The International Maritime Organisation (IMO) adopted the Ballast Water Management (BWM) Convention in 2004 in order to curb the number of invasive species spread by ships’ ballast water. Since that time, 14 sets of guidelines and one mandatory code have been developed to address the complicated issue of validation and compliance testing for ballast water treatment. At present, more than 70 ballast water management systems (BWMS) have received type approval from their respective Administrations following the IMO guidance. Currently, nine BWMS have been approved by the United States following U.S. regulations, which were effective for new vessels on December 1, 2013 (existing vessels’ compliance dates are phased in afterwards). The BWM Convention entered into force on September 8, 2017, and the shipping industry continues its efforts to prepare marine vessels for adherence to it.
2018 challenges & how to overcome them
As governments consider their own ballast water regulations, we see three notable challenges that the industry will face in 2018:
- how to ensure that a suitable sample port and sample probe are installed on vessels,
- how to collect and analyse a representative and appropriately sized ballast water sample, and
- how to gain a clear understanding of regulations.
The IMO BWM Convention, through the G2 Guidelines and the G8 Code, offers guidance on the ballast water sample probe to be installed on ships. Having performed more than 3,000 ballast water tests, we have observed a variety of issues with ballast water sample probes—installed in the wrong location, improperly sized, corroded, inaccessible, unknown to the vessel crew, or even non-existent despite being a requirement according to the installation obligations of the G8 Code. As a member of the International Organisation for Standardisation (ISO) Working Group on Aquatic Nuisance Species, SGS is part of the effort to refine and identify ballast water sample connection that can be standardised for the industry. An international standard for the size, type, and location of the sample port and probe will facilitate optimal testing and, therefore, benefit both the shipowners and the Administrations.
Ballast water testing to the IMO D-2 ballast water performance standard requires a relatively large volume of treated ballast water to be sampled. We have developed the BWS1, a sampling device that helps to meet the sample volume requirement. The BWS1 can sample the large volume of treated ballast water required (up to several cubic meters) with minimal interruption to the ship’s operations. Because the sampling device can be configured in a “closed loop” arrangement, the filtered ballast water can safely be discharged into the ship’s ballast water discharge line after the sampling point, meaning no contribution to the ship’s bilge tanks.
Each year brings a myriad of new regulations, and 2018 seems to follow this trend. The challenge for the industry is how to gain a clear understanding of the new regulations that apply to vessels. The regulations themselves can be an impediment to compliance because they are sometimes difficult to interpret. To support the adequate interpretation and implementation of regulatory frameworks, SGS experts participate in international meetings and working groups on research and policy development.
Looking forward to address future challenges
Starting a decade ago, we observed the growth of maritime environmental regulations. We envisioned a pipeline of future regulations, which would, in turn, drive the need for the maritime industry to have access to internationally recognised laboratory testing that is available along global shipping routes. Being a testing, verification, and certification company with more than 95,000 employees and 2,400 offices globally, SGS Marine Services operates in nearly every major port around the globe. As a response to the increasing demand for support from the industry and governments, we have recently remodeled our leadership footprint to ensure that one of our global leaders is available at any time (Europe, Americas, Asia-Pacific).
To date, our focus has been mainly on ballast water compliance monitoring. With the BWM Convention having entered into force, many things remained unanswered for the shipping industry. With various industry stakeholders, we are engaged with various stakeholders to share our experience and knowledge to address the challenges discussed above and help answer questions such as:
- What is a practical, accurate, and reliable approach to sampling and analysis for ballast water compliance testing?
- How can the industry overcome logistical challenges when carrying out ballast water testing?
- How can a sample of a relatively large volume of treated ballast water be tested and analysed with minimal interruption to ship’s daily operation?
Currently, there are two main national programs conducting sampling to assess compliance to ballast water regulations: in the United States and in Saudi Arabia. In the USA (and in global ports), sampling is conducted to provide support to shipowners aimed primarily at complying with the Environmental Protection Agency (EPA) 2013 Vessel General Permit (VGP). In Saudi Arabia, SGS is approved by the Saudi Governmental Agency for sampling and indicative analysis testing at ports. SGS also works with ship operators, manufacturers, etc. to help ensure compliance. We expect additional governments to follow this trend in the coming years as data are collected during the Experience-Building phase of the BWM Convention.
The future of ballast water regulations
A common misconception about the IMO D-2 performance standard is that the testing against this standard will become mandatory for every port in the world. It is actually the decision of each signatory to the IMO BWM Convention to create their own legislation and to decide how to govern ballast water discharges for their state, with the objective to ensure that the IMO D-2 performance standard is met. For example, Saudi Arabia currently requires indicative testing for ships discharging ballast water at major oil loading terminals but has not required that all ships’ ballast waters are tested using detailed analyses for compliance against the IMO D-2 performance standard. As SGS is a Saudi Arabia-approved body to conduct ballast water testing, SGS is familiar with this regulation scheme.
The United States, while not a party to the IMO BWM Convention, has a nearly identical ballast water discharge standard (the BWM Convention allows for toxigenic Vibrio cholerae to be measured in zooplankton as well as water samples, whereas the U.S. regulations only prescribe concentrations of the bacterium in water samples). The EPA VGP stipulates limits for each organism size class (again, which are nearly identical to those in the IMO D-2 performance standard), but the VGP requires annual monitoring in one (not three) of the size classes: organisms <10 µm in size (indicator and pathogenic bacteria). This is an example of how the national regulatory framework of a non-party to the BWM Convention can be compatible with the IMO D-2 performance standard for ballast water and require monitoring for a portion of the organisms specified in the BWM Convention.
SGS is collaborating with several countries as they start to apply the IMO D-2 performance standard for ballast water to their own regulations and enforcement schemes. We foresee that the most stringent testing and enforcement scheme from a country that sees a large amount of the world’s tonnage will become the default testing routine by which ballast water compliance testing will be carried out globally.
Emerging trends in ballast water testing
Countries and Port State Control inspectors are increasingly interested in developing a testing protocol to enforce a discharge standard for the ballast water discharged into their harbors. In that vein, SGS is working closely with several governments to share experience and expertise on the practicalities of sampling and testing ballast water.
There are many indicative testing technologies that are coming to market—in general, these are the fast, easy-to-use, handheld devices that estimate the density of organisms in ballast water. We expect to see more of them enter the market, but regardless of the device, a representative sample of ballast water must be collected.
Gerd Schneider is the SGS Environment, Health & Safety Marine Business Area Manager for Europe and the Marine Business Global Project Manager Shipping.
He started with the Business Development Program for Marine Services in 2012. Previously, he worked as a Marketing and Sales Manager for SGS Germany since 2005. Gerd Schneider holds a Master in Marine Biology from the University in Kiel, Germany.
Guillaume Drillet is the SGS Environment, Health & Safety Marine Business Area Manager for Asia.
He has many global work experiences and have resided in Asia for almost a decade. Guillaume Drillet has recently been re-elected Chair of the Global TestNet, an organisation supporting the robust testing of solutions to the maritime sector (ballast water and biofouling). As immediate Past-President of the World Aquaculture Society for the Asia Pacific, he also continues to act as an executive member of the board. He holds a Master degree with a major in coastal management (France) and a PhD in marine life sciences from Denmark.
Lisa Drake is the SGS Environment, Health & Safety Marine Business Area Manager for the Americas.
Previously, she was Section Head of Code 6137, Marine Biological Engineering, at the U.S. Naval Research Laboratory (NRL). As a Post-Doctoral Researcher and then a Research Assistant Professor, Lisa Drake conducted research on organisms in ships’ ballast water and in biofouling. After teaching at the U.S. Coast Guard Academy, she joined NRL. There, she led an interdisciplinary team that conducted research in support of the USCG and other federal agencies’ missions. She holds Master and PhD degrees in Oceanography from Old Dominion University in Norfolk, Virginia, USA.
Vladimiro Bonamin, as Vice President and Global Business Development Manager, leads the Global Marine Services group.