Compliance assessment for the ballast water convention: time for a re-think? A U.K. case study

Abstract

The damaging introduction of invasive species continues unabated fourteen years after the adoption of the IMO Ballast Water Management Convention (BWMC). The Convention came into force in September, 2017, 13 years after its adoption. Qualifying commercial vessels will need to comply with international discharge regulations and must now contend with complex regulations, uncertain Ballast Water Treatment System performance and potentially inconsistent enforcement internationally. Part of the dilemma rests with the stringent standards which often take days to determine. When certification testing is superseded by rapid Port State Control (PSC) compliance assessment during a port visit, questions arise regarding the logistics of sampling/analysis and the functionality of the BWTS. Reflecting doubts about the performance of installed BWTS IMO have proposed an interim Experience Building Phase (EBP) wherein BWTS non-compliance would not be penalised if operated in good faith. This paper presents a rationale for a robust global programme to test the efficacy of BWTS through Port State Control, using the U.K. as a ‘Case Study’. Rapid prognostic testing during port visits would be employed using technologies certified by regulatory agencies. Such indicative testing would not necessarily address every single aspect of international standards, but would represent robust compliance assessment, that would provide feedback data vital to the improvement of BWTS. Abbreviations: AIS: Aquatic Invasive Species; BWMC: Ballast Water Management Convention; BWTS: Ballast Water Treatment System; CFC: Chlorofluorocarbons; EBP: (IMO) Experience Building Phase; FDOM: Fluorescent Dissolved Organic Matter; HC: Hydrocarbons; HCF: Hydrofluorocarbons; HCFC: Hydrochlorofluorocarbons; IMO: International Maritime Organization; IOPP: International Oil Pollution Prevention; MARPOL: Marine Pollution (Convention); MEPC: IMO Marine Environmental Protection Committee; NOx: Nitrogen oxides; SERC: Smithsonian Environmental Research Center, Edgewater, Maryland, U.S.A.