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Conflicts and dangers in new IMO regulations

Conflicts and dangers in new IMO regulations. IMC 2008 Korea Dr 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)

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Conflicts and dangers in new IMO regulations

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  1. Conflicts and dangers in new IMO regulations IMC 2008 Korea Dr M Raouf Kattan – Safinah Ltd

  2. 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)

  3. 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

  4. IMO SBWS • To ensure that adequate measures to ensure control of alien species migration. • Aim to manage living organisms

  5. 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.

  6. 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.

  7. 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

  8. 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?.

  9. Treatment Systems • Systems employ different technologies such as: • Chemical additives (oxidants) • Ozone • Hypochlorites • UV radiation • Carbon Dioxide • Inert gases

  10. Potential problems Source Ballast water treatment technologies – PCE magazine July 2005

  11. 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.

  12. 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?

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