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 –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?