Ballast water Management Convention :-are we heading in right direction.
We are hearing lots of MEPC and MSC meeting and resolutions, but are they really taking into force. For argument sake author is leaving MSC resolutions , this has been followed by companies and other concerned parties without much trouble / opposition. But the items coming through MEPC is always taking a back seat. The article is small investigation on the backdrop of Ballast water convention (BWMC).
I am not going into the history of BWMC, but it was supposed to come into force on 08th September 2017. Hence the implementation of all ships to be done by next IOPP renewal ( do not confuse with docking of vessel). Now the smart fraternity is start thinking of how to defer the installation of the system. The easiest solution offered by stalwarts are Deharmonise IOPP with other statutory , then get an extension for 5 years.
The plethora of bending the rules not finished there also, there was a separate MEPC resolution (MEPC 71) as per that vessel whose IOPP renewed between 2012 to 2014 need to install Ballast water treatment system (now onwards BWTS) in her second IOPP renewal only. The problem is that a vessel of age 7 year old by 2017 will be installing her BWTS at the age of 14. Looking the the present age of vessel of scrapping and early scrapping predicted , such vessel will not be installed with BWTS. So the system will provide with 2 kinds of vessel
- Vessel complying D-2 standard
- Vessel need not comply with D-2 standard.
Now let us look into reason why different intersested parties reason for finding the loop holes.
- Flag State
- Some of the flag state are mentioning that they don’t have the resource for proper survey and certification.
- Constant pressure from owners.
- In availability of enough equipments.
- They are at mercy of owners and they are the first one who found the loop hole some of the RO’s gone step ahead advised owners the intricacies and loop hole of the convention.
- Avoid sudden expenses to their old fleet of vessel.
- Insecurity of the future of shipping.
First let me go through owners woes , because of the latest developments , owners were at the receiving end for utopian ideas implemented by IMO. I was talking to one of the owner whiose ship was docking nearby shanghai. As per him the carbon cloud is not only because of shipping all industry is contributing, then WHY ONLY SHIPPING. This company has reduced their percentage of distribution of their asset and concentrated more into aviation. Back to the subject implementation of BWTS will tak another atleast one million dollars for a handy max bulk Carrier including docking expenses. As businessman ,
- will it be there an increase of daily charterer rate, the answer is a NO.
- Will there be any increase of the value of the ship , the answer is NO.
But for him the most worrying factor is he can go an install one of the system but there is only 4 companies are approved with USCG approval, so his scope of getting the right one is narrowed down. Moreover none of the system is fool proof is enough to work in all conditions.
- Electrolysis system cannot work in where density is less or conductivity is less
- UV cannot work properly if the turbidity is more than 70- 80 %
- Chemical dosing , has never been successfully worked in any of the ship installed.
I could not find any justification from their side , may be I am an outsider , I think they are happy as and when new regulation is being implemented , more attendance , more issual of certificate, more revenue.
I would say they are biggest culprit in all such failure of implementations. They should have a background study about the feasibility and their owners commitment towards such drastic measures. Even before starting a” Pan” shop, one will do the ground study. But fkag state and IMO without doing any such study has implemented such a major change. The basic question is that ARE WE READY FOR THIS , has not done properly.
It is nice to talk about conventions and regulations in the boards or in Lecture halls , but an approach without practicality will kill the industry.
Disclaimer:- The Opinion expressed by the author is purely belongs to him. KMF / the organization he is working for do not share such views officially.
About The Author:
He is Technical Superintendent with Misuga Kaiun (HK ) Limited from beginning of 2015. He was actively participated various seminars organized by different RO and manufacturers.