Ballast water testing and compliance: match fit and fit-for-purpose?
4 November 2020
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The webinar was part of Riviera’s week of ballast water-themed webinars, and it was held with premier partner Maritec and sponsored by Alfa Laval.
Part of the global testing company CTI, Maritec Pte Ltd global business development manager (ballast water testing), Michael Haraldsson gave an overview of the current testing and monitoring situation. He noted the first question is to ask is why ballast water testing is being discussed at all.
After all, he said, a ballast water treatment system installed into a newbuilding or retrofit installation has to be US Coast Guard type-approved and / or type-approved by IMO to its latest standard? The answer lies in the belief among owners and operators that a ballast water treatment system is regarded as a fit-and-forget system.
"A lot of owners do not understand how strict the regulations can be,” Mr Haraldsson cautioned.
“We believe it is very important to have experienced technicians onboard to come on a vessel, take the samples and if the test fails, to take the samples to our labs,” he said.
CTI has been accepted for commissioning testing by DNV GL, and ABS and Lloyd’s Register (LR) are expected to approve Maritec later in the year.
Maritec Pte has service labs around the world that undertake testing and has a presence in or close to major ports, meaning it can quickly test and offer remedies in situations where a ballast water treatment is anticipated to fail PSC or has actually failed.
During commissioning, a ballast water treatment system is tested for efficiency of the installation. Once at sea, an installed ballast water treatment system could fail a Port State Control (PSC) inspection for a variety of reasons. Having regular testing would alert the operator to failure to comply or a likelihood of needing to reduce flow rate / capacity to comply.
Ballast water system provider Alfa Laval’s head of global sales, PureBallast, Viktor Friberg noted that there were several types of ballast water testing taking place or proposed. There is testing for type-approval by the US Coast Guard and IMO, both of which use different test methods.
There is also VGP water sampling and potential indicative testing under commissioning testing and Port State Control (PSC) discharge compliance. “Indicative testing is only an indication that the water is in compliance,” he said.
“The commissioning sample is there to indicate if the engineering work has been done properly, if you have prepared for the installation and if the installation has been done in the correct manner. If this is not done correctly, you can have chosen the best system in the world but the water that is discharged will still be out of compliance.”
According to Alfa Laval, it is the engineering work that is most vital, so the installation company is trained by the manufacturer. The manufacturer should also review the engineering drawing – for example, location of sampling points is a key point in compliant testing.
And, “last, but not least, ensure the crew is properly trained,” Mr Friberg said.
He also pointed out that the testing is far from being a known quantity. None of the testing kits available have been approved and only provide an indication - the ISO guidelines on indicative testing / compliance monitoring devices is still under development. However, sometimes, this indicative test, which is only an indication, is taken as fact, which can be very costly to the owner as further samples must be taken and full laboratory analysis is needed to ensure a correct reading.
How can the shipowner guard against failures in indicative testing? One method of compliance comfort is treatment of the outgoing water, as happens in the Alfa Laval system.
However, in a poll, two-thirds of those surveyed did not have knowledge of a test method that is most suitable for a successful testing. In another poll, only one third of respondents had actually tested the ballast water onboard vessels.
As both the Maritec and Alfa Laval panellists pointed out, one of the keys to ballast water compliance is a well-installed ballast water treatment system by an engineering company with experience of the system. As one of those experienced operators, Aries Marine managing director (design & offshore engineering), Gireesh M Menon noted that his company had undertaken over 800 ballast water treatment engineering projects across a range of vessel sectors and just about every make and type of ballast water treatment system.
Aries Marine’s portfolio includes UV (60% of its installations, including Alfa Laval) and electrochlorination (27%) as well as chemical and other methods.
“It is critical that the engineering company has knowledge of what goes wrong and the issues during commissioning,” Mr Menon said.
Looking at the development of ballast water, the shipping industry is now in the commissioning phase, he said.
“This is when owners find out what they have spent there money on,” Mr Menon noted, pointing out that there are systems that are not meeting D-1 standards on commission.
Asked about the main cause of ballast water treatment systems failure to comply, Mr Menon said “One aspect we see owners overlooking is (crew training).”
Mr Menon’s point was underscored by a poll of attendees in which 62% noted positively that indicative testing is an effective way to measure successful installation and/or crew competence.
When will ballast water testing become mandatory?
Maritec’s Mr Haraldsson said that under the US VGP process, ballast water is tested twice after installation and once a year thereafter.
IMO is likely to mandate, through MEPC, ballast water testing at the earliest in May 2022.
In the question and answer session, the panellists were asked about continuous in-line testing of ballast water – would not this be the most efficient way to confirm compliance. Michael Haraldsson pointed out that the requirement to collect one tonne of water would make inline testing challenging.
Viktor Friberg noted that while online testing was desirable, the different size of the species in the ballast water and the different methodologies required to identify different organisms would be challenging. From an engineering point of view, Gireesh M Menon felt there was still some work required before inline testing was a reality.