Conflicts and dangers in new IMO regulations

IMC 2008 KoreaDr 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?