IMarEst Ballast Water Technology Conference

London Feb 23 2012 Chris Wiley Chair IMO Ballast Water Groups

International Maritime Organization

The common sense and experience of seafarers coupled with technological knowledge, scientific research and political agendas of member states and observers

IMO Process for Ballast Water

Marine Environmental Protection Committee Ballast Review Group Bulk, Liquid Gas Subcommittee Ballast Water Working Group Flag State Implementation Sub Committee input into Port State Control Working Group Input from other Committees as appropriate Marine Safety Committee, Legal etc.

Ballast Water Convention 2004

International solution for an international problem Biological efficacy, environmental impact and ship safety are all considered Consistency between jurisdictions and definitive timelines Biological discharge standards are as low as is currently feasible and verifiable Applies to all ships unless specifically exempted

BW Convention
33 Countries / 26.44% of Tonnage Requirement 30 Counties / 35% Tonnage Convention comes into force one year after conditions met. Retroactive implementation Need to ensure sufficient guidance in place prior to implementation Working Group

Implementation of BWM Convention dependant upon:

Sufficient approved BW Technologies available to the market in line with required implementation dates for all ships sizes Sufficient Capacity to manufacture (and install) the technologies An economic environment where ship owners have the capital to install BWMS (and still have a return on their investment) An enforcement regime that is fair and consistent word wide A mechanism for port states to protect their environment Resolution of uncertainty for ship owners to install BWMS and Administrations to ratify

BWMS Approval Process

Procedure for Approval of BWM systems that make use of Active Substances (G9)
GESAMP (Basic and Final Approval at IMO

Guidelines for approval of Ballast Water Management Systems (G8)

Land Based Testing, Shipboard Testing

Guidelines for Type testing

Flag States, Classification Societies

Guidelines for Sampling (G2)

Sampling and Analysis Protocols

Active Substances (G9)

Many BWMS use some sort of active substance chlorine, ozone etc Reviewed by GESAMP world experts on toxicology Dossier with many requirements by-products produced, method of applying chemical in process, neutralization Decision that BWMS that use Ultra Violet do not have to go through G9 % of dossier confidential

An inter-agency advisory body of the United Nations

FAO, IAEA, IMO, UNDOALOS, UNEP, UNESCO-IOC, UNIDO and WMO

Land Based Testing of BWMS

Land based testing Specific test facilities word wide Test protocol set out by G8 high level Experience has indicated issues with Protocol Consistency with Test Facilities QA / QC Requirement to test only 2 of 3 salinities Alternate protocols - ETV

Shipboard Testing of BWMS under G8

Issues Ability to find sufficient organisms under real world conditions Installation of sampling ports onboard Logistics of getting sufficient volume to sample Logistics of working within commercial reality of most ships

Guidance for Uniform Implementation

Guidelines for sediments reception facilities (G1) Guidelines for Ballast Water Sampling (G2) Sampling & Analysis protocol Guidelines for ballast water management equivalent compliance(G3) Guidelines for BW Management and Development of BW Management Plans (G4) Guidelines for ballast water reception facilities (G5) Guidelines for Ballast Water Exchange (G6) Guidelines for Risk Assessment under Regulation A-4 (G 7) Guidelines for approval of Ballast Water Management Systems (G8) Procedure for Approval of BWM systems that make use of Active Substances (G9) Guidelines for approval and oversight of prototype BWM technology programs (G10) Guidelines for Ballast Water Exchange Design and Construction Standards (G11) Guidelines for sediment control on ships (G12) Guidelines for additional measures including emergency situations (G13) Guidelines on designation of areas for ballast water exchange (G14) Guidelines for Ballast Water Exchange in the Antarctic Treaty area Guidelines for Scaling Guidelines for Type testing Guidelines for Use of Basic Approval Guidelines for Other Methods

Guidance
High Level To assist in providing uniform application No other Convention has such a large suite of Guidance put in place in such a short time frame In some cases the Guidance was in place prior to the actual BW Technology Is not intended to provide prescriptive and specific detailed requirements Certain Guidance needs to be updated now that experience in place. A review process is included in D-5

Type Testing
Traditional way for shipboard machinery to be tested and certified by Flag State in order to be safely used aboard vessels Some administration have embraced Others have delegated to Classification Societies In case of BWMS, not typical of traditional type testing - biology Certificate to reflect testing carried out e.g. salinity Type testing not equivalent to sampling for compliance

Are there sufficient BW technologies available?

Lloyds Review http://www.lr.org/bwm 23 Type approved systems currently 60 + systems in the market at various stages of approval GESAMP approvals MEPC Experience in real world being reported Concerns with large vessels, high flow, submersibles Cold Water, Fresh Water MEPC Review Group

Sufficient Capacity ?
Manufacturing Actual numbers required per year MEPC 61/2/17 Huge numbers in certain years Lead time new builds / retrofits Sourcing Installation Facilities Dock capacity Ability to fit along side or underway

Current Economic Reality

Banking Crisis Word wide 2008 Recession Credit less available Shipyards fulfilling orders that are laid up on delivery Cash Flow / lower freight rates Higher capital requirements on new builds from Banks Crisis in Greece Uncertainty in Europe Contraction of economies

Inspection Ships for Compliance Article 9 of BWM Convention

Valid Certificate aboard Inspection of BW Record Book and /or Sampling of ships BW in accordance with Guidance developed by Organization Condition of ship / equipment does not correspond with certificate Crew not familiar with essential BW Procedures or have not implemented Stop the discharge

Article 12 Undue Delay

All possible efforts shall be made to avoid a ship being unduly detained or delayed Article 7.2 Extra Survey, Additional Measures Article 8 Violations of Convention shall be prohibited and sanctions established proceedings ASAP Article 9 Inspection of ships if sampled, time required to ANALYZE, not to be used as basis for undue delay Article 10 Detection of Violations control of Ships warn, detain or exclude

Port State Control

Initial inspection Documentation IBWM Certificate BWMP / Approved by Administration Type test certificate / appropriate environment Ballast Water Record Book Electronic records from BWMS D-1 Sampling / Salinity D-2 Monitoring / Indicative D-2 Detailed FSI Paris MOU

Sampling Issues
Guideline (G2) discussed prior to any real experience in sampling for compliance Sampling for certification vs. sampling for compliance What exactly is a representative sample of whole discharge Logistic and operational realities of obtaining a representative sample volume required sampling port that allows representative sampling BW not homogeneous Experience and training of those taking sample Technologies to take sample Filtration, Electronics etc Protocols

Analysis
After representative sample taken under Article 9 need to analyze Indicative Analysis
monitoring of indicative process of BWMS chlorine level, UV dose etc Measurement of contents of actual sample Gross Excedance Can tell whether ship not in compliance

Detailed Analysis
Counting of actual organisms Use of certified laboratories Standardized methodologies ISO? Can tell whether ship is in compliance

Port State Control Issues

BW Convention allows sampling before clear grounds established (Article 9) Not the same order as typical PSC before clear grounds Survey Requirements Regulation E What is required of PSC Officer with respect to sampling / indicative analysis Opportunities for abuse? Why cannot simply accept type approval? More stringent requirements regionally

Resolution of uncertainty
Some level of uncertainty possible in virtually all steps as wording literally in place before many of the technologies / protocols actually invented Current concerns mostly centred on sampling / analysis used for compliance Sampling and Analysis Protocols at BLG gave snapshot of current state of the art. Next Step pair representative sampling methodology with indicative / detailed analysis methodology Standardize

Ability of Port States to protect their environment from discharge of AIS from ships
Regulation C-1 Additional measures Reflects the reality of differing experience of threat of AIS from ships ballast water discharge Article 6 Science and technical research and monitoring Reflects the risks

Remaining Hurdles
Ensuring that BWMS will be available for use in all environmental conditions at discharge ports. Acceptance of other methods providing the same level of protection to the environment Continuing AIS introductions attributed to ships not fitted with BWMS Possibility of unilateral action by Port States if BWM Convention not ratified in near future Already in place under D-1 requirements in many countries