Ballast water convention remains a major cause for concern
(Dec 14 2012)
Representatives of the leading worldwide associations of shipbuilders, class
societies and shipowners have expressed serious concerns about the obstacles
faced by the impending Ballast Water Management Convention.
The group met in Busan, South Korea for its annual Tripartite meeting hosted by
the Korean Register of Shipping and KOSHIPA, the national shipbuilders
association.
They said that 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 programme 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 BWM Convention does meet its ratification
criteria, thousands of ships will need to be fitted in a very short time period.
While strenuous efforts were made by industry, this will put unattainable
demands on shiprepair facilities, engineering capabilities and on the
relatively small number of manufacturers that have developed suitable treatment
equipment, the group said.
The meeting also expressed serious concerns about type approval requirements.
Having 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 has also asked its members 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 five year survey, rather than the next intermediate survey.
Speaking at the end of the 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 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.
As for 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 $1-5
mill 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," concluded Morooka.
Fm TANKEROperator magazine =========
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