The global ballast water treatment market driven by a number of different regulations, each designed to prevent the spread of invasive species by ships through the transfer of ballast water. Ballast water allows organisms to travel across geographical barriers and take hold in non-native environments where there are no natural predators.  This global problem has exacerbated by steadily increasing water temperatures that create more hospitable environments for non-native species.

The key to understanding ballast water treatment is to understand the regulations that govern your vessel.  There are two primary regulations that drive this market, each are detailed below.

IMO BWM Regulations

The primary regulation driving ballast water treatment is the 2004 IMO Convention for the Control and Management of Ships’ Ballast Water and Sediments.  This Convention was written in 2004, but languished in the ratification stage from 2006 through 2016. Finally in 2016, the convention was ratified by Finland, bringing the total signatory tonnage above the 35% threshold. Now, over 80 countries representing over 80% of world’s shipping tonnage are signatory to the Convention.

The Convention has gone through a number of potential implementation schedules, but the final one was proposed at the Marine Environmental Protection Committee (MEPC) at their 71st meeting.  This was ratified and adopted at MEPC 72 in April of 2018.  This revised schedule has ships requiring ballast water treatment onboard their vessel at their next International Oil Pollution Prevention (IOPP) Renewal survey after September 8, 2019.  

There a few wrinkles in those dates, however. Vessels that completed their previous IOPP renewal survey before Sept 9, 2014 are allowed to wait until they complete their second IOPP Renewal Survey after that date.  This Renewal Survey is typically done every five years, so these ships should all be complete their second IOPP renewal between Sept 9, 2019 and Sept 9, 2024 depending on when that last survey was done.  For vessels that complete their IOPP Renewals between Sept 9, 2014 and Sept 9, 2017, they must install a system at their first IOPP Renewal Survey after September 9, 2017.  For ships who completed their IOPP renewal surveys after Sept 9, 2017, they must install a system at the first IOPP Renewal Survey after Sept 9, 2019. Graphically, the schedule looks like this:

The critical point to remember about the IMO Convention is that your implementation date has no direct correlation to when the vessel is placed in drydock.  So it is very likely that a vessel will be placed in drydock before the implementation date, but will not install a system because their implementation date may not be for months, or even years.  Since drydock periods are often the easiest times to do retrofit installations, this can significantly impact the cost and schedule of a project.

U.S.C.G. Ballast Water Rule

The second regulation impacting the ballast water treatment market is the United States Coast Guard (USCG) Final Ballast Water Rule found in 33CFR Subchapter O.  This rule was first published in June of 2012 and created a number of unique requirements for ship owners.

Primarily, the rule requires that all ballast water treatment systems used to comply with the rule must be certified specifically by the USCG through their network of Independent Laboratories. The USCG also did not allow UV-based systems to be tested using growth assays, as was typically used for IMO Approved systems.  This has caused UV-based systems to use more power to pass their testing.

The USCG Implementation schedule is based on the amount of ballast a ship carries.  For ships that carry between 1500 and 5000 m3 of ballast onboard, they were required to install a treatment system at their first scheduled drydocking after January 1, 2014.  For all other vessels, they were required to install a treatment system at their first scheduled drydocking after January 1, 2016.  As drydocking surveys are also 5-year surveys, this means that all vessels with between 1500 and 5000 m3 of ballast onboard should have installed a system before January 1, 2019 and all other ships must be complete by January 1, 2021.  Graphically the schedule looks like this:

Due to the lack of USCG Type Approved systems, many ships were awarded extensions to their compliance dates.  Largely, there has been very little installation of USCG ballast water treatment systems to date.

There are two very important things to note about the USCG Final Rule.  First, the Rule only applies to vessels >1,600 GT, vessels that Deballast inside the waters of the US (12-mile limit), and vessels that move between multiple Captain of the Port Zones (as defined by the CFR). Most worldwide vessels do not fall into these three categories, so this Rule does not apply to most of the world’s shipping.  The second is that the Rule ties the compliance date to the Out-of-Water Drydocking date required once every five years by SOLAS. This has two impacts because vessels with extended drydock windows must still get this survey endorsed every five years regardless of whether or not they enter a drydocking, and the survey is not tied to the IOPP certificate like the IMO requirements are.

So it is extremely likely that a vessel may be acceptable for one of the standards, but in violation of the other, despite doing their best to try and comply.

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