I:\MEPC\55\2-27.DOC 

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INTERNATIONAL MARITIME ORGANIZATION

IMO

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

55th session 

Agenda item 2 

MEPC 55/2/27

 18 August 2006

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

Request for re-evaluation of the proposal for the approval of Active Substances 

Submitted by the Republic of Korea

SUMMARY

Executive summary: This document contains supplemental data to provide explanations 

against comments raised by the GESAMP-BWWG in its evaluation 

report on the proposal for the approval of Active Substances 

submitted by the Republic of Korea and a request to reconsider the 

proposal. 

Action to be taken: Paragraph 7 

Related documents: BWM.2/Circ.2, MEPC 54/2/12, MEPC 55/2/3 and MEPC 55/2/16 

Introduction 

1 This document is submitted in accordance with paragraph 4.10.5 of the Guidelines 

on the organization and method of work of the Maritime Safety Committee and 

Marine Environment Protection Committee and their subsidiary bodies 

(MSC/Circ.1099 - MEPC/Circ.405) and comments on document MEPC 55/2/16 “The report of 

the second meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG)”. 

It contains supplemental data to provide explanations against comments raised by the Group in 

its evaluation report on the proposal for the approval of Active Substances submitted by the 

Republic of Korea. 

2 The Republic of Korea appreciates the hard work of GESAMP-BWWG for the review 

of proposals submitted and fully respects the result of the Group’s evaluation on its proposal. 

3 The GESAMP-BWWG did not recommend Basic Approval of the system provided by 

the Republic of Korea on the basis of “lack of required data”. The Group noted that, in 

particular, the application took the form of a general concept for a system to be developed and 

did not include a complete description of the system nor a firm proposal for the actual Ballast 

Water Management System (BWMS) to be installed. While recognizing the validity of all the 

comments raised by the Group as described in annex 6 of its report, the Republic of Korea 

would like to point out following aspects in an effort to explain its positions: 
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.1 The Procedure for approval of ballast water management systems that make use of 

Active Substances (G9) adopted by resolution MEPC.126(53) is very general in 

nature and thus, its descriptions are not clear enough with regard to the 

information to be submitted for Basic Approval. In this regard, the Methodology 

for Information Gathering and the Conduct of Work of the GESAMP-BWWG as 

contained in document MEPC 54/2/12 is under development. Consequently, there 

may be some misunderstanding on the approval procedure between the Group and 

the applicant. For example, in the Procedure (G9) and the draft Methodology, 

there is no specific requirement for the submission of detailed descriptions of the 

system, in case of use of the Active Substances, with the application nor a clear 

description of the scope of detailed descriptions of the system to be provided at 

Basic Approval stage. Section 4 of the draft Methodology requires submission of 

detailed descriptions of the system in case of use of the preparation only and not 

of Active Substances and it was noted that the section was later changed by the 

Group during its second meeting to include both cases. Also, since the detailed 

descriptions are to be given at the Final Approval stage, the applicant provided the 

descriptions, albeit partly, in the appendix to the application (as submitted as 

Exhibits). 

.2 Both Procedure (G9) and draft Methodology indicate that the Group, in the course 

of the review, may request additional data if necessary. However, an opportunity 

for submitting additional information (except those on the planned dosage 

of Ozone to be injected into the ballast water) was not given to the applicant 

even though the Group was informed of the applicant’s availability in London 

during its second meeting to respond to such request. Furthermore, it was not 

possible to identify the comments of the Group on the proposal since the report of 

the second meeting of GESAMP-BWWG was not posted on the IMO website 

until 21 July 2006. 

4 Taking this opportunity, supplementary data to clarify some of the comments raised by 

the Group is briefly provided hereunder: 

4.1 Comment: the application is a general concept and does not include firm proposals for 

actual BWMS (paragraphs 0.1 and 2.1, annex 6, MEPC 55/2/16). 

4.1.1 The proposed system is an actual BWMS, not a generic concept. This Ozone injection 

ballast water treatment system has been developed and extensively tested by Nutech O3, Inc. 

through four years of laboratory testing and also on board two 125,000 DWT oil tankers during 

their regular operation in the Pacific Ocean. The system, as installed and tested on board the 

M/T Prince William Sound, will be ready for commercial use by the shipping industry as soon 

as this fully tested technology is certified by the United States government as meeting the ballast 

water treatment requirements. Both the United States Coast Guard and the American Bureau of 

Shipping (ABS) have certified it as a safe system for use at sea (Exhibit I attached to the dossier). 

4.1.2 Outlined technical specifications are briefly described hereunder as stated in Exhibits 

attached to this submission. 

- Ozone system produces a low concentration of Ozone treatment by injecting 

Ozone into the ship's ballast water. The Ozone gas mixture is injected in the main 

ballast water pipe via one side-stream injection systems. 
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- Ozone system is composed of two integrated modules which consist of Ozone 

producing part and injection part. So that the system as modularized can be 

installed in the manner of plug and play. 

4.1.3 Independent teams of scientists and research engineers designed the on board ship test 

protocols and conducted all of the laboratory tests for the operational effectiveness of Ozone on 

board the M/T Tonsina (2000) and the M/T Prince William Sound (2006), in addition to 

extensive on-shore laboratory testing. Copies of both reports, the former of which is peer 

reviewed as a published article and the National Oceanic Atmospheric Administration (NOAA) 

of the United States approved test protocol were attached as Exhibits IV and V to the dossier. 

4.2 Comment: The bromate ion has a high potential for mutagenicity and carcinogenicity. 

This is particularly important if the crew has to enter a ballast water tank after treatment. 

(paragraphs 0.3 and 0.6, annex 6, MEPC 55/2/16). 

4.2.1 Ozone is safe to use on board a ship – testing for proof of compliance. 

- When Ozone interacts with bromide ions that naturally occur in seawater, 

hypobromous acid/hypobromite ion (HOBr/OBr-

), small quantities of bromoform 

and bromate ions may be created. In studies, no bromate ions were ever detected. 

The two chemicals that resulted were bromoform and a residual oxidant composed 

of HOBr/OBr-

. Bromoform is a volatile chemical, the presence of which is 

regulated in drinking water. However, bromoform has no adverse ecological effects 

that are known. 

- The Total Residual Oxidant (TRO) remains in the ballast water and it is the active 

chemical agent responsible for killing the organisms. This TRO has a half-life of 

between 1 and 2 days. In studies, it appears that the TRO is reduced to oxygen and 

bromide ions in the ballast tank, in the dark, over time. 

- A ship's crew would not be permitted to enter a ballast tank unless the ballast water 

is completely removed and the tank properly aired out so as to remove any harmful 

gases that might have accumulated. This is done in accordance with any ship's 

standard operating procedures and procedures mandated by various bodies. 

4.2.2 Ozone and bromine compounds are not dangerous to human health as used in the Ozone 

injection system. 

- In theory, bromates and bromoform are chemicals that are created as a result of the 

interaction between Ozone and bromine. However, no detectable amount of these 

chemicals was found after extensive testing of treated ballast water. This is due to 

Ozone’s very short half-life and an excess amount of bromide in relation to the 

quantity of available Ozone in seawater. 

- Bromoform is created by the interaction of HOBr/OBr-

 (TRO) if there is natural 

organic matter in the ballast water. The presence of humic and fulvic acids are 

mandatory precursors to the production of bromoform. Many marine waters do not 

contain natural organic matter in sufficient quantity to cause the formation of 

bromoform. 

4.2.3 Bromate ion does not create any reasonable risk of causing cancer or mutations as used in 

the Ozone injection system. 
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- Bromate ions pose absolutely no threat to human health unless it is ingested. The 

bromate ion is part of salt. As it occurs only in the ionic form in seawater, it is 

absolutely non-volatile and thus, impossible to inhale. Also, there is no scientific 

evidence that the bromate ion and compounds are absorbed through the skin. In 

addition, when a ship's crew works in the ballast tanks, the tanks are drained and 

fully ventilated with fans before the crew is allowed to enter and during the entire 

time he/she works in the tanks. 

4.3 Comment: The potential risks to a ship’s hull when it is exposed to ozonated water for 

a significant time period (paragraph 0.4, annex 6, MEPC 55/2/16). 

4.3.1 Ozone does not damage the hull or ballast tanks of a ship 

The Licensor contracted with the La Que Institute for Corrosion Research, in Wrightsville Beach, 

North Carolina, in 1999, to conduct extensive tests to determine if the injection of Ozone into a 

ship's ballast water would increase corrosion rates and damage ship's hull. Extensive on-shore 

laboratory testing proved conclusively that the additional of substantial quantities of Ozone to 

seawater does not increase the rate of corrosion. In fact, Ozone decreases it since bacteria and 

other microorganisms secrete acids which corrode a ship's hull. Thus Ozone removes the source 

of the acid and diminishes the rate of corrosion. See Exhibit IV attached to this submission.

4.4 Comment: As no information had been provided on the dose of Ozone to be used 

in application, the group could not give an estimation of the concentration levels of Ozone and 

relevant chemical expected to be found in the environment (paragraph 0.5, annex 6, MEPC 55/2/16 ). 

4.4.1 Amount of Ozone required to treat a ship’s ballast water 

The quantity of Ozone required to treat a ship's ballast water is determined by the flow rate at 

which the ballast water is taken on board the ship. The System is designed to require between 

1mg/L and 2 mg/L of Ozone to effectively treat the ballast water. Stoichiometric (fixed) ratios 

are such that the concentration of HOBr/OBr-

 is a maximum of 4 mg/L. Bromate concentration 

will not exceed 5 parts. Bromoform levels will be less than 1 part per billion. 

5 Based on the information above, the Republic of Korea believes that the proposed 

system is a technically sound system which is ready for actual use and that all of the comments 

raised by the Group could be resolved without any difficulty if the opportunity for providing 

relevant supplemental data is given. The Republic of Korea was and is ready to provide such 

data. Therefore, considering the fact that relevant procedures and methodologies have yet to 

be clearly defined and set-up and the possibility of consequential misunderstanding and error 

on the proceedings as a result, the Committee is requested to consider the re-evaluation of the 

proposal submitted by the Republic of Korea. 

6 In this regard, paragraph 2.7.2 of Draft Methodology contains right of appeal against 

any decision made by the Organization. However, in the absence of detail procedure for appeal 

by the Administration and reconsideration by the Organization or the Group, it is requested 

that the supplementary data be allowed to be submitted to the Group by the scheduled deadline 

of 15 December 2006 for re-evaluation during the third meeting of GESAMP-BWWG in 

February 2007 regardless of the number of the new applications made and without any further 

payment of fee. 

Action requested of the Committee

7 The Committee is requested to consider the above and take action as appropriate.

_______________