1. Green Ship Technology Conference Rotterdam March 11-12 th 2008 Water Ballast Tank regulations IMO BWMS Convention IMO PSPC SOLAS regulations Some challenges and concerns for Water Ballast Tank Coatings Rodney Towers C.Eng., MRINA Safinah Limited

2. SOLAS regulations Objective to raise the long term performance standards of WB tank coating systems Coatings to be performance tested and Type approved Surface preparation standards raised Much increased QC during application Shipbuilders to create a Coatings Technical File for ship on delivery Increased cost for shipbuilders & paint makers

3. Ballast Water Management Convention Objective to prevent environmental damage arising from the transport of harmful aquatic organisms from one sea region to another New technologies required for on board treatment of SW ballast Testing procedures required for acceptability of Active substances induced or added in treatment process Testing procedures required to confirm efficacy of treatment process

4. Ballast Water Management Convention No specific requirement for treatment technologies to be tested against WBT coatings No clear requirement which supports the long term WBT coating performance objective of SOLAS regulations

5. Ballast Water Management Convention BWMS systems should be tested for their corrosivity to other materials in a WB tank this implies tank coating materials BUT there are no guidelines for such coating tests AND coatings do not corrode

6. Ballast Water Management Convention Current status of ratification after 4 years 11 nations representing 3.6% of tonnage requirement for ratification 30 nations representing 35% of tonnage Norway & Spain are the only marine heavyweights There is a long way to go

7. Ballast Water Management Convention Main reasons for slow progress Many States unwilling to ratify ahead of some BWMS product choice for their shipowners Other reasons Convention will not apply to large ships until 2012 – long way off in Greek shipping terms In US, the USCG claim no legal authority to act until Congress approves appropriate Act with consequential problem for US manufacturers

8. BWMS approval process Flag State Administrations decide if BWMS proposals use Active substances or not make application to IMO if G9 Basic Approval of any Active substance required manage the evaluation of BWMS for efficacy make application to IMO for Final Approval are the authority to issue Type Approval Cert.

9. BWMS approval process IMO will initiate Basic Approval through GESAMP grant Basic Approval of acceptability of Active substance in BWMS issue Final Approval of Active substance after positive technical evaluation of BWMS by F/S Admin

10. BWMS approval process Important to understand that IMO do not involve with G8 approval procedures Basic & Final Approvals concern the Active substances Approvals are not for the efficacy of the BWMS do not monitor or collate any list of Type Approval Certificates as issued by F/S Admins

11. BWMS approval process Information from BWMS manufacturers IMO guidelines require multitude of tests duration of tests 18-24 months, even longer facilities of a whole lab may be needed cost of testing may be too high for small companies process slow and hugely expensive

12. BWMS technologies BWMS technologies fall into 2 categories systems using mostly physical actions systems using chemical additives

13. TechnologyActionApproval process IMO Basic IMO Final Type Approval Coating tests de-oxygenationphysicalG8not req not req yes light sourcephysicalG9yes expect mid 08 no cavitation + de-oxygenation + electro disinfection physicalG9yesexpect end 08 pendingyes ? hydroclonic filtration + biodegradeable chem physical + chem G9yesimminentpendingyes ozone injection + electrolysis physicalG9Yesno info split pipe + ozonephysicalG9yesno info electro-disinfectionphysical + chem G9yesno info electrolysis of s/waterphysicalno info Summary table

14. BWMS technologies effect on coatings Concerns about WBT coating integrity Change in BW composition after treatment Testing procedures for coating integrity Change in pH

15. BWMS technologies effect on coatings Concerns are Coatings are permeable Risk is that chemicals either induced by physical treatments or by addition will create a new composition of BW which might be too aggressive for a WBT coating Soluble gases, hydroxyl, chloride, bromate, hydrobromous ions, hydrogen peroxide and peracetic acids are all Active substances

16. BWM Convention Responsibilities for testing Current situation F/S Admin responsible for deciding G8 or G9 approval procedure of BWMS BWMS maker responsible for all testing required for G8 & G9 procedures IMO responsible for providing the Guidelines No Guidelines for BWMS makers about how to test their systems against WBT coating systems

17. Challenges raised for Coating Manufacturers SOLAS PSPC –development of new technology coatings to assist shipbuilders regain productivity lost due IMO regulations BWM –some BWMS induce, give rise to or use various chemicals which can be aggressive to epoxy coatings –purity of inert gas generated –oxygen depletion –caution needed with hypochlorites, chlorides, hydroxyls, hydrogen peroxide, hydrobromous and peracetic acids –need to know PSPC Type approved coatings will not be damaged

18. Challenges raised for BWMS Manufacturers need for Guidelines on what and how to test their systems against PSPC Type approved WBT coatings additional testing costs seem likely responsibility for testing will be for makers Shipbuilders guarantee requirements likely to include no long term negative effects on WBT coating systems used by yard ( will include shop primer)

19. Challenges raised for Shipbuilders could benefit financially from new technology coatings which help to regain productivity lost due PSPC regs production issues may lead shipyards to conclude WBT coatings need to become a yard supply item - as shop primer under shipyard control, can new warranty terms, longer than 12 months, for WBT coating systems be developed ? Shipbuilders likely to make severe warranty demands on BWMS suppliers before accepting their supply

20. Challenges raised for IMO Amendment to BWM Convention needed which will link with and support PSPC long term performance objectives for WBT coating systems terminology used for approvals in BWM Convention is confusing no composite list of BWMS Type Approvals is readily available - F/States and Class likely to have some need to access this info - who can provide this?