Transactions on Ballast Water Treatment Systems for the Great Lakes-St. Lawrence Seaway System
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Were the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (the “Convention”) to enter into force now, technical and regional compatibility factors would pose challenges to implementation of its performance standard by ships operating primarily on the Great Lakes-St. Lawrence Seaway system.
As this Convention has not yet entered into force, Canada will continue to monitor these challenges, and is considering options in case they persist upon the Convention’s entry into force.
Canada remains committed to the Convention, and will continue to work with all stakeholders towards fair, practicable, and protective Great Lakes requirements meeting its international obligations.
Ballast water is important for the safety and stability of ships but contains aquatic plants and animals that can introduce potentially invasive species like the zebra mussel into Canadian waters. Canada is committed to marine transportation on the Great Lakes-St. Lawrence Seaway system, reducing the introduction and spread of damaging invasive species and protecting the safety of ships and crews.
Although Canada established its own ballast water regulations in 2006 for most vessels arriving in Canada, shipping is a global industry and a uniform global approach is needed. Thus, in 2010, Canada acceded to the Convention. The Convention will not be applicable in Canada until it enters into forceFootnote 1 and is implemented in Canadian regulations.
While Canada’s present regulations apply to most vessels arriving in Canada, the Convention would also apply to Canadian Great Lakes ships, reducing the risk of introduction and spread of invasive species posed by these ships. Footnote 2Canada must also apply the requirements of the Convention as may be necessary to ensure that no more favourable treatment is given to ships of countries that have not adhered to it, but which operate in waters under Canadian jurisdiction. Ships complying with the Convention will plan their ballast water management, meet a performance standard limiting the number of viable organisms discharged, receive surveys, carry a certificate, and keep ballast water records. Transport Canada (TC) expects that most ships would need to fit a ballast water treatment system (BWTS) to comply with the Convention’s performance standard.
While the regulatory process regarding the Convention in Canada has not yet formally begun, TC has been consulting with U.S. and Canadian stakeholders. The process began in October 2012 when TC invited comments from Canadian and U.S. stakeholders on a pre‑regulatory discussion paper containing a proposed approach for Canadian regulations. Since that time, TC has continued to develop its policy approach, in consultation with U.S. and Canadian stakeholders, taking into account legal, scientific, technical, cost-benefit and compatibility considerations. This document focuses on TC’s technical considerations. Canada remains committed to fair, practicable and protective ballast water regulations.
TC’s technical considerations process to date
TC Discussion Paper
Mouawad Study (Efficacy)
STX Canada Study (Feasibility)
TC Workshop Submissions
CSA (before and after),
Shipping Federation of Canada,
Lake Carriers Association
Vard Marine/STX Response
TC Transactions on BWTS
for the Great Lakes
The discussion paper took note of concerns expressed by owners of Great Lakes ships centering on the availability of BWTS that perform under Great Lakes conditions and practical considerations for shipboard installation of BWTS. The discussion paper sought to open a more specific technical discussion on these efficacy and feasibility concerns. On technical efficacy concerns, it outlined the view that consideration should be given to BWTS that had been tested in fresh water, that were expected to work in fresh water, or that could be augmented to work in fresh water, and that vessels requiring a BWTS to meet the performance standard would find a suitable one amongst these groups. On technical feasibility concerns, it outlined the view that, while certain Great Lakes vessels might incur more expensive engineering and installation costs to install a BWTS, all vessels can physically install BWTS. Whether or not such installation would impair the economic viability of the vessels was not considered.
In response to the discussion paper, TC received comments from many Canadian and U.S. stakeholders, some of which raised technical considerations pertaining to the use of BWTS on the Great Lakes. In particular, the Canadian Shipowners Association (CSA) raised a number of specific and detailed technical issues pertaining to both the efficacy of BWTS with respect to Great Lakes conditions and the feasibility of installing BWTS on Great Lakes ships. While TC’s role is not to identify or recommend specific BWTS for use on the Great Lakes or on specific ships (both the Convention and U.S. requirements take a performance approach), TC responded to these technical concerns by taking steps to more closely consider the consistency of BWTS processes with installation and operation on the types of ships operating on the Great Lakes.
In response to the detailed CSA comments, TC commissioned two independent Great Lakes BWTS technical studies with the intention of bringing additional data and expert insight to bear on the matter, and to obtain independent expert reviews of the CSA concerns to facilitate TC’s regulatory considerations. The portion of the CSA’s comments pertaining to technical matters formed a part of the terms of reference for the studies. The first study, which focused on the efficacy of existing BWTS processes, was undertaken by Mouawad Consulting, a recognized international expert in BWTS technology and type-approval. The second study, which focused on the feasibility of fitting BWTS on representative categories of Great Lakes ships as well as specific example ships, was undertaken by Vard Marine (formerly STX Marine Canada), which has recognized expertise in naval architecture and marine engineering for both Great Lakes and international ships.
Following completion of the reports, Transport Canada held a one-day workshop to allow shipowner associations representing a cross-section of Canadian, U.S. and international shipowners on the Great Lakes to pose questions to the study authors concerning their conclusions. These associations were asked to submit their written comments in advance of the workshop in order to allow the study authors to prepare for a substantive discussion of the reports. These workshop submissions and the face to face discussions significantly deepened the dialogue on efficacy and feasibility of ballast water treatment systems, and allowed stakeholders to introduce more specific concerns in relation to the considerations and conclusions of the technical studies. In light of this, TC asked the associations to revise their technical submissions as necessary and commissioned responses to remaining stakeholder concerns from the study authors.
Summary of TC technical position
With respect to efficacy, the Mouawad Consulting study and response have advised TC that BWTS processes centering on ozonation, other chemical injection, side-stream electro-chlorination and ultra-violet irradiation are applicable to Great Lakes conditions, however this advice was qualified. Ozonation and chemical injection processes need confirmation testing, side-stream electro-chlorination is logistically challenging (as large volumes of brine need to be bunkered. The U.S. Coast Guard has made no decision regarding the general acceptability of ultraviolet radiation as a treatment process.Footnote 3
With respect to feasibility, the STX/Vard Marine study and response have advised TC that it is technically feasible to install any of the four BWTS processes in several specific ships that were examined in detail, and that a technically feasible approach can be found for vessel categories reflective of Canadian, U.S. and international ships operating on the Great Lakes. However, noting risks to the uncoated ballast tanks of Great Lakes ships, Vard Marine reinforced the need for confirmation testing of BWTS using active substances and noted that impacts on ship performance and costs are greater for some types of Great Lakes ship than for the closest comparable seagoing ships.
Having considered the independent efficacy and feasibility reports, stakeholder submissions to the associated technical workshop, and the responses of the study authors to these submissions, TC agrees with the qualified advice from the studies that existing BWTS processes could be applicable to Great Lakes conditions and could be fit and operated on Great Lakes ships. However, TC also agrees with both the authors and domestic stakeholders that there is a need to address the confirmation testing recommended by the study reports and/or to allow the U.S. to complete its BWTS approval processes before Great Lakes shipowners can fit BWTS with confidence.
Therefore, were the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (the “Convention”) to enter into force now, there would be technical challenges for ships operating primarily on the Great Lakes-St. Lawrence Seaway system. As the Convention has not yet entered into force, Canada will continue to monitor these challenges, and is considering options in case they persist upon the Convention’s entry into force. Canada remains committed to the Convention, and will continue to work with all stakeholders towards fair, practicable, and protective Great Lakes requirements that meet its international obligations.
About this document
TC has received a number of requests for copies of the technical studies from members of the Great Lakes and international marine communities, as well as requests to provide more detail on its technical considerations to date. Specific documents within this process have already been referenced in submissions of others to the Marine Environment Protection Committee (MEPC) of the International Maritime Organization (IMO) and in the discussions of its Ballast Water Review Group. As these discussions have shown, there is a risk that, if taken in isolation, the various studies, documents and comments generated through TC’s technical considerations could inadvertently be taken out of context.
The components of this dialogue need to be considered together, as they represent efforts by many stakeholders and experts to come to agreement on a complex, multi‑faceted and technical issue for which a variety of scientific, engineering and operational experience needs to be brought to bear prior to establishing regulatory policy. Each participant in the process has brought a different perspective to the issue, and TC has taken each perspective into account in advancing its technical considerations.
TC’s technical consideration process has unfolded in steps over time, while development of BWTS technology—including both introductions and withdrawals of various BWTS—has continued in parallel. For example, the number of BWTS type-approved under the Convention has increased from 28 when the TC discussion paper was released to 58 at present. The type-approval of 10 BWTS to date has been based on fresh water testing, while 31 were only tested in other salinitiesFootnote 4 The U.S. Coast Guard has determined that 9 of the 47 BWTS it has accepted for temporary use in U.S. waters as Alternate Management Systems (AMS) have been type-tested in fresh water. However, these BWTS are not necessarily suitable for Great Lakes voyages, and the need for confirmation testing remains.
In order to increase transparency concerning its technical position, TC has decided to compile the documents associated with the study process into these Transactions on BWTS for the Great Lakes. The release of these transactions as a whole will mitigate the risk that elements of them will be inadvertently taken out of context. It will also respond to requests from shipowners associations and study authors to put their views directly on the record. Finally, the information will ensure that other interested parties have access to the most recent Canadian information on BWTS technology for the Great Lakes, with a view towards increased compatibility in ballast water requirements in this region.
TC remains well aware that discussions on technical considerations are likely to continue between different stakeholders, TC and regulators in other jurisdictions. New data on the performance of BWTS in waters comparable to the Great Lakes is expected to deepen these dialogues, and TC’s technical consideration will evolve as appropriate as additional technical data is received.
To facilitate references to these transactions and the documents within them, the original page numbers of each document have been retained, but page numbers have also been added that refer to the page number within the transactions as compiled.
Table of Contents
|Topic||Document||Received Date||Transactions page number|
|Technical response to TC discussion paper||Comments of the Canadian Shipowners Association||March 31, 2013||8|
|Technical Studies||Mouawad Consulting (Efficacy)||November 26, 2013||21|
|STX Marine Canada / Vard Marine (Feasibility)||June 30, 2014Footnote 5||87|
|Pre-workshop comments on technical studies||Shipping Federation of Canada comments||September 8, 2014||381|
|Lake Carriers Association comments||September 8, 2014||387|
|Canadian Shipowners Association Comments on efficacy||September 8, 2014||410|
|Canadian Shipowners Association Comments on feasibility||September 11, 2014||432|
|Post-workshop comments on technical studies||Supplementary Canadian Shipowners Association Comments||October 1, 2014||437|
|Responses to workshop comments by technical study authors||STX/Vard Marine response||January 26, 2015||460|
|Mouawad Consulting response||January 30, 2015||510|
Although the Mouawad and STX/Vard reports were prepared at Transport Canada´s request, the analysis and conclusions presented therein were developed independently based on an agreed statement of work and constitute the professional opinion and advice of their authors. The comments submitted by the Canadian Shipowners Association, the Lake Carriers Association and the Shipping Federation of Canada constitute the views and opinions of these associations and their respective members. These reports and comments are input to Transport Canada’s technical considerations on ballast water, but they do not constitute Transport Canada’s views.
For further information, please contact:
A/Senior Policy Advisor
Marine Policy (ACFS)
330 Sparks St.
Ottawa, ON K1A 0N5
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Transactions on Ballast Water Treatment Systems for the Great Lakes-St. Lawrence Seaway System (PDF Version, 10.57 MB)
- Footnote 1
The Convention will enter into force one year after its ratification by countries representing 35% of the world’s merchant shipping tonnage. As of January 12, 2015, countries representing 32.86% of this tonnage had ratified it.
- Footnote 2
This risk assessment considered the level of risk of introduction of aquatic invasive species to Canadian waters in the ballast water of ships transiting between international and Canadian ports and by domestic shipping. The assessment was based on a comparative analysis of the relative risk among 11 ballast water pathways in Canada, across Atlantic, Pacific, Arctic and Great Lakes regions. The complete assessment is available online.
Fisheries and Oceans Canada (2014) Science Advice from the National Risk Assessment for Ballast Water Introductions of Aquatic Nonindigenous Species to Canada. Report 2013/064.
- Footnote 3
U.S. Coast Guard (December 2013) Clarification regarding Coast Guard type approval of ballast water management systems using ultraviolet radiation. Available at: https://homeport.uscg.mil/ballastwater.
The risk to a shipowner of fitting a BWTS before its type approval by the U.S. is that it could need modification or early replacement should it not ultimately receive type approval. While Transport Canada has recognized such regional compatibility challenges, they will not be further discussed in this document, which focuses instead on technical considerations.
- Footnote 4
The 58 BWTS include 51 BWTS approved as of MEPC 67, four BWTS for which type approval information has been submitted to MEPC 68, and three BWTS for which type approvals have been issued publically by the relevant administration, but which have not yet been reported to MEPC. The present Convention type approval guidelines permit, but do not require, BWTS to be tested in fresh water. A system that has not been tested in fresh water may or may not work under such conditions. Complete data was not readily available online to the public concerning the salinities in which 17 of the 58 BWTS were tested.
- Footnote 5
The correction of one minor typographical error on January 21, 2015 has been included in this transaction.