Simplicity is necessary

Kuldeep Singh of US-based Gallagher Marine Systems says that, starting with the technology, any BWT system, or for that matter other pollution prevention device, should be chosen for its simplicity and effective management from the ship board personnel’s perspective.

Admittedly, equipment and installation cost is one of the prime criteria while choosing a system, but the end users are the crew; the efficacy of the equipment is largely dependent on the ‘man behind the machine’ being able to consistently deliver compliance. “It has to be practical and user-friendly for the personnel onboard the ship to actually deal with, ” he says.

This sounds obvious, but behind this rather plain statement is the history of what happens if the technology onboard doesn’t make it that easy to comply with the regulations.

For example, recent cases have come to light concerning oily water separators: a handful of ships were found to have been discharging bilge waste and sludge illegally, bypassing a non-functioning separator by a so called ‘magic pipe’ that discharged oily waste straight over the side instead of letting the separator collect it.

IMO

While it’s almost a truism to point out that well functioning systems lead to better compliance, not just because the technology is robust but because it simply makes it easy to do the right thing, the corollary is true: malfunctioning or poorly designed technologies lead crews to be tempted to bypass both antipollution systems and the law.

So, the same issues may well crop up in different forms with other antipollution technology: “The oily water separator cases of today may well become the ballast water treatment issues of tomorrow,” says Mr Singh. While the seas need our protection, “the only way to achieve this is to keep both legislation and technology practically achievable”.

Which leads onto the second issue: the legislation, at time of writing, is somewhat tangled. While the IMO has released a list of ‘approved’ systems, the US Coast Guard, which has been mandated under the aegis of the US Environmental Protection Agency to take action on this matter, hasn’t yet settled on full approvals.

So, vessels entering US waters realistically only have two options since the other possibilities – that of using US supply water, pumping into reception facilities or retaining it all onboard -aren’t usually going to be viable. This means the owners can either apply for an extension to the BWT implementation schedule, or just go ahead and install an alternative, IMO approved treatment plant, hoping that it will ultimately be in compliance with the USCG rules. As these systems can be between US$2m and US$3m for only a moderate sized cargo ship it’s a huge gamble on something that may, at the end of the grace given by the USCG, eventually just have to be replaced.

While all this is going on, the IMO itself is having some issues ratifying its own BWT legislation though some remain of the opinion that this will happen in the coming year.

The two, therefore, could be out of step with each other. Mr Singh explains that what people are afraid of is that the US take on the BWT rules could work out to be subtly different from the IMOs, driven by propositions by places like California who may demand a ‘zero tolerance’ policy toward any live organism that could impact it’s ecology. “The issue is that ‘zero’, while it sounds good, is extremely difficult to achieve and test given the present technology,” says Mr Singh.

Of course these delays aren’t good for an industry that needs certain rounds of buyers’ investments and R&D feeding back to the manufacturers to obtain robust, stable systems. It may even repeat the issue that has been hanging around scrubber technology, where the delays could cause enough hardship that some manufacturers go out of business before the orders start coming in.

Further, the goal posts might move. “What happens if the microorganisms change?” asks Mr Singh. Single celled or simple organisms like those found in ballast water can adapt as a defence mechanism, and although most BWT systems are two-pronged attacks, there are a number that involve chemicals that organisms may become resistant to.

So, finally, there is a chance that any technology could be found wanting at some point in the future. Both Mr Singh and Martial Claudepierre of Bureau Veritas agree that the legislation is having an impact on the skills needed onboard, Mr Claudepierre pointing out that while many systems run without intervention – and automatically shut down if the ship gets into difficulty – crews have to be prepared to deal with malfunction and resets. “If the system has a fault, the ship is then not in compliance with legislation and this carries heavy penalties. So it’s necessary for the crew to be deeply involved; after all they may well have to replace chemicals that are missing or fix the pump.”

All this, including the element of responsibility and the possibility of criminalisation, is weighing more and more heavily on crew members. It has to be said that the industry, already struggling to find competent personnel, isn’t actually making life any easier. There is a danger that crews will lose confidence in being able to effectively manage the necessary environmental measures, and as the seas really do need protecting, losing heart really means a consequent rise in cowboy operators – those who really don’t give a damn.

Look at the whole

Mr Claudepierre of BV says retrofitting any system is a complex business, and while, unlike scrubbers, the stability of the ship is not usually impacted by Ballast Water Treatment systems as the weight is low down, it is still a tight fit.

However, many BWT systems come with an additional power requirement, especially as filtration and UV elements need to have powerful pumps which force the water through. So, while the treatment plant may not affect the global power requirement as the system kicks in on arrival in port, it may make a significant difference to how this energy is produced and handled, requiring reconsideration of both pumps and generators.

Further, the combined effect of all the antipollution systems together is, for Mr Claudepierre, of some concern. “BWT treatment requires a considerable step up in the power needed close to shore, plus there is the impact of items like scrubbers which also require a significant amount of energy – each, for example, has an impact on fuel and therefore CO2. Although all these things are good ideas, the standards are being developed by different working groups, acting separately.”

So, he says, a true evaluation of their benefits may be more complex than one might think. “What is missing so far is a way to look at the overall picture, a way to tie it together.”

Gallagher Marine Systems, based in the US, is a leading maritime industry provider of Environmental Compliance and Oil Spill Response services under OPA 90. Bureau Veritas is a globally recognised class society involved in testing, inspection and certification services.