November’s IMO MEPC 75 addressed the practical constraints industry has faced on BWMS commissioning testing by approving revised guidance on ballast water sampling and analysis. However, confusion surrounds testing versus type-approval
The confusion around ballast water treatment system type-approval and commissioning testing stems from the notion that buying and installing a ballast water treatment system that is type-approved by IMO and/or the US Coast Guard should be a sufficient investment to meet the required regulations.
The difference between type-approval and testing was explained in Riviera’s BWMS commissioning testing: making it work in practice webinar, by SGS regional manager Dr Guillaume Drillet, Golden Bear Research Center scientific program manager Stephen Loiacono, CTI-Maritec global business development manager Michael Haraldsson, and Filtersafe Automatic Screen Filtration head of marine Mark Riggio.
The event was sponsored by silver partner, Cal Maritime Golden Bear Research Centre, and also sponsored by SGS, and Filtersafe.
In a poll to the question: Do you need to commission test your newly installed BWM system before June 2022? Two thirds (66%) replied that you only need commissioning testing of newly installed ballast water treatment systems before June 2022 for certain flags and 27% did not know. The rest (8%) were of the opinion that it was not necessary.
The answer is that from June 2022, all new BWM Convention installations will require a commissioning test, as agreed at MEPC 75. IMO suggested early commissioning testing, which has led to some anomalies – India requires commissioning testing although it has not signed the BWM Convention.
Some classification societies have also developed an approval scheme for service providers. Dr Drillet noted that even the classification societies are confused by IMO standards regarding testing, such as is testing the inlet water mandatory (follow BWM.2/Circ.70) or voluntary? (follow BWM.2/Circ.70, as amended).
Golden Bear Research Center is located at the California State University Maritime Academy (Cal Maritime) and has testing facilities in the tidal waters around Vallejo and on board the training ship Golden Bear. This means, said Mr Loiacono, that the facility has access to saltwater, brackish water and a nearby source of fresh water. In addition to shoreside labs, there is the facility to conduct tests on the 152-m long ship, Golden Bear.
Golden Bear has travelled the world in the capacity of a training ship and Golden Bear Research Center has been able to test in real-life conditions. In 2020, testing has been limited to US waters using a mobile lab, but it is highly flexible. “I have even analysed samples back in my hotel room,” said Mr Loiacono.
Golden Bear is part of Global TestNet, an organisation comprising nearly all the labs and facilities that undertake the testing of ballast water.
Is it important that testing companies have their own laboratories? In a poll, 70% were of the opinion it is important testing companies to have their own laboratories, 19% thought this was not required and 11% were not sure if this was important.
Mr Haraldsson noted that although his company is a relative newcomer to ballast water testing, it has a lot of experience of testing from marine fuel to Inventory of Hazardous Materials. “Last year we conducted tests and surveys on thousands of vessels ahead of compliance with the EU Inventory of Hazardous Materials,” he said.
Picking up on the confusion of why testing is required of ballast water treatment systems that have already been type-approved, Mr Haraldsson pointed out that a newly installed retrofit needs to be tested to eliminate the possibility of failure from other elements.
“There may be dirty ballast water tanks or leaky valves,” he said. “Also operators do not understand how strict the regulations are.” One advantage that CTI-Maritec has is that although it does not have a global network, it is based in China, where many vessels are built and retrofit installations are popular. This has been especially useful during the pandemic – its technicians are already in place in China and do not face the same travel restrictions.
Mr Haraldsson concluded that owners and operators “Don’t see compliance testing as a punishment, see it as an insurance policy,” he said. “Testing: no worries”.
How extensive has been the use of Independent Laboratories? In a poll, attendees were asked: Have you used an Independent Lab to test your ballast water system? 56% replied that they had used an Independent Laboratory, 25% had not used one, and 19% were not sure.
Mr Riggio remarked that as an equipment provider, Filtersafe has a different view on ballast water compliance. “As systems are installed in ships, we are meeting new and unique challenges,” said Mr Riggio, “and these challenges are stressing systems in different ways.”
The filter has a huge impact on the functionality of the ballast water treatment system. It is in the real world that problems occur and Mr Riggio noted that these fall into specific areas: clogging, poor back pressure; water hammer during filling; and dirty ballast lines.
A big issue that can result in one or more of the above negative aspects is the quality of the water in the shipyard where the retrofit installation is taking place. “Often, these are sheltered harbours with a lot of silt and heavy sediments,” he said. “Ships will often be closer to the bottom (of the harbour) than they would be in operation.”
He noted that a vessel leaving drydock is in a rare state – there is a very small amount of ballast on board and the vessel is floating higher than in normal conditions. “This can cause significant hydrodynamic affects. Both in taking in the water and being able to overcome any head loss,” he said. “It is important to have your vessel in the condition to be able to pass the test.”
It is these factors, outside the designers control, that contribute to the failure of commissioning testing.
Left to right: CTI-Maritec global business development manager Michael Haraldsson, Golden Bear Research Center scientific program manager Stephen Loiacono, Filtersafe Automatic Screen Filtration head of marine Mark Riggio, and SGS regional manager Dr Guillaume Drillet