MEPC 75 is expected to fix ballast water commissioning testing, but shipowners will still be left with real compliance risks

Dimitrios Tsoulos from ballast water management system manufacturer De Nora writes for Splash today ahead of next week’s IMO-convened MEPC 75.

Installing a ballast water management system (BWMS) that is compliant with and certified to the relevant parts of the current patchwork of global ballast water regulation is becoming a prerequisite for global trade. Shipowners have already made significant financial investments in these systems, rightly expecting easy compliance. Yet, too often this is not the case.

The industry always knew that there would be challenges with maintaining operational compliance once systems were installed. However, some have found that these issues can render a system non-compliant from delivery. Changes expected at MEPC 75 will help shipowners, but on their own they will not eliminate ongoing risks.

21% of BWMS installed today may never treat water to the correct standard

It can be easy to understand and rectify issues when you know that you are not complying with regulations. If you are following the correct processes, and have a certified system installed, you are likely to believe that you are not at risk from enforcement – and are not realistically going to be able to rectify issues you know nothing about.

For many, the nightmare scenario comes when an IMO or USCG certified BWMS does not treat water to the legally mandated minimum standard from its installation. The first time a shipowner or crew may find out about this is when they will have to manage the cost of non-compliance. At the moment, this is a real risk for shipowners.

Recent research by SGS found that over one in five BWMS installed on commercial vessels might not be treating water to a compliant standard when they are delivered. In its study, 21% of systems failed their commissioning testing – meaning that these systems had been installed and/or operated incorrectly and that owners would be liable for fines or other enforcement action should the issues not be rectified. Right now, most regulators do not require commissioning testing and these systems may remain non-compliant, representing a compliance risk for the entire lifespan of the system.

MEPC 75 is set to change this, with new commissioning testing standards on the agenda. These will ensure that systems are tested quickly after they are installed, and any faults found and rectified prior to delivery. If adopted, this is expected to come into force next year and will ensure that a BWMS is working as intended when a shipowner receives it. However, it will not ensure that the system remains compliant afterwards.

There are, however, other steps shipowners can take to reduce the risk of a BWMS being installed incorrectly. Through working with naval architects, system integrators and shipowners to ensure that installations are properly designed, suppliers can ensure that the risk of error is as low as possible. At De Nora, we have found that this approach significantly cuts the risk of error and increases efficiency of installation. This may be a vital tool until commissioning testing becomes mandatory, while working collaboratively with suppliers will always represent logistical benefits; it is easier, faster, and less expensive to install a BWMS correctly at the first instance.

Operational compliance risks remain, even if a system is installed correctly

Ensuring that BWMS work as intended when they are installed is only the first step for ensuring operational compliance. Maintaining that standard, and maintaining it consistently and reliably, is the real challenge for the industry.

Many Shipowners – despite their efforts to follow best practice – have consistently reported operational problems, usability and training issues since ballast water regulations came into force. A BWMS that fails to treat ballast water to the appropriate standard for whatever reason leaves a shipowner open to enforcement action and severe penalties.

The biggest drivers of these issues are mechanical failures and human error. Systems that prioritise operability in their design represent clear benefits, providing an added layer of confidence to shipowners, but this alone is not enough.

At De Nora, we have worked incredibly hard to minimise that risk through the high standards we have in design, manufacturing, and aftersales support. This includes through designing self-cleaning electrodes that automatically remove hardness that builds up, utilizing reliable sub-components and by rigorous testing standards that prove efficacy with water conditions, combined with extended crew training courses. But, as with any complex piece of machinery, there is always some risk of mechanical issue – and even the smallest failure can cause water to be treated to a standard below what is required, without providing clear outside indications for crew.

Combatting this requires good data, and good data requires accurate monitoring equipment. Most BWMS use Total Residual Oxidant (TRO) analysers to measure the concentration of disinfectant used in a BWMS. These systems are complex for seafarers to use and require complex maintenance. The alternative is Oxidation Reduction Potential (ORP) testing, which provides an easy to read measurements and validate the disinfection power of water through an in-line, easily installed, and easily calibrated analyser.

However, providing crews with data that is easier to receive and understand is not always enough. We cannot expect crews to be microbiologists, even with the best training. It is thus vital that parts of any system that we cannot expect a crew to easily monitor can be analysed in real time by system experts through integrated condition monitoring. This provides onshore specialists to spot and diagnose problems remotely, as well as advise crews on how to fix them.

The amendments on the commissioning testing standards that MEPC 75 is expected to adopt represent a real positive step, and can solve one of the real hidden risks shipowners face in ballast water management. However, this will not stop shipowners who have followed best practice to the letter from facing a similar risk of accidental operational non-compliance. Shielding from this risk requires careful evaluation of the BWMS available, the ongoing data and monitoring they provide crews, and working closely with suppliers.