With the first few fully certified Ballast Water Treatment systems now on the market, shipowners are slowly drifting into the purchase phase of compliance.
In the near future, a mechanical Ballast Water Treatment system will now need to be retrofitted on all large ships and ship’s crew will have a new piece of equipment that will need to be operated, monitored, and maintained.
Many equipment suppliers have invested their hearts, souls and hard earned dollars in designing and certifying Ballast Water Treatment Systems and now these systems will see the hard test of real life operation. In the simplest terms, this story played out on Oily Water Separators, and quite possibly there are some lessons to be learned from the OWS implementation history.
In OWS implementation there was an initial belief in the infallibility of technology, but the belief never matched reality. After many stops and starts, and lots of blood, sweat, and tears, it became apparent that a workable solution to bilge water treatment required a combination of functional equipment, crew training, planning, record keeping, monitoring and operational transparency.
While OWS equipment is capable of treating most bilge waters, nature does not always cooperate and occasionally fails to deliver the proper oil/water/contaminant mixture to a ship’s bilge. In those cases the crew, being self sufficient engineers (the type of people who have made the world as safe and convenient as it is today, and who also abhor reading instructions, filling out forms, or leaving good enough, or bad enough, alone) are then often compelled to engage in tinkering mode.
OWS are essentially black boxes and an OWS fails when the discharge level exceeds 15 parts per million. At that stage the OWS will not discharge and the crew will face a difficult and time consuming trouble shooting sequence that may end in a frustrated fix that may not be legal.
Ballast Water Treatment systems are a slightly different animal. They do not have an output measurement device. Instead, this equipment is certified based on a test protocol that stresses repeatability of results using a variety of ballast water intake types that pass through a specific treatment system. Once the system passes these tests, it is assumed that it can operate sufficiently effectively to kill everything in every type of ballast water that is pumped into a ship anywhere in the world.
Hopefully that will work, and, undoubtedly, various environmental enforcement agencies will take field samples from the ships that enter the ports under their control and check to make sure that what is supposed to be dead actually is dead. But mother nature is a stern task master. Could there be conditions that fall outside the test protocol and could there be maintenance, fouling or wear and tear issues that can make a BWT system operate below its certified effectiveness? And who will be responsible? The easiest solution would be to have a field measurement device to continually monitor the BWT output, but such a piece of equipment does not exist (well it sort of exists, but is too expensive and unsuited for shipboard operation).
Barring such equipment, shipowners and crews will be in an uncomfortable position. They will be asked to operate a piece of equipment for which there is little operating experience, and where the success of its operation cannot be measured.
So how can one obtain operating experience on such a piece of equipment?
Are there other approaches out there? At this year’s Connecticut Maritime Association Exhibit, MSI and ABB are suggesting an approach that shows promise. Instead of treating the BWT system as mostly a black box, MSI/ABB suggests modifications that make the system a transparent box. This means that besides the certified on/off modes, the system can also be modified by the operator to work to a higher level of effectiveness if internal BWT conditions so indicate.
This approach is part of an MSI patent on BWT technology, and with lots of BWT test water now under the dam, it is starting to appear that their approach may be more workable when the BWT equipment becomes more deeply integrated aboard ships with increasing shipboard operating experience. The ability for engineers to adjust operating parameters and to transparently record those adjustments will build a body of operational knowledge that ultimately will result in quicker industry wide solutions.
As a world wide shipping community, we made an error when we did not drag bilge water management practices into the public domain and we have to be careful that we do not make the same mistake again. We can never lose sight of the fact that a cleaner environment or invasive species control is a community effort, if we do not allow the entire community to be part of the solution, the process will quickly devolve into a finger pointing exercise, and that will take much longer to solve.
We need equipment supplier competition, and may the best supplier win, but we can only identify the best supplier if there is transparancy as far as operational experience is concerned.
