Ballast Water Management Plan: Critical Analysis and Recommendations for James Fisher Everard

Introduction
The seas and oceans of the world have for centuries presented a picture of an endless landscape, a huge section of the environment that man was largely ignorant of, presenting threats to the survival to those working with it, and was impossible to control. For previous generations, it was almost inconceivable that oil waste discharged in the seas could seriously affect the marine eco-system. In many ways the history of marine pollution is the pinnacle of the principle of ‘dilute and disperse’ (O’Sullivan, 2010). This principle is behind other pollution control measures such as uncontained landfill sites and the tall-stacks policies of the 1950s and 1960s for controlling air pollution. The idea is that toxic or nuisance substances lose their harmful qualities if dispersed into an environment where they can become highly diluted. In small quantities this is not unreasonable (Pinder and Slack, 2004). However, as discharges increase in quantity, the principle breaks down. The sea was regarded, for a long time, as an unlimited location where dilute waste from the land could be disposed of. Nowadays, we realise that these types of discharges are harmful to the environment, to marine species as well as for humans (Pinder and Slack, 2004; Katharine et al, 2013).
The following report critically analyses current legislation, policies and global practices regarding ballast water management. The pollution issues are assessed on a national, port, and ship level, and recommendations are presented for a UK ship company: James Fisher Everard in the efficient management of their ballast water.

Ballast Water Pollution
Ballast Water is a substance that is used aboard a ship to weigh or balance it and it is used when it’s carrying little or no cargo. At the end of the trip the ballast water is usually deposited back into the sea (Firestone and Corbett, 2006).
Ballast water generates two principal pollution issues:
Removal of ballast water from polluted water (that contains, for instance heavy metals or some persistent organics) and its subsequent discharge into a cleaner environment;
Transferring living organisms from one area to a distant region (Endresen, et al., 2003).
Because ships circulate from one port to another transporting goods and using ballast water, they inadvertently introduce invasive varieties of marine life in new locations. Actually thousands of marine species are introduced along with the water into the ships ballast tanks (ICCMS, 2004).
Similar to floating aquariums, these species include small invertebrates, eggs, bacteria, other microbes and sometimes fish. The use of ballast water, and the circumstances inside the ballast tanks affect the chances of survival of each organism. According to McConnell (2003), the majority of the species do not survive the journey. Those that do usually have a difficult time adjusting to their new environment, particularly when they are moved between different water conditions (e.g. salt water to fresh water).
If all factors are favourable and the introduced species survives and creates a reproductive population in the host environment, then ballasting could be advantageous to the marine eco-system (Stephan and Matej, 2012). However, as argued by Low (2003), ballasting usually endangers marine eco-systems, as most newly introduced species are invasive, out-compete native species, and threaten already endangered species including even human health.
Invasion of Unwanted Water
The ballast water used by ships to ensure their stability and ability to make manoeuvres contains many microscopic organisms, some of which, after surviving the voyage, contaminate the new environment in which they are released when the vessel changes its ballast water (Gov.uk, 2012). Consequently, these non-native species may drastically affect the new ecosystems, which results in ecological, economical and health-related risks (Endresen et al, 2003).
A large number of organisms have been disseminated in the United Kingdom, among them being Chinese mitten crabs, barnacles and microscopic organisms. For the time being, this process has raised only locally contained issues, but in other places around the world, these kind of organisms, that have been introduced as a result of ballast water are the source for significant economic, health and environmental disturbances (Hulsmann and Galil, 2011).
The introduction of the European Zebra mussel into the Great Lakes, USA as a result of ballast water has been documented extensively (Stephan and Matej, 2012; O’Sullivan, 2010). It is estimated that the expenses generated by containing and cleaning of these phenomenon has topped $400-$500 million per year just in the area of Great Lakes, USA. Nevertheless, the problem exceeds beyond the boundaries of North America. Another well-known case has occurred in the Black Sea, where the North-American carnivorous comb jellyfish has reached abnormal numbers.
This sort of issues could affect the well-being of the population, as documented in the movement of microscopic dinoflagellates from oriental countries through to Southern America and into Australia. These dinoflagellates cause paralytic shellfish poisoning and have been caused as a result of ballast water movements (European Environment Agency, 2011).
Furthermore, IMO (2005) dictate that there are ecological, economic and public health concerns from the use of indiscriminate transfer of ballast water, as shown in the table below:
Ecological Effects
•Predation
•Parasitism
•Competition
•Introduction of new Pathogens
•Genetic changes
•Habitat alterations
•Species shifts/loss of biodiversityEconomic Impacts
• Industrial water users
• Municipal water user
• Nuclear power plants
• Other water sports
• Damages to levees/dams
• Commercial & RecreationalPublic Health Concerns
•Cholera risk
•Paralytic Shellfish
•Poising
•Harmful blooms
Source: IMO (2005); O’Sullivan (2010).
Ballast Water Legislation and Policies
Migration of unwanted ballast water therefore results in adverse effect for the host marine eco-system and it’s surrounding human population. It is for this reason that Matej et al (2012) argued that the need to control the discharge of ballast water is critical and should be handled on an international basis. The International Convention for the Control and Management of Ships Ballast Water and Sediments (BWC) has therefore proposed several policies and legislations regarding the management of ballast water.
These policies and legislations are aimed at offering a structure that would deal with the issue of ballast substances (water). The event resulted in two performance standards for ballast water discharge, namely D1 and D2. The former is a standard for ballast water exchange and regulates the volume that has to be replaced, while the latter deals with the various treatments of ballast water together with the organisms that are allowed to remain after the water treatment process (ICCMS, 2004).
Ballast water exchange, involves the control of the dissemination of invasive species by discharging of port or coastal water and exchanging it with new water. This is usually conducted at a distance of at-least ‘two hundred nautical miles from the nearest shore and in water that is at least two hundred meters deep’. In situations where the vessel cannot achieve this, the exchange can be conducted in areas at least ‘fifty nautical miles from the nearest shore and where the depth of the water is of at least 200 metres’ (ICCMS, 2004).
The enactment of this legislation has received some criticism, notably from Firestone and Corbett (2006), who argue that it is difficult to effectively enforce such legislation due to lack of required resources by international bodies or co-operation by local port authorities. The Ballast Water Management convention is meant to enforce this legislation by supervising tankers several times yearly based on a vessel’s ballast-tank capacity and the year of its construction, however, as stated by the ICCMS (2004), this convention is currently not in force. Pinder and Slack (2004) also argued that water discharged within 200 nautical miles could circulate back towards their port of origin, and could essentially invalidate any benefit that could have accrued. However, Katherine et al (2013), citing a hydrological study, however argued that water discharged after 200 nautical miles does not circulate backwards. However, the issue about enforcement still persists.
The BWC also requires for all ships to have a Ballast Water and Sediments Management Plan and follow through on ballast substances manipulation procedures to a certain standard. Furthermore:
“Regulation D-3 of the Ballast Water Management Convention beseeches that ballast water management systems used to comply with the Convention must be approved by the Administration taking into account the Guidelines for approval of ballast water management systems (G8)” (IMO, 2005).
Ballast water also causes environmental disturbances due to its damaging effects encountered by various organisms. However Pinder and Slack (2004) argue that it is impossible to accurately measure the impact of ballast water on the environment as:
“the densities and composition of organisms carried by individual vessels are extremely variable, and there is no simple relationship between the quantity of ballast discharged and environmental impact”.
Furthermore, the water source, compatibility of the eco-system of the source and host ports, and the interaction between native and discharged species are of key importance in estimating risks of introduced organisms into their new eco-systems (Pinder and Slack, 2004). Thereby noting that it is somewhat difficult to measure risks between individual shipping routes or ballast water movements. However, as argued by Hulsmann and Galil (2001), this does not negate the fact that ballast water movement could be dangerous in certain circumstances, and this is the reason why legislations and policies should not only be enacted, but also enforced. IMO (1997) documents that due to the identification of these risks, state and international procedures to decrease the risk of external organisms being introduced have been discussed repeatedly across a time p of over a decade (IMO 1997).
This threat has led to the development of a range of tools that aim to help experts assess the risk of introducing species to other environments (IMO 2002). Among the other guidelines the Convention issued are the ones that specify ballast water management plans, the recording of ballast management procedures and the efforts made to minimise the uptake of organisms, the removal of sediments and the avoidance of unnecessary ballast water discharge. Ships ought to carry out ballast water management plans together with the adjacent safety procedures for their crew. The plans have to contain detailed descriptions of the actions performed to implement the requirements for ballast water procedures. Furthermore, they have to be approved by an acknowledged Classification Society; the ships are also advised to have Ballast Water Record Books, in which all the ballast water operations are to be recorded (IMO, 2005). Most of these, according to Firestone and Corbette (2006) are difficult to enforce, particularly in the UK where compliance with these guidelines are not a legal requirement in the UK, even though registered vessels are strongly advised to follow them. This therefore poses the question of how ballast water can be managed in an efficient and effective manner, without national authorities having to result to more stringent forms of legislation.
A potential solution could however be more commercial. Commercial justifications for the reduction in ballast water transportation seem to be making progress. Assuming ballast water represents up to 30 per cent of the cargo transported per year, on a global level, the total quantity of ballast water transported is estimated to be somewhere around 2.8 billion tons (Endersen et al. 2003). According to Endresen et al (2003), commercial ships now carry as much cargo as they can, in order to reduce the amount of ballast water they hold. A practice that is argued by Stephan and Matej (2012), to be much more effective than any form of legislation or policy restricting conventional ballast water use.
Port-States Procedures
IMO (2005) dictates that every ship should implement and apply an individual and unique procedure for ballast water management. This procedure ought to provide detailed safety measures for the vessel, and the crew, a detailed description of ship’s actions and for the safe removal of sediments at sea and the coast. The Ballast Water Management plan should also include procedures for coordinating shipboard, referring to discharge to the sea according to procedures regulated by the establishments governing the State. All of these are required to be in the working language of the ship.
In order to assist a ship with the appropriate implementation of their precautionary practices, Port States are also tasked with the responsibility to inform local agents and the ships in the area on methods and areas at which they can minimise uptake of ballast water. They are also required to inform ships about areas with blooms of phytoplanktons such as crimson tides, nearby sewage outfalls and dredging operations. Port-states are also required to make known regions with poor tidal flushing, and about periods where tidal streams are disturbing.
According to Endresen et al (2003), this provides a useful platform and support system to assist ship owners looking to follow legislations and manage ballast water effectively. It ensures that ship captains are well informed and could theoretically reduce the impact of pollution as a result of ballast water. The main question this practice poses is therefore whether port authorities provide sufficient support and ship owners as recommended. According to O’Sullivan (2010), some nations have imposed specific regulation on the evacuation of the ships’ ballast water, which are supposed to reduce the settlement of non-native species within their rivers and estuaries.
However, a study by Katherine et al (2013), on the difficulties in obtaining representative samples of compliance with the Ballast Water Convention, found that several port authorities, particularly in developing countries, did not comply with these legislations, care about ballast water discharge, and did not provide sufficient support to allow ship captains dispose of ballast water effectively. In developed states, including the U.K., special regulations for ballast water management have been implemented, which include a request that ship owners voluntarily co-operate in applying the recommended techniques. Customary measures have also been designed concerning the acceptance of quarantine authorities regarding the maximal level of acceptability desired by the port state (Firestone and Corbette, 2006).
Ballast Water Management at James Fisher Everard
James Fisher Everard (JFE) is a leading British company that specialises in providing shipping services to Marine, Oil and Gas and other ‘high assurance industries’. The company began its operations as a ship operator and today, 170 years later, is a leading provider of marine services. JFE has been operating tankers for over 40 years, with a fleet of 18 tankers with a capacity of 3,000 – 11,000 tons of petroleum products (James Fisher Everard, 2013).
JFE has adopted a basic waste management plan, based on voluntary requirement by the UK Port Authority. The following Ballast Water Management plan provides recommendations that JFE could use to improve their ballast water management plan and procedures.
According to Matej et al (2012), the current procedure for keeping ballast waste under control is through a process known as ‘mid-ocean ballast water exchange’, which is based on the assumption that deep ocean water contains a small number of organisms and those that live there will not be able to resist in a costal or fresh water areas. According to James Fisher’s 2012 Annual Report, this is how they currently manage ballast water waste. However, as argued by Katharine et al (2013) the evacuation procedure can be risky, because the procedure of pumping out and refilling tanks sequentially can damage longitudinal integrity if the vessel is not built for such an operation. Also if sea conditions get bad (e.g. a sea storm) when the tanks are incompletely evacuated, accidents can happen and this could destroy bulkheads.
An ideal substitute could be for the ship to discharge its ballast water in stages. This option, as described by Firestone and Corbette (2006) involves flushing on a continuous basis, which requires the tank to be pumped at a volume that exceeds at least three times the volume of the tank. This procedure has also been supported by Katherine et al (2013), whose empirical study identified this method as a sustainable replacement to the mid-ocean ballast water exchange. JFE could therefore improve its ballast water management practices by substituting its mid-ocean ballast water exchange procedure for the more sustainably flushing procedure.
This procedure however has shortages, because it can allow unwanted organisms to survive in the sediments. It is also equipment demanding because the tanks are not designed for constant evacuation of ballast substances. It is for this reason that Firestone and Corbette (2006) state that “it may be necessary to route the overflow through opened manholes, but this is not always possible, especially where these are located in holds or storerooms”.
Alternative proposals are currently under consideration on a global scale (Marine Environmental Protection Committee, 2002). A clear quantitative limit will need to be enforced to restrict the number of the density of propagates that can be evacuated. This type of procedure could be applied for establishing the effectiveness of the procedure for helping to build the legislation for actual ballast water discharges (ICCMS, 2004).
Another possible solution for JFE could be to gauge the effectiveness of ballast water processing in reducing the concentration of microorganisms. As a relative standard, the efficiency of the treatment poses an barrier for naval operators to introduce procedures for lowering the quantity of propagules in ballast reservoirs (for example, the evacuation of ballast in deep waters, or the frequent maintenance of ballast tanks by ensuring removal efficiencies that are harder to achieve (Hulsmann and Galil, 2001). Also, by managing the location and quantity of ballast water evacuations, the risk of releasing external species into a marine eco-system could be reduced (McGee, 2011).
According to Stephan and Matej (2012), these procedures may not be 100% effective, however, they could improve the manner in which ships manage ballast water waste. Other methods for keeping the dissemination of organisms under control are still under revision, such as a recommendation by O’Sullivan (2010) to keep ballast waters on ships, discharge them to ‘reception facilities’ and treat them through ultraviolet radiation, heat, chemical disinfection or ultraviolet radiation. There would still continue to be several methods through which ballast water could be processed, and despite efficient technical procedures being put in place, ballast substance exchange still remains the most practiced option. It is therefore recommended that James Fisher Everard invest in technologies that could help them take advantage of substitute procedures such as the flushing system or disinfection, if they prove to be more commercially or operationally viable.
Conclusion
Ballast waste management is a serious maritime issue. It poses serious ecological, economical and public health concerns for host eco-systems and countries where these waste are deposited. As a result, it is crucial that such waste are disposed of and processed properly. Based on extensive research, it is apparent that the current legislations and policies in place are not being enforced appropriately, which leaves the system still open to abuse, and as a result, public health concerns are not being addressed.
This study has assessed a number of recommendations for James Fisher Everard in the efficient management of their ballast water management, such as adopting a flushing system or disinfecting the water before it is discharged. It is believed that these processes, if deemed commercially or operationally viable, could help them better manage ballast water waste.
References
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