothing is done to address this situation, a very large number of treatment equipments costing billions of dollars may be required to be installed on ships with the prior knowledge that these systems may not always work reliably to the demanded biological efficacy.
Not least of the problems is that the certified performance criteria of sophisticated new treatment equipment seems to fall short of testing requirements that may be applied by port state control authorities. Much more work still needs to be done by governments to rectify the current situation.
"We note that IMO decided not to reopen the G8 guidelines but asked BLG 17 to look into certification guidance on the G8 guideline with the aim of providing greater clarity on the operating conditions in which BWTS are expected to operate. Factors to be taken into account include seawater salinity, temperature and sediment load, as well as operation at flow rates significantly lower that the rated treatment flow rate.
IMO also asked member States to submit case studies with quantitative evidence of BWTS failures to improve understanding of the areas of weakness within the approval process.
While this is a step in the right direction, the BWM Convention was designed to assure the ability to meet the required standard by a treatment system installed on an operating vessel. Having requirements that ensure the equipment is fit for purpose is an important element in achieving successful implementation.” said IACS Chairman, Tom Boardley.
The Tripartite meeting agreed that the industry is faced with a challenge both in respect to the timeline and to the lack of maturity of individual treatment systems. One mitigating factor would be to define existing ships as those having been constructed prior to entry into force of the Convention, and that retrofitting of Type Approved ballast water management systems should not be required until the next full 5 year survey, rather than the next intermediate survey.
Speaking at the end of the Tripartite meeting ICS Chairman, Masamichi Morooka said: “It is good that many governments now seem to understand the shipowners’ arguments that it will be very difficult indeed to retrofit tens of thousands of ships within the timeline of two or three years of entry into force, as the Convention text currently requires. IMO has agreed to develop an IMO Assembly Resolution, for adoption in 2013, to smooth the implementation.” “It is vital that we ease the log jam by spreading implementation over five years rather than two or three.” said Dave Iwamoto, Chairman of the Committee for Expertise of Shipbuilding.
The meeting agreed jointly to engage further with governments in order to explain the scale of the challenge faced by the shipbuilding and repair community in order to cope with the vast number of ships that will be required to install the new treatment systems.
The Tripartite went on to discuss the enforcement and compliance issues that will arise as systems are installed and the Convention comes into force. A major challenge is that any compliance action will not be taken against the treatment system manufacturer or test facility, but rather against shipowners who in good faith may have installed a system Type-Approved by a government. Given the current knowledge about apparent shortcomings in the Testing and Approval requirements when compared with the real life operating environment, the G8 Guidelines must be updated. A Type-Approved system, costing between one and five million dollars per ship, should reasonably be expected to robustly operate effectively under all of the normal operating conditions encountered by that ship.
“We are all in full support of the IMO and the intentions behind the Ballast Water Convention. However, given where we are today, we need to re-address both the timeline and the Approval requirements defined in the G8 guidelines in order to ensure that we achieve the real intentions of the Convention without unnecessary costs and unintended compliance issues”
“We need to urgently engage with both the IMO and with individual Governments in order to address these issues” said ICS Chairman Mr Morooka.