The IMO Regulations in Conflict – A Statement of Concern
Latest industry news and reports from Safinah Ltd - October 2006
Background
Two IMO initiatives relating to Water Ballast are effectively in force and could raise potential conflicts and dangers for owners, yards and regulatory bodies alike:
- The Coating Performance Standard for Ballast Tank Coatings (CPS) (PDF file)
- International Convention for the Control and Management of Ships Ballast Water & Sediments (SBWS) (PDF file)
The CPS is aimed improving ship safety by eliminating as practically as possible corrosion within a ship’s water ballast tanks. This will be achieved by defining the system and method of selection and application of coatings to ballast tanks at new building to provide a 15-year life for the coating scheme selected and applied in accordance with the requirements of the CPS. Its sole focus is the corrosion protection of the ballast tanks and will require coating products to be tested and approved and the process of application to be audited and controlled as well as the keeping of records for the purpose of traceability through life.
The SBWS is aimed at ensuring that owners take adequate measures to ensure that alien species migration is properly controlled and minimised. There are a number of proposed solutions for this. However all solutions will change the environment in the ballast tank.
The objective is to have a system which will effectively neutralise the alien species transportation by limiting their ability to be taken on board in the first place, but also subjecting them to a variety of treatments on board to ensure they cause no harm on discharge at a foreign port.
What is interesting is that the two regulations make no reference to each other and could cause serious problems for IMO and regulators. There is a real potential for conflict here.
Cause for concern
The cause for concern can be best summarised by the following plausible scenario:
A ship owner placing a contract for a ship in 2007 will need to comply with the CPS. The indications are that he will pay up to a 10% premium on the new vessel price because of the additional work it imposes on the shipyard, in terms of coating operations.
Why should there be a cost increase? This can be simply explained by the fact that for most shipyards (Korea and Japan in particular) ballast tank coating is a bottleneck activity. So if 10% more effort is required to surface prepare, paint and inspect them, then output from the yard will decrease by 10%. To recoup this lost turnover the yards need to charge more per ship to maintain their levels of performance.
The increase will be made up of the following elements:
- Increased inspection and audit
- Increased paper work control and management
- Control of salt levels
- Control of dust
- Control of DFT
Studies undertaken by Safinah in Korean, European and US yards indicate that 10% is about the right figure. Of course the real figure will ultimately depend on ship type and size as well as the practices and facilities of each yard.
In addition the variation in the capability of the inspectors also can result in considerable variation in effort as many of the standards referred to, are normally assessed subjectively rather than objectively.
Having selected his approved paint scheme the owner also decides to install a type approved water ballast system. The system is using a variety of physical and chemical processes to achieve it desired goal. It may be noted that most ballast water treatment systems currently being developed are categorised as "Active Substance" systems – systems using chemical additives or causing chemical changes to the ballast water characteristics and thus the environment in the ballast tank. The methods applied could (several systems proposed, will) damage the coating.
So the owner by attempting to comply with the two regulations, could end up having paid 10% extra for his ship to get a 15 year coating scheme applied that is promptly damaged by an approved ballast water treatment system.
Responsibility
The following options could be argued:
- It is the responsibility of the designer/yard to ensure that the systems selected are compatible, but where are they to get the data from?
- It could be the responsibility of the paint company to ensure that all systems are compatible with all their recommended schemes at new build, but what happens if the owner changes paint supplier later?
- It could be the responsibility of the treatment equipment supplier to assure compatibility with all paint company materials, but this would be a long and drawn out testing processes with a considerable number of schemes and products to assess.
This ambiguity needs to be addressed and responsibility placed firmly with one party or another. There is a need therefore to co-ordinate to ensure that either the supplier of the ballast water treatment system of the paint company, or the shipyard or the owner ensure that the two systems (coating and treatment) are compatible.
Possible outcome
In simple terms, catastrophic failure of the ballast coating system could result and surely at this point, if both of the systems selected have been approved to the IMO standards and, then some one will need to take responsibility.
To the knowledge of Safinah, to date only one system has carried out extensive testing of the impact of their water ballast treatment system on the coatings and on corrosion in the tanks in general.
Some of the proposed water ballast treatment systems are using some of the following potentially harmful mechanisms to control alien species:
- Chemical additives such as chlorine and other oxidants
- Ozone
- Hypochlorites
- UV irradiation
- Carbon Dioxide
The potential to damage the coating or aggravate corrosion varies considerably from system to system.
Table 1 gives an indication of potential problems:
[Source: Ballast water treatment technologies – corrosion control issues PCE Magazine July 2005]
Current costs
It has been estimated [Ballast Water De-oxygentation can prevent aquatic introductions while reducing ship corrosion – Biological Conservation Vol. 103 2002] that an owner of a 150,000dwt new build tanker, will have paid a 10% premium on the vessel price to get a 15 year coating scheme – this would be an additional $7.4 million at today’s prices.
Installed a Ballast water treatment system at a cost of $0.3 to 1million.
Currently an owner typically can spend up to $10million over the life of the vessel (20 years) to maintain the coatings. The result would be to catastrophically damage the coating scheme leading to a re-painting tanks at a cost of about $50 x 180000 sqm (about $9million), without the attendant loss in potential earnings.
Conflict
If these IMO regulations result in this conflict the owner can condemn his coatings to be described as poor on a regular basis and this in turn would increase all the costs described above.
Evidence
At present very little evidence exists to enable the effect of these systems to be properly evaluated and this work needs to be done as a matter of urgency.
It is known that one treatment system manufacturer is in the process of carrying out long term (1 year) lab and field testing, others have spoken to paint companies to get an opinion as to the likely impact of these regulations, but no body of knowledge has yet been built up.
Proposal
Within either the CPS or the SWBS, wording should be introduced to ensure that the systems employed are compatible. It is the opinion of the author that probably the best people to confirm compatibility should be the paint companies or independent laboratories, but that they will have to charge for this service and it will have to be paid for by the SWBS supplier.
In addition, systems that could improve the overall situation in the ballast tanks in terms of corrosion should be identified as such and offer the potential to owners to reduce the costs they may face.
Way forward
There is a need to conduct some laboratory-based tests to confirm this danger and hence identify the best solutions to move forward.
Raouf Kattan BSc MSc PhD FRINA C.Eng
Managing Director
Safinah Ltd
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