Over the last months, the pressure to decarbonise shipping has been significantly increased, with initiatives and relevant points been touched upon globally with COP26 or regionally with the “Fit for 55” legislation proposal.

Although it’s been over four years since the Ballast Water Management (BWM) Convention entered into force, it’s anticipated that the peak installation period for ballast water treatment systems will be from now until 2024. This is due to the compliance schedule being based on a vessel’s second International Oil Pollution Prevention (IOPP) renewal survey. Additionally, ships that are not issued with IOPP certificates (less than 400 GT), but have to comply with the BWM convention, also have to comply by 2024.
Installing a treatment system is the most common way of complying with the D-2 Ballast Water Performance Standard but meeting the demand of the number of ships that still need to install systems is going to be a considerable challenge for the industry. The full installation process, from planning to installation to receiving a compliance certificate, can take months.
There are a number of factors that need to be considered when retrofitting a treatment system on an existing ship. Shipowners should work backwards from their second IOPP renewal survey date and start planning what type of treatment system they need based on their operational requirements. The COVID-19 pandemic has also affected the implementation schedule due to the supply chain disruption affecting system components, microchips and support parts like piping, cables, etc. Some ballast water treatment system manufacturers have experienced difficulties sourcing the required components to produce the systems and have been forced to move in to just-in-time production, meaning shipowners must order ballast water treatment systems in advance.
Operational issues
One of the major issues highlighted by shipowners is that their ballast water treatment system cannot be used in certain weather conditions or ports due to high sediment load. There have been several submissions to MEPC/PPR IMO sub-committees regarding this issue.
This has led to shipowners taking water in port without treatment, bypassing the system and then exchanging at sea before they visit the next port. As a result of this, we have recently seen a number of manufacturers produce filter-less ballast water treatment systems – essentially a modified version of their existing chemical injection and electro-chlorination type systems. A number of filter-less systems have now been type approved and to help shipowners address this issue, LR continues to work with several manufacturers to type approve their filter-less systems. LR also working with manufacturers to type approve their third and fourth generation ballast water treatment systems.
Shipowners that are yet to install a ballast water treatment system may now be at an advantage, as the increased number of choices may help alleviate some of the issues experienced by early adopters.
Another issue that has been highlighted by Shipowners is related to maintaining operating compliance. This is closely linked with the need for adequate crew training. If the crew has not been sufficiently trained on the operation and maintenance of the installed BWMS, it would not be possible for them to maintain the system in good working condition, thus meeting the discharge regulations. Some of the problems which may be encountered during BWMS operation could be an “easy fix”
for a knowledgeable and well-trained crew and this can be important in avoiding disruptions during operations.
Most crews are trained by the BWMS Manufacturer during installation and commissioning of the system. However, it is also very important to ensure that this knowledge is maintained following a crew change, for example. Therefore, investing in adequate and regular training of the ships’ crews on the operation and maintenance of BWMS is of paramount importance.
Regulatory requirements
Shipowners also need to consider the specific requirements of their flag of choice. With a lot of flag Administrations becoming a signatory to the BWM Convention, we are seeing more and more flags implementing their own local regulations. For example, a ballast water treatment system installed on a Greek flagged vessel must have a type approval issued by the flag itself or by a Recognized Organization on behalf of the flag. This additional process can take several days to weeks, and this is just one possible requirement, there may be more to consider.
LR can assist with the approval process through issuing a type approval on behalf of many administrations if required. LR can also assess existing ballast water treatment system type approvals and review relevant data to issue a subsequent type approval on behalf of the respective flag.
Despite the industry being aware of the compliance deadline for years, there are still some shipowners who are yet to act. Effective planning needs to be the priority with the compliance deadline looming and the industry on the brink of a peak installation period.
Commissioning testing requirements explained
Commissioning testing is a mandatory requirement that forms
part of the installation and commissioning survey of ballast water treatment systems, prior to certification. The requirement will enter into force on 1 June 2022. There are already certain flag Administrations, such as Greece, Cyprus, Australia, and Singapore, that are mandating commissioning testing, but from June it will be a requirement for all ships.
Firstly, commissioning testing shouldn’t be confused with com- missioning of the ballast water treatment system. Installation and commissioning of the system as well as commissioning testing are all part of the initial survey, which must be completed in accordance with class and statutory requirements. The resulting commission- ing testing report is a requirement for a completion of successful survey and issuance of International Ballast Water Management Certificate.
Secondly, commissioning testing consists of two parts. One is the sampling and analysis of ballast water. The other part is assessing the self-monitoring parameters work as intended. The intention of the commissioning testing is not to retest the ballast water treatment system (as it is already type approved), but to ensure that the ballast water management system has been installed correctly and commissioned to meet the required performance standards.
Thirdly, there are certain requirements as per IMO Circ.70/Rev.1 as to how commissioning testing needs to be carried out. One very important point to note is that the commissioning testing needs to be conducted independently from the ballast water treatment system manufacturer and suppliers to avoid conflict of interest. So the question for shipowners is, who can do the commissioning testing? For LR classed ships the commissioning testing must be conducted by an approved service provider only (as of 1st June 2022). As part of the LR approved service provider scheme, LR audits the company through the review of their commissioning testing experience, knowledge and operational procedures to ensure they are fit for purpose. However, it is the shipowner’s responsibility to assess if the service provider has a conflict of interest with the ballast water treatment system manufacturer or installer.
Some ballast water treatment system manufacturers or yard/engineering companies offer turnkey solutions that include installation, and possibly even commissioning testing, as a complete package, but the commissioning testing must be carried out by an independent party. As part of the commercial contract, it may be paid for by the manufacturer/supplier, which is permitted as long as the com- missioning testing is a completely independent process conducted by a different entity/supplier.
Supporting the Greek shipping community
LR’s office in Greece has developed an in-depth technical knowledge and experience with ballast water treatment technologies, which has reached to the successful completion of all necessary BWMS installation reviews for over 500 vessels of various ship types and sizes locally. Utilising the right mix of skills, knowledge and experience, we assist local clients in BWMS installations, from the initial design stage through to final certification and commissioning of the systems.
LR’s local team in Athens covers a broad spectrum of activities including project management, design appraisal and onboard survey, providing the assurance required by all project stakeholders, while ensuring the added value and commitment to safety based on well-established standards and procedures.
With less than 1000 days until 8 September 2024, where the shipping industry has to meet the deadline for compliance with the Convention’s D-2 standard, it is estimated that more than 30,000 vessels are yet to install a BWMS. All stakeholders, from Shipowners to BWMS Manufacturers and Regulators, need to act timely and work closely together for this deadline to be achieved.

* Principal Specialist and Technical Authority for Ballast Water Management, Lloyd’s Register (Right) -Senior Specialist and Technical Authority for Ballast Water Management Plans, Lloyd’s Register (Left)

Decarbonization is probably the most significant challenge the shipping industry is facing today. In the context of several demanding requirements to be complied with over the upcoming years, in the short-term owners need to implement the new IMO EEXI and CII requirements. These require a systematic approach and early action to make sure that fleets comply in time, but most importantly timely implementation of the necessary upgrades to stay operationally competitive. Read the articlr of Dr. Loizos Isaias, PhD, VP-Manager Maritime Service Centre, Region Sout East Europe, M. East & Africa, DNV

Shipping is an important economic sector, responsible for
transporting the majority of goods around the globe.

The third ABS Low Carbon Outlook demonstrates challenges for the industry and provides an integrated approach to strategy, writes Georgios Plevrakis, Vice President, Global Sustainability, ABS.
For the third in the series of Low Carbon Shipping Outlooks, ABS has updated the maritime sector’s progress towards reducing its emissions, analysed how it will be affected by external decarbonization trends, and presented a life-cycle or value chain perspective of GHG emissions of leading alternative marine fuels.
The maritime industry is clearly undergoing a significant transformation centred around decarbonization motivated by International Maritime Organization (IMO) regulations, the financial institutions that support new vessel construction and retrofits and market-based measures and incentives emerging from the multinational charterer community.
It is critical for shipowners and operators to understand the expect- ed changes in the global supply chains in order to plan their future fleet composition and renewal strategy.
Short Term Challenges
The short-term IMO measures, the Energy Efficiency Existing Ship Index (EEXI) and Carbon Intensity Indicator (CII) create a very challenging landscape for many vessels of the global fleet. Some vessel segments may experience early vessel retirement due to their inability to comply.
Analysis of qualified ships from five key shipping categories — bulk carriers, tankers, gas carriers, LNG carriers and containerships
— revealed the following about compliance with the IMO’s EEXI regulation:
A large section of the global tanker fleet is expected to have difficulty meeting the EEXI requirements. Smaller dwt segments, such as Aframax tankers, are expected to meet the requirements more comfortably than larger tankers.
A similarly large fraction of the global bulk carrier fleet is expected to also have difficulty meeting the EEXI requirements. Again, smaller dwt segments, such as Panamax bulkers, are expected to meet the requirements more comfortably than larger vessels, such as Capesizes or very large ore carriers (VLOCs).
Gas carriers — particularly those of higher dwt capacity — have proven capable to meet the EEXI requirements.
LNG carriers with dual-fuel or trifuel diesel electric propulsion or two-stroke dual-fuel engines are expected to meet the EEXI regulations. However, those LNG carriers propelled by steam turbines will face significant challenges.
Containerships above 80,000 dwt are expected to meet the EEXI requirements. However, smaller dwt segments are expected to face
some challenges with EEXI compliance.
Fuel life-cycle analysis
The current regulatory framework focuses on vessel emissions (tank-to-wake) rather than the life-cycle emissions of a fuel (well- to-wake), though recent discussions at IMO have included whether to change this assessment to a life-cycle basis as this provides a more accurate assessment of total carbon footprint.
The required scale up of technology for green fuel production is significant - by an order of magnitude - before they can be widely adopted by the global fleet.
The life-cycle analysis clearly identifies the need for green ammonia and hydrogen production in order to achieve meaningful GHG emissions reduction from these zero-carbon fuels.
LNG can provide almost 25 percent reduction in carbon emissions on a tank-to-wake basis; however, the reduction will fall depending on combustion principles if a life cycle approach is adopted. Methanol can be made carbon neutral on a well-to-wake basis. Ammonia offers very low well-to-wake emissions, but the use of pilot oil contributes to carbon emissions from the vessel.
Biofuels do not offer any tank-to-wake emissions reduction, but they can offer benefits on the well-to-tank component. However, the feedstock and production pathway greatly affect their well-to-tank emissions.
The advent of modern dual-fuel engine technology makes the transition to low and zero-carbon fuels easier to achieve than the recent past. The transition to alternative fuels can be made much more at- tractive if it is planned at the newbuilding design stage. In particular, the design of the propulsion system should be specified based on all the fuels that could be used throughout the life of the vessel.
Towards a Low Carbon Fleet
Designing a low-carbon fleet is a continuing process. Shipowners need to be conscious of using the lessons from the transition to decarbonization to build a cycle of continuous process improvement: they can do this by getting to know the impact of decarbonization on all aspects of their business and using that information to power the cycle.
Because the technological solutions that support the decarbonization of international shipping will continue to advance over time, so should safety strategies and the ability to adapt to changes with the least possible disruption.
Shipping is an integral part of the value chain, including its carbon footprint. By using carbon-accounting principles to evaluate the contribution of each link, shipowners can gain information that helps to identify areas in need of improvement and targets for carbon reduction.
However, a harmonized decarbonization strategy is just the first step towards gaining a competitive advantage. ABS is working with clients on strategies and principles that can be used to help meet the requirements of charterers, secure access to green financing and support a company’s sustainability strategy.
The end goal is for the shipowner to use their decarbonization strategy to achieve corporate targets and meet international regulations, but the plan can be designed to go beyond compliance and form the cornerstone of a company’s business strategy.
*Vice President, Global Sustainability, ABS

The use of AI-enabled voice and chatbots will deliver insights to a wider range of maritime stake- holders and make data-driven decision making the norm, says Smarty Mathew John, Vice President, Digital Solutions, ABS.