IMO Ballast Water Convention Latest Developments CLK

Tell them what you are going to tell them… Overview of NAMEPA Maritime song sheet Regulatory framework Ballast water- how little critters spawned a challenge and an industry What happened in October, 2017 Where are we today?

Southport, CT Mission: Preserve and protect the marine environment Demonstrate maritime industry’s commitment to environmental protection Engage maritime businesses, government and public to “Save our Seas” by promoting sound environmental practices Educate the public CLK – very brief introduction of NAMEPA.

Shipping’s Size There are over 90,000 merchant ships trading internationally, transporting every kind of cargo. The world fleet is registered in over 170 nations, and manned by over a million seafarers of virtually every nationality. CLK

Shipping’s Role in Global Trade Our marine transportation system delivers nearly 90% of all global trade In 2008, for example, it is estimated that the industry transported a total volume of world trade by sea of over 32 thousand billion tonne-miles and nearly 50 thousand billion tonne-miles in 2014- an increase of 50% (Source: UNCTAD) CLK

Shipping is Environmentally Efficient Sea transport is one of the least environmentally damaging modes of transport and, when compared with land based industry, is a comparatively minor contributor to marine pollution from human activities.  CLK

Comparable modes CLK

Shipping is regulated by IMO CLK International Maritime Organization (IMO), London-based United Nations agency responsible for the safety of life at sea and the prevention of marine pollution by ships.

Enforcement The principal responsibility for enforcing IMO regulations concerning ship safety and environmental protection rests with the flag states (i.e. the countries in which merchant ships are registered - which may be different to the country in which they are owned). Flag states enforce IMO requirements through inspections of ships conducted by a network of international surveyors. Much of this work is delegated to bodies called classification societies.

In the United States

Rewind on BWM Since the introduction of steel-hulled vessels around 120 years ago, water has been used as ballast to stabilize vessels at sea. Ballast water is pumped in to maintain safe operating conditions throughout a voyage. This practice reduces stress on the hull, provides transverse stability, improves propulsion and maneuvrability, and compensates for weight changes in various cargo load levels and due to fuel and water consumption.​

Scientists first recognized the signs of an alien species introduction after a mass occurrence of the Asian phytoplankton algae Odontella (Biddulphia sinensis) in the North Sea in 1903. But it was not until the 1970s that the scientific community began reviewing the problem in detail. In the late 1980s, Canada and Australia were among countries experiencing particular problems with invasive species, and they brought their concerns to the attention of IMO's Marine Environment Protection Committee (MEPC).

The zebra mussel, which is native to the Caspian and Black Seas, arrived in Lake St. Clair in the ballast water of a transatlantic freighter in 1988. Within 10 years it had spread to all of the five neighbouring Great Lakes. The economic cost of this introduction has been estimated by the U.S. Fish and Wildlife Service at about $5 billion.

Ballast water discharges are believed to be the leading source of invasive species in U.S. marine waters, thus posing public health and environmental risks, as well as significant economic cost to industries such as water and power utilities, commercial and recreational fisheries, agriculture, and tourism.[3] Studies suggest that the economic cost just from introduction of pest mollusks (zebra mussels, the Asian clam, and others) to U.S. aquatic ecosystems is more than $6 billion per year.[4] A form of cholera, Vibrio cholerae, previously reported only in Bangladesh apparently arrived via ballast water in Peru in 1991, killing more than 10,000 people over the following three years.

Needed: Global Action!

Steps to the IMO Convention on BWM MO has been at the front of the international effort by taking the lead in addressing the transfer of invasive aquatic species (IAS) through shipping. In 1991 the MEPC adopted the International Guidelines for preventing the introduction of unwanted aquatic organisms and pathogens from ships' ballast water and sediment discharges (resolution MEPC.50(31)); while the United Nations Conference on Environment and Development (UNCED), held in Rio de Janeiro in 1992, recognized the issue as a major international concern.

In November 1993, the IMO Assembly adopted resolution A In November 1993, the IMO Assembly adopted resolution A.774(18) based on the  1991 Guidelines requesting the MEPC and the MSC to keep the Guidelines under review with a view to developing internationally applicable, legally-binding provisions. While continuing its work towards the development of an international treaty, the Organization adopted, in November 1997, resolution A.868(20) - Guidelines for the control and management of ships' ballast water to minimize the transfer of harmful aquatic organisms and pathogens, inviting its Member States to use these new guidelines when addressing the issue of IAS.

After more than 14 years of complex negotiations between IMO Member States, the  International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) was adopted by consensus at a Diplomatic Conference held at IMO Headquarters in London on 13 February 2004.  

“Our duty to our children and their children cannot be over-stated “Our duty to our children and their children cannot be over-stated.  I am sure we would all wish them to inherit a world with clean, productive, safe and secure seas – and the outcome of this Conference, by staving off an increasingly serious threat, will be essential to ensuring this is so”. --Efthimios Mitropoulos,Secretary-General-IMO, 2004

Considerations During the Convention development process, considerable efforts were made to formulate appropriate standards for ballast water management. They are the ballast water exchange standard and the ballast water performance standard. Ships performing ballast water exchange shall do so with an efficiency of 95 per cent volumetric exchange of ballast water and ships using a ballast water management system (BWMS) shall meet a performance standard based on agreed numbers of organisms per unit of volume. Regulation D-3 of the BWM Convention requires that ballast water management systems used to comply with the Convention must be approved by the Administration taking into account the Guidelines for approval of ballast water management systems (G8).

The Convention requires a review to be undertaken in order to determine whether appropriate technologies are available to achieve the standard. MEPC has conducted a number of such reviews and agreed that appropriate technologies are available to achieve the standard contained in regulation D-2 of the BWM Convention. 56 systems using active substances received Basic Approval from the IMO 41 systems using active substances received final approval from IMO 69 systems have received type approval certification by their respective Administrations (both active substances and non-active)

What does this look like?

Ratification at last!!! (Thank you, Finland!)

We’re good, right?

Not so fast…

MEPC 70- October 2016 Ongoing concerns about consistent performance of approved systems (250/12/2) G-8 revision and resolution approved G-8 to become mandatory in Code Form All systems installed after October 28, 2020 must be approved under the revised G-8 guidelines After October 28, 2018 systems must be approved under the revised G-8 Between those dates, ships can still install systems type approved under the old G-8 B-3 implementation schedule- current 1st IOPP after entry into force

Now what??? IMO BWM Convention enters into force September 8, 2017 Implementation date of D-2 discharge standard not yet established; 2 proposed schemes will be considered at MEPC 71 (July 2017) Scheme 1 – September 8, 2017 New construction on/after September 8, 2017: D-2 on delivery Existing ships constructed prior to September 8, 2017: D-2 at first IOPP renewal survey on/after September 8, 2017 Scheme 2 – September 8, 2019 New construction on/after September 8, 2019: D-2 on delivery Existing ships constructed prior to September 8, 2019: D-2 at first IOPP renewal survey on/after September 8, 2019

First Stage – “Initial Inspection” Adopted Guidelines for Port State Control under the BWM Convention, Resolution MEPC.252(67) First Stage – “Initial Inspection” Documentation–international BWM Certificate, approved BWMP, and Ballast Water Record Book BWM Officer properly trained, and knows how to operate the BWMS Maintain evidence that BWM system is type approved and has been maintained and operated in accordance with BWMP if the use of a BWMS is required Second Stage – “More Detailed Inspection” Check compliance of operations in accordance with the BWMP Operation of BWMS checked against records, crew knowledge, operating status and bypass records BWMS operated in according to BWMP and self-monitoring indicators Third Stage Indicative or detailed sampling would occur Fourth Stage Detailed analysis to verify compliance with D-2 Standard

New guidelines Revised G8 Guideline Existing G8 Guidelines ETV/ USCG Final Rule Harmonization Level Testing Facilities Testing is to be carried out by an independent facility accepted by the Administration, which implements a rigorous quality control/quality assurance program. Any laboratories holding the required certificates for performing biological and microbiological analysis for the D2 standards could perform such tests. QAMP had to be approved from the certifying administration prior each testing. As per Revised G8. Independed Laboratories (ILs) have undertaken this role. High Testing at temperatures ranging from 0°C to 40°C BWMS performance should be checked in the above given temperature range. BWMS unable to demonstrate successful performance across these salinity and/or temperature ranges will be assigned Limiting Operating Conditions on the Type Approval Certificate Such temperature range was not specified. No specific temperature range is mentioned. Testing must include temperate, semi-tropical, or tropical locations and for all BWMS, temperature must be measured either continuously during or at the beginning, middle, and end of the period of ballast water uptake, as appropriate and practicable for the parameters to be measured. Moderate

Revised G8 Guideline Existing G8 Guidelines ETV/ USCG Final Rule Harmonization Level Consecutive Testing Land-based testing is to consist of five consecutive valid test cycles that show D-2 compliance. Shipboard testing is to reflect actual ballast operations and consist of at least three consecutive valid tests, which show D-2 compliance spanning a period of not less than six months.   In this guideline no such requirement existed. For Land Based the vendor had to reach five successful tests in two water salinities irrespectively the total tests he had to perform. For shipboard testing the vendor had to achieve three consecutive successful tests at period not less than 6 months. For Land Based at least five consecutive, valid, and successful replicate test cycles per water salinity. For ship board test 5 consecutive test have be performed in period not less than 6 months. The number of required ship board tests for USCG is double than revised G8. High System Design Limitations System Design Limitations (SDL) are to be identified by the manufacturer, validated during testing and indicated on the Type Approval Certificate. No such requirement was existed in the G8 guidelines. As per G8. All critical/ limitation operation parameters should be described in the Type Approval Certificate. Challenge level of Total Suspended Solids (TSS) It requires more onerous examination of the effects of TSS on the BWMS’s ability to perform in the waters found in worldwide shipping. Existing G8 were requiring up to 50 mg/L TSS. This is considered a normal value for harbour waters but no much attention was given on the type of these particles. This has been thoroughly covered on ETV protocol. Definition of viability Organisms inactivation concept (killing) is recognized but still includes the reproduction ability of the organism as a benchmark. The existing G8 guidelines definition of viability does not include the inactivation (render harmless) of the organism. Only the inactivation (killing) is considered as a benchmark. Low

Revised G8 Guideline Existing G8 Guidelines ETV/ USCG Final Rule Harmonization Level Bypass arrangement Bypass activation should be recorded in BWMS control and monitoring equipment. The same was mentioned in the existing guideline. The same applies on USCG Final Rule. High Scaling The revised G8 guidelines identified approval of scale units is very important and due to time constraints further technical discussions were forwarded to PPR4.   Few information about scaling was mentioned in the existing guideline. Scaling is thoroughly covered in USCG Final Rule. Self-monitoring BWMS are to be provided with a system that monitors, records and stores sufficient data/parameters to verify correct operation for the past 24 months. Alerts are to indicate when the system is shutdown or when an operational parameter exceeds the approved specification. Few information about self- monitoring was mentioned in the existing guideline. Self- monitoring is thoroughly covered in USCG Final Rule. Environmental test It refers to test requirements of IACS UR_E10 Existing G8 Environmental tests were requiring less testing than the revised guidelines. However, BWTS with Class Type Approvals had to follow the IACS UR_E10. IACS UR_E10 requires 120 min but USCG Final Rule 240 min.

Installation Requirements following type approval Revised G8 Guideline Existing G8 Guidelines ETV/ USCG Final Rule Harmonization Level Installation Requirements following type approval The revised G8 guideline specifies the installation requirements primarily for the bypass and its function on board ship. No such requirement was mentioned in existing guideline. However, this was covered by classes installation guidelines and the requirements of the International Ballast Water Management Certificate. Such requirement is covered by USCG Final Rule. High Installation Survey & Commissioning Procedures Requirement for post type approval. The responsibility in verifying the proper operation of BWMS following installation and commissioning lies with the flag Administration of the ship. This includes the performance check following commissioning.   No such requirement was mentioned in existing guideline. However, this was covered by classes installation guidelines and the requirements of the International Ballast Water Management Convention Certificate.

Considerations Tug between regulation and technology Social license to operate

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