The following article is a summary of Mark Riggio’s participation in a discussion on the topic from BWMTech 2020. You can see the summary of his discussion on ensuring the proper installation of your BWTS here.
The Ballast Water Treatment System (BWTS) is incredibly important, but at the end of the day, it is at best tangential to the functioning of the vessel itself. It’s important for the BWTS manufacturers to have a comprehensive and readable manual and ballast water management plan.
The BWTS Operations Management System (OMS) is the bible for onboard ship maintenance. Mark likes to joke that the ballast water management plan in the OMS is good creative fiction – that is, the manufacturer needs to create the fiction of what could go wrong and then decide what you can do to address that. It is very important not to put a lot of text that no one will read but practical advice as to how to address actual problems – addressing poor water conditions, component maintenance and repairs, operating outside the design limitations, etc.. The key challenge is to communicate this information in a way that the reader will be able to understand and implement while at the same time ensuring that the installer and shipyard owner have all the information they need to install the system in the best way possible.
Feedback from Shipowners: The Good and the Bad
Manufacturers do not get sufficient feedback about their systems’ operation. As manufacturers, we hear every day about the 20% of our systems that have problems, yet we don’t hear from the other 80% which are working great, or perhaps even better than anticipated. Since Mark joined Filtersafe, the company has been reaching out to customers who don’t have problems to understand why it’s going well. It could be simply that the system was installed properly and they are following the OMS, or it could be they’ve found hacks for how to operate the system in difficult situations. We are encouraging this type of feedback across the industry.
We as an industry need to be bigger than a loose collection of competitors. We have a unique opportunity during the experience-building phase to ‘fail’ – but to learn from what is going on. We just want to work together as a partner and help improve systems, make better systems so that crews can use them better and we can learn from the crew’s experience to make it easier for them and decrease the impact these systems will have on shipping. Shipowners want a black box to make the problem go away, and we will continue to reach out to ship owners to get that feedback so we can arrive at a combined solution.
Placing the Blame for Problems
There is tension between the ship owners and the manufacturers as to who is responsible if there is a problem. On the one hand, the shipowner needs to make sure the system is installed properly, on the other hand, the manufacturer is the one who knows how it is supposed to be installed. If there is a problem, who is to blame?
Installing the BWTS is just one aspect of hundreds of other jobs happening on a ship during a shipyard period and the installation does not usually get the attention and treatment it deserves. The manufacturer cannot always be there for the entirety of the installation, and while they aren’t there, decisions can be made that have a fatal consequence to the system’s functionality. At the time in the shipyard, the decisions made don’t seem like they will cause a problem later on – obviously, otherwise they wouldn’t decide as such. Ultimately, a seemingly small decision such as changing a pipe placement can turn out to be a fatal flaw in the operation of the BWTS. It’s really important that the shipyard employees have the right education so they care about the proper functioning of the BWTS and not just finding ways to cut corners and save money on installation.
Mentality and Compliance
Part of the issue is that operators have not yet had to deal with widespread compliance testing. This has meant that
industry best practice became to do the best you can, and that’s good enough.
There needs to be a new culture in place of not relying on ‘good enough’. It’s not as if you can just open your BWTS and look at the screen and see if it’s still functioning at its peak with just a visual inspection, you need to test. The problem is ship owners are hesitant to check their system to see if they have a compliance issue. They don’t want to know if their ships aren’t filtering properly because then it creates a record of non-compliance.
At the same time, the US Coast Guard would rather a ship owner test and see that they aren’t complying and continue operating on a contingency measure while trying to solve the problem. If the shipowner is documenting that he is trying to solve the problem he’ll be in better shape than if a compliance officer happens to board his ship and discover he’s non-compliant. As an industry, we have to encourage ship owners to switch to indicative testing to preemptively find a problem, rather than waiting for them to be tested and discover it. The shipowner thinks he may be saving time on testing, but at the end of the day, it’s the environment that is suffering.
Looking Towards The Future: Bottlenecks and Orders
The session ended with a discussion about ramping up production post-COVID and the anticipated bottlenecks in production and manpower for installations.
The culpability in delays gets blamed on manufacturers, but part of that problem is with forecasting and shipowners not being transparent about their own installation plans and timelines. BWTS manufacturers have had inventory building up because shipowners weren’t buying at the rate anticipated. This caused a ripple effect across industries and supply chains – since manufacturers weren’t buying parts the way they previously had, inventory was also building up at suppliers, and a number of them went out of business because they couldn’t weather the economic slowdown. Filtersafe is working to bring production of some parts in-house so that they have more control over this aspect, but it still doesn’t solve the problem. Looking at Clarkson’s data vs IMO for installations in 2020, only about 60% of shipowners installed BWTS that said they would. Where are those vessels that didn’t install and when are they going to come in and put in their orders?
At the same time, the supply chain issue isn’t just a result of COVID-19. There have been issues supply chain issues since the beginning, causing EPCs and shipyard owners to be wary of working with companies they didn’t think would be able to deliver after-sales service and support.
Filtersafe has worked to disperse the risk by creating regional supply chains. They have a manufacturing center in Israel and Hong Kong so they draw from both of those areas. Also, as they’ve seen small companies go out of business, they started to bring some aspects of small part manufacturing in house. At the end of the day, these steps will only go so far if shipowners aren’t more transparent about their true plans for installation in the coming years.