The Ballast Water Management Conundrum

^ Confusion Pervades the Global Shipping Industry – Image Courtesy alphaspirit at

Confusing Times

Uncertainty is perhaps the most potent of all business killers. Strategic uncertainty is in fact an important cause of war. Although sometimes essential for professional dealings, ambiguity makes the mind play games and resort to unnecessary courses of action, or inaction.

After a decade of painful trot and long after the initial 2013 compliance deadline, the Ballast Water Management (BWM) Convention 2004 may finally see the light of the day at the 13th Ballast Water Management Summit at Rotterdam, Netherlands on 21-22 October, 2015.

Now, the International Maritime Organization’s (IMO) BWM Convention (International Convention for the Control and Management of Ship’s Ballast Water and Sediments 2004) can enter force 12 months after 30 states representing 35% of global merchant shipping tonnage ratify it.

As of September 22, 2014, 44 nations representing 32.86% of the world’s merchant fleet tonnage have ratified it. With India adopting the BWM Convention in April this year, it may be ratified at this summit. That is great news. But there is more, as usual.

A host of glitches dot the path, the primary being the variance between the standards prescribed by the IMO and by the United States Coast Guard (USCG). The uncertainty means, ship owners prefer to wait so much that Frost & Sullivan lists this as a key industry challenge.

Greg Trauthwein, Editor of Maritime Reporter & Engineering News believes the debate on BWMS to be the most caustic after the Exxon Valdez spill triggered regulators into ordering double hulls on tankers.

What Ails Ballast Water Management System (BWMS) Installation?

Since we started using steel hulled ships about 120 years ago, we have used ocean water as ballast for ship stability and maneuverability. Ships take in and release ocean water as and when needed. An estimated 68,000 commercial ships annually transfer 7billion tons of seawater.

Ballast Water Discharges & the Challenge of Invasive Species - Image Courtesy Anna Leigh at

Ballast Water Discharges & the Challenge of Invasive Species – Image Courtesy Anna Leigh at

Seawater contains umpteen microbes. Ballast water exchanges transfer them to non-native areas in the ocean where they flourish at the cost of the local species. Ballast water exchanges introduce a fresh invasive aquatic species every 9 weeks or so.

This is precisely why two decades ago the IMO started to talk of an international agreement for better management of ballast water exchanges. Because shipping is a genuinely global activity, any shipping related convention has to be of the international level.

Graham Westgrath, COO of GasLog Logistics and former Chairman of Intertanko, believe, the authorities forced legislation before the technology was ready.

Even if the BWM Convention musters the numbers at the Rotterdam summit and goes operational in a year, it would create a mammoth demand-supply gap. Around 57,000 ships will need BWMS installation over the next 3-4 years. It takes about 6-8 months to install a BWMS.

Invasive Underwater Weeds Image Courtesy Ethan Daniels at

Invasive Underwater Weeds
Image Courtesy Ethan Daniels at

Needless to say, the prices of BWMS would jump to astronomical levels and make this, perhaps, the most expensive retrofit in the history of shipping.

Expenses apart, ships will have to queue for months to get compliant BWMS installed. This will seriously disrupt scheduled dry dockings and upset the financials of shipping companies. And we are not even talking of the consequences on supply chains.

You would expect BWMS makers to be jubilant, eyeing a $80billion market as they are. But they do not know what exactly to make because:

  • Differences in BWMS standards of the IMO and the United States Coast Guard (USCG)
  • IMO has not yet completed the review of G8 Testing Protocols
  • No one knows when the USCG will start granting Full Type Approvals to BWMS

Not for nothing have the International Chamber of Shipping (ICS), BIMCO, Intercargo, and INTERTANKO jointly voiced their concern on the state of affairs at a recently held conference.

These organizations also succeeded in getting the IMO to agree to upgrade its G8 Testing Protocols. Presently, these protocols require testing BWMS only in two salinity levels although ships sail through three salinity levels during global voyages.

Sea Shore Infested with Zebra Mussels, an Invasive Species Image Courtesy Winnebago Photo at

Sea Shore Infested with Zebra Mussels, an Invasive Species Image Courtesy Winnebago Photo at

This is precisely why the United States Coast Guard (USCG) lays down stricter norms for BWM systems than those of the IMO. But this does leave ship owners-operators baffled as to which BWMS to use. And, a BWM system costs anywhere between $50,000 and $5million.

Ships entering the U.S. waters need to have BWMS with Full USCG Type Approval. The BWMS also has to adhere to the BWM regulations of individual states and the Vessel General Permit (VGP) of the United States Environmental Protection Agency (USEPA).

Instead of granting Full Type Approval, the USCG grants permits under the Alternate Management System (AMS) – it accepts a BWM Convention compliant BWMS approved by another flag state.

However, the AMS is a temporary, five year approval. The approved BWMS is eligible for ballast water exchanges in U.S. waters for five years only. And within these five years, it has to obtain full type approval. But why would anyone invest thousands or millions for just five years?

As of now, some 50 BWMS have obtained IMO Type Approval. About 35-40 possess IMO Final Approval and more than 50 have secured IMO Basic Approval. But only 17 BWMS makers have dared to venture into getting USCG Type Approval. Thus far, none have won it.

The Way Ahead

But USCG approval you have to get. For if you cannot get your ship in U.S. waters to trade with the largest importer and third largest exporter in the world, who will you trade with? In 2014, the U.S. imports clocked $2.334trillion while its exports hit $1.61trillion.

Maersk Line, one of the world’s largest shipping companies, has adopted a mixed approach. While fitting 30 new builds with BWMS that seem compliant with USCG Full Type Approval norms, it is waiting for renewal surveys and dry docks before installing these on its existing fleet.

Classification societies, shipyards, and the USCG are advising ship owners to ensure that they affix the responsibility of upgrading the BWMS if they fall short of USCG standards at a later date.

And while shipyards and BWMS makers can look forward to lucrative times, they too have their task cut out. For, profits will not materialize unless they plan a year in advance. Looks like everyone needs to plan things ahead.

Damen Shipyards for example has collaborated with three vendors that specialize in diverse technologies. This way, Damen will offer greater choice to its clients while covering a greater section of the market.


NSF International and DNV GL are the two independent labs where BWMS makers can test compliance with USCG BWM standards. It takes between 18 and 24 months and $1-2million for complete testing. Makers then refine the approved BWMS before releasing it in the market.

Effectively this means USCG-approved BWMS will be available only around 2017. And although the USCG published its standards in 2012, only 10-12 BWMS are currently in the testing cycle. If ever there was a case for proactive planning and flawless execution!

Visit our blog for more details on shipping-related regulations and how they affect the global maritime industry. Contact Kemplon Engineering for first rate marine fabrication services, marine pipe fitting, and large scale custom metal fabrication.