From the desk of Rear Adm. John Nadeau, assistant commandant for prevention policy
In various contexts and in the course of many conversations, shipowners have expressed the expectation that ballast water management systems (BWMS) should be “plug and play” equipment. Owners who recently built ships and wrote BWMS specifications into the contracts with the expectation that, upon delivery, there would be sufficient space, power, and piping available for a future “plug and play” type system are now frustrated that the selection and installation of a BWMS requires additional work specific to the ship and its operating profile. Others expect a system that will “plug and play” into their operations and be effective under all conditions wherever they operate around the world. The different treatment technologies employed by the various BWMS manufacturers each have unique features and operational requirements that must be satisfied in order for the equipment to function properly. Owners should expect that fitting a BWMS to a specific vessel will require a thorough analysis of the vessel’s engineering systems, cargo operations, and trade routes.
While consultation with specialists and contractors may help vessel owners and operators meet this new challenge, it may not be appropriate to completely outsource this work and expect a “plug and play” capability. A more realistic expectation is that the selection, installation, operation, and maintenance of a BWMS will require analyses specific to the vessel and its operating profile. Every BWMS installation is a customized installation, and every ballast water management plan (BWMP) is a customized plan.
To comply with the regulations, vessel operators may have to modify the vessel design operations and, to some extent, their technical and logistical support operations. Some ships will require more extensive modifications and support. “Plug and play” may have been a reasonable expectation for other types of pollution control technologies, yet it is not a reasonable expectation for a BWMS. The operation of a BWMS directly impacts cargo operations. Cargo loading and discharge typically do not depend on the operation of an OWS, an exhaust scrubber, or a tank cleaner in the same way they depend on the operation of a BWMS. Because ballast water management is so closely linked to the ability to load or discharge cargo in real time, owners shouldn’t expect “plug and play” but instead should require the same level of diligence, analysis, and integration they would give to any other aspect of a cargo management system.
The complexity and breadth of a BWMS’s impact on vessel operations means that a “plug and play” solution is not likely to succeed. The preferred approach may be to “get in the game.” Successful efforts include additional design and engineering, a full review of maintenance requirements, a comprehensive comparison and analysis of BWMSs to shipboard operations, and the development and implementation of a crew training plan for the BWMS.
Read the other blogs in our new ballast water series:
12/1/2017: Ballast Water Series Part 5 – Contingency planning for ballast water management
11/30/2017: Ballast Water Series Part 4 – The “plug and play” ballast water management system
11/29/2017: Ballast Water Series Part 3 – Coast Guard BWMS type approval program update
11/28/2017: Ballast Water Series Part 2 – The Coast Guard’s focus on compliance
11/27/2017: New ballast water series from Coast Guard’s assistant commandant for prevention policy
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.
Categories: Commercial Vessel Compliance