Commissioning testing is a mandatory step to verify that newly installed ballast water management systems (BWMS) meet the D2 standard and function correctly – as per the IMO’s 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70/Rev.1). The D2 standard sets specific discharge limits for viable organisms in ballast water and requires ships to have an approved BWMS. According to the implementation schedule of the Ballast Water Convention, all ships must meet the D2 standard by September 8th, 2024.  

Approval for service providers is granted by classification societies like DNV, Lloyds Register, ABS, and RINA, among others. However, the International Association of Classification Societies (IACS) has established a common set of basic requirements for the certification and approval of service suppliers. 

In this article, we explain the requirements for commissioning testing service providers and help you to prepare what you need to apply for service provider approval.

Requirements to be approved as a BWMS commissioning test service provider 

To become an approved service provider for commissioning testing of BWMS with an IACS member, companies must adhere to the Z17 Procedural Requirements for Service Suppliers, along with any relevant local rules and practices defined by the individual classification societies.  

We dive into the specifics of the requirements when applying for ballast water commissioning testing service provider approval, as defined by IACS, below: 

• Organisational requirements 
• Documentation requirements 
• Requirements to BWMS commissioning test personnel

Organisational requirements: 

On an organisational level, you must: 

• Be independent of any BWMS manufacturer/supplier, including shipyards. If you perform activities that might present a conflict of interest, this information must be communicated to the classification society when applying.  
• Have a documented quality system (explained in section 5.5 of IACS requirements), which must be accredited to relevant standards, for example, ISO 9000 (note that if doing detailed analysisi, or testing for ships under the Cyprus flag, you must be accredited to ISO/IEC 17025 or equivalent)  
• Understand the operation of the BWMS that you will be testing. In practice, this means that when Inspectors board a vessel to perform commissioning testing, they need to know the ship’s BWMS well enough to assess correct operation. They must understand the features and limits of the relevant ballast water treatment technology and the system’s self-monitoring parameters. 

Documentation requirements: 

You are required to document your process for BWMS commissioning testing, including how you: 

• Communicate with the crew prior to commencing work 
• Collect and handle ballast water samples 
• Analyse ballast water samples – and assess whether the BWMS is operating correctly 
• Report the above steps for both classes of organisms (10-50um and >50um) – check out DNV’s reporting template for inspiration 
• Operate your ballast water compliance testing equipment, such as BallastWISE 
• Calibrate, adjust and maintain your ballast water compliance testing equipment

Requirements to BWMS commissioning test personnel 

As the Inspector performing BWMS Commissioning testing, you must fulfil general and task-specific requirements, which we detail below.  

Firstly, all inspectors who conduct commissioning testing are required to document that they understand how and why to conduct BWMS commissioning testing – through training in the relevant engineering and biological knowledge. In practice, this means that inspectors understand the D-2 ballast water regulation standard and the current guidelines for commissioning testing:  

• IMO BWM.2/Circ.70/Rev.1 ‘Guidance for the Commissioning Testing of Ballast Water Management Systems’  
• IMO BWM.2/Circ.42/Rev.2 ‘Guidance on Ballast Water Sampling and Analysis for Trial Use in accordance with the BWM Convention and Guidelines (G2)’

Performing ballast water sampling and analysis 

Inspectors performing sampling and analysis of ballast water from a ship are required to: 

• Be trained using indicative analysisii equipment to verify ballast water compliance on-site.  
• Understand how to properly use and maintain the ballast water sampling port. In practice, inspectors must know why and how to keep the vessel’s water ballast system’s G2 sampling device free of contaminants and know to monitor flow rates to avoid organism mortality (i.e. damaging the organisms) in the process of taking a sample. 
• Understand the potential challenges of your indicative sampling equipment, such as the sampling port and filter. In practice, this means inspectors must be aware of any circumstances or water quality issues that might interfere with the correct use of the equipment. 
• Know the proper way to dispose of water samples after testing.

Performing verification of BWMS self-monitoring equipment 

Inspectors must verify that personnel operating the BWMS installation is familiar with it. Therefore, inspectors performing verification of the self-monitoring equipment are required to:  

• Understand the System Design Limitations of the BWMS (these are stated in the BWMS type approval certificate). 
• Know the BWMS self-monitoring parameters (such as flow rate, pressure, TRO concentration, UV transmittance/intensity, etc.). 
• Know how the BWMS notifies the inspector if the BWMS is operated outside its system design limitations. 
• Understand how to access the BWMS log to evaluate that the BWMS operated correctly during ballasting operations when the inspector is not present. 
• Have the procedures and knowledge to assess the applicable self-monitoring parameters of the BWMS – taking into account the System Design Limitations of the BWMS.

Next step: Becoming an approved service provider 

We hope this article has helped you prepare to start the BWMS commissioning testing service provider approval process. Once your application is accepted by the classification society, they will review the documentation and, in some cases, perform an on-site audit before issuing final approval. 

If you have any questions, feel free to reach out. We are happy to share our expertise gained from years of developing ballast water compliance testing technology for customers worldwide.  

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