D-2

Prepare for D-2 Commissioning

Testing of BWTS

Whitepaper content:
The need for preparation
of D-2 Commissioning
Testing
Common reasons why
Commissioning Tests fail
Recommendations for
adequate preparation of
D-2 compliant discharge

March 2022

How shipowners can take ownership

of ballast water management in the
era of D-2 compliance.

We propel shipping to sustainability,

also by sharing expertise.
How to best prepare for D-2 compliant discharge

In less than three months D-2 Commissioning Testing will become mandatory following every
new Ballast Water Treatment System (BWTS) installation. The BWTS is but a part of the whole
Ballast Water Management System (BWMS), including tanks, piping, pumps and valves. Many
vessel owners are not yet aware of their critical role in ballast water management to ensure D-2
compliant ballast water discharges, starting at the D-2 Commissioning test and beyond. The
requirement for this test is fairly new to vessel owners and only required by certain flag states.
This surprisingly often results in successful execution of the test as such, but alas fails to meet
the D-2 Standard.

Many of these failed tests can be attributed to the lack

of experience in ballast water management now that the
What the BWM Convention implies
shipping-community is transitioning from D-1 (ballast
for ships.
water exchange) to D-2 (limiting discharge of viable
organisms). In this whitepaper we want to share our Ships on international voyages have to manage
experience on why we see tests failing, the importance of their ballast water and sediments to a certain
using the right equipment and qualified personnel, and standard (D-1 or D-2), according to a ship specific
more important: give clear recommendations on how ballast water management plan. Ships must
vessel crew and owners can help increasing the chance of therefore carry:
a satisfactory test via adequate preparation.
• A ballast water management plan - a detailed
description of the actions to be taken to
Why is treatment of Ballast water required?
implement the ballast water management
Ballast water allows vessels to operate safely. Ballast water requirements and supplemental ballast water
management practices, it is ship specific;
has to be taken on board or released when a vessel needs
to be stabilized, like when cargo is unloaded or loaded • A ballast water record book - to record when
at ports or because of bad weather. At the same time, ballast water is taken on board; circulated
ballast water has also been contributing to the spread of or treated for ballast water management
aquatic invasive species (species that live in the water and purposes; and discharged into the sea; and
become harmful when outside of their natural habitat)
• An International Ballast Water Management
and human pathogens (bacteria causing disease). These
Certificate - (ships of 400 gt and above) – this
invasive species may grow quickly in number in their new
is issued by or on behalf of the Administration
habitat and outcompete local species for habitat or food
(Flag state) and certifies that the ship carries
threatening our marine biodiversity. Also, the economic out ballast water management in accordance
and environmental impact may be very high1. with the BWM Convention and specifies which
standard the ship is complying with, as well as
To prevent the spread of these potentially harmful aquatic
the date of expiry of the Certificate.
organisms and pathogens via ships’ ballast water, the
International Maritime Organization (IMO) adopted Source:
The Ballast Water Management Convention (BWM https://www.imo.org/en/MediaCentre/HotTopics/
Convention). Pages/Implementing-the-BWM-Convention.aspx

1. https://tc.canada.ca/en/marine-transportation/marine-pollution-environmental-response/managing-ballast-water

D-2 Commissioning Testing of BWTS | 2

Two ballast water management standards
As a result of the BWM Convention, ships must manage
their ballast water so that aquatic organisms and
pathogens are removed or rendered harmless before the
ballast water is released into a new environment. Two
ballast water management standards are defined in the
BWM Convention (D-1 and D-2).
D-1 standard: this applies to all ships and requires ships
to exchange their ballast water in open seas, away from
coastal areas.
D-2 standard: this limits the number of viable organisms
allowed to be discharged, including certain indicator
microbes harmful to human health.2
Since the BWM Convention entered into force in 2017, all
vessels must adhere at least to the D-1 Standard. For new
vessels, D-2 Standard compliance is already required, and
this will apply eventually to all vessels. In practice, vessels
must install a Ballast Water Treatment System (BWTS) to
be able to meet the discharge limits of the D-2 Standard.
Table 1: D-2 standard parameters and limits
Parameter
Organisms with ≥50 µm size
Organisms between ≥10 - <50 µm size
Toxicogenic Vibrio cholerae (O1-O139)
Escherichia coli
Intestinal Entercocci
2. https://www.imo.org/en/MediaCentre/HotTopics/Pages/Implementing-the-BWM-Convention.aspx
3. As of February 2021: the flags Australia, Canada, Croatia, Cyprus, France, Greece, India, Singapore, Tuvalu, Portugal oblige IMO Commissioning tests –
Bahamas, Liberia and Panama recommend. Call our experts for updates!
After BWTS installation, D-2 Commissioning Testing
soon to be required for most vessels.
Following MEPC 75 of November 2020 (IMO’s Marine
Environmental Protection Committee in its 75th meeting)
it became clear that Commissioning Testing will become
mandatory for all BWTS-installations globally, as of
June 1st 2022. Until this date, Commissioning Tests is
mandatory only for a limited number of Flag states3.
Prior to issuing the International Ballast Water
Management Certificate (IBWMC) a vessel with a newly
installed BWTS must pass a Commissioning Test in line
with BWM.2/Circ.70 (or its Revision 1). The Commissioning
Test specifically examines compliance with the D-2
Standard by sampling and analyzing the treated ballast
water discharge. The D-2 standard specifies that ships
can only discharge ballast water that meets the following
criteria:
Limits in the Vessels Ballast Water Discharge
< 10 viable organism/m3
< 10 viable organism/mL
<1 cfu/100ml
<250 cfu/100ml
<100 cfu/100ml
D-2 Commissioning Testing of BWTS | 3
After completing the Commissioning Test ships receive
a test report which Class Societies require to issue the
IBWMC on behalf of the Flag state. Without the IBWMC
ships are not allowed to ballast or de-ballast.
Revision 1 of the BWM.2/Circ/70 clarified several aspects
of the Commissioning Test, adopted at the MEPC 75, and
applicable depending on specific Flag requirements:
• Representative samples should be analyzed for the
two organism size classes larger 50 µm and 10-50
µm, as specified in the D-2 standard, using indicative
analysis methods listed in BWM.2/Circ.42/Rev.2.
• A representative sample follows BWM.2/Circ.70, with
one important clarification: the total sample volume
should be at least 1 m3.
• Local ambient water should be used for testing.
• The analysis of an ambient water sample is only
optional.
The Commissioning Test intends to validate the installation
of the BWTS by demonstrating that its mechanical,
physical, chemical and biological processes are working
correctly – as per the design specifications. The test is
explicitly not intended to validate the type-approved
design of a BWTS.
Most common reasons why Commissioning Tests
fail.
Vessel Performance Centre’s and Control Union’s
Commissioning Testing Services, Class approved by ABS,
Lloyd’s Register, DNV, Bureau Veritas and RINA have
completed D-2 Commissioning Tests the past year in:
The Netherlands, Belgium, Malaysia, Singapore, Spain,
Portugal, Turkey, Poland and Germany.
Due to strong focus on preparation with involvement of the
crew, tests were in all cases successfully performed. Here,
‘successful’ means compliant and correct sampling and
testing, on the agreed date (to avoid delays). The outcome
of a test, despite correct execution of the same, can of
course result in a failure to meet the D-2 Standard.
In some occasions (10 to 20%) a failed test result was
obtained. In response, due to our SOPs and quality
framework as well as using the BallastWISE analytical
device, we firstly confirm if the test was successfully
executed. Then we evaluate, trying to find out what may
have caused the test to fail. We noticed that the following
factors or a combination thereof played a role thus far:
Incorrect scope Circ.70 versus Circ.70/Rev.1
BWTS malfunction Installation, Training,
Operation
Challenging water Check ambient water
conditions
Contaminated vessel Tanks – Piping – Valves
False-positive Check CMD Data –Expert review
We could establish that in all cases the likelihood of a failed
tests could have been reduced significantly or even fully
prevented. Our aim to continuously improve combined
with our highly experienced ballast water team of Control
Union with our partner NIOZ, shifted our focus to: what
can shipowners do to prevent such failures? The result is
a clear checklist (see below) for the ship’s crew and the
vessel owner, indicating what is required to optimize their
ballast water management practices. Since many aspects
that are not under the responsibility of the service provider
influence the test outcome, we have summarized them as
recommendations.
D-2 Commissioning Testing of BWTS | 4
Recommendations for optimized ballast water
management practices at BWTS commissioning
The easiest advice we have, is to prepare. That starts with
understanding what D-2 compliance is about and that the
crew also has a responsibility for making the test a success,
mainly through support and preparation. Preparation
includes not to underestimate the test; it’s not difficult, but
lack of preparation can cause failed test results.
Upon retrofitting an existing vessel with a BWTS, the ship’s
ballast water system (tanks and piping) is up to that point
•
•
•
heavily contaminated with untreated water and sediments.
It’s crucial to realize that merely fitting a BTWS will not
magically resolve this contamination upon first use. Thus,
we recommend thoroughly cleaning the ballast water
tanks to get rid of all sediments and/or untreated water.
Furthermore, strictly adhering to hold-time requirements
of the BWTS and flushing of tanks and piping with treated
water is important, especially if sediment removal from
tanks cannot (completely) be achieved, which is the case
in many projects.
Version: 2022.1
D-2 Commissioning Testing of BWTS | 5
Also check TRO sensors (if applicable for the system) per
the manufacturer’s instructions, discharge and strip your
tanks in advance, clean filters (if applicable for the system),
and ideally fill 100% of the tank which will be used for
discharge. A BWTS may work as designed, but if tanks and
pipes are not flushed, tanks not cleaned and for instance
only a portion of the tank is filled, this may negatively
affect the outcome of the test. Even then, it could still
be the case that valves are leaking. Consider this whilst
preparing, trying to at least check if everything works in
good order. A small leak in a valve easily contaminates an
otherwise clean ship with a well-functioning BWTS.
Furthermore, the local water used for ballasting varies
among different locations. Some yards or ports are
in waters with high sediment levels and/or low UV-
transmission. In these locations it is advisable to carefully
check the System Design Limitations (SDL) of your BWTS,
as listed on the type-approval certificate. If the local water
exceeds the SDL, taking your D-2 Commissioning Test may
be better carried out during a bunker stop of in the next
port call. Also determining the appropriate scope (Circ.70
or Circ.70/Rev.1) is important since the preparation is
different, as well as the time required after testing for the
Report to become available.
Crew’s understanding of, and ability to work with the BWTS
system is another area of attention which may seem
obvious, yet practice is often lacking. Ensure training and
understanding is in place including retrieval of log-data
after the test. A basic understanding of what the service
is about as well as operational experience using the BWTS
is sometimes lacking. Therefore, sharing our insights and
experience is considered essential, not only by the VPC
and Control Union, but throughout the industry.
4. Final Report considers more elements than only these results, for which Final Results are not available immediately
Standardized processes combined with the right
equipment
Apart from standard operating procedures, an excellent
quality system and adequate training of our staff, we have
found that the test-equipment used is very important. In
particular the method used for indicative testing, which
happens on board of the vessel, is very important. After
thorough validation of the available techniques, together
with the NIOZ institute, our preferred option is to use the
BallastWISE.
BallastWISE is a portable Compliance Monitoring Device
(CMD) to analyze small organisms in water by video-
monitoring their movements and/or fluorescence.
BallastWISE automatically detects and counts living
heterotrophic and autotrophic microorganisms within
two size-ranges: 10 – 50µm and >50µm. It uses high-
resolution cameras, light-emitting diodes and automated
video analysis algorithms. Compliance with the D-2
standard4 can be determined immediately after the
onboard 30-minute analyses. Its unique advantage is that
expert-review of the results (in case of doubt or slightly
above threshold value results), can additionally be done
by manually checking the raw video-files. Other benefits
are the ease-of-use to operate the system, as no additional
chemicals are required, and the counting process is fully
automated. As mentioned, records (videos) of the analyses
are stored, which in case of dispute may serve as evidence.
(relevant once Port State Authorities will be enforcing the
regulation, but also in cases where doubt over a failed test
result arises).
D-2 Commissioning Testing of BWTS | 6
Our solution for D-2 Commissioning Testing
Using our own certified in-house inspectors and network
of laboratories, our Commissioning Testing Services are
designed to provide maximum flexibility for the timing of
this test, and at that same time ensure a 95% success rate.
This is unmatched in the industry.
The scope of our Commissioning tests is in line with both
IMO BWM.2/Circ.70 and its Version 1 and in accordance
with G2 guidelines. Our service builds on the foundation of
our group’s team of BWMS type-approval testing experts.
We have secured our “Approved Service Provider”-
certificates from the leading Class societies ABS, Lloyd’s
Register, DNV, Bureau Veritas and RINA.
We offer Commissioning Testing Services where both
Detailed and Indicative analyses is possible, in case
requested with microbiological analyses or combined
with our world class VGP 2013 Monitoring Services. To
ensure the highest quality standards, all our procedures
are managed via our online ISO 9001-certified quality
management system. Our online reporting web-platform
that is accessible 24/7 globally, ensures swift and secure
client access to test results.
How the VPC can help you in successfully planning
and performing your Commissioning Testing
More than 30,000 vessels have not yet installed their
BWTS. They have until September 2024 to become
compliant with the D-2 Standard of the BWM Convention.
A very busy period lies ahead for shipyards and service
providers related to the installation of the BWTS systems.
On the date of publishing this whitepaper, less than 3
months are left until Commissioning Testing will become
5. The convention applies to ships registered under contracting Parties to the BWM Convention, which take up and use ballast water during international
voyages. https://www.imo.org/en/MediaCentre/HotTopics/Pages/Implementing-the-BWM-Convention.aspx
a requirement under all Flag States5. As of June 1st 2022
we expect that securing a compliant Commissioning Test
from a trusted service-provider will become more and
more difficult . At the VPC we are already available to serve
you as well as to attend your inquiries and questions.
With our global network of VGP 2013 Monitoring Services,
we have now set up our D-2 Compliance Hubs from where
we can offer Commissioning Tests. Our in-house teams
are ready to assist you in over 150 ports and key trade
locations worldwide across all continents and can assist
with setting up dedicated service for you in your shipyard
of choice as well. Securing your Commissioning Test now,
may prevent any potential delays or errors once you vessel
is undergoing retrofit or about to leave the shipyard for the
first time.
ABOUT US
The Vessel Performance Centre, part of Royal
Peterson Control Union, helps all types of
vessels and ships to comply with the newest
regulations and improve fuel performance with
tailor-made solutions.
For owners and operators we offer a range of
solutions for your environmental compliance,
including Water discharge monitoring (EPA
VGP), commissioning testing (IMO BWM
Convention) & system type approvals (USCG),
CO2 emissions reporting & verification (EU
MRV, IMO-DCS) as well as fuel compliance (IMO
Sulphur Cap).
VPC: we propel shipping to sustainability!
VESSEL PERFORMANCE CENTRE
Authors Coen Esser & Cees van Slooten
E expertise@vesselperformancecentre.com
W www.vesselperformancecentre.com
D-2 Commissioning Testing of BWTS | 7
 Get more info:
www.vesselperformancecentre.com
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