Article by Jamey Bergman for Ballast Water Treatment Technology
Time has run out for shipowners who have put off ordering and installing ballast water treatment systems for their vessels, according to the Ballast Water Equipment Manufacturers’ Association (BEMA).In spite of the myriad challenges shipowners face in choosing and installing ballast water management systems (BWMSs), BEMA told the industry in an open letter published Friday, installing and optimising the systems is a lengthy process. Further delays in decision making would put owners in contravention of the Ballast Water Management Convention and at risk of falling afoul of enforcement bodies, the group cautioned.
“Have there been issues with the early designs of BWMS? Absolutely,” read the letter signed by BEMA president and Hyde Marine product manager Mark Riggio. “Can a BWMS be difficult to operate? Yes. Will a BWMS affect the normal, pre-ballast water treatment operations of your vessels? Definitely.”
“All of these questions have led many of you to delay this decision until the last possible minute in order to optimise your best chance for success,” Mr Riggio said. “While we understand that, we want to caution you that it is already the last possible minute.”
Using the recent industry gathering at SMM Hamburg as a litmus test, Mr Riggio said that while BWMS manufacturers in attendance saw strong interest, “firm orders are still very hard to come by”.
There is also a fundamental misunderstanding at work for owners seeking compliance date extensions in an attempt to take advantage of BWMSs that promise dual compliance with both International Maritime Organisation (IMO) ballast water treatment regulations and stricter United States Coast Guard (USCG) regulations, according to BEMA’s letter.
“Some owners are operating under the mistaken belief that they have more time to make decisions and that a USCG type-approval certificate is evidence that a system is suitable for all types of vessels, under all operating circumstances. The reality is that neither is the case. The IMO convention is in force now, and owners must start their selection process if they are to ensure compliance with international regulations.” Coldharbour Marine chief executive Andrew Marshall was quoted as saying in the letter.
“Detailed engineering, ship surveys, class approvals and many other factors extend the timeline for a retrofit to more than a year in typical cases,”he said.
All vessels that operate under the IMO ballast water treatment convention will be required to have a system installed at their first international oil pollution prevention (IOPP) survey after 8 September 2019.
According to BEMA, for many ships, it may already be too late to plan an optimal retrofit.
Ecochlor chief executive Steve Candito was quoted in the letter: “We are assisting several clients now on the more costly and difficult prospect of installing systems while the vessel remains in service rather than in a drydock simply because the decision was made too late.”
BEMA was formed in April 2018 to represent what it calls “the treatment technology side of the ballast water debate”. Nearly 40 members have joined the organisation in its first five months and the businesses they represent cover every type of treatment technology in the market, according to the association.
In line with our expansion plans for the Asian market for our unique inert gas based BWTS, a new office in Singapore has been opened to be run by Capt Mohit Batra, a master mariner with an MBA from Oxford University.
Capt Batra, Managing Director of Coldharbour Asia Pte Ltd has extensive experience of the shipping sector gained over more than two decades. He has held several senior positions ashore including spells with classification society ABS and marine technology company Wärtsilä. He has also been involved in international business development, marketing and sales, implementing effective supply chain strategies and consulting on merger and acquisition activities.
Andrew Marshall, Coldharbour Marine’s Chief Executive, commented on Capt Batra’s appointment and the new Singapore office. “Having a hub in Asia has always been a key part of our development strategy and I believe we have found just the right man to head our operation in this important market. Mohit has an unusual combination of seagoing and shore management experience and will bring these strong capabilities to our operations in Asia.”
Capt Batra explained the company’s strategy: “We have timed the new Singapore set-up in advance of being awarded US Coast Guard type approval which we expect to receive in 2019. And it is next year that we expect the ballast water treatment installation market to take off strongly. This is particularly the case in our specific target markets which include large tankers, big bulk carriers and LNG vessels.
“We have identified a large number of ships in these sectors for which owners will need to plan system installations from 2019 onwards. Many of these retrofit projects will be undertaken in Chinese shipyards, whilst we will also be supplying treatment systems for new ships under construction at yards across Asia.”
The Ballast Water Equipment Manufacturers’ Association Holds First Annual Meeting
ALEXANDRIA, VA – April 24, 2018 – The manufacturers and stakeholders in the ballast water treatment equipment market have taken a major step forward by codifying a unified manufacturers’ association. The Ballastwater Equipment Manufacturers’ Association (BEMA) met on April 19, 2018 for their first Annual Meeting and elected the inaugural Board of Directors. The paramount need for this association arose from the growing demand for well-founded information on the practicability of ballast water treatment technologies, as well as on the technical and environmental aspects of implementing ballast water management regulations worldwide.
Following the announcement of a further delay of the 2004 IMO Ballast Water Convention implementation dates, which occurred at MEPC 71, a small group of dedicated industry insiders gathered in New York City to draw up the framework of what was to become BEMA. The association moved from concept to reality with their first official meeting on March 9, 2018. The attendees at this seminal meeting, made up of representatives of equipment manufacturers, industry stakeholders, and component suppliers from all technologies and regions of the world, voted on and adopted a set of draft Bylaws as well as other formation documents, setting the stage for selecting the organization’s Board of Directors and electing the first slate of association officers.
The idea to form an association of ballast water equipment manufacturers dates back many years. “What makes this time different,” says Mark Riggio of Hyde Marine who was elected President of the Association and was a member of the initial formation committee, ”is the realization that we needed to have a unified voice in the conversation.” BEMA will be that voice.
BEMA, a registered trade association based in the United States, seeks to provide coordinated, technical, non-commercial guidance to both the maritime industry and the regulatory agencies that are trying to understand the intricacies of ballast water treatment. The Association will serve as a key resource for ship owners, designers, testing equipment suppliers, and regulators to discuss openly how ballast water treatment systems work and what should be the expectations of each technology operating across a world fleet.
“It has been encouraging to see how enthusiastically the equipment manufacturers have embraced the organization,” said Marcie Merksamer, Secretary General of BEMA and member of the formation committee. “We have had a quick and energetic response from suppliers representing all of the major technology types in the industry and from every region of the world. BEMA is truly a global enterprise.”
During the initial formation meeting in London, held during PPR5, the organizers discussed applying for non-governmental organization (NGO) observer status at the IMO in 2018. After consulting with the shipping industry and prospective members, their focus quickly turned to ensuring that the association first provides value to the industry and then revisits the effort of obtaining IMO acceptance as an NGO. “There is a lot of value that [BEMA] can provide even before we achieve NGO status at the IMO,” said Steve Candito, Ecochlor CEO, member of the formation committee, and newly elected member of BEMA’s Board of Directors. “We have already been approached by ICS, BIMCO, and other ship owner associations to discuss the important implementation challenges. The industry wants to discuss solutions and we are ready to talk.”
Representatives from Cathelco, Coldharbour, DESMI Ocean Guard, ERMA FIRST, Evoqua, Optimarin, Panasia, and Wӓrtsilӓ were also elected to serve as members of BEMA’s Board of Directors. The makeup of the Board ensures that the organization has balance with regard to the technologies that are being used in the market, the different regions of the world that serve the marketplace, and companies of different sizes and scope. Riggio reinforced the need for this balance, “Representing the entire market is critical if we want to be a truly impartial, technical resource for the shipping and regulatory community.” The other elected officers of the association are: Vice President Efi Tsolaki of ERMA FIRST; Treasurer Birgir Nilsen of Optimarin; and Secretary Andrew Marshall of Coldharbour.
BEMA is scheduling meetings with numerous shipowner associations and industry trade groups to provide unbiased direction and advice to their membership about the impending retrofit period, currently scheduled to begin in September of 2019.
According to the organizations’ formational document, BEMA will operate with the basic purpose to provide manufacturers and service providers in the ballast water treatment market with leadership and a unified voice. To accomplish this mission, the organization has set forth the following key objectives:
Represent and serve as a central, common voice for ballast water equipment manufacturers;
Provide the shipping industry with design and operational expertise to balance the directives and opinions of regulators, ship owner organizations, scientific testing networks, and environmental organizations that influence the requirements that directly impact the manufacturers as stakeholders in the ballast water treatment community;
Participate at the IMO level and give technical support to all stakeholders as outlined in Article 13 of the BWM Convention by and providing knowledge about the design, manufacture, installation, maintenance, and long-term functionality of ballast water treatment systems;
Provide and stimulate authoritative organized research, education and information exchange within the industry and with other industries, government bodies, and interested organizations;
Mobilize and finance volunteer, internal staff, and external professional expertise to provide the required range of service to members; and
To maintain a liaison to and cooperate with the governmental agencies and allied trade and professional associations throughout the world.
BEMA is actively seeking out new members to join the organization and is actively recruiting members for the newly forming committees of the organization. For a complete list of the BEMA Board of Directors or for more information on becoming a member, please contact the association at Info@BWEMA.org or visit their website www.BWEMA.org.
Agreement has been reached with TMS Tankers to fit the GLD BWT System.
The 2013-built 158,513DWT Suezmax tanker “BORDEIRA”, owned and operated by TMS Tankers, will be the first to be fitted with the Coldharbour BWT System in March of this year and will be used to carry out US Coast Guard (USCG) type approval tests for the Coldharbour system, supervised by Lloyd’s Register. LR has Independent Laboratory Approval status with the USCG. The classification society has already overseen IMO type approval for the Coldharbour system, validated by the UK’s Maritime and Coastguard Agency. The “Revised G8” certification tests agreed by the IMO’s Marine Environment Protection Committee last year will be undertaken simultaneously.
The Coldharbour system was designed from the outset for large tankers and similar sized vessels. There is still much confusion regarding ballast water compliance timetables and how the practicalities of implementation will happen. Our mission is to safeguard the interests of ship-owners in our market segment and to protect their profits from the costs associated with the delays and the unavoidable regrowth dangers that will lead to PSC fines and C/P disputes.
Evangelos Sfakiotakis, TMS Tankers Technical Manager, commented: “We have carried out a careful assessment of the available technologies for our large tankers and have satisfied ourselves with Coldharbour’s inert gas-based system. There are several reasons for this, but the two main ones are; firstly, that the Coldharbour technology featuring the combination of no filters plus in-voyage treatment process guarantees that our ballasting operations will never be disrupted, and secondly, that the treatment during voyage avoids the potential risk of regrowth during a long ballast voyage. This ensures that not only will our tankers be able to meet required discharge standards at all times, but also that we can be absolutely certain that the commercial availability of the vessel will never be adversely affected by BWTS issues.”
TMS Tankers have been clear that the technology it selected would need to be a long-term solution for existing ships that could serve without any risk or compromise to the way that its vessels are operated. Selection of the GLD™ BWT System by a company with TMS Tankers’ reputation for technical expertise vindicates our approach to solving the problem of treating ballast water – providing a solution which is fit for purpose in the long-term and which protects owner’s interests by eliminating the risk of delays and costs arising from delays to normal ships’ operations.
There is still much “discovery” to be made by ship owners as they start to come to grips with the realities of day to day BWT system operation. Delays, breakdowns, crew training and the repercussions of Port State Control sampling protocols are just some of the hidden costs that are set to bite.
The consequences, both financial and reputational for ship owners of making an incorrect decision on treatment technology will haunt the industry for years to come. Owners must ensure that the systems they install are fit-for-purpose – and that does not simply mean having an IMO or USCG Type Approval certificate.
Delegates at the IMO’s Marine Environment Protection Committee 71, due to gather in London during the first week of July, may well have the last chance to ensure that the long-delayed Ballast Water Convention is implemented, as intended, in an orderly fashion when ships undergo their special surveys, once every five years.
This will ultimately decide whether the Convention’s requirements are finally fulfilled across the many thousands of ships which require ballast water treatment system installations.
It is a couple of minutes to midnight for this Convention and the outcome of the next MEPC meeting will surely decide its fate. Delegates at the meeting have a real chance to demonstrate that the IMO does indeed have teeth and will not put up with deliberate flouting of its best intentions.
Some flag states are now actively marketing a decoupling of the special survey – the time when practically all ballast water treatment system retrofit installations will take place – from renewal of the International Oil Pollution Prevention Certificate (IOPPC). This is the point in time that the IMO set as the trigger for system installations because the IOPPC renewal normally takes place during a ship’s special survey. Decoupling of the two events is a cynical means of enabling ship owners to buy more time, Marshall believes, which flies in the face of the IMO’s intentions.
A two-year postponement of the Convention’s entry-into-force could prove helpful for the industry in several ways, even though it is already 13 years since the Convention was adopted. Any postponement must come as part of a package which sees shipboard treatment system installations timed, as the IMO has always intended, to coincide with renewal of the IOPPC at the next special survey. Decoupling must stop.
For ship operators whose vessels trade or may trade in US waters, any IMO postponement of the installation schedule is irrelevant. The US is not a party to the IMO Convention and, under US regulations, the trigger for installing treatment systems – either type-approved by the US Coast Guard or authorised for up to five years from a ship’s compliance date under its Alternate Management System – is the first dry-docking after January 1, 2014 or January 1, 2016 depending on a vessel’s ballast water capacity.
Some flag states are using the IOPPC decoupling process as a means of winning more tonnage from ship operators who wish to delay system installations for as long as possible, but this is likely to have some unwelcome consequences for ship owners.
If a two-year postponement is agreed at MEPC 71, and the decoupling process is not stopped, the IMO’s most-delayed Convention will have no impact on many ships for possibly another seven years from today. This would be iniquitous for proactive owners who have already invested in the installation of treatment systems and have the Convention’s best interests at heart.
It would also mean that many of the independent ballast water system manufacturers will have given up or gone bust by the time the market emerges, and as a result ship operators will be restricted in their choice of system to the large corporate manufacturers which have diversified product lines that are revenue generating and thus allow them to wait for the sector to come good.
We already know that no single technology is suitable for all ship types, and having plenty of choice is essential if operators are to undertake effective due diligence before deciding on a particular treatment system that is not only fit for purpose but also, most importantly, reflects the actual operational requirements of their vessels.
I urge delegates at MEPC 71 to take a strong line on these issues which will ultimately seal the fate of the Ballast Water Convention. As an industry, we must have an unambiguous timeline and a chance to see through the IMO’s best intentions to completion.
Coldharbour will offer its patented GLD™ BWTS, as part of Sembcorp Marine’s Green Technology Retrofit (GTR) solutions. This BWTS was chosen from a select group of equipment manufacturers with whom Sembcorp Marine is working closely.
Coldharbour CEO Andrew Marshall said: “We are delighted to sign this agreement with Sembcorp Marine. We have always maintained that no single technology is suitable for all vessel types and for all operating requirements. Our ballast water treatment systems target the largest vessels with the highest pumping rates, largest ballast volumes and longest ballast legs. For many ballast water treatment technologies, these three elements combined would have translated into a perfect storm of terminal delays and unrecoverable costs for owners, which by comparison, would make the initial cost of installing a ballast water treatment system pale into insignificance.”
As the global marine industry prepares for the implementation of the Ballast Water Convention, there is still a considerable level of confusion and uncertainty surrounding the questions of suitable equipment choice for different types of vessel and securing a successful retrofit installation strategy.
Addressing these concerns, Sembcorp Marine executive vice president and head of repairs and upgrades, Lee-Lin Wong, said the company had examined various ballast water technologies and established collaborations with the best manufacturers around the world over the past 24 months.
She said: “Our one-stop GTR solutions have everything needed to achieve successful ballast water treatment outcomes – from the analysis of requirements, system selection, scanning and engineering, to full installation and commissioning of equipment. We are confident that ship owners working with us and our chosen equipment partners such as Coldharbour, will no longer be confused by ballast water treatment requirements.”
Reproduced from Tanker Operator. Red the full article here
Simon Gu, Chairman & Michael Wang, General Manager, Hansun Marine Technology
Graham Cole, Chairman & Andrew Marshall, CEO, Coldharbour.
In a ceremony held today in Shanghai, China, UK based Coldharbour Marine Ltd has signed an agreement with Hansun (Shanghai) Marine Technology Co Ltd which provides for the marketing and distribution of Coldharbour products in mainland China as part of the company’s joint preparations for the emerging ballast water treatment technology market.
The wide-ranging agreement brings a number of Coldharbours product lines, including their unique inert gas generation systems and award winning in tank ballast water treatment technologies into Hansuns already impressive portfolio of in-house marine technology products.
Credit: Ballast Water Treatment Technology Tue 04 Apr 2017
Coldharbour’s Gas-Lift Diffusers provide constant treatment within the ballast tank (credit: Coldharbour)
Faced with a range of treatment technologies, shipowners must weigh up which techniques best suit their operations. Filtration, for example, can have a detrimental effect on ship operations where it forms part of the treatment process.
If the filter constantly needs to be flushed it will make the ballasting process longer which could in turn have an effect on demurrage and despatch claims or time charter performance issues. So if a vessel relies upon a high ballasting or deballasting rate, then either it should not have a filter fitted or use one that is able to cope with the flow.
It is in the choice between mechanical, electrochemical and UV systems where most considerations will come to bear. A UV system treats the water immediately on uptake and can repeat the treatment again on discharge if it is felt necessary. Such systems are not without problems of their own. The method of treatment with UV is aimed more at rendering organisms unviable than killing which has caused some issues in the past as to their suitability for use in US waters. This is less of a problem now that two of the three systems with USCG type-approval are UV systems. The biggest problem with UV is that of turbidity which can reduce the effectiveness of treatment.
A mechanical system such as Coldharbour’s Gas-Lift Diffusers or Bawat may rely on constant treatment of ballast in the ballast tanks and therefore not be suited to ships that operate on short voyages. The same issue can arise with electrochemical or pure chemical systems where the disinfection takes place in the ballast tank. Different systems will have different dwell times that will be influenced by the size of the tanks, the chemical composition of the water and the temperature.
Temperature and salinity of the uptake water are vital parameters for any electrochemical system and, if outside of the range where electrolysis can take place, remedial measures must be taken. That involves adding chemicals to the water in appropriate quantities which will need to be determined by measurement and monitoring of the intake water. Control and monitoring systems have been covered by the BWMC’s G8 Guidelines from the outset but the section devoted to them in the revised version issued by MEPC 70 has been much enlarged and extended.
This is another area where more work is needed. There are expectations that, as more technologies for measuring the biological effectiveness of treatment systems are developed, these will need to be integrated into systems. Such systems will give a degree of confidence to crew that the system is working as intended or if that is not the case make necessary arrangements at the next port of call.
Credit: Paul Gunton, Ballast Water Treatment Technology
Boris Johnson plays with a yo-yo gifted to him by Coldharbour Marine
Foreign Secretary Boris Johnson visited Coldharbour Marine in Nottinghamshire today to take a tour of one business that is making waves in the global market. The specialist engineering firm designs water treatment systems for some of the largest ships.
Mr Johnson donned a reinforced flat cap and hi-viz jacket and was given a tour of the facilities following his arrival on Thursday March 9, just after 5pm.
From a demonstration in a laboratory, to the firm’s ballast tank simulator and the inert gas generator, the former Conservative leadership candidate was given a meticulous explanation of each step of the firm’s engineering process, which was met with the occasional “wow” and “that’s fantastic.”
Speaking about his visit Mr Johnson said: “Look at this business here. You can see the extraordinarily, inspirational business that has taken British technology, come up with some ideas, really refined them, and then found a way to get those water purifying systems, which you need for global trade, on to as many ships as possible. The more trade there is the better this company in the heart of England will do.
“I’ve been invited here to see what they are doing because this technology depends on global free trade.
“The UK is now being released to campaign for global free trade in a way it couldn’t for a long time. Trading policy was entirely run from the EU, we can now do free trade deals in the way we couldn’t before and one of the slightly worrying things about the world at the moment is that trade as a proportion of global GDP has been declining. We want to increase that again, we want to get trade moving and this company and this area will benefit from that.
Boris Johnson speaks to Dr Gagandeep Singh, of Coldharbour Marine
Mr Johnson added: “I hope what will happen, as our economy re-engages with the world, we will stop talking about Brexit and talk about ‘Bre-entry’ into the rest of the world, to think globally again.”
The U.S. Coast Guard has initiated civil penalty proceedings against the operator, Vega Reederei GmbH & Co. KG, after an investigation into ballast water discharge violations by the bulk carrier Vega Mars.
Investigators found that around January 29, 2017, while moored in Tacoma, ballast water was discharged from the 580-foot Liberian-flagged vessel without the use of a Coast Guard approved ballast water management system or other approved means, a violation of the National Invasive Species Act with a maximum penalty for $38,175.
It is the responsibility of vessel masters, owners and operators to ensure the proper discharge of ballast water into any water within U.S. jurisdiction, or to ensure proper waivers or extensions are processed through the Coast Guard’s Office of Operating and Environmental Standards.
The Coast Guard has established a ballast water discharge standard which is the same as that adopted by the IMO in 2004. In addition, the U.S. EPA 2013 Vessel General Permit has adopted numeric limitations of ballast water organisms that affect all vessels that operate in U.S. waters. The regulations mean that vessels are required to install and operate a treatment system before discharging into U.S. waters.
“The Coast Guard is committed to the protection of the marine environment through strong and robust administration and oversight of ballast water management practices,” said Capt. Joe Raymond, commanding officer, Coast Guard Sector Puget Sound. “These efforts are in line with the recent [type] approval of four different ballast water management systems.”
In conjunction with the first type approval certifications, the Coast Guard released Marine Safety Information Bulletin 14-16 which provides answers to frequently asked questions concerning the extension program, vessel compliance dates and the use of Alternate Management Systems.
As there are now U.S. type approved systems, operators can no longer request an extension to their waiver of regulatory requirements simply citing there is no Coast Guard type approved system available. Each extension request requires an explicit statement supported by documentary evidence that one of the accepted methods in the regulations, including installation of a Coast Guard type approved system, is not possible for purposes of compliance with the regulatory implementation schedule.
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