We are all acutely aware of the countdown to compliance. Much has been made of types of ballast water treatment systems (BWTS) available, the pros and cons, the deadlines, the costs, both immediate and on-going. But we are yet to be told what is truly expected when it comes to regulatory compliance based upon ballast water indicative sampling and monitoring.
There are still many unanswered questions, and the time is ripe for the IMO to step forward and debate. IMarEst has done a great job with the submission of the MEPC paper ‘Harmful aquatic organisms in ballast water, a summary of currently available ballast water indicative analysis instruments’ (MEPC 74/4/INF.18), which explores available indicative analysis instruments for ballast water testing. It’s now up to the IMO to prioritise and decide an industry standard, in order for ship owners, port state control and port authority officers to make a truly informed decision when it comes to testing and performance monitoring.
From our perspective, the IMO must decide how sampling is to take place, what the standard procedures should be for accessing samples, who is responsible for completing the sample, and, lest we forget, what are the consequences of non-compliance at this stage?
Currently, at last count, there are at least 12 portable ballast water fast evaluation kits available on the market. Some might even say we are spoilt for choice! They are each a product of extensive research and development based on sound scientific evidence and testing. But if we lined them all up and used them on a control sample, you can bet they would come back with differing results. It is not a simple question of which one has worked, and which hasn’t; but more which is testing for what? If we were to expand our control sample further, perhaps to include water that has been treated using different methods, well; it is safe to say we would end up with far more questions than when we began.
As those in the industry will know, treated ballast water is the product of complex biological and biochemical processes.. So, with all the good will in the world, a selection of performance monitoring kits based on their own unique methodologies does little to aid standardisation. Furthermore, the language we use to outline and describe the process needs to be consistent and clearly defined. There are significant differences between gathering, sampling, analysing and evaluating.
We can gather and test all we like, but it will provide us little insight into analysis and evaluation unless we have clearly defined parameters for sample size and frequency of data collection. It is all very well and good testing for one thing or another, but in the realms of science and legislation, it means very little without due process.
Which leads us to the crux of the issue – what is it we are hoping to find, or perhaps more fittingly, rule out? We may examine phytoplankton cell density, in-line with current IMO D2 and USCG Discharge Standards, but neglect to look for non-photosynthesising zooplankton. Are we safe to assume that the presence of anaerobic organisms in a ballast tank is not a risk to compliance? There are plenty more iterations, such as this one, that have the potential to cause significant contention, and for ship owners on the front line, it is vital that we take steps towards clarity and a cohesive approach.
Practically speaking, we still need to decide who should be collecting these samples. From where I am standing, the only way we can hope to guarantee true impartiality is through independent assessors, trained in the yet-to-be-agreed upon standardisation and practice. Then of course, we also have to consider the role of Port State Control officers, as the lynch-pins between the testers and the scientific experts assessing the samples. If, hypothetically speaking, a ship fails to meet compliance, due to current rulings surrounding undue delays, will port authorities be mandated to communicate this to the next port en route? And what then? What are the implications for shipowners and their ballast water management operations?
Here at De Nora, we are of the firm belief that in order for us to move forward, we need some concrete answers to all of the above. I, of course, have my own opinions on best practise – but ultimately, it is up to the IMO to provide us with some direction. We can advise shipowners on the best treatment system for their vessels. We can support them with choosing the right system, in-line with the living structure of their vessel, carry out successful installations and offer on-going support for maintenance and up-keep. But we are not able to shed-light on sampling and testing processes without sound guidelines.