Features
Industry Insight: Ballast Water - A Challenge Not a Reprieve
There are not many things in this world that are at once unexpected, heavily rumoured and a long time coming. But one year ago, the industry was shaken by an announcement that matched all of these descriptions.
Last September, the ratification of the IMO's Ballast Water Management Convention (BWMC) set the clock ticking on compliance. The whole industry started to shift into action expecting entry into force on 8th September 2017. One year on, the industry is facing a very different picture. We have gone from the controlled urgency of an industry ready to gear up and tackle an oncoming challenge, to one that has been shifted into neutral and asked to wait.
At MEPC 71, the deadline for retrofitting vessels was extended by two years to the first survey after September 2019. Although an additional two years on the deadline for retrofitting vessels may not sound like a long extension, with many owners choosing to renew their five-year International Oil Pollution Prevention certificate (IOPP) on the cusp of entry into force, the reality is that this pushes ship compliance out by up to seven years in some cases.
IMO was advised in July by ship owner NGOs that the ballast Water Treatment System (BWTS) industry was not ready and that proven BWTS options were not available. This is not the case. Over 50 ballast water treatment systems have achieved IMO Type Approval. Several now also have USCG Type approval, with many more certified under the Alternate Management System. Within the next 6-12 months, USCG Type Approvals will continue to be applied for and granted, including for De Nora's BALPURE system. The BWTS equipment market is prepared, options are available for all vessel types and sizes, and manufacturers like De Nora have spent the last year preparing to meet demand.
It has taken the BWTS industry 13 years of hard work to get to this point, and put in place sufficient capabilities to meet compliance for the BWMC's entry into force. However, many owners still do not have a clear plan in place of how to address both IMO and USCG requirements. After a year of confusion and instability, we must now work together to forge a route forward that is clear and decided (or decisive?). In the next two years, owners and operators must take the necessary steps toward compliance and should not leave it until the last minute to start thinking about compliance options, as has happened since 2004.
The industry is likely to see a peak requirement for BWTS installations between 2022 and 2024 which will influence dry dock capacity and the manufacturer's ability to supply. During this time BWTS manufacturers, class societies, design companies, installers and dockyards are likely to be operating at full capacity, meaning long waiting lists for BWTS installation projects and the potential that owners may have to forfeit their first-choice solution to meet compliance.
It is vital that owners get the correct solution for their vessel type to ensure that they can reliably meet compliance with minimal impact on already stretched crew time and resources. The BWTS is a long-term investment critical to the owner's business. As it is unlikely that a single technical solution will fit all ship types, sizes and itineraries ship owners should not delay further but start now with technology selection, vendor qualification and planning of their fleetwide projects. It is worth noting that a BWTS retrofit project could have up to 12 months lead time from project launch to completion.
Over the past year, the picture of the ballast water requirements has changed so frequently it has created a very real confusion for both owners and suppliers. It may be tempting to breathe a sigh of relief at the extension granted by IMO. However, these two years should not be seen as a reprieve but it is an opportunity to catch-up and get ready. The IMO has thrown down the gauntlet to the industry, to prepare in the next two years for what they hadn't managed to ready themselves for in the previous 13. With collaboration between owners, operators and suppliers it is possible – but we must start now.