Ballast Water Management is on top of the international maritime agenda in order to prevent contamination of the oceans with microorganisms. Although the regulatory framework still is somewhat unclear, Maersk is already today preparing for the international convention - and MMT is playing a key role in this.
How we tackle an industry wide challenge
In 2004, the International Maritime Organisation (IMO) adopted the Ballast Water Management Convention requiring all ships to have installed equipment to clean the ballast water they discharge into the oceans and port areas. The background for this is that IMO considers invasive marine species to be one of the 4 largest threats to the world’s oceans since their effects – unlike other forms of marine pollution such as oil spills – are irreversible. This convention will affect the entire industry and since its adoption, Niels Bjørn Mortensen and Jai Alimchandani from Regulatory Affairs in MMT have been keeping an eye on the regulatory developments in this area in order to ensure that Maersk is best prepared for when it enters into force.
“At this point, the convention has not yet entered into force because states representing 35% of the world tonnage have to ratify the convention, while at present, only 30.25% have done so. At the last IMO Council meeting, several member states declared that they would be ready to ratify within 2014 and 2015, which could bring the convention into force in 2016", says Niels Bjørn Mortensen.
For Maersk this means that we will have to invest 500 MUSD over a period of –6-7 years in order to comply with the ballast water management convention.
US rules vs. international rules
In 2012, the US adopted and implemented its own ballast water regulation, and the US regulations are for the larger part a reflection of the IMO convention, with one very important exception: Testing and approval of ballast water treatment equipment. The IMO G8 Guidelines and the US ETV Protocol differ in many ways. It is believed that equipment passing the US approval will thereby also be considered as having passed the IMO test, but not vice versa. The major problem the shipping industry is facing in this context is that US Coast Guard has not yet approved any equipment. A number of makers are being tested, but it is unknown when the first piece of US type approved equipment will be available on the market.
In Maersk, the first ballast water treatment systems were already installed back in 2010. Since 2012, all of the larger new-buildings have been equipped with BW treatment systems. Presently, Maersk has installed approx. 30 systems on six different ship types, including drill ships. MMT is doing the groundwork in evaluating the technical possibilities and facilitate the decisions the Maersk business units such as Maersk Line and Maersk Tankers will have to take. Palle Wredstrøm, head of Engines and Propulsion in MMT has taken the technical lead in ballast water management initiatives. The system we have used is IMO type approved, however, as with all other BW equipment, not yet US Coast Guard approved, which means that we may end in a situation where these ships, or at least some of them, will be banned from trading to the US unless the ballast water treatment systems are replaced.
Wredstrøm says: “We are using a UV-based system, which we will continue to install on newbuilds, but we are concerned about the pending stringent U.S. Coast Guard approval. Our strategy for the installation on newbuilds is to install ballast water treatment systems where we have a commitment from the supplier that they expect to obtain U.S. Coast Guard approval. Considering the installation cost of USD 2M per ship, we would like to be able to expect that such a system fulfils all requirements.”
Retrofits: even more challenging than newbuilds
When it comes to retrofits on older, existing ships, the process is even more challenging. “We’ve seen on a new build how it can be a challenge to integrate a BWTS into the ship’s control system. It will be an even bigger challenge on a retrofit.”, Wredstrøm adds. With 60,000 vessels having to comply within the next 5 years, it was decided to wait for the renewal survey and dry dockings before installing BWTS. The focus is currently geared towards larger suppliers because of better global service possibilities. With ships drydocking at different yards, we need to be sure to have functional service in place and based on the experience with newbuilds, the demand for service will be even higher.
What is the “same location”?
Since the Maersk fleet also includes offshore supply ships and tugs, Maersk Supply Service and Svitzer may be able to utilize the “same location” exemption clause for some of these ships. This clause states that vessels operating within a confined geographical area (the “same location”) are exempt from the convention and thus do not have to install any ballast water treatment system.
The US rules are quite clear on what can be considered “same location”, but in the IMO convention it is left to the member states to agree internally. So far we know that all Danish waters will be considered “same location” and we have also been unofficially informed that the same will apply to Brazilian Waters.
“The challenge comes when several littoral states “share” the same water. Take for instance ferry routes between Denmark and Germany. Some routes are only 10-15 miles long and ferries have been plying the waters for more than a century, yet the administrations cannot yet agree to designating it to the “same location””, says Mortensen.
An extended timeframe would be welcome
One thing is for certain: an extended timeframe for shipowners to implement the convention would be welcome bearing in mind that US rules have to be clarified, class societies have to approve all installations, testing has to be carried out properly and crew needs to be trained.
As with all regulations, Maersk is fully committed to complying with what is decided by IMO. However, it needs to be ensured that there is a level playing field in the industry, i.e. we are not the only ones making an effort to follow such conventions.