We can gather and test all we like, but it will provide us little insight into analysis and evaluation unless we have clearly defined parameters for sample size and frequency of data collection. It is all very well and good testing for one thing or another, but in the realms of science and legislation, it means very little without due process.
Which leads us to the crux of the issue – what is it we are hoping to find, or perhaps more fittingly, rule out? We may examine phytoplankton cell density, in-line with current IMO D2 and USCG Discharge Standards, but neglect to look for non-photosynthesising zooplankton. Are we safe to assume that the presence of anaerobic organisms in a ballast tank is not a risk to compliance? There are plenty more iterations, such as this one, that have the potential to cause significant contention, and for ship owners on the front line, it is vital that we take steps towards clarity and a cohesive approach.
Practically speaking, we still need to decide who should be collecting these samples. From where I am standing, the only way we can hope to guarantee true impartiality is through independent assessors, trained in the yet-to-be-agreed upon standardisation and practice. Then of course, we also have to consider the role of Port State Control officers, as the lynch-pins between the testers and the scientific experts assessing the samples. If, hypothetically speaking, a ship fails to meet compliance, due to current rulings surrounding undue delays, will port authorities be mandated to communicate this to the next port en route? And what then? What are the implications for shipowners and their ballast water management operations?
Here at De Nora, we are of the firm belief that in order for us to move forward, we need some concrete answers to all of the above. I, of course, have my own opinions on best practise – but ultimately, it is up to the IMO to provide us with some direction. We can advise shipowners on the best treatment system for their vessels. We can support them with choosing the right system, in-line with the living structure of their vessel, carry out successful installations and offer on-going support for maintenance and up-keep. But we are not able to shed-light on sampling and testing processes without sound guidelines.