1. PSPC and the BW Convention Tokyo Tripartite Meeting, 2010

2. History of the BW Convention Adopted February 2004 (Not Yet Ratified) Guidelines for Approval of Ballast Water Management Systems (G8) adopted in July 2005 as MEPC.125(53), revised October 2008 Procedure for Approval of Ballast Water Management Systems That Make Use of Active Substances (G9) adopted in July 2005 as MEPC.126(53), revised October 2008

3. General Text of G8/G9 G8 Section 1.6 - The operation of ballast water management systems should not impair the health and safety of the ship or personnel… G8 Annex Section 1.3 - …consider the potential for longer- term impacts to the safety of the crew and vessel through effects of the BWMS on corrosion in the ballast system and other spaces. G9 Section 4.2.1 - A proposal for approval should include information on the… corrosivity to the materials or equipment of normal ship construction

4. Specific Recommendations The April 2009 Report of the eighth meeting of the GESAMP-Ballast Water Working Group (MEPC 59/2/16) in Section 5.1 provides detailed corrosion and coating testing recommendations for evaluating the effect of BWMS on coatings and other materials of ship construction. These are recommendations, and do not require previously reviewed systems to conduct such testing. The number of BWM technologies reviewed by the GESAMP BWWG for Basic or Final for MEPC 61 was 13. The Chairman of the GESAMP BWWG reported that four technologies reviewed since April 2009 include results from some or all of the testing recommended in MEPC 59/2/16. The October 2010 Guidance for Administrations on the type approval process for ballast water management systems in accordance with Guidelines (G8) (BWM.2/Circ.28) in Section 3.1.13.2 recommends a preliminary assessment of the corrosion effects of the system proposed

5. BWT Technologies There are currently 12 IMO Type Approved ballast water treatment technologies. Six of these make use of oxidizing chemicals. The 2010 Lloyd’s Register Ballast Water Treatment Technology handbook lists 47 ballast water treatment technologies in development; 20 of these use either ozone, chlorine, chlorine dioxide, peracetic acid, or a combination of these oxidizers. The effective dose of an oxidizing biocide is measured by Total Residual Oxidant (TRO). The residual is what’s left after the chemical has reacted with everything else.

6. Oxidizers Cause Oxidation International Paint’s Intergard 423 Ballast Tank Coating exposed to less than 1.0 mg/l ozone for 15 days. Ozone BW treatment dose range = 1.0 to 2.0 mg/l TRO. Source: SHIP BALLAST TANK INTEGRITY EFFECTS OF USING OZONE AS A BALLAST WATER TREATMENT METHODOLOGY, BMT Fleet Technology, Ltd., 2003

7. History of the PSPC Amendment to SOLAS regulations II-1/3-2 and XII/6 adopted in December 2006 as IMO Resolution MSC.215(82). Requires all ballast tank coatings to be Type Approved according to the test procedures. Target useful life to be 15 years. PSPC Maintenance Rules make ship operators responsible for maintaining ballast tanks in PSPC condition. In-service ballast tank coating repair must be carried out using PSPC procedures.

8. Text of the PSPC “The actual useful life will vary, depending on numerous variables including actual conditions encountered in service.” Table 1, 1.1 - The selection of the coating system shall be considered by the parties involved with respect to the service conditions and planned maintenance. Annex 1, Appendix 1, Section 1 - Test on simulated ballast tank conditions shall satisfy each of the following conditions: 1.5 As simulating the condition of actual ballast tank, the test cycle runs for two weeks with natural or artificial seawater and one week empty. No direct reference is made to ballast water treatment.

9. Interpretation IACS Interpretation of PSPC (DE 52/17) - The Type Approval Certificate shall indicate the Product and the Shop Primer tested. The certificate shall also indicate other type approved shop primers with which the product may be used which have under gone the cross over test in a laboratory meeting the requirements in Method A, 1.1 of this UI. What about the other side of the coating? The side that is exposed to the atmosphere? Should there be a consideration of actual ballast tank condition other than natural seawater?