I:\MEPC\57\2-8.doc 

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INTERNATIONAL MARITIME ORGANIZATION

IMO 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

57th session 

Agenda item 2 

MEPC 57/2/8

 26 December 2007

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

Application for Basic Approval of the ballast water management system using 

“TG Ballastcleaner and TG Environmentalguard” as Active Substances 

(Toagosei Group) 

Submitted by Japan 

SUMMARY

Executive summary: This document contains non-confidential information for 

Basic Approval of the ballast water management system using “TG 

Ballastcleaner” and “TG Environmentalguard” as Active Substances 

developed by Toagosei Group in accordance with the Procedure for 

approval of ballast water management systems that make use of 

Active Substance (G9) adopted by resolution MEPC.126(53). 

Relevant documents and an application dossier will be provided to 

Marine Environment Division of the Organization for review by the 

GESAMP-Ballast Water Working Group. 

Action to be taken: Paragraph 5 

Related documents: BWM/CONF/36; MEPC 53/24/Add.1 and BWM.2/Circ.12 

Introduction 

1 Regulation D-3.2 of the Ballast Water Management Convention (BWM Convention) 

requires that ballast water management systems that make use of Active Substances to comply 

with the Convention shall be approved by IMO based on a procedure developed by the 

Organization. 

2 MEPC 53 adopted the Procedure for approval of ballast water management systems that 

make use of Active Substances (G9) by resolution MEPC.126(53). Section 8 of Procedure (G9) 

sets out the methodology to be followed for the approval of such systems and requests IMO to 

establish a Technical Group (the GESAMP-Ballast Water Working Group) to review the 

proposals submitted by Members and report to the Organization on its findings. 

3 According to BWM.2/Circ.12, proposals for approval of ballast water management 

systems that make use of Active Substances are to be submitted to Marine Environment Division 

of the Organization to be reviewed by the GESAMP-Ballast Water Working Group. In the 

meantime, a document on the proposal for approval containing all the non-confidential data 
MEPC 57/2/8 - 2 - 

I:\MEPC\57\2-8.doc 

related to the respective ballast water management system that makes use of Active Substances 

needs to be submitted to MEPC 57. 

4 Japan therefore submits the non-confidential part of the applicant’s dossier in the annex to 

this document to the Organization for evaluation according to Procedure (G9). The complete 

dossier will be made available to the experts of the GESAMP-Ballast Water Working Group with 

the understanding of confidential treatment. 

Action requested of the Committee 

5 The Committee is invited to consider the proposal for approval and decide as appropriate. 

*** 
MEPC 57/2/8 

I:\MEPC\57\2-8.doc 

ANNEX 

NON-CONFIDENTIAL INFORMATION ON THE BALLAST WATER MANAGEMENT 

SYSTEM USING “TG BALLASTCLEANER AND TG ENVIRONMENTALGUARD” AS 

ACTIVE SUBSTANCES DEVELOPED BY TOAGOSEI GROUP (JAPAN) 

SUMMARY 

The Toagosei Group (TG Corporation, Toagosei Co. Ltd. and Tsurumi Soda Co. Ltd.) has 

developed a chemical system for the treatment of ships’ ballast water and sediments. The system 

minimizes or completely eliminates the risks that the transfer of harmful aquatic organisms and 

pathogens poses to environment, human health, property or resources. It also avoids the 

undesired effects of the Active Substances used for disinfection. 

The framework of this ballast water treatment system that uses two kinds of Active Substances is 

composed of the following. 

Firstly, while ballasting, most of aquatic organisms and large size suspended particles which are 

larger than 50 μm in pumped up seawater are removed by high performance filters and returned 

to the sea in backwash water of the filters. Secondly, TG Ballastcleaner (sodium hypochlorite) is 

added into the turbulent flow in the pipe in order to kill all the living aquatic organisms left in 

ballast water. Thirdly, while deballasting, residual chlorine contained in the disinfected ballast 

water is reduced and eliminated by adding TG Environmentalguard (sodium sulfite) in order to 

protect marine habitats in the surrounding seawater where the treated ballast water is discharged. 

This is a groundbreaking chemical system in the senses of effective disinfection and 

harmlessness to the environment in three aspects: (1) it returns most of aquatic organisms to 

their natural habitats by filter backwash; (2) it uses very effective disinfectant, sodium 

hypochlorite, during ballasting; and (3) it completely eliminates residual chlorine by adding 

sodium sulfite during deballasting stage. The concept of this chemical system is outlined in Fig.1. 

Fig.1 Concept of the chemical system 

Active Substances, Other Components and Relevant Chemicals generated by the reactions of the 

Active Substances, which are related to this system, are shown in Table 1. Screening results for 

risk assessments and examining mammalian toxicity are also shown in this table. 

NaClO ...

TG Ballastcleaner TG Environmentalguard 

Ballast 

NaClO 

Na2SO3 Na2SO4

Seawater 

Freshwater 

BALLASTING DEBALLASTING 

Disinfected 

Ballast Water 

Treated Ballast Water 

Ballast Line 

Water Environment 

NaClO Na2SO3

Filter 

Back 

Wash 

Water 
MEPC 57/2/8 

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Table 1 Screening results for risk assessments and mammalian toxicity 

Classifi Required investigation 

-cation 

Chemical substance 

Risk 

assessment 

Mammalian 

toxicity 

Reason for exclusion 

Trade Name: TG Ballastcleaner

AS Sodium hypochlorite X O Reduced by aquatic 

organisms, organic matter and 

sodium sulfite 

OC Sodium chloride X X Conc. is very low compared 

with natural conc. in seawater 

OC Sodium hydroxide X X Becomes salt and water (pH 

is neutral) 

RC Residual chlorine X N/A Reduced by sodium sulfite 

RC Chloroform O N/A 

RC Bromodichloromethane O N/A 

RC Dibromochloromethane O N/A 

RC Bromoform O N/A 

RC Sodium bromate O N/A 

RC Monochloroacetic acid O N/A 

RC Dichloroacetic acid O N/A 

RC Trichloroacetic acid O N/A 

RC Bromochloroacetic acid X N/A Generated in trace 

No regulations such as WHO 

RC Bromoacetic acid O N/A 

RC Dibromoacetic acid O N/A 

RC Other haloacetic acids X N/A Not detected 

RC Haloacetonitriles X N/A Not detected 

Trade Name: TG Environmentalguard

AS Sodium sulfite O (short 

only ) 

O 

(acute only ) 

Becomes sodium sulfate 

reacting with residual chlorine 

and dissolved oxygen 

OC/RC Sodium sulfate X O Very slight compared with 

natural concentration in 

seawater 

AS: Active Substance, OC: Other Component, RC: Relevant Chemical, N/A: Not Applicable 

From the above results, chemical substances to be assessed for their effects on aquatic organisms 

are the following 11 chemical species: 

sodium sulfite (acute toxicity only), sodium bromate, chloroform, 

bromodichloromethane, dibromochloromethane, bromoform, monochloroacetic acid, 

dichloroacetic acid, trichloroacetic acid, bromoacetic acid and dibromoacetic acid. 
MEPC 57/2/8 

ANNEX 

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Chemical substances to be examined for mammalian toxicity are the following three chemical 

species: 

sodium hypochlorite, sodium sulfite and sodium sulfate. 

The effect of dissolved oxygen (DO) decrease which is induced by the reaction with sodium 

sulfite is examined, and it is found to be quite minute and not to affect the environment. 

Toxicity tests and risk assessment were performed in order to evaluate the effects on the 

environment posed by the discharging of treated ballast water when using this chemical system. 

.1 Results of the toxicity tests using three types of aquatic organisms are as follows: 

(a) No acute toxicity was observed for all the types of aquatic organisms. 

(b) No chronic toxicity was observed for fish and crustacean. 

(c) Slight effect on the growth rate of algae was observed, but the growth rate 

was not affected if the treated ballast water was diluted more than 5.24 fold. 

.2 The assessment by PBT criteria was performed. There are no chemical substances 

which fall under the three categories, and it proceeds to risk assessment. 

.3 Risk assessments were performed by measuring the concentrations of the above 

described eleven chemical substances in the simulated ballast water and using the 

estimated dilution factors of PEC calculated using the MAM-PEC model. 

The results of PEC/PNEC examination are shown in Table 2 and Table 3. 

Table 2 PEC/PNEC ratios for six chemical substances using MAM-PEC model 

Chemical substance PEC / PNEC 

Chloroform Freshwater: 0.052, seawater: 0.025 

Bromoform Freshwater: 0.11, seawater: 0.46 

Monochloroacetic acid 0.28 

Trichloroacetic acid 0.98 

Bromoacetic acid 0.61 

Sodium sulfite 0.0013 (short) 
MEPC 57/2/8 

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Table 3 PEC/PNEC ratios for five chemical substances using 

the conservative dilution factor 

Chemical substance Dilution factor PEC / PNEC 

Sodium bromate 1/58 0.005 

Bromodichloromethane 1/58 0.004 

Dibromochloromethane 1/58 0.006 

Dichloroacetic acid 1/58 0.0001 

Dibromoacetic acid 1/58 0.014 

After the above considerations, the ballast water treated with the TG Ballastcleaner and 

TG Environmentalguard is deemed to have no effect on the surrounding water and aquatic 

organisms. 

Studies in the physical and chemical properties of the two Active Substances have shown that 

this chemical system does not threaten the structural integrity of ships or the health and safety of 

the ship’s personnel when they are properly based on the prepared operating instructions. 

1 INTRODUCTION 

Aquatic organisms artificially transported to other regions beyond their natural areas of 

distribution disrupt the ecosystems of those regions. Invasive species are introduced not only as a 

result of fishery practices that allow benthic organisms and periphyton such as bivalves, starfish, 

balanomorpha and seaweed to be transported with marine products intended for feed or for stock. 

They are also introduced by ships to which they attach themselves or in whose ballast water they 

are carried. 

The International Maritime Organization took up this issue in the latter half of the 1980s and in 

February 2004 adopted the International Convention for the Control and Management of Ships’ 

Ballast Water and Sediments, which regulates the management of ballast water. It articulated the 

direction of efforts for this problem by specifying mandatory to adopt an approved ballast water 

treatment management system (such as ballast water treatment equipments) for all ships engaging 

in international voyages. 

Toagosei Group (TG Corporation, Toagosei Co. Ltd. and Tsurumi Soda Co. Ltd.) therefore 

utilized a widely used disinfectant to kill invasive species in ballast water. It is effective yet 

inexpensive chemical compound, sodium hypochlorite (trade name: TG Ballastcleaner). 

The disadvantage of this concept is that the discharged ballast water containing residual chlorine 

derived from sodium hypochlorite will adversely affect aquatic organisms in the water where the 

discharged ballast water is received. Residual chlorine has been much concerned in sewage 

treatment and electrical power plants that use chlorine to disinfectant. 

To avoid this adverse effect, a reducing agent was conceived to be added to the disinfected 

ballast water in order to reduce and eliminate residual chlorine completely. For this purpose 

Toagosei Group selected a reducing agent, sodium sulfite (trade name: TG Environmentalguard) 

that is an approved food additive. 
MEPC 57/2/8 

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2 OUTLINE OF CHEMICAL SYSTEM 

This chemical system uses, as the first Active Substance, sodium hypochlorite which is the main 

ingredient in TG Ballastcleaner as a disinfectant to kill aquatic organisms, and uses, as the 

second Active Substance, sodium sulfite which is the main ingredient in TG Environmentalguard 

as an agent to eliminate residual chlorine from the ballast water which is disinfected with 

TG Ballastcleaner (hereafter it is described as disinfected ballast water) because of its reducing 

ability. This system operates as follows: 

.1 When ballast water is loaded on board using a ballast pump, a high-performance 

filter is used to remove organisms and sediment over a certain size before 

TG Ballastcleaner (containing sodium hypochlorite) is injected into the ballast 

water. The organisms which are filtered out are sent back to their natural habitats 

in the backwash water of the filter. 

.2 TG Ballastcleaner is supplied from a storage tank to the ballast line at the 

prescribed addition ratio of 0.024% for seawater. This amount yields a free 

available chlorine (hereafter it is described as FAC) concentration of 30 mg/l when 

the agent contains a 12% of FAC. 

.3 TG Environmentalguard is supplied from a storage tank to the deballast line at the 

prescribed addition ratio of 0.021% for seawater. This amount yields sodium 

sulfite concentration of 22 mg/l when the agent contains a 10% of sodium sulfite. 

.4 To operate this system efficiently, the chemical agents are designed to be added in 

turbulent flow regions for complete mixing. 

Total treatment system with 250 m3

/h capacity using this chemical system, filtration and 

cavitation generation device has been already tested for two years. The system shows good 

performances and the several operational parameters are successfully obtained as a complete 

ballast water management system. Development of the injection control system of the 

“Active Substance” has been done in order to minimize the consumption of TG Ballastcleaner 

and TG Environmentalguard aiming at the application for the Final Approval of this total system. 

2.1 Disinfection process 

TG Ballastcleaner, whose main ingredient is sodium hypochlorite, is injected into the ballast line 

and the disinfected ballast water flows into the ship’s ballast tanks, where aquatic organisms are 

killed just after the injection and during the ship’s voyage. 

2.2 Reduction process of residual chlorine 

To prevent that the residual chlorine in the discharged ballast water kills local aquatic life, 

reproduction and finally disrupting the ecosystem, TG Environmentalguard, which mainly 

consists of sodium sulfite as its “Active Substance”, is mixed into the disinfected ballast water to 

reduce the residual chlorine before the ballast water is discharged. Residual chlorine in 

disinfected ballast water is completely eliminated and become harmless because of this process. 

The excess of sodium sulfite becomes sodium sulfate by reacting with dissolved oxygen. 

Although a portion of dissolved oxygen in the surrounding water receiving the treated ballast 

water decreases immediately after the ballast water is discharged, environmental effects are 
MEPC 57/2/8 

ANNEX 

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unlikely to exist because the oxygen is quickly supplied from the atmosphere to surface water. 

The environmental effects of this method of removing residual chlorine have been examined near 

sewage-processing plants that empty sewage effluent into Lake Michigan. The preservation of 

the quality of the water region was demonstrated using aquatic organisms as the benchmark 

(A.M.Beeton, 1976). 

3 GENERAL REQUIREMENTS 

3.1 Identification 

3.1.1 Screening of “Active Substances”, “Other Components” and “Relevant Chemicals”

TG Ballastcleaner contains sodium hypochlorite as its Active Substance, and it also contains 

sodium hydroxide and sodium chloride as Other Components which are remaining in the product. 

Using sodium hypochlorite generates or may generates by-products, their by-products are 

designated as Relevant Chemicals, which include hypochlorous acid, hypobromous acid, sodium 

hypobromite, sodium bromate, chloramine, trihalomethanes, haloacetic acids and 

haloacetonitriles. 

Another chemical agent, TG Environmentalguard contains sodium sulfite as its Active Substance 

and sodium sulfate as an Other Component which is remaining in the product. Sodium sulfate is 

also designated as a Relevant Chemical because it is generated when sodium sulfite reacts with 

residual chlorine and dissolved oxygen in the disinfected ballast water. 

Relevant Chemicals are selected from chemical substances which WHO and others enumerate as 

concerned chlorine disinfection by-products, and chemical substances which Robert L. Jolly 

et al. enumerate in “Water Chlorination Environmental Impact and Health Effects volume 1 to 5” 

with relation to power station cooling water in addition to chlorine disinfection by-products. 

3.1.2 Identification of “Active Substances”, “Other Components” and “Relevant 

Chemicals” 

Identification results on TG Ballastcleaner (sodium hypochlorite) and TG Environmentalguard 

(sodium sulfite) as “Active Substances” are listed in Tables 3.1.2.1 and 3.1.2.2, respectively. 
MEPC 57/2/8 

ANNEX 

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Table 3.1.2.1 Identification of substances relative to TG Ballastcleaner 

Substance Chemical 

Formula 

Identification no. Concentration 

Active Substance: 

Sodium hypochlorite NaClO CAS no. 7681-52-9 

EINECS no. 231-668-3

UN no. 1791 

IMCO Class 8.0 

5–13 wt% (as free available 

chlorine*) 

*hereafter it is described as 

FAC 

Other Components: 

Sodium hydroxide NaOH CAS no. 1310-73-2 

EINECS no.215-185-5

UN no. UN1824 

IMCO Class 8.0 

Less than 1 wt% in amount 

corresponding to 12% FAC 

Sodium chloride NaCl CAS no. 7647-14-5 Less than 13 wt% in amount 

corresponding to 12% FAC 

Relevant Chemicals: 

Hypochlorous acid HClO CAS no. 7790-92-3 --- 

Chloroform CHCl3 CAS no. 67-66-3 --- 

Bromodichloromethane CHBrCl2 CAS no. 75-27-4 --- 

Dibromochloromethane CHBr2Cl CAS no. 124-48-1 --- 

Bromoform CHBr3 CAS no. 75-25-2 --- 

Hypobromous acid HBrO CAS no. 13517-11-8 --- 

Sodium hypobromite NaBrO CAS no. 13824-96-9 --- 

Sodium bromate NaBrO3 CAS no. 7789-38-0 --- 

Monochloroacetic acid CH2ClCOOH CAS no. 79-11-8 --- 

Dichloroacetic acid CHCl2COOH CAS no. 79-43-6 --- 

Trichloroacetic acid CCl3COOH CAS no. 76-03-9 --- 

Bromochloroacetic acid CHBrClCOOH CAS no. 5689-96-8 --- 

Bromodichloroacetic 

acid 

CBrCl2COOH CAS no. 71133-14-7 --- 

Dibromochloroacetic 

acid 

CBr2ClCOOH CAS no. 5278-95-5 --- 

Bromoacetic acid CH2BrCOOH CAS no. 79-08-3 --- 

Dibromoacetic acid CHBr2COOH CAS no. 631-64-1 --- 

Tribromoacetic acid CBr3COOH CAS no. 75-96-7 --- 

Chloroacetonitrile CH2ClCN CAS no. 107-14-2 --- 

Dichloroacetonitrile CHCl2CN CAS no. 3018-12-0 --- 

Trichloroacetonitrile CCl3CN CAS no. 545-06-2 --- 

Dibromoacetonitrile CHBr2CN CAS no. 3252-43-5 --- 

Bromochloroacetonitrile CHBrClCN CAS no. 83463-62-1 --- 

Monochloramine NH2Cl CAS no. 10599-90-3 --- 
MEPC 57/2/8 

ANNEX 

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Table 3.1.2.2 Identification of substances relative to TG Environmentalguard 

Substance Chemical

Formula 

Identification no. Concentration 

Active Substance: 

Sodium sulfite

Na2SO3 CAS no. 7757-83-7 More than 10 wt% 

Other Component and 

Relevant Chemical: 

Sodium sulfate

Na2SO4 CAS no. 7757-82-6 Less than 5 wt% 

3.1.3 Chemical substances to be examined 

Among chemical substances described in the previous section, the substances excluded from the 

examination and the reasons for exclusion are as follows:

.1 Concentration formed in the chemical reaction is very low compared to the natural 

concentration in seawater, less than 1/500 and 1/100, respectively: NaCl, Na2SO4

.2 To be reduced by added sodium sulfite: NaClO, HClO, HBrO, NaBrO, NH2Cl 

.3 To form salt and water after reacting with components in water. Not change pH of 

the ballast water: NaOH 

.4 To become another chemical substance, sodium sulfate, rapidly: Na2SO3

Consequently, chemical substances to be examined are sodium sulfite (acute toxicity only), 

sodium bromate, trihalomethanes, haloacetic acids and haloacetonitriles. 

3.2 Data set of “Active Substance”, “Other Components” and “Relevant Chemicals” 

The toxicity of the selected five chemical substances and groups, related with TG Ballastcleaner 

and TG Environmentalguard to aquatic organisms was examined using references such as 

IUCLID (International Uniform Chemical Information Database), OECD SIDS 

(Screening Information Data Sets) and ECOTOX (United States EPA Database). 

3.2.1 Effects on aquatic plants, invertebrates, fish and other biota 

Acute and chronic toxicity to aquatic organisms 

Acute and Chronic Toxicity is shown in Tables 3.2.1.1 to 3.2.1.6. 
MEPC 57/2/8 

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Table 3.2.1.1 Acute toxicity value of the most sensitive species to trihalomethanes 

Substance Type/Organism Endpoint Concentration 

(mg/l) 

Reference 

Fish (Freshwater) 

(Lepomis macrochirus) 

LC50 96h 18 IUCLID 

Fish (seawater) 

(Limanda limanda)

LC50 96h 28 as above 

Crustacean (Freshwater) 

(Daphnia magna) 

EC50 48h 29 as above 

Crustacean (seawater) 

Brine shrimp 

(Artemia salina) 

EC50 24h 30.37 G.D. Foster et al.

(1984) 

Phytoplankton (Freshwater) 

(Chlamydomonas reinhardtii)

EC50 72h 13.3 IUCLID 

Chloroform 

Aquatic Plant (seawater) 

Diatom (Skeletonema 

costatum) 

EC50 120h 437 as above 

Fish 

Common carp 

(Cyprinus carpio) egg 

EC50 

72-120h 

67.4 J.S. Mattice et al.

(1981) 

Bromodichloromethane 

Crustacean 

Ciliate 

(Tetrahymena pyriformis) 

EC50 24h 240 Y. Yoshioka et al.

(1985) 

Fish 

Common carp 

(Cyprinus carpio) egg 

LC50 72-

120h 

33.5 J.S. Mattice et al.

(1981) 

Dibromochloromethane 

Crustacean 

Ciliate 

 (Tetrahymena pyriformis) 

EC50 24h 65 Y. Yoshioka et al.

(1985) 

Fish (Freshwater) 

Bluegill (Lepomis 

macrochirus) 

LC50 96h 29 R.J. Buccafusco et al.

(1985) 

Fish (Seawater) 

Sheepshead minnows 

(Cyprinodon variegatus) 

LC50 96h 7.1 G.S. Ward et al.

(1981) 

Crustacean (Freshwater) 

Water flea (Daphnia pulex) 

LC50 96h 44 J.R. Trabalka et al.

(1977) 

Crustacean (Seawater) 

Brown Shrimp 

(Peaneus aziecus) 

LC50 96h 26 ECOTOX 

Phytoplankton (Freshwater) 

Green algae 

(Selenastrum capriocornutum) 

EC50 96h 38.6 PAN Pesticides 

Database 

Bromoform 

Phytoplankton (Seawater) 

Diatom 

(Skeletonema costatum) 

EC50 96h 12.3 ECOTOX 

From the above data, the acute toxicity values of the most sensitive species to trihalomethanes, 

chloroform, bromodichloromethane, dibromochloromethane, and bromoform are 13.3, 67.4, 33.5 

and 7.1 mg/l, respectively. 
MEPC 57/2/8 

ANNEX 

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Table 3.2.1.2 Chronic toxicity value of the most sensitive species to trihalomethanes 

Substance Type/Organism Endpoint Concentration 

(mg/l) 

Reference 

Chloroform Fish 

(Oncorhynchus mykiss)

LC50 27d 2.03 IUCLID 

Crustacean 

(Daphnia magna)

NOEC 21d 13 as above 

Phytoplankton 

Diatom 

(Skeletonema costatum) 

NOEC 5d 216 U.M. Cowgill et al.

(1989) 

Bromoform Fish 

Sheepshead minnow

(Cyprinodon variegatus) 

NOEC 4d 2.9 P.T. Heitmuller et al.

(1981) 

 Mollusk Littleneck clam 

(Protothaca staminea) 

Not reported 7 C.I. Gibson et al.

(1979) 

NUREG/CR-0835 

PNL-3023 

 Phytoplankton Green 

algae (Selenastrum 

capricornutum) 

NOEC 4d 10 Pan Pesticides 

Database 

From the above data, the chronic toxicity values of the most sensitive species to chloroform and 

bromoform are 2.03 mg/l (LC50 27d) and 2.9 mg/l (4d), respectively. Chronic toxicity data is not 

found for bromodichloromethane and dibromochloromethane. 

Table 3.2.1.3 Acute toxicity value of the most sensitive species to sodium bromate

From the above data, the acute toxicity value of the most sensitive species to sodium bromate 

is >30mg/l (EC50). 

Type Organism Endpoint Concentration 

(mg/l) 

Reference 

Mollusk Pacific oyster 

(Crassostrea gigas) 

EC50 96h > 30 E.A. Crecelius 

(1979) 

Nematodes & 

Flatworms 

Planarian 

(Polycelis nigra)

LT50 48h 3,018 J.R. Erichsen 

Jones (1941) 
MEPC 57/2/8 

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Table 3.2.1.4 Acute toxicity value of the most sensitive species to 

haloacetic acids and haloacetonitriles 

Substance Type Organism Endpoint Concentration 

(mg/l) 

Reference 

Rotifera 

(monochloroacetic 

acid) 

Rotifer (Brachionus 

calyciforus) 

EC50 48h 68.9 P. Radix et al.

(1999) 

Phytoplankton algae 

(monochloroacetic 

acid) 

Green algae 

(Scenedesmus 

subspicatus) 

EC50 48h 0.028 R. Kuhn et al.

(1990) 

Others Amphibian 

(dichloroacetic acid) 

African clawed frog 

(Xenopus laevis) 

EC50 96h 3,560 D.J. Fort et al.

(1993) 

Fish 

(trichloroacetic acid) 

Fathead minnow 

(Pimephales 

promelas) 

LC50 96h 2,000 W.H. Dennis 

Jr. et al. (1979) 

Others Amphibian 

(trichloroacetic acid) 

African clawed flog 

(Xenopus laevis) 

EC50 96h 1,740 D.J. Fort et al.

(1993) 

Phytoplankton algae 

(trichloroacetic acid) 

Green algae 

(Chlorella 

pyrenoidosa) 

LC50 14d 0.3 T. Bednarz 

(1981) 

Crustacean 

(bromoacetic acid) 

Water flea (Daphnia 

magna) 

EC50 24h 65 R. Kuhn et al.

(1989) 

Phytoplankton 

(bromoacetic acid) 

Green algae 

(Scenedesmus 

subspicatus) 

EC50 72h 0.2 as above 

(1990) 

Haloacetic 

acids 

Fish 

(dibromoacetic acid) 

Fathead minnow 

(Pimephales 

promelas) 

LC50 96h 69 M.A. Mayes 

et al. (1985) 

ECOTOX 

Haloacetonitriles Fish 

(dibromoacetonitrile) 

Fathead minnow 

(Pimephales 

promelas) 

LC50 96h 0.55 M.A. Mayes 

et al. (1985) 

From the above data, the acute toxicity values of the most sensitive species to chloroacetic acid, 

dichloroacetic acids, trichloroacetic acid, bromoacetic acid and dibromoacetonitrile 

are 0.028, 3560, 0.3, 0.2 and 0.49 mg/l (LC50 for dibromoacetonitrile and EC50 for others), 

respectively. Acute toxicity data is not found for other chemical substances. 

Table 3.2.1.5 Chronic toxicity value of the most sensitive species to haloacetic acids 

Substance Type/Organism Endpoint Concentration 

(mg/l) 

Reference 

Chloroacetic acid Crustacean Water flea 

(Daphnia magna) 

NOEC 21d 32 R. Kuhn et al. (1989) 

Bromoacetic acid Crustacean Water flea 

(Daphnia magna) 

NOEC 21d 3.2 as above 

From the above data, the chronic toxicity value of the most sensitive species to chloroacetic acid 

and bromoacetic acid are 32 and 3.2mg/l (NOEC 21days), respectively. Chronic toxicity data is 

not found for other chemical substances. 
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Table 3.2.1.6 Acute toxicity values of the most sensitive species to Sodium sulfite 

Type Organism Endpoint Concentration

(mg/l) 

Reference 

Fish Leuciscus idus NOEC 96h

LC50 96h 

220 

220-460 

IUCLID 

Crustacean Daphnia magna TLm 100h 203 as above 

Mollusk Buccinum undatum LC50 24h 400 as above 

Echinoderm Psammechinus miliaris LC50 24h 330(as SO3) as above 

Phytoplankton Green algae 

(Chlamydomonas reinhardtii) 

(Chlorella vulgaris) 

(Scenedesmus basiliensis) 

EC50 8.9h

EC50 6.4h

EC50 8.2h 

16-32 (as SO3) 

as above 

as above 

as above 

A. STAMM (1980) 

From the above data, the acute toxicity value of the most sensitive species to sodium sulfite 

is 25.2mg/l (EC50) (16mg/l as the concentration of SO3). 

Because all the toxic data is more than NOEC 0.01 mg/l, all of these chemical substances are 

concluded as “not toxic.” 

3.2.2 Endocrine disruption 

On the “Active Substances”, the “Other Components” and the “Relevant Chemicals” concerning 

TG Ballastcleaner and TG Environmentalguard, no endocrine disruption is listed in various 

databases such as EC list.

3.2.3 Sediment toxicity 

 

Sediment toxicity is determined by using the absorption coefficient (Koc) of soil. 

The representative “Relevant Chemicals” such as chloroform are obtained from ECOTOX. All 

the chemicals under evaluation have Koc values less than 500 l/kg. Thus the evaluation for the 

effects on benthic organisms is unnecessary. 

3.2.4 Bioavailability / biomagnification / bioconcentration 

The log Pow (parameter for bioaccumulation) for any of the selected chemicals is less than 3, 

thus they cannot be judged to show great bioaccumulation tendency, and testing of 

them is unnecessary. BCF values are calculated by using the regression formula, 

log BCF = 0.767log Pow - 0.929. Results are shown in Table 3.2.4.1. 
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Table 3.2.4.1 Bioavailability / Biomagnification / Bioconcentration 

Chemical substance logPow BCF (l/kg) Reference 

Relevant Chemicals 

Chloroform 1.52 1.7 Syracuse Research Corporation, 

Bromodichloromethane 1.61 2.0 Syracuse Research Corporation, 

Dibromochloromethane 1.70 2.4 Syracuse Research Corporation, 

Bromoform 1.79 2.8 Syracuse Research Corporation, 

Sodium bromate -7.18 3.7×10-7 Syracuse Research Corporation, 

Chloroacetic acid 0.34 2.1×10-1 Syracuse Research Corporation, 

Dichloroacetic acid 0.52 3.0×10-1 Syracuse Research Corporation, 

Trichloroacetic acid 1.44 1.5 Syracuse Research Corporation, 

Bromochloroacetic acid 0.61 3.5×10-1 Syracuse Research Corporation, 

Bromoacetic acid 0.43 2.5×10-1 Syracuse Research Corporation, 

Dibromoacetic acid 0.70 4.1×10-1 Syracuse Research Corporation, 

Chloroacetonitrile 0.11 1.4×10-1 Syracuse Research Corporation, 

Dichloroacetonitrile 0.29 2.0×10-1 Syracuse Research Corporation, 

Trichloroacetonitrile 1.21 1.0 Syracuse Research Corporation, 

Bromoacetonitrile 0.20 1.7×10-1 Syracuse Research Corporation, 

Dibromoacetonitrile 0.47 2.7×10-1 Syracuse Research Corporation, 

Monochloramine -1.19 1.4×10-2 Syracuse Research Corporation, 

Active substance 

Sodium Sulfite -7.78 1.3×10-7 Syracuse Research Corporation, 

Other component 

Sodium sulfate -4.38 5.2×10-5 Syracuse Research Corporation, 

Because the BCF values obtained are less than 500 l/kg (wet weight), evaluation of crosscontamination (effects of concentration and migration) is unnecessary. 

Food web/population effect 

For the reasons described above, there are no chemical substances applied to this category. 

3.3 Data on mammalian toxicity 

The mammalian toxicity of the “Active Substances” and the “Other Components” is evaluated by 

using the available data here. Chemical substances under evaluation are listed in Table 3.3.1. 

Table 3.3.1 “Active Substances” and “Other Components” for Mammalian toxicity 

Product Substance Concentration 

TG Ballastcleaner Sodium hypochlorite 5–13 wt% (as FAC) 

TG Environmentalguard Sodium sulfite > 10 wt% 

Sodium sulfate < 5 wt% 
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The following two “Other Components” of TG Ballastcleaner shown in Table 3.1.2.1 are 

excluded: 

Sodium hydroxide – one of general purpose chemicals, which is evaluated as “non toxic” 

in OECD SIDS (2002). 

Sodium chloride – a major constituent of seawater. 

3.3.1 Acute toxicity 

The most sensitive data for acute toxicity are shown in Table 3.3.2, and they are moderately 

toxic. 

Table 3.3.2 Oral toxicity of chemical substances to mammals 

Substance Species (animal) LD50 Reference 

Sodium hypochlorite Rat 1.23–1.46 g/kg ECBI/14/05 

Sodium sulfite Rat 2.61 g/kg bw IUCLID, 

Na2SO3,(2000) 

Sodium sulfate Mouse 5.99 g/kg bw OECD SIDS, 

Okahara ,(2005) 

3.3.2 Effects on skin and eye 

The most sensitive data for effect on skin irritation are shown in Table 3.3.3. There are some 

irritation effects for sodium hypochlorite at each concentration, while no effects are found for 

sodium sulfite and sodium sulfate. 

The most sensitive data for effect on eye irritation are shown in Table 3.3.4. There are some 

irritation for sodium hypochlorite and sodium sulfate, but no effects are found for sodium sulfite. 

Table 3.3.3 Effects on skin irritation 

Substance Species 

(animal) 

Exposure 

duration 

Concentration Observation and 

remark 

Reference 

Sodium 

hypochlorite 

Rabbit

6 

24 hours 12.7% 

(as FAC) 

Intact skin and 

abraded skin 

Result: Moderately 

irritating 

ECBI/14/05, 

Colgate 

Palmolive,(1985) 

Sodium 

sulfite 

Rabbit Not 

reported 

Not reported Not irritating 

Draize 

IUCLID, 

Na2SO3,(2000) 

Sodium 

sulfate 

Rabbit 4 hours 

Occlusive 

500 mg Sligtly irritating 

EC classification-not 

irritating OECD 404, 

Draize 

OECD SIDS, 

Na2SO4,(2005) 
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Table 3.3.4 Effects on eye irritation 

Substance Species 

(animal) 

Exposure 

duration & 

concentration 

Method Observation and 

remark 

Reference 

Sodium 

hypochlorite 

Rabbit 

6 

14days 

12.7% 

Draize 

method 

Severely irritating. 

Recovery not 

complete at 14days 

ECBI/14/05, 

Colgate 

Palmolive,(1985) 

Sodium 

sulfite 

Rabbit Not reported BASF-test Not irritating IUCLID, 

Na2SO3,(2000) 

Sodium 

sulfate 

Rabbit 90 mg, 

pulverized 

into 

conjunctival 

sac 

OECD 

guideline 

405 

Slight irritating 

redness of the 

conjunctiva 

observed. The 

redness was 

reversible within 7 

days. 

OECD SIDS, 

Na2SO4,(2005) 

From the data shown above, the conclusion is given as follows: 

Sodium hypochlorite causes irritations on skin and eye at each production concentration, 

but sodium sulfite has no effect. Sodium sulfate has only slight irritation. There are no 

data of skin sensitization for sodium hypochlorite at the production concentration and no 

data at all for sodium sulfite and sodium sulfate. OECD SIDS(2005)concluded that 

skin sensitization to sodium sulfate is highly unlikely. 

3.3.3 Chronic and long-term toxicity 

The most sensitive data for chronic toxicity are shown in Table 3.3.5. For sodium hypochlorite 

and sodium sulfite, no effects are observed for chronic and long-term toxicity. For sodium 

sulfate, OECD SIDS concluded that “Since this substance has no discernable systemic toxicity, a 

tentative chronic NOAEL that is equal to or greater than 320 mg/kg/day in rats would seem to 

provide a reasonable margin of safety.”
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Table 3.3.5 Chronic toxicity of chemical substances to mammals 

Substance Species 

(animal)

Dosage route & 

concentration 

Duration of 

treatment 

Observation and 

remark 

Reference 

Sodium 

hypochlorite 

B6C3F1 

Mice 

Drinking water 0, 

70, 140 and 275 

mg/l as FAC 

2 years Significant decrease 

in body weight at the 

highest dose was 

observed but it was 

ascribed to less 

water consumption. 

ECBI/14/05 

Sodium 

sulfite 

No data. 

WHO has recognized as non toxic. 

WHO Food 

Additives 

Series21 IPCS 

INCHEM Home

Sodium 

sulfate 

Rats 

Sprague 

dawley 

In food 0.84% in 

diet 

27 and 44 

weeks daily 

NOAEL 320-400 

mg/kg/day 

Mortality, tumor, 

Body weight, food 

and water 

consumption 

OECD SIDS, 

Na2SO4,(2005) 

3.3.4 Developmental and reproductive toxicity 

The typical data for developmental toxicity are shown in Table 3.3.6, and there are no significant 

effects except sodium hypochlorite that has minor effects. The typical data obtained for 

reproductive toxicity are shown in Table 3.3.7. But no effect is found for these three chemical 

substances.

Table 3.3.6 Development toxicity of chemical substances to mammals 

Substance Species 

(animal) 

Dosage route & 

concentration 

Duration of 

treatment 

Observation 

and remark 

Reference 

Sodium 

hypochlorite 

Female 

SD rats 

Drinking water 

0, 0.1, 1 and 10 

mg/kg/day 

(mg FAC/kg/day) 

2.5 months prior 

to conception 

and throughout 

gestation 

Minor effects at 

100 mg/l 

ECBI/14/05 

Sodium 

sulfite 

Rat 

Wistar 

Oral Feed 

0.32; 0.63; 1.25; 

2.5 and,5% 

(300, 1100, 2100 

and 3300 mg/kg) 

8-20 days of 

gestation, daily 

20 days and 

after birth. 

No significant 

effect 

IUCLID Na2SO3

(55)(56)(57) 

Sodium 

sulfate 

The limited available data give no indication that sodium sulfate is 

toxic for development. 

OECD SIDS 

(2005) 
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Table 3.3.7 Reproductive toxicity of chemical substances to mammals 

Substance Species 

(animal) 

Dosage route & 

concentration 

Duration of 

treatment 

Observation 

and remark 

Reference 

Sodium 

hypochlorite 

LongEvans 

rats 

Gavage Males: 66 days 

Females: 35 days 

No effects 

observed 

ECBI/14/05 

Sodium 

sulfite 

No data 

With WHO’s recognition testing for reproductive toxicity is deemed 

unnecessary. 

WHO Food 

Additives 

Series 21 IPCS 

INCHEM Home 

Sodium 

sulfate 

The available data on fertility are quite limited but in view of the fact 

that the substance is abundantly occurring in the body, toxicity for 

reproduction is unlikely. 

OECD SIDS 

(2005) 

3.3.5 Carcinogenicity and mutagenicity 

The typical data for carcinogenicity are shown in Table 3.3.8, and there are no significant effects. 

The typical data for mutagenicity are shown in Table 3.3.9. Although in vitro test some results 

are positive for sodium hypochlorite, in vivo test results show negative. There are no in vivo test 

results available for sodium sulfite and sodium sulfate, but in vitro test results are negative. 

Table 3.3.8 Carcinogenicity of chemical substances to mammals 

Substance Species 

(animal) 

Type of test, 

duration 

Doses (mg/l, 

FAC) 

Observation and 

remark 

Reference 

Sodium 

hypochlorite 

Rat Oral, drinking 

water, 104 weeks 

Males: 0, 475 

and 950 

Females: 0, 

950 and 1,900 

Negative ECBI/14/05 

Sodium 

sulfite 

No specific data 

IARC designates as “group 3”. 

Pan 

Pesticides 

Database 

Sodium 

sulfate 

Swiss 

albino 

mice 

Carcinogenicity 

26 weeks, daily 

31 μg in 0.01 

ml (0.9%) per g 

body weight, 

s.c. injected 

Tumor of subcutis 

and/or skin in 1% 

of the female and 

4% in male 

(normal for this 

strain in this lab). 

OECD SIDS 

(2005) 
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Table 3.3.9 Mutagenicity of chemical substances to mammals 

Substance Species Type of test Concentration 

(mg/l) 

Observation 

and remark 

Reference 

Sodium 

hypochlorite 

In vivo: 

mouse BM

Micronucleus 312.5–2,500 mg/kg Negative ECBI/14/05 

Sodium 

sulfite 

In vitro: 

Salmonella 

typhimurium 

OECD 

Guide-line 

471 “Genetic 

Toxicology: 

Salmonella 

typhimurium 

Reverse 

Mutation 

Assay” 

20-500 μg/ plate 

Metabolic activation: 

with and without 

Negative IUCLID 

Na2SO3(2000) 

Sodium 

sulfate 

In vitro: 

Salmonela 

typhimurium 

Ames test 

under GLP 

Salmonella 

Microsome 

test 

312-5,000μg 

Metabolic S-9 

activation: with and 

without 

Negative OECD SIDS 

(2005) 

From the above data sodium hypochlorite, major component of TG Ballastcleaner, and sodium 

sulfate, the “Other Components” of TG Environmentalguard, show slight acute and chronic 

toxicity, and irritation to skin and eye. Except vents of storage tank, these chemicals are treated 

within closed piping system where they are supplied from storage tank to ballast line. Therefore, 

there is no possibility of crew’ exposure to these chemicals during the ordinary ballasting and 

deballasting operations. 

On the other hand, there are possibilities that crew are exposed to these chemicals during 

operation of filling up to storage tanks and flushing of leaked chemicals from tanks or piping. 

During these operations it is necessary for crew to work with sufficient protections based on the 

operation manuals. Instructions on these special works are described in chapter 5. 

3.4 Physical and chemical properties of the “Active Substances” and the treated ballast 

water

The physical and chemical properties of the “Active Substances” and the “Other Components” of 

TG Ballastcleaner are investigated. Those of sodium sulfite, the “Active Substance” of 

TG Environmentalguard and sodium sulfate, the “Other Component” and the “Relevant 

Chemicals” of TG Environmentalguard, are also investigated. The data for ”Relevant Chemicals” 

are not listed in this summary. 

Tables 3.4.1 and 3.4.2 show the physical and chemical properties of TG Ballastcleaner and 

TG Environmentalguard. 
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Table 3.4.1 Physical and chemical properties of TG Ballastcleaner 

Classification Active Substance Other Component Other Component 

Trade name TG Ballastcleaner 

Chemical name Sodium hypochlorite Sodium hydroxide Sodium chloride 

Molar mass 74.44 g/mol 40.00 g/mol 58.44 g/mol 

Formula NaClO NaOH NaCl 

Melting point -20 to -30oC 323oC 801oC 

Boiling point 96 to 120oC at 1013 hPa 1388oC 1413oC 

Specific gravity 1.15 (13.1wt% as FAC) 

aqueous solution at 25oC 

1.00 (0.04wt%) 

 at 27oC 

1.10 (3 wt%) at 23oC 

Vapor Pressure 17.4 – 20 kPa at 20oC 0.133 kPa at 739oC 0.133 kPa at 865oC 

Aqueous solubility 29.3 g/100g at 0oC 109 g/100 g at 20oC 35.6 g/100 g at 0oC 

PH >11.5 12 in 0.05 wt% Neutral 

Octanol-water 

partition coefficient 

logPow=-3.42 logPow=-3.88 logPow=-0.46 

Table 3.4.2 Physical and chemical properties of TG Environmentalguard 

Classification Active Substance Other Component 

Trade name TG Environmentalguard 

Chemical name Sodium sulfite Sodium sulfate 

Molar mass 126.04 g/mol 142.05 g/mol 

Formula Na2SO3 Na2SO4

Melting point 600oC 888oC 

Boiling point None (To become sodium sulfate) 1429 oC 

Specific gravity 1.10 g/cm3 (11wt%) at 23oC 1.10 g/cm3 (10wt%) at 27oC 

Vapor Pressure Substantially 0 mm Hg at ambient 

temperature 

Substantially 0 mm Hg at ambient 

temperature 

Aqueous solubility 13.8 g/100g at 0oC 19.5 g/100g at 0oC 

PH > 10 Neutral 

Octanol-water partition 

coefficient 

logPow=-7.8 logPow=-4.4 
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4 RISK ASSESSMENTS 

Risk assessments for chemical substance concerning the chemical behavior within ballast water 

were undertaken before screening of persistency (P), bioaccumulation (B) and toxicity (T) are 

evaluated. 

4.1 Reactions of TG Ballastcleaner (Sodium Hypochlorite) in ballast water 

Sodium hypochlorite, the main ingredient of TG Ballastcleaner, is chemically changed into 

hypochlorite, hypobromite, sodium hypobromous acid and chloramine in the ballast water. 

4.2 Reactions of TG Environmentalguard (Sodium Sulfite) in ballast water 

Sodium sulfite, the main ingredient of TG Environmentalguard, reduces residual chlorine by the 

following reaction: 

NaClO + Na2SO3 NaCl + Na2SO4 

The excess of sodium sulfite becomes sodium sulfate by reacting with dissolved oxygen in 

ballast water by the following reaction: 

2Na2SO3 + O2 2 Na2SO4 

This reaction temporarily decreases the dissolved oxygen concentration in water where the 

ballast water treated with TG Environmentalguard is discharged. But the treated ballast water is 

discharged into surface layer water, which is in equilibrium with the atmosphere and even large 

amount of TG Environmentalguard is unlikely to adversely affect the environment because the 

natural concentration of dissolved oxygen is quickly supplied from atmospheric oxygen. 

4.3 Selection of chemical substances for presenting risks to environment

The chemical substances to be evaluated here are sodium sulfite (acute toxicity only), sodium 

bromate, trihalomethanes, haloacetic acids and haloacetonitriles as described in Section 3.1.3. 

4.4 Exposure assessment on aquatic organisms 

Five chemical substances and groups selected above are evaluated based on PBT criteria.

4.4.1 Persistence test (P) 

From the data gathered, some organic chemicals undergo reductive decomposition in the 

anaerobic environment of sediment. As the environment under consideration is the treated ballast 

water and surrounding water where it is discharged, trihalomethanes, haloacetic acids, 

haloacetonitriles and sodium bromate are determined as persistent in accordance with PBT 

criterion for persistency (half-life periods in hydrolysis is greater than 60 days in seawater). 
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4.4.2 Bioaccumulation test (B) 

No observed data for inorganic chemicals is available, but inorganic chemicals and their 

“Relevant Chemicals” are not thought to be bioaccumulate because they are water-soluble. 

The log Pow, the bioavailability / biomagnification / bioaccumulation factor is smaller than 3 for 

all substances. Therefore, they are thought unlikely to be bioaccumulative and do not 

require testing. The log BCF values are obtained using the regression formula, 

log BCF = 0.767log Pow - 0.929 (R2=0.793, n=199, 95% confidence interval: ±1.027) 

substituting log Pow values to this equation. 

Because obtained BCF values in Table 3.2.4.1 are far less than 500 l/kg, evaluation of 

cross-contamination (effects of concentration) is unnecessary. 

4.4.3 Toxicity test of substances (T) 

Because all the chronic toxicity values (NOEC) shown in Tables 3.2.1.1 to 3.2.1.6 are greater 

than 0.01mg/l, no toxic substance is judged to exist among to the chemical substances to be 

evaluated. 

4.4.4 Evaluations based on PBT criteria 

Based on the results described above, PBT criteria are identified for each chemical substance in 

consideration. Results are shown in Table 4.4.1.

Table 4.4.1 PBT Criteria on trihalomethanes, sodium bromate, haloacetic acids, 

haloacetonitriles and sodium sulfite 

Substance for PBT criteria Persistence (P) 

(Yes or No)

Bioaccumulation (B) 

 (Yes or No)

Toxicity (T) 

 (Yes or No) 

Trihalomethanes Yes No No 

Sodium bromate Yes No No 

Haloacetic acids Yes No No 

Haloacetonitoriles Yes No No 

Sodium sulfite No No No 

Because there are no substances which meets P, B and T all together, all substances under 

investigation are designated as non-PBT material. The effects on aquatic organisms of above 

substances are to be evaluated using the following toxic tests and PEC/PNEC values. 

4.5 Evaluation for effect of treated ballast water to aquatic organisms 

The simulated ballast water is defined as follows:

.1 Test water is filtered to remove large aquatic organisms and particles, and then 

disinfected with TG Ballastcleaner at a FAC concentration of 30 mg/l; 
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.2 Residual chlorine in test water is reduced and eliminated by adding 

TG Environmentalguard after five days storage under dark condition; and 

.3 Added TG Environmentalguard is 0.021% of testing water in weight 

corresponding to a sodium sulfite concentration of 22 mg/l when the concentration 

of sodium sulfite in TG Environmentalguard is 10%. 

Initial injection quantity of TG Ballastcleaner can be decreased by using this injection control 

system in reference to the residual chlorine concentration immediately after injection. This is 

based on the fact that initial decrease of residual chlorine is affected by water quality 

pumped up into ballast tank. Consequently adding quantity of TG Ballastcleaner and 

TG Environmentalguard can be decreased and this leads to the decrease of by-products. 

4.5.1 Toxic testing of the simulated ballast water 

The toxic tests were carried out under OECD guidelines, and the detail is described in a separate 

document. In these tests three types of organism were exposed to the simulated ballast water at 

two different levels of dosages in a way that simulated the treatment of ballast water. 

The dosages of TG Ballastcleaner were 0.016% and 0.024% of seawater, those are equivalent to 

FAC concentrations of 20 mg/l and 30 mg/l. Tested organisms were Java medaka on fish, marine 

Gammarid Hyale barbicornis on crustacean and Skeletonema costatum on algae (diatom). 

These results suggest that the simulated ballast water at both dosage levels do not have lethal or 

sublethal effects on the first two organisms, Java medaka and marine Gammarid, in the early life 

stages. However, the results indicate that the diatom Skeletonema costatum is slightly affected by 

the seawater at both dosage levels. There are no serious acute toxic effects, but there are 

statistically differences in the growth rate, those are slightly lower than that of the controlled 

group, at both dosage levels. 

The results of experiments using dilutions of the 0.024% solution show that regardless of the 

degree of dilution (1/2.29, 1/5.24, 1/12, or 1/27.5) an increase in cellular density is seen. 

A dilution required to observe a effect of LOEC was 1/2.29, and that of NOEC was 1/5.24. 

These results indicate that organisms in the water into which the treated ballast water is 

discharged will not be affected at all when the ballast water is diluted to 1/5.24.

4.5.2 Environmental effect tests 

Concentrations of the evaluated five chemical substances and groups in the simulated ballast 

water were measured for both seawater and freshwater. The results are shown in Table 4.5.1 

together with acute toxicity values collected in sections 3.2.1 and 3.2.4.
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Table 4.5.1 Measured concentrations of haloacetic acids and haloacetonitriles in 

simulated ballast water (haloacetic acids and haloacetonitriles) 

Chemical substance Conc. in 

simulated 

ballast water 

(mg/l) 

Acute toxicity 

value (mg/l) 

Chronic toxicity 

value (mg/l) 

monochloroacetic acid 0.002 0.028 32 

Dichloroacetic acid 0.022 3,560 No data 

Trichloroacetic acid 0.03 0.3 No data 

Bromochloroacetic acid 0.003 No data No data 

Bromodichloroacetic acid <0.01 No data No data 

Dibromochloroacetic acid <0.03 No data No data 

Bromoacetic acid 0.007 0.2 3.2 

Dibromoacetic acid 0.055 69 No data 

Tribromoacetic acid <0.05 No data No data 

Chloroacetonitrile <0.001 No data No data 

Dichloroacetonitrile <0.004 No data No data 

Trichloroacetonitrile <0.001 No data No data 

Dibromoacetonitrile <0.001 0.49 No data 

Bromochloroacetonitrile <0.001 No data No data 

4.6 Model taking dilution into account

The degrees of dilution of these six chemical substances in harbours were evaluated by using the 

dilution calculation of the MAM-PEC model. The MAM-PEC model was developed in order to 

predict the concentrations of antifouling agents painted on ship hulls in a harbour to prevent 

pollution of the marine environment. 

The simulation results for these six chemical substances are obtained in the ballast water model 

in the Port of Rotterdam model. The obtained dilution factors for each chemical substance are 

shown in Table 4.6.1. Because sodium sulfite becomes sodium sulfate by a reaction with 

dissolved oxygen in the order of ten minutes, high degradation rate accounts for very small 

dilution factor.

Table 4.6.1 Dilution factors of chemical substances to be assessed 

Chemical substance Dilution factor 

Chloroform 1/58 

Bromoform 1/145 

Monochloroacetic acid 1/252 

Trichloroacetic acid 1/102 

Bromoacetic acid 1/58 

Sodium sulfite 1/67,600 
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4.7. Evaluation using PEC/PNEC 

PNEC values obtained by dividing acute toxicity values with assessment factors are shown in 

Table 4.7.1. These acute toxicity values are listed in section 3.2.1. Assessment factor 100 is 

selected for sodium sulfite, as it has no remaining characteristics. Assessment factor 1000 is 

selected for other chemical substances.

Table 4.7.1 Toxicity value and PNEC of chemical substances to be assessed 

Chemical substance Toxicity Value 

Endpoint Concentration (mg/l) 

Assessment 

factor 

PNEC 

(μg/l) 

Chloroform (freshwater) EC50 72h 13.3 1000 13.3 

Chloroform (seawater) LC50 96h 28 1000 28 

Bromoform (freshwater) LC50 96h 29 1000 29 

Bromoform (seawater) LC50 96h 7.1 1000 7.1 

Monochloroacetic acid EC50 48h 0.028 1000 0.028 

Trichloroacetic acid EC50 96h 0.3 1000 0.3 

Bromoacetic acid EC50 72h 0.2 1000 0.2 

Sodium sulfite EC50 6.4-

8.9h 25.2 100 252 

PEC/PNEC values are shown in Table 4.7.2. PEC values are calculated using MAM-PEC model 

in the Port of Rotterdam. 

Table 4.7.2 PEC/PNEC of chemical substances to be assessed 

Chemical substance Conc. in 

simulated 

ballast water 

(μg/l) 

Dilution 

factor 

PEC 

(μg/l) 

PNEC 

(μg/l) 

PEC/PNEC 

Chloroform (freshwater) 40 1/58 0.69 13.3 0.052 

Chloroform (seawater) 40 1/58 0.69 28 0.025 

Bromoform (freshwater) 470 1/145 3.24 29 0.11 

Bromoform (seawater) 470 1/145 3.24 7.1 0.46 

Monochloroacetic acid 2 1/252 0.008 0.028 0.28 

Trichloroacetic acid 30 1/102 0. 294 0.3 0.98 

Bromoacetic acid 7 1/58 0.121 0.2 0.61 

Sodium sulfite 22,000* 1/67,600 0.33 252 0.0013 (short) 

* Calculated maximum concentration 

For the excluded chemical substances, PEC/PNEC values are calculated as a reference using the 

dilution factor of 1/58, which is the most conservative value. 
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Table 4.7.3 PEC/PNEC of chemical substances to be assessed 

Chemical substance Measured 

conc. (μg/l) 

Dilution 

factor 

PEC 

(μg/l) 

PNEC 

(μg/l) 

PEC/PNEC 

Sodium bromate 9.4* 1/58 0.16 30 0.005 

Bromodichloromethane 15 1/58 0.26 67.4 0.004 

Dibromochloromethane 12 1/58 0.21 33.5 0.006 

Dichloroacetic acid 22 1/58 0.38 3560 0.0001 

Dibromoacetic acid 55 1/58 0.95 69 0.014 

*Bromic acid concentration of 8μg/l is converted to sodium bromate concentration by multiplying 

by 151/128. 

All the above chemical substances are confirmed not to give adverse effects on aquatic 

environment because each PEC/PNEC value is less than one. 

4.8 Evaluation of environmental exposure 

Accordingly, dilution test of the above simulated ballast water was conducted to determine the 

dilution factor with which the chronic toxicity to phytoplankton is negligible. The results showed 

that the LOEC and the NOEC (both described in dilution factor) were obtained when the 

solutions are diluted 2.29 times and 5.24 times, respectively. Therefore, no adverse effect will be 

expected. 

The evaluation of environmental exposure is done for chemical substances contained in the 

treated ballast water discharge. The results show that PEC/PNEC’s of examined 11 chemical 

substances are less than 1, and therefore, these values assure that the treated ballast water 

discharge with TG Ballastcleaner and TG Environmentalguard has no adverse effect on aquatic 

environment. 

4.9 Assessment of exposure to humans 

Possibility of exposures to humans

Because the ballast water management system is supposed to be controlled remotely and the all 

liquids listed above are flowing in a closed system, there is no possibility for humans to contact 

with those liquids in normal operation. For instance system configuration is shown in Fig. 4.9.1. 

However, human’s exposure to those liquids can be assumed in the following cases: 

.1 entering ballast tanks; 

.2 leakage during filling operation of the chemicals; 

.3 leakage of the chemicals from tanks, pumps valves and fittings on piping; and 

.4 cleaning operation of chemicals leakage of .2 and .3. 
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During the above operations the work should be done wearing the appropriate protection devices 

as described in sections 5.3.1 and 5.3.2. 

Fig. 4.9.1 System configuration 

5 EFFECTS AND SAFETY OF SHIP AND CREW 

5.1 Effects on ship’s hull 

5.1.1 Effects on ballast tanks by TG Ballastcleaner

Although TG Ballastcleaner (sodium hypochlorite) is corrosive, low residual chlorine 

concentration in ballast water with a pH around neutral, allows epoxy or plastic paint for the 

internal surface coating of ballast tanks. This coating should be done for ships without painting 

ballast tanks. 

5.1.2 Effects on ballast tanks by TG Environmentalguard 

TG Environmentalguard (sodium sulfite) as reductant has no other effect on ship. 

5.1.3 Effects on outer hull 

When the treated ballast water is discharged, it contains sodium sulfite. Sodium sulfite works as a 

reducing agent and gets its strong reducing power from transition metals such as iron and zinc. 

Therefore, it has no effects on the outer hulls of ship. 

Ballast water 

 Filtration 

Water quality check 

Ballast tank 

Departure 

Voyage

Ballast tank 

Check of residual chlorine 

Port entry 

TG Environmentalguard 

 Pump Surrounding 

water 

TG Ballastcleaner 

BALLASTING

DEBALLASTING
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5.2 Ballast water treatment equipment 

5.2.1 Outline of distribution system 

TG Ballastcleaner and TG Environmentalguard are supplied from storage tanks to ballast line. 

The injections of the chemicals should be controlled using remote control. Therefore, crew will 

never contact with these chemicals in normal work to inject chemicals into ballast lines. 

5.2.2 Materials of chemical storage tanks, pipes, and fittings 

Materials used on board storage tanks, piping and valves should be compliant with things which 

has been high performance in chemical manufactures. Steel lined or coated with polypropylene, 

polyethylene, polyvinylchloride or titanium are suitable materials for TG Ballastcleaner tank. 

Above stated materials are also suitable for TG Ballastcleaner supplying and injection lines from 

storage tank into ballast lines. Also, corrosion resistant materials should be used for chemical 

distribution pipes and valves of the system. Steel lined or coated with polypropylene or, 

polyethylene, and stainless steel, etc. are suitable materials for TG Environmentalguard tank. 

Above stated materials are also suitable for TG Environmentalguard supplying and injection lines 

from storage tank into ballast lines and valves. 

5.2.3 Storage of chemicals 

The chemicals are supplied to storage tanks of ships during berthing at ports. 

5.2.4 Management of chemicals 

TG Ballastcleaner should be kept below 20oC to prevent its decomposition and above 0oC to keep 

it away from freezing. TG Environmentalguard should be kept above 0oC to avoid freezing. 

5.3 Crew safety and emergency responses 

 

If the ballast water disinfectant system is run in a normal manner and maintained appropriately, it 

poses no threat to the safety or the crew. When TG Ballastcleaner and TG Environmentalguard 

are supplied from land to storage tanks onboard at port, the work should be done following the 

instruction in section 4.9. 

In case of emergencies during the ballast water treatment system is in operation, chemical 

injection operation should be shut down by remote control system. In case of power failure, 

whole ballast water treatment system should be stopped and chemical injection valves are also 

automatically closed. 

5.3.1 Leakage of TG Ballastcleaner 

TG Ballastcleaner should be washed away with water after being reduced with 

TG Environmentalguard. Do not wipe it up with paper. Paper reacts with sodium hypochlorite, 

and heat is generated. 

When handling leaked TG Ballastcleaner, the crew must wear protective goggles, masks, 

alkaline-resistant and chlorine-resistant gloves, boots and helmet. Full apron or smock (made of 

chlorine-resistant fibers) is recommended. If splashing occurs, it should be immediately flushed 

away with a lot of water. 
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5.3.2 Leakage TG Environmentalguard

Leaked small amount of TG Environmentalguard should be washed away with water or wiped up 

with cotton dust clothes. Even if the quantity of TG Environmentalguard is not small, it is 

sufficiently safe to be washed away with large amount of water. 

When handling leaked TG Environmentalguard, crew must wear protective goggles, 

alkaline-resistant gloves, boots and helmet. As sodium sulfite does not react easily with other 

substances except oxidizer, TG Environmentalguard does no harm to crew. If splashing occurs, it 

should be immediately flushed away with water and wash the splashed spot with soap. 

6 CONCLUSION 

 

The “Active Substances”, the “Other Components” and the “Relevant Chemicals” in the 

TG Ballastcleaner and TG Environmentalguard system used to treat ballast water are evaluated in 

terms of environmental effect according to Procedure (G9). The results showed that the treated 

ballast water out of this chemical system does not have any adverse effects on the water into 

which it is discharged. 

This chemical system is also deemed sufficiently safe to ships and crew, because the sufficient 

considerations are made on the safety of ships and crew. 
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