Colin Watson November 2011

1. International Convention for the Control and Management of Ships’ Ballast Water and Sediments:A Paint Manufacturer’s Perspective Colin Watson November 2011

2. 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

3. 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.

4. 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 Asian Kelp Mitten Crab Zebra Mussel Northern Pacific Seastar

5. 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)

6. 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

7. 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

8. 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

9. Ballast Water Treatment Systems Chemical Treatment: Typical biocides include chlorine, chloride ions, chlorine dioxide, sodium hypochlorite and ozone Actual equipment may use combined technologies

10. 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

11. 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)

12. 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

13. 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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19. 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

20. 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

21. 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

22. 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

23. 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

24. 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?

25. 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?

26. 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

27. 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.

28. 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

29. 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

30. 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

31. International Convention for the Control and Management of Ships’ Ballast Water • THANK YOU • QUESTIONS?