Transcript Document

Conflicts and dangers in new
IMO regulations
IMC 2008 Korea
Dr M Raouf Kattan – Safinah Ltd
The regulations
Two new IMO regulations dealing with
the environment within the ballast tank:
– The Performance Standard for Ballast
Tank Coatings (PSPC)
– International Convention for the Control
and Management of Ships Ballast Water &
Sediments (SBWS)
IMO PSPC
Aimed to improve through life performance of ballast
tank coatings for a “target” 15 year life.
Defines systems of
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Preparation
Application
Product selection
Inspection
Record keeping
Testing
Auditing
Focus on corrosion prevention
IMO SBWS
To ensure that adequate measures to
ensure control of alien species
migration.
Aim to manage living organisms
PSPC and SWBS
Both affect ballast tanks
– PSPC – prescriptive in terms of what
happens and what is applied
– SWBS – requires certain targets to be
achieved
Net result is a change in the ballast tank
environment.
PSPC/SWBS
No cross reference between the two
regulations
Could raise the issue of an approved
PSPC system interacting with and
approved SWBS system resulting in a
catastrophic failure of one or the other
system.
No cross testing or compatibility needs.
Owner requirements
Vessel that meets IMO PSPC and
SBWS system and are compatible.
Who is responsible to deliver this
– Yard
– Paint supplier
– SBWS system supplier
Cross testing to date
Cross testing of systems has been
minimal to date, with only one known
real exception in which appropriate
ballast tank coatings have been used
No supplement yet been issued by IMO
to resolve the issue.
Where does the compatibility lie?.
Treatment Systems
Systems employ different technologies
such as:
– Chemical additives (oxidants)
– Ozone
– Hypochlorites
– UV radiation
– Carbon Dioxide
– Inert gases
Potential problems
Source Ballast water treatment technologies – PCE magazine July 2005
Costs
Estimates vary from between 0 – 20%
for PSPC implementation per ship.
SBWS costs can vary based on
installation and operation costs, type of
system and vessel size
If things are not checked could result in
a costly repair exercise.
Action
At this time yards should seek
assurances from suppliers
Owners should seek assurances
IMO needs to issue a statement of
clarification
End result is likely to be more testing,
but what form should it take?