Ballast water management systems in spotlight after issues

Latest findings highlight the failure to remove invasive species in between 29% to 44% of operational systems. 

Analysis of the deeper layers of compliance assessment is required to gain real understanding of why a significant percentage of installed ballast water management systems (BWMS) are failing the IMO regulation D-2 discharge standard. 

Such is the viewpoint of Marcie Merksamer, EnviroManagement Vice-President and former chair of IMarEST’s Ballast Water Management Special Interest Group (BW SIG). It comes in response to several recent reports submitted to the IMO’s Marine Environment Protection Committee (MEPC), including Global TestNet’s findings that 29% to 44% of operational systems are failing to remove invasive species, despite 95% of those systems having previously passed commissioning tests. 

“Achieving compliance in any industry requires a holistic and multi-faceted approach,” Merksamer states. “Many elements need proactive attention – equipment, crew, operational practices, management, organisational commitment to environmental and social responsibility, compliance testing procedures and methods, and more. The popular focus, however, is often on ‘BWMS failure to comply’. 

“A critical shift in our thinking is needed because the regulations are not ‘BWMS discharge standards’, they are ballast water discharge standards for ships. Certainly, BWMS performance is critical to compliance, but the BWMS is just one piece of a larger compliance puzzle. All aspects from the moment the ballast water is pumped onboard to the moment it is discharged contribute to a ship’s ability to meet the ballast water discharge standards.” 

Delving further, Merksamer notes that within document MEPC 82/INF.5, Global TestNet concludes that “the failures are largely due to contamination from uncleaned tanks or non-treated ballast water present onboard”. 

Continues Merksamer: “After evaluating samples from 108 ships from the period of 2019-2023, the Republic of Korea reported in document MEPC 82/INF.11 that while specific causes for 51 samples from non-compliant ships could not be determined ‘…several potential issues that could contribute to these failures were identified...’.” 

Identified issues: 

• Insufficient training and familiarisation of crew in operating BWMS (20 ships) 

• Maintenance omission of BWMS (seven ships) 

• Contamination of ballast water (13 ships) 

• Operation failure of BWMS due to CWQ (challenging water quality) (11 ships) 

“These are findings that cannot be overlooked as they play just as critical of a role in ship compliance as the BWMS does,” says Merksamer, also highlighting an alternative “positive view of the percentage of compliance”. 

“Document MEPC 82/INF.40 (Australia) reports 27% non-compliance (six of 22 ballast water samples collected and analysed) for the ≥50 µm size class, which therefore indicates a 73% compliance rate.” 

However, she notes that notwithstanding the “good shipping companies” given the “limited” amount of current compliance and enforcement inspections, “some crews pay little mind to ballast water compliance as they view an inspection taking place as a low risk”. 

“Once inspections are more common and consequences for non-compliance are the norm, I believe we will see increased efforts towards implementing ballast water management regulations holistically to ensure compliance,” she explains.

Staying ahead of the curve

Reflecting on her role as the former chair of the BW SIG and now as a member, Merksamer says she very much enjoys working with a wide range of stakeholders from different sectors of the ballast water industry to “stay abreast of the current implementation challenges faced”. 

“Discussing things such as how BWMS equipment performance can be improved, the resources that ship owners/crew need to support their ability to implement the regulations, and technical information that regulators need to evaluate compliance are ways that the SIG contributes,” concludes Merksamer. 

“Each stakeholder has a role, as well as challenges, that contribute to overall implementation of the convention to prevent transfer of aquatic invasive species. The SIG is an excellent way to bring together stakeholders from across the globe for transparent technical conversations that can lead to solutions.” 

Discover more about the IMarEST BW SIG. 

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Image: ballast water exchange process on board a ship; credit: Alamy.