ABS gives some new advice on operating ballast water systems, including regulatory extensions, challenges with shipyards, says a press release published on their website.
The Delays exacerbated
The COVID-19 pandemic has not spared vessel owners from requirements to comply with national and international ballast water management regulations. The pandemic has exacerbated the delays previously observed with retrofits. The US Coast Guard is providing COVID-19 extensions [to installation deadlines] for vessels with no ballast water management system (BWMS) installed.
12-month extensions for vessels
It provides extensions for some vessels with Alternate Management Systems (AMS) accepted as BWMS at or near the end of the vessel’s five-year AMS periods. The USCG’s Marine Safety Information Bulletin (MSIB) 14-20 provides 12-month extensions for vessels with compliance dates (either original or extended) between 1 April 2020 and 1 April 2021.
With their AMS accepted BWMS and 2008 G8 Type Approvals, these ships are compliant with the BWM Convention. With the short-duration AMS extensions, they could operate in US waters and internationally until the BWMS can be upgraded.
Vendors and shipyards
Many BWMS vendors have 2016 G8/BWMS Code Type Approvals necessary to complete the USCG and BWMS Code approved reconfigurations.
However, some BWMS vendors continue struggling to complete either their USCG approval or BWMS Code Type Approval due to the pandemic.
The USCG’s COVID-19 extensions provide an important compliance strategy until the pandemic subsides.
The bigger challenge is that some shipyards, required to observe social distancing, are being forced to limit the scope of work that can be accomplished until the pandemic is over.
This could prevent some vessels from completing their BWMS retrofits. Leading to challenges when the vessel’s IOPP Renewal Survey is completed.
IMO / international
Flag Administrations should provide some accommodations to support vessels struggling to get a BWMS installed on the ship. Or if it is not completed due to limited vendor technical assistance because of restrictions on international travel.
While the USCG’s extension policy provides extensions for vessels affected by the pandemic, the IMO BWM Convention does not. Missing a retrofit deadline creates a noncompliance problem.
IMO has limited guidance to date on how vessels that cannot retrofit BWMS will be treated.
It is possible that IOPP Renewal Survey dates could be delayed for three months to allow some breathing space.
Views of ship operators
ABS held a series of workshops providing practical guidance and advice for Best Management Practices (BMP) with BWMS under IMO and USCG regulations, for shipowners operating installed systems. The feedback received from owners [in the workshop] demonstrated that the operation of BWMS continued to be challenging.
In addition to installation issues, training, commissioning, operations, and maintenance, planning for inspections, outages and the development of contingency measures continue to be key topics. The most recent update to the Best Management Practises included a survey of owners’ experience in practice.
It found that between 2017 and 2019 – with more systems in service – the number of inoperable units fell by more than half, though the number of owners who found operations problematic doubled. A minority of systems were not subject to monitoring or testing. A quarter was regularly operated and subject to monitoring and testing.
Installation of a BWMS requires a well-planned timeline and a focus on training the crew, ideally from before the system is installed. Crew rotation means that [people with] sophisticated understanding can simply walk off the ship. So proper training records should include video of the installation and commissioning if possible.
For new vessels delivered with systems fitted and for those vessels already retrofitted, officers and crew must make special efforts to understand operations, maintenance, and repair. Also, what to do when things go wrong, or Port State Control comes onboard.
The burden is shared between the senior officers, the crew, and even shore staff in operation. Likely pressure from the owner to return the vessel to service puts pressure on the engineering crew to understand not just the facets of BWMS operation but its maintenance and breakdown procedures.
After installation and commissioning, technical support may disappear. This means the vessel must rely on its approved BWM Plan which itself must be updated regularly. The crew must also understand how to produce data records, especially in US ports.
Training in sampling
Sooner or later, an inspector will want to come on board and sample the output of the BWMS. Guidelines (G2) to the BMW Convention provide design and installation guidance for the sampling facility.
But there remains limited training and know-how for keeping the G2 facility clean and how to obtain a sample to avoid cross-contamination that could falsely indicate non-compliance.
This requires additional training for the crew. It is advised that the crew practice for Port State Control inspections to better understand requirements they will sooner or later have to meet. Even when the BWMS is not targeted in an inspection, they will need to understand how to prove that they can produce compliant ballast water, including sampling procedures to avoid potential false results.
It is important to recognize that different administrations could have different requirements. So there needs to be communication with ship managers on sailing routes. The applicable rules in different locations should be understood by port engineers and communicated to the vessel’s crews.
Despite the rise in the number of systems in operation, it is important to understand what happens if the system fails and the fastest way to restore it to normal operations. In the case of failure, the water on board might not be considered properly treated and it may be necessary to stop cargo operations. Interpreting alarms and alerts are critical, as well as understanding the system design limitations (SDL).
When the ballasting port’s ambient water is outside the water quality suitable for treatment, the crew must be trained to know what to do next. Ballasting rates can vary by the design of each system’s computer-based controls. Cargo operations may need to be repeatedly started and stopped if BWMS repairs and resets are required.
Maintenance and spares
Maintenance intervals should be planned based on other equipment maintenance schedules. Spare parts should be acquired in the most cost-effective ways to maintain the system in operation. The Type Approval certificate granted to the system will be valid for the lifecycle of the vessel, but the use of unverified spares or mis-repairs can invalidate the warranties.
This can be exacerbated by the likelihood that some parts will become obsolete through the vessel lifecycle.
Another issue for vessel operators in preparing contingency measures is whether the system is non-operational or fails. Though initially optional for the BWM Convention, the USCG expects measures to be included in the BWM Plan for when something goes wrong.
These contingency measures should be practical and feasible to protect the port. The IMO’s MEPC and USCG have published high-level guidelines covering equipment redundancy and crew training. But in reality, vessels may need to use ballast water exchange (BWE) if they have non-compliant water onboard.
Owners using the BWMS bypass need to be aware that regaining compliance for all ballast water on the ship may become more complicated. The use of potable water is still only allowed for US compliance. Numerous other complicated operations including transitions between light and heavy weather ballast conditions and the potential impact on vessel air draft should also be considered.
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