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International Convention for the Control and Management of Ships’ Ballast Water and Sediments:A Paint Manufacturer’s Perspective
Colin WatsonNovember 2011
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Contents
• The Convention: What is it?
• Implementation timings and scope
• Who is involved?
• Ballast Water Treatment Systems
• Type Approval of BWT systems
• Implications to the Paint Manufacturer
• Current activities of International Paint
• Conclusions
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International Convention for the Control and Management of Ships’ Ballast Water: What is it?
• The development of international measures to minimise the transfer of invasive aquatic species (estimated that >7000 species moved around the world on a daily basis)
• These measures include:• Ballast water treatment• Bio-fouling of ships’ hulls
• Re-ballasting at sea currently provides the best available measure to reduce the risk of transfer of harmful aquatic organisms, but is subject to serious ship-safety limits. Even when it can be fully implemented, this technique is less than 100% effective in removing organisms from ballast water.
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International Convention for the Control and Management of Ships’ Ballast Water: What is it?
• For ballast, the Convention focuses on treating ballast water to achieve as high as possible kill rate of organisms and bacteria to ensure no potentially harmful non-native species is introduced into a port or coastal area.
• Resulted in the International Convention for the Control and Management of Ships’ Ballast Water and Sediments: 2004
Zebra Mussel
Mitten Crab Asian Kelp
Northern Pacific Seastar
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Implementation Timings & Scope
• IMO Ballast Water Management Convention will come into force 12 months after 30 IMO member states, representing 35% of world merchant shipping tonnage, have brought the convention into their own national legislation
• As of November 2011, 30 states, representing 26.4% of world tonnage had signed up. Therefore the Convention may come into force in the first half of 2013.
• The main obstacles to introduction were:• Lack of track record of ballast treatment system technologies• Lack of harmonised test procedure
• Certain areas of the world (e.g. California) have their own regulations (often much stricter than IMO)
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Implementation Timings & Scope
• The convention will cover :• Existing tonnage delivered before 2009, with ballast capacity 1500–5000m3, by
2015• Existing tonnage delivered before 2009, with ballast capacity <1500 or >5000m3,
by 2017• Newbuilding keels laid 2009 onwards with ballast capacity <5000m3 at delivery• Newbuilding keels laid 2009-2012, with ballast capacity > 5000m3 by 2017• Newbuilding keels laid 2012 onwards , with ballast capacity > 5000m3 upon
delivery• Ships participating in a programme approved by the Administration to test and
evaluate promising ballast water treatment technologies have a leeway of five years before having to comply with the requirements
• It is therefore estimated that >57,000 ships will need to retrofit ballast water treatment systems
• The investment cost of a ballast water treatment system is US$50K – US$2M
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International Convention for the Control and Management of Ships’ Ballast Water: Who is involved?
• The IMO re-established a correspondence group, covering in-water cleaning as well as ballast water, and agreed to establish a ballast water and a biofouling working group at its 14th session in March 2010
• The Ballast Water Working Group (BWWG) is to review and revise draft guidelines and consider appropriate time frames and a process for evaluating effectiveness of the convention
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Ballast Water Treatment Systems
• “Equipment which mechanically, physically, chemically or biologically processes either singularly or in combination to remove, render harmless or avoid the uptake or discharge of harmful organisms or pathogens. Ballast water treatment equipment may operate at the uptake or discharge of ballast water, during the voyage, or at a combination of these events”
• Can be shoreside or shipboard – the latter being much more flexible (but a much bigger issue for owners)
• There are several types of ballast water treatment system, broadly falling into 3 categories, with most systems using one or more of these methods in combination
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Ballast Water Treatment Systems
Chemical Treatment: Typical biocides include chlorine, chloride ions, chlorine dioxide, sodium hypochlorite and ozone
Actual equipment may use combined technologies
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Ballast Water Treatment Systems
• MECHANICAL• On ballast uptake
• PHYSICAL• On uptake, transit or discharge
• De-oxygenation strips with inert gas, e.g. N2, CO2 (latter could reduce pH)
• CHEMICAL• On uptake, transit or discharge• Gas or liquid stored on board or generated in-situ• Oxidising – chlorine, ozone*• Non-oxidising – acrolein, gluteraldehyde, menadione• Effectiveness depends on water temp., salinity, organic content etc.• Crew safety concern
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Ballast Water Treatment Systems
• Active substances of concern:
• Chlorine• Have history of testing with paint• No detrimental effect at low levels (current IP & IPPIC
recommendation up to 8ppm)
• Ozone• Increases oxygen content• Reported to increase corrosion rate, particularly at waterline /
splashzone• Tests have shown not to be detrimental to anticorrosive
properties of paint, but degrades surface (colour, texture)• May reduce anode effectiveness (oxidation)
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Ballast Water Treatment Systems: Type Approval
• Type approval is covered by two IMO guidelines:• Guideline G8: Type approval of ballast water management
systems• Guideline G9: Similar to G8 but deals with those systems
using active substances. For these systems, G9 must be carried out in addition to G8
• Type approval must include preliminary assessment of the corrosion effects of the system
• At DE48 (March 2005), it was stated that IMO’s procedures for the approval of active substance systems (G9) should take into account that the relevant substances / chemicals are compatible with the coating system
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Ballast Water Treatment Systems: Type Approval
• There are 2 levels of approval for active substance systems, basic and final
• It can take between 6 months and 2 years to gain approval
• To date (August 2011), approximately 22 active substance systems have been granted basic approval and 14 of these have received final approval
• Additionally, 6 systems not using active substances have approval
• However, there are around 59 systems on the market in total
• In addition to approval at IMO, systems can then obtain type approval from flag states (or their Recognised Organisations)
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Ballast Water Treatment Systems
Supplier System IMO approval
Type approval
Type Description Tested with coatings
IP “letter”
Comment
Alfa Laval Pureballast Final Norway (DNV)
Mechanical & Physical
Filtration / hydroxyl radicals
Should not affect coatings
Aquaworx AquaTriComb Basic Mechanical & Physical
Filtration / Ultrasound / UV
Should not affect coatings
Atlas-Danmark Applied Applied to LR
Mechanical & Chemical
Filtration / Electrochemical activated water
Uses Anolyte
Auramarine Crystal no Mechanical & Physical
Filtration / UV
COSCO Blue Ocean Shield
Basic Mechanical & Physical
Filtration / UV
DESMI Ocean Guard Basic Mechanical, Physical & Chemical
Filtration / Ozone / UV
Ecochlor Final Mechanical & Chemical
Filtration / Chlorine Dioxide
√ √ 5ppm chlorine dioxide
Envirotech BlueSeas Basic Mechanical & Chemical
Filter / Sodium hypochlorite
Envirotech Blueworld Basic Physical / Chemical
Filtration / Chlorine
12ppm
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Ballast Water Treatment Systems
Supplier System IMO approval
Type approval
Type Description Tested with coatings
IP “letter”
Comment
Erma First ESK Solutions S.A.
Erma First Basic Mechanical & Chemical
Filter / Sodium hypochlorite
GEA Westfalia BallastMaster Basic Mechanical & Chemical
Filtration / Chlorine
Greenship Final Mechanical & Physical
Sedimentor and Electrolyse system
Hamman SEDNA Final Germany Physical & chemical
Filtration/ disinfection (oxidising agent (Peraclean)
? GL state should not affect coatings
Hamworthy Greenship
SEDINOX Final Mechanical & Chemical
Filtration / Chlorination
1ppm chlorine?
Hitachi ClearBallast Final Japan Mechanical & Physical
Flocculent Injection, magnetic separation & filtration
Stated in brochure
Hyde Marine Hyde Guardian Yes (G8) UK (LR) Mechanical & Physical
Filtration / UV
Hyundai HI EcoBallast Final Mechanical & Physical
Filtration / UV
Marine CoatingsAll products supplied and technical advice or recommendations given are subject to our standard Conditions of Sale.
Ballast Water Treatment Systems
Supplier System IMO approval
Type approval
Type Description Tested with coatings
IP “letter”
Comment
Hyundai HI HiBallast Final Mechanical, Physical & Chemical
Filtration / Electrolysis / hypochlorite
JFE Engineering
BallastAce Final Japan Mechanical, Physical & Chemical
Filtration, / Chlorination / Cavitation
Kwang San Basic Mechanical, Physical & Chemical
Filtration, Electrochlorination / neutralization
Mahle NFV n/a Mechanical & Physical
Filtration / UV
MH Systems n/a Physical Disinfection
Deoxygenation / Carbonation
Mitsui Engineering
S-P Hybrid Final Mechanical, Physical & Chemical
Filtration / Ozone / Neutralisation
NEI-Marine Yes (G8) Liberia Physical Deoxygenation / Cavitation
√ √Nutech 03/NKCo
BlueBallast Final Korea Physical & Chemical
Ozone & Thiosulphate
√ (short-term)
√ 2.5ppm ozone
Marine CoatingsAll products supplied and technical advice or recommendations given are subject to our standard Conditions of Sale.
Ballast Water Treatment Systems
Supplier System IMO approval
Type approval
Type Description Tested with coatings
IP “letter”
Comment
Oceansaver Final Norway Mechanical & Physical
Filtration / Cavitation / Deoxygenation
√ Should not affect coating
Optimarin Yes (G8) Norway Physical & Chemical
Ozone & Thiosulphate
Panasia GLoEn-Patrol Final Korea Mechanical & Physical
Filtration / UV
Qingdao Headway
Oceanguard Final Mechanical & Physical
Filtration / Oxidation / Ultrasound
Resource Ballast Technology
Unitor Final South Africa Physical & Chemical
Ozone, hypochlorite, cavitation, filtration
√ 1.5ppm hypochlorite & 1.5ppm ozone
RWO CleanBallast Final Mechanical & Chemical
Filtration / Electrolysis
√Severn Trent de Nora
Balpure Final Mechanical & Chemical
Filtration / Hypochlorite
√ (with IP) √ 8ppm free chlorine
Katayama/Shinko / Nippon
Peraclean Ocean SKY-SYSTEM
Basic Chemical Peraclean Ocean + neutralisation
Peracetic acid / hydrogen peroxide
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Ballast Water Treatment Systems
Supplier System IMO approval
Type approval
Type Description Tested with coatings
IP “letter”
Comment
Siemens SiCure Basic Mechanical, Physical & Chemical
Filtration, Oxidation and Sodium Hypochlorite
√ (with IP) Test results look acceptable
SHI Purimar Basic Sodium Hypochlorite
Under test with IP
3ppm
SHI Neo Purimar Basic Sodium Hypochlorite
Under test with IP
10ppm
Sunrui BalClor Final Mechanical & Chemical
Filtration, Electrochlorination, neutralising agent
Techcross Electro-Cleen Final Korea Chemical Electrolytic Chlorination
√ √ 10ppm hypochlorous acid
Wartsila no Mechanical & Physical
Filtration / UV
21st Century Blue Ocean Guardian
Basic Filtration / Plasma / UV
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Ballast Water Treatment Systems: Testing
• If not designed, operated and maintained properly, BWM systems could detrimentally affect coatings, resulting in increased corrosion.
• The report of the 8th meeting of GESAMP-BWWG at MEPC 59th session in April 2009 stated:
• Testing should include uncoated substrates and marine epoxy (in accordance with IMO PSPC) coated steel
• Testing should be in accordance with ISO 2812-2 (immersion method)
• Assessment criteria are adhesion, blistering, rusting, cracking, delamination from scribe
• Paint manufacturers had no official input into the Convention or test method
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Ballast Water Treatment Systems: Testing
• A new test method has been proposed by NACE / Exova
• 12 month immersion / cycling test based on IMO PSPC water ballast tank test (MSC215(88) “cross-over” test method). Look at disbondment, corrosion creep, effect on surface etc.
• Testing in artificial sea water and duplicate testing in sea water dosed with BWMS active substance
• Aggressive active (oxidising) substances would be more likely to cause degradation, chalking etc.
• IPPIC has commented on the proposal as there are many areas of concern, and will (as independent paint manufacturers) be involved with the NACE process
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Ballast Water Treatment Systems: Testing
• Concentration of active substances should be considered• The effect of overdosing• Change in concentration with temperature, pH etc.• How long the active substance remains present in the ballast
water
• IPPIC are therefore carrying out their own testing (at an independent laboratory):• Generic coating types (PSPC approved plus coal tar epoxy)• Various levels of active substance• etc.
• The results of this testing will give information on test methodology but may also allow us to revise our current recommendations on maximum levels
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Implications to the Paint Manufacturer: Responsibility & Liability
• Ballast water management system suppliers have the responsibility to ensure no detrimental effect on coatings, and this is part of their type approval process
• However, what if there is a claim for coating failure?
• A major ballast tank coating failure claim could be several million US$
• It is almost certain the owner would claim against the coating manufacturer for coating failure
• The onus would therefore be on the coating manufacturer to investigate the cause of failure
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Implications to the Paint Manufacturer: Responsibility & Liability
• Currently, if there is coating failure in ballast tanks, this could be due to:• Surface preparation• Paint application• Coating failure
• Often a combination of more than one of these factors
• Very difficult to find the true cause
• Ballast water treatment systems add one more factor, and it would be very difficult to prove that this was the cause of coating failure
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Implications to the Paint Manufacturer: Responsibility & Liability
• We would therefore need to have confidence in the tests that the treatment system has passed to obtain type approval:
• Has the system been tested appropriately (in accordance with practice and including overdosing), and with relevant coatings?
• How was the test carried out?• Who carried out the test (treatment system manufacturer, paint
manufacturer, independent laboratory)?• Paint manufacturers could not test physical systems, only active
substances. But to what method? Simply adding chemicals to water and immersing coated panels may not reflect practice, e.g. active substances may only remain in the water for limited periods.
• If the test was not independent, was it verified independently?
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Implications to the Paint Manufacturer: Requirement to Recommend and “Approve”
• Despite the responsibility for proving ballast water treatment systems are “compatible” with coatings resting with the system manufacturer, there is no doubt owners and shipyards will come to the coating manufacturer for verification
• This is already happening, and with greater and greater frequency
• On what basis can the coating manufacturer base their response?
• Will treatment system suppliers provide details of their tests?• If a system fails a test, the coating manufacturer would not be
aware.
• Should the onus be on the body that has given type approval to provide these assurances?
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Implications to the Paint Manufacturer: Requirement to Recommend and “Approve”
• We would be naive if we think that the coating manufacturer will not be approached
• Currently, we can assume that those systems relying on mechanical and physical treatment methods only will not detrimentally affect coatings
• But active substances (chemicals) are likely to have a detrimental effect under certain conditions:• Substance type• Concentration• Time in contact with coating• Temperature, etc.
• Equipment suppliers (and paint manufacturers and approval bodies) need a reliable, harmonised test method
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Implications to the Paint Manufacturer: Requirement to Recommend and “Approve”
• Paint manufacturers can give recommendations / advice
• But we cannot “approve” treatment systems – this is the domain of the Administration (often Class)
• “Approval” may assume liability
• We can only say:• XXXX ballast water treatment system from YYYY has been tested for its effect on
epoxy ballast tank coatings by ZZZZ. Testing was carried out using a ballast tank coating, approved to IMO Resolution MSC.215(82). The results of these tests showed that, when operating under normal conditions and with active substances within the specified levels, the treatment system is unlikely to have a detrimental effect on epoxy ballast tank coatings approved to IMO Resolution MSC.215(82). This assumes that active substances will be present in ships’ water ballast tanks at similar levels to those used in the test.
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Current Activities of International Paint
• International Paint has approached ballast water treatment suppliers with offers to aid testing
• For those using mechanical / physical systems, this may involve supply of coated panels
• For those using active substances, this may involve supply of coated panels or offering to carry out immersion tests (but no recognised method)
• Some treatment suppliers have already carried out tests, often with our coatings, but at times without our knowledge
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Current Activities of IPPIC and Paint Manufacturers
• International Paint attended the 5th Annual Ballast Water Management Conference in London (December 2009)• Coatings would not have been mentioned if we had not been
present
• The 6th Annual Ballast Water Management Conference took place in December 2010, again in London.• International Paint, along with IPPIC (PSPC WG) attended.• Safinah organised a seminar immediately prior to the conference• A series of talks from interested parties who will voice their concerns regarding
ballast treatment systems effect on coatings and interaction with PSPC. Following the talks, discuss potential solutions, e.g. testing, and hopefully come to a consensus.
• IPPIC spoke on behalf of the marine coatings industry
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International Convention for the Control and Management of Ships’ Ballast Water: Conclusions
• The Convention will be implemented in the near future and will have enormous implications for ship owners and shipyards, and therefore for paint manufacturers
• International Paint (via IPPIC) will aim to have pro-active involvement in test method development, and/or interpretation.
• International Paint’s current position, until treatment systems have track record in coated ballast tanks and/or a harmonised test method is produced, is that:• Those systems which primarily rely on physical and
mechanical means or treatment are much less likely to have detrimental effects on ballast tank coatings than those which primarily rely on addition of active substances such as ozone or chlorine
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International Convention for the Control and Management of Ships’ Ballast Water
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