Proposed Criteria for Determining
Whether Proposed Technologies
Meet NISA Requirements
For Discussion by Ballast Water and Shipping Committee
Allegra Cangelosi, Northeast-Midwest Institute
June 21, 1999
NISA-Related Screening
Parameters for evaluating technologies for use as substitutes for ballast exchange
include safety, cost, practicability, environmental soundness and effectiveness. Regarding
safety, NISA calls upon the USCG to adopt national guidelines which generally protect the
safety of ships. The USCG and classification societies have criteria in place for
screening installations on ships for safety. Experts in marine engineering and naval
architecture should evaluate existing procedures to determine if they need to be revised
to accommodate special circumstances of ballast treatment technology proposals. What is
and what is not acceptable cost and practicability may vary from company to company, and
NISA logically assumes that the proposing company will evaluate technologies for these
parameters prior to proposing them as substitutes.
Accordingly, the remaining concerns of the USCG pursuant to NISA in evaluating
technologies are environmental soundness and biological effectiveness, and NISA directly
authorizes the Coast Guard to approve the use of substitutes for ballast exchange which
are environmentally sound (as defined in the Act), and are as effective or more effective
than ballast exchange. This paper proposes an approach to screening technologies for these
parameters.
Two-Tiered Screening
In making determinations about environmental soundness and effectiveness, the Coast
Guard could utilize the same two-tiered approach that the U.S. is proposing to the IMO for
alternative technologies. The system would involve an initial screening to qualify a
technology for a trial status; followed by a more involved and comprehensive screening to
qualify a technology for full acceptance as an available substitute for ballast exchange.
Screening for the trial status could be much less rigorous than screening for full
inclusion in the list of acceptable substitute for ballast water exchange. Data collected
during the trial stage could be adequate to support inclusion of the technology in a
permanent list of acceptable substitutes.
Specific Considerations
Like for safety and practicability evaluations, the USCG, at least initially, will have
to consider the specific voyage pattern and ballast discharge pattern of prospective host
vessels (or vessel/voyage type) in evaluating environmental soundness and efficacy.
Ultimately, some technologies may prove acceptable only for certain ship types or voyage
patterns.
Listed below are considerations which the USCG should weigh for evaluating
environmental soundness and biological effectiveness. Consistent with NISA, the USCG
should make a determination in favor of allowing a technology if, on the whole, the
technology as applied to the proposing vessel, will likely be as effective or more
effective than ballast exchange (defined by studies currently underway) with respect to a
range of taxonomic groupings. Noting that ballast exchange is not free of environmental
impacts (notably, air emissions and fuel expense from increased pump use), a similar
standard could be applied to the evaluation of environmental soundness, namely that a
technology meeting legal requirements should be accepted if it is as environmentally sound
or more environmentally sound than ballast water exchange. However, environmental
soundness and effectiveness should be considered independently, as much as possible.
Considerations in evaluating the alternative technology should include:
1. Environmental Soundness: All proposals should show compliance with
international, federal and state environmental laws and consistency with the requirement
that any chemical treatments be part of an integrated pest management strategy within the
NISA definition of "environmentally sound". Tho technology's environmental
soundness should be compared with the environmental soundness of ballast water exchange.
Specific considerations should include:
Acute impacts on receiving systems, including the atmosphere, and fresh and salt water
systems as applicable
- Cumulative and/or long-term impacts on receiving systems as above
- Impacts, acute or cumulative, resulting from interactions with pollutants or organic
matter within the tanks or receiving system
- Sensitivity of the environmental soundness to voyage specifics which may change (e.g.
does the technology require a retention time to degrade which may not be met if the voyage
pattern undergoes an unexpected change? Is it only environmentally sound in fresh water
use?)
- Life-cycle pollution potential (i.e. including manufacture, transportation and disposal)
2. Biological Effectiveness -- Proposers should show that the
technology is able to kill or remove organisms in a variety of taxonomic groupings such as
fish, macrozooplankton, microzooplankton, cysts and eggs, bacteria, protozoa and viruses.
Effectiveness with respect to a surrogate organism's life stages, such as Artemia, could
provide a streamlined approach to showing technology effectiveness on most of the above
taxa. The technologies' effectiveness should be compared to the effectiveness of ballast
water exchange as described by current research. Because ballast water exchange may be
more or less effective depending upon the ship's voyage and discharge pattern, these
specifics must also be taken into account. Other considerations include:
- Applicability to coastal as well as transoceanic voyages
- Ability of the USCG to monitor and track use of the technology
- Durability of system on board a ship and lifespan of components
- Ability of operators to detect system malfunction
- Sensitivity of the technology's efficacy to voyage specifics which may change (e.g. Is
it effective only in less turbid conditions?)
3. Quality of Supporting Information -- The extent and amount of
supporting information should also be a major consideration for the USCG in making its
evaluation. Considerations include:
- Extent to which necessary permits are in hand (the absence of necessary permits should
be a show stopper until they are obtained)
- Independence of the environmental soundness and biological efficacy analysis (the more
independent the better)
- Extent to which the information has been peer reviewed (this is an essential practice in
experimental tests to help assure that decisions are made on the basis of meaningful
results)
- Depth of environmental and efficacy analysis (Are considerations cited above left to
speculation? Is the research depth appropriate to the tier sought?)
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