For reasons of economy, this document is printed in a limited number. Delegates are 

kindly asked to bring their copies to meetings and not to request additional copies.

I:\MEPC\58\2-8.doc 

INTERNATIONAL MARITIME ORGANIZATION

IMO 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

58th session 

Agenda item 2 

MEPC 58/2/8

 28 July 2008

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

Report of the seventh meeting of the GESAMP-Ballast Water Working Group 

Note by the Secretariat 

SUMMARY

Executive summary: This document contains the report of the seventh meeting of 

the GESAMP-Ballast Water Working Group (GESAMP-BWWG) 

and includes the evaluation of proposals submitted for approval 

by Norway, Germany and the Republic of Korea 

Strategic direction: 7.1 

High-level action: 7.1.2 

Planned output: 7.1.2.4 

Action to be taken: Paragraph 4 

Related document: GESAMP-BWWG 7/9 (attached) 

Introduction

1 The seventh meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG) 

was held at IMO Headquarters from 30 June to 4 July 2008 and its report regarding approval of 

ballast water management systems that make use of Active Substances to treat ballast water prior 

to discharge into the marine environment is attached to this document as GESAMP-BWWG 7/9. 

2 The main purpose of this meeting was to review the remaining three proposals, which had 

been submitted before the deadline established for MEPC 58 (i.e. 21 March 2008) and which 

could not be reviewed during the regular meeting of the Group held from 19 to 23 May 2008. 

The reviews of the proposals evaluated by the Group are shown in annexes 4 to 6 of the attached 

report. 

3 The Group noted that the quality of the information submitted by the applicants has, in 

general, improved, however, effective communication with the applicants during the meeting 

week was time consuming and not always possible. The Group reiterated the need to provide the 

full data set, in accordance with the existing Methodology, at the time of the submission of the 

application dossier. 
MEPC 58/2/8 - 2 - 

I:\MEPC\58\2-8.doc 

Action requested of the Committee

4 The Committee is invited to: 

 .1 agree that Final Approval should be granted to the OceanSaver® Ballast 

Water Management System (OS BWMS) submitted by Norway in document 

MEPC 58/2/1 (see annex 4); 

 .2 agree that Basic Approval should be granted to the Ecochlor® Ballast Water 

Treatment System submitted by Germany in document MEPC 58/2/2 

(see annex 5); 

.3 agree that Final Approval should not be granted to the NK-O3 BlueBallast System

submitted by the Republic of Korea in document MEPC 58/2/3 (see annex 6); and 

.4 approve the report in general. 

*** 
I:\MEPC\58\2-8.doc 

GESAMP-BWWG 

7th meeting 

Agenda item 9 

GESAMP-BWWG 7/9

 4 July 2008

 Original: ENGLISH

REPORT OF THE SEVENTH MEETING OF THE GESAMP-BALLAST WATER 

WORKING GROUP (GESAMP-BWWG) 

Table of Contents 

 

Section Page Number

1 INTRODUCTION ....................................................................................... 3 

2 ISSUES OF CONFIDENTIALITY ............................................................ 3 

3 TERMS OF REFERENCE AND TIME FRAME ...................................... 4 

4 REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER 

MANAGEMENT SYSTEMS THAT MAKE USE OF ACTIVE 

SUBSTANCES ........................................................................................... 5 

5 CONSIDERATION OF QUERIES REGARDING THE WORK OF THE 

GESAMP-BWWG ...................................................................................... 5 

6 ANY OTHER BUSINESS .......................................................................... 7 

7 CONSIDERATION AND ADOPTION OF THE REPORT ...................... 7 
GESAMP-BWWG 7/9 - 2 - 

I:\MEPC\58\2-8.doc 

ANNEXES 

Annex 1 List of members who attended the seventh session of the GESAMP-BWWG 

Annex 2 Agenda for the seventh session of the GESAMP-BWWG 

Annex 3 Terms of reference for the Technical Group (GESAMP-BWWG) 

Annex 4 Review of proposals for approval of Ballast Water Management Systems that 

make use of Active Substances – OceanSaver® Ballast Water Management 

System, submitted for Final Approval by Norway 

Annex 5 Review of proposals for approval of Ballast Water Management Systems that 

make use of Active Substances – Ecochlor® Ballast Water Treatment System, 

submitted for Basic Approval by Germany 

Annex 6 Review of proposals for approval of Ballast Water Management Systems that 

make use of Active Substances – NK-03 Blue Ballast Water Treatment System, 

submitted for Final Approval by the Republic of Korea 
 - 3 - GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

1 INTRODUCTION 

1.1 The seventh GESAMP-Ballast Water Working Group (GESAMP-BWWG) meeting was 

held at IMO Headquarters, London, from 30 June to 4 July 2008, under the chairmanship 

of Mr. Finn Pedersen. This extraordinary meeting was held in addition to the sixth regular 

meeting in May 2008. The list of participants is shown in annex 1 and the agenda, as adopted by 

the Group, is set out in annex 2. 

1.2 The meeting was opened by Mr. Dandu Pughiuc, Head, Marine Biosafety Section, who 

conveyed the appreciation of the Director of Marine Environment Division for the effort made by 

the members of the GESAMP-BWWG to have this additional meeting before MEPC 58 in an 

attempt to review the remaining proposals which had been submitted before the deadline 

established for MEPC 58 (i.e. 21 March 2008). Mr. Pughiuc informed the Group that, based on 

their kind agreement to have this additional meeting, arrangements had been made and the 

necessary approval requested from the Secretary-General of the Organization for processing the 

report as a matter of urgency with the necessary relaxation of the deadline for submission of 

documents to MEPC 58. 

1.3 Mr. Pughiuc noted with appreciation the return of Mr. Finn Pedersen, who acted 

as Chairman for the first two meetings of the GESAMP-BWWG, and wished all the members of 

the Group every success in this new endeavour. Particular appreciation was expressed for the 

effort made by Dr. Brigitte Behrends in preparing the remaining three proposals for evaluation by 

the Group and for liaising with the respective Member States in an attempt to provide all the 

necessary data required for the evaluations. 

1.4 Mr. Pughiuc then reported on the contractual arrangements and informed the Group 

on the logistics of the meeting. He also informed the Group that, at the request 

of Mr. Egil Dragsund, arrangements had been made for him to be excused when the proposal for 

approval of the ‘OceanSaver® Ballast Water Management System’ (Norway) is reviewed, due to 

his involvement in the development of this technology. Mr. Dragsund took no part in this 

evaluation and his contract was consequently reduced to nine working days. 

2 ISSUES OF CONFIDENTIALITY 

2.1 One proposal for Basic Approval of a system that makes use of Active Substances had 

been submitted by Germany (MEPC 58/2/2) and proposals for Final Approval had been 

submitted by Norway (MEPC 58/2/1) and the Republic of Korea (MEPC 58/2/3). All three 

submissions contained confidential supporting data. 

2.2 The confidential nature of the information was recognized by the Group and was treated 

as such in order to protect the commercial interests of the manufacturers concerned. In order to 

ensure that the report did not contain any confidential information, the Group noted that 

the Secretariat would liaise with the relevant Administrations prior to submitting the report 

to GESAMP and MEPC. 

2.3 Pursuant to paragraphs 4.2.2, 8.1.1 and 8.1.2.7 of the “Procedure for approval of ballast 

water management systems that make use of Active Substances (G9)”, all information gathered, 

materials, notes and reports obtained or made out during the work of the GESAMP-BWWG, 

were, and will be, treated as confidential. In this respect all the members of the Group and 

the Consultant signed the Statements of Acceptance related to confidentiality. 
GESAMP-BWWG 7/9 - 4 - 

I:\MEPC\58\2-8.doc 

2.4 The original copies of these Statements duly signed and dated by all involved were filed 

with the Technical Secretary of the Group and will be kept together with the submissions. 

2.5 The submissions (dossiers) were deposited in a safe place in the IMO Headquarters and 

made available to the Consultant, at her request, during the working hours. They were available 

for consultation by the members of the Group for the duration of the meeting in the 

meeting room and returned to the Organization’s designated room after the working hours. 

2.6 On completion of the work, the Chairman of the GESAMP-BWWG obtained from the 

other members all the documents, drafts and any other associated records and reports, which 

were transmitted to the Technical Secretary of the GESAMP-BWWG for retention in confidence. 

All electronic records and data held on personal computers/laptops were destroyed when they 

were no longer necessary for the work of the GESAMP-BWWG. 

3 TERMS OF REFERENCE AND TIME FRAME 

3.1 The Group agreed to continue to be guided by the Terms of Reference approved 

by MEPC as contained in annex 3 of this report. 

3.2 The Group used the table previously agreed by the MEPC and reproduced below to 

determine the timetable for activities related to its regular meetings and agreed to decide, on a 

case-by-case basis, on the timing of additional meetings as appropriate. 

TIMETABLE FOR ACTIVITIES RELATED TO GESAMP-BWWG MEETINGS 

Timeline Activity 

28 weeks before MEPC Deadline for submission of application dossiers and related 

documents to be reviewed by the GESAMP-BWWG 

(8 weeks) Preparation of the meeting, including circulation of any relevant 

information provided by other delegations 

20 weeks before MEPC GESAMP-BWWG Meeting 

(1 week) Editing and completion of the draft report of the meeting 

(1 week) Administrations confirm that no confidential data are contained 

in the report 

(3 weeks) Review and approval of the report by GESAMP 

(1 week) Produce the final report addressing the comments by GESAMP 

13 weeks before MEPC Submission of the report of the meeting of the GESAMP-BWWG 

in accordance with the 13 weeks’ deadline for MEPC 

3.3 The Group reconfirmed its agreement to tentatively schedule its 8th meeting 

from 16 to 20 February 2009 subject to the submission of the application dossiers in accordance 

with the deadline of 19 December 2008 agreed during its 6th meeting. 

3.4 Recognizing the possibility that more than three proposals may be submitted for its 

review and approval by MEPC 59, the Group expressed its availability to have an additional 

meeting to accommodate all the proposals provided that all necessary conditions for organizing 

such a meeting are met. 
 - 5 - GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

4 REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER 

MANAGEMENT SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

4.1 General review of the submissions 

4.1.1 The Group agreed to consider the submissions in chronological order and noted that the 

quality of the information submitted by applicants has generally improved. However, the Group 

noted that effective communication with the applicants during the meeting week was not always 

possible and reiterated the need to provide the full data set, in accordance with the 

existing Methodology, when submitting the application dossiers. 

4.2 Detailed review of the submissions 

4.2.1 A detailed review of the submissions can be seen in: 

 .1 Annex 4 Review of proposals for approval of Ballast Water Management 

Systems that make use of Active Substances – OceanSaver® 

Ballast Water Management System, submitted for Final Approval 

by Norway (document MEPC 58/2/1); 

 .2 Annex 5 Review of proposals for approval of Ballast Water Management 

Systems that make use of Active Substances – Ecochlor® Ballast 

Water Treatment System, submitted for Basic Approval by 

Germany (document MEPC 58/2/2); and 

 .3 Annex 6 Review of proposals for approval of Ballast Water Management 

Systems that make use of Active Substances – NK-03 Blue 

Ballast Water Treatment System, submitted for Final Approval by 

the Republic of Korea (document MEPC 58/2/3). 

4.2.2 Having reviewed all of the information associated with the submissions, the Group 

recommended that: 

.1 Final Approval to be granted to the OceanSaver® Ballast Water Management 

System (OS BWMS), submitted by Norway in document MEPC 58/2/1; 

.2 Basic Approval to be granted to the Ecochlor® Ballast Water Treatment System, 

submitted by Germany in document MEPC 58/2/2; and 

.3 Final Approval not be granted to the NK-O3 BlueBallast System, submitted by 

the Republic of Korea in document MEPC 58/2/3. 

5 CONSIDERATION OF QUERIES REGARDING THE WORK OF THE 

GESAMP-BWWG 

5.1 Inquiry on the Final Approval procedures by Greenship Ltd. 

5.1.1 The Group considered an inquiry received from the Greenship Ltd. (The Netherlands), 

which sought clarification on the timing and the characteristics of the tests required for the 

application for Final Approval with reference to annex 6 of the Report of the sixth meeting of 

the GESAMP-Ballast Water Working Group(MEPC 58/2/7). The questions of clarification and 

the Group’s response are reproduced hereunder: 
GESAMP-BWWG 7/9 - 6 - 

I:\MEPC\58\2-8.doc 

1. Period between treatment and analytical and toxicity tests: It should be 

done immediately after treatment and after 2 and/or 5 days according to 

document MEPC 57/WP.5, paragraph 40.6. According to the review of our 

application, FAC and relevant by-products should be measured after 2 days’ 

storage (MEPC 58/2/7, annex 6, paragraph 7.2.4 ). We understand the following: 

1.1 Whole effluent toxicity tests (algae, shrimp, fish) immediately after 

treatment at discharge (2nd treatment) and after 2 days’ storage of this 

treated ballast water? 

Answer: Yes, with the understanding that it is not absolutely necessary to take a 

sample after 2 days; as for the Group, the discharge at time 0 (zero) is the 

worst-case situation. 

1.2 Chemical analysis (FAC, by-products) of treated ballast water immediately 

after treatment at intake, after 2 days of storage in the ballast water tanks 

(= immediately before the 2nd treatment at discharge), immediately after 

treatment at discharge and after 2 days of storage of the treated ballast 

water. This is the minimum. We will include a number of extra analyses 

of FAC to monitor decay of FAC in the tanks and after the 2nd treatment. 

Is this correct? 

Answer: For ballast water management systems like Greenship treating ballast water

both at uptake and at discharge, the discharge situation represents the worst case and 

samples for chemical analysis should therefore mainly be taken from these. 

.2 Combination of G8 test cycles and G9 tests: This is a new issue. Greenship has 

completed the 5-test cycles under G8 in May/June 2007 and has done G9 tests 

for Basic Approval separately in August 2007. There seems to be no need to 

repeat the 5-test cycles under G8. We propose a test programme according to G9 

and combine this with efficacy testing according to G8. Is this correct? 

Answer: Yes, the Group recommends the applicant to thoroughly read 

Procedure (G9) and, in particular, paragraph 5.2.1.2 before further testing is 

carried out. 

.3 Number of measurements of FAC and by-product: Some applicants have 

performed FAC and by-product measurements in 5-test cycles according to G8; 

others have not. The GESAMP-BWWG is not consistent in its comments on this 

procedure. We propose a series of FAC and by-product measurements, according 

to the scheme mentioned in point 1. Basically, this means one test run with a 

series of observations over a prolonged time period (approximately 4 days). Is 

this correct? 

Answer: The Group recommends FAC measurements after treatment and in 1 day 

intervals until no detectable levels are found to be carried out in all G8 tests. The 

content of organic matter will vary between each test and the degradation rates of 

FAC will therefore vary. Degradation rates for FAC in ballast water at discharge 

are – together with the PNEC – crucial for an environmental risk assessment of 

the discharged FAC. Similarly, the quantities of disinfection by-products will vary 

depending on variations in the organic content of the treated ballast water. For 
 - 7 - GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

these analyses, the Group recommends analyses with satisfactorily detection 

levels to be carried out with samples from at least two G8 tests. 

.4 Greenship is at present not planning to perform tests in fresh water. The BWMS 

is designed for salt and brackish water systems (>3 PSU), which means, it can 

operate in 96% of all situations. Is testing in fresh water obligatory 

for Final Approval? 

Answer: No, the distinction between the different water types is an efficacy item 

(Guidelines G8) and has nothing to do with Procedure G9. 

6 ANY OTHER BUSINESS 

6.1 The Group was informed by the two members assigned during its sixth meeting to liaise 

with the United States delegation on issues related to the Human Exposure Assessment (HEA) on 

the work carried out and agreed that most of the technical comments regarding this assessment 

contained in document BLG 12/5/8 (United States) are valid and could be incorporated in the 

Methodology. However, further discussion with the experts from the United States was still 

needed on a number of aspects raised in the above document. The Group reiterated its invitation 

to other interested Administrations to send their comments and suggestions on this issue to 

the IMO Secretariat with an understanding that they will be disseminated among the members of 

the Group at the earliest opportunity. 

7 CONSIDERATION AND ADOPTION OF THE REPORT 

7.1 A draft report of the seventh meeting of the GESAMP-BWWG was produced 

on 4 July 2008 and, after a paragraph-by-paragraph review, the Group agreed on the final text 

and requested the Secretariat to make the necessary editorial changes to ensure consistency 

with IMO documents’ format and style. 

7.2 Mr. M. Palomares, Director, Marine Environment Division, expressed his appreciation 

for the hard work of the Group and congratulated its members for the results achieved. 

The Chairman thanked the members of the Group for the long hours and substantial efforts made 

throughout the week and closed the meeting at 17:30 hrs. 

*** 

GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

ANNEX 1 

LIST OF MEMBERS WHO ATTENDED THE SEVENTH SESSION OF THE 

GESAMP-BALLAST WATER WORKING GROUP 

Mr. Finn Pedersen (Chairman) 

Senior Scientific Officer 

ECHA 

P. O. Box 400 

00121 Helsinki 

Finland 

E-mail: 

Tel: 

Finn.PEDERSEN@echa.europa.eu 

+358 9 6861 8447 

Ms. Teresa Borges 

Senior Technical Officer 

Praça Pasteur 

No. 9 - 1◦

 esq. 

1000-238 Lisboa 

Portugal 

E-mail: 

Tel: 

Mobile: 

tborges@dgs.pt 

+351 2 1843 0599 

+351 9 1779 8048 

Mr. Egil Dragsund 

Principal Marine Biologist 

Environmental and Technical Solutions 

Det Norske Veritas AS 

Veritasveien 1 

NO- 1322 Høvik 

Norway 

E-mail: 

Tel: 

Fax: 

Mobile: 

egil.dragsund@dnv.com 

+47 6757 8894 

+47 6757 9911 

+47 9702 6956 

Mr. Shinichi Hanayama 

Senior Research Fellow 

Maritime Technology Department 

Ocean Policy Research Foundation 

1-15-16 Toranomon 

Minato-ku 

Tokyo 105-0001 

Japan 

E-mail: 

Tel: 

Fax: 

s-hanayama@sof.or.jp 

+81 3 3502 1886 

+81 3 3502 2033 

Ms. Annette Kronborg 

Director 

Adalia Toxicology Consultants 

Runslingan 3E 

SE-187 72 TÄBY 

Sweden 

E-mail: 

Tel: 

Fax: 

Mobile: 

annette.kronborg@adalia.se 

+46 8 510 149 36 

+46 8 510 126 02 

+46 70 483 11 23 

Mr. Jan Linders 

Senior Risk Assessor 

National Institute for Public Health and 

 Environment Expert Centre on Substances 

Anthonie van Leeuwenhoeklaan 9 

RIVM-SEC 

P.O. Box 1, NL-3720 BA Bilthoven 

The Netherlands 

E-mail: 

Tel: 

Fax: 

jan.linders@rivm.nl 

+31 30 274 3164 

+31 30 274 4401 
GESAMP-BWWG 7/9 

ANNEX 1 

Page 2 

I:\MEPC\58\2-8.doc 

Mr. David Tongue 

Marine Manager 

International Chamber of Shipping 

12 Carthusian Street 

London EC1M 6EZ 

United Kingdom 

E-mail: 

Tel: 

Fax: 

Mobile: 

david.tongue@marisec.org 

+44 20 7417 2860 

+44 20 7417 8877 

+44 78 5539 1258 

IMO-GESAMP CONSULTANT 

 

Dr. Brigitte Behrends 

Marine Environment Chemist 

Beluga Shipping GMBH 

P. O. Box 10 72 69 

D-28072 Bremen 

Germany 

E-mail: 

Tel: 

Fax: 

Mobile: 

Brigitte.Behrends@beluga-group.com 

+49 (0) 421 160 60 – 5292 

+49 (0) 421 160 60 – 42 

0049 16-2244-3484 

IMO SECRETARIAT

 

Mr. Dandu Pughiuc 

IMO Technical Secretary 

 to GESAMP-BWWG 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

dpughiuc@imo.org 

+44 (0)20 7587 3247 (Direct) 

+44 (0)20 7587 3261 

Mr. René Coenen 

IMO Technical Secretary to GESAMP 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

rcoenen@imo.org 

+44 (0)20 7587 3239 

+44 (0)20 7587 3261 

Mr. Huang Tianbing 

Technical Officer, Marine Biosafety Section 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

thuang@imo.org 

+44 (0)20 7463 4198 (Direct) 

+44 (0)20 7587 3261 

***
GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

ANNEX 2 

AGENDA FOR THE SEVENTH SESSION OF 

THE GESAMP-BALLAST WATER WORKING GROUP 

1 Introduction 

2 Issues of confidentiality 

3 Terms of reference and time frame 

4 Review of proposals for approval of BWMS that make use of Active Substances 

5 Consideration of queries regarding the work of the GESAMP-BWWG 

6 Any other business 

7 Consideration and adoption of the report

*** 

GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

ANNEX 3 

TERMS OF REFERENCE FOR THE TECHNICAL GROUP 

1 Consideration of development of necessary methodologies and information requirements 

in accordance with G9∗

 for consideration by MEPC 58. 

2 For Basic Approval, the Group should review the comprehensive proposal submitted by 

the Member of the Organization along with any additional data submitted as well as other 

relevant information available to the Group and report to the Organization. In particular, 

the Group should undertake: 

.1 scientific evaluation of the data-set in the proposal for approval 

(see paragraphs 4.2, 6.1, 8.1.2.3, 8.1.2.4 of G9); 

.2 scientific evaluation of the assessment report contained in the proposal for 

approval (see paragraph 4.3.1 of G9); 

.3 scientific evaluation of the risks to the ship and personnel to include 

consideration of the storage, handling and application of the Active Substance 

(see paragraph 6.3 of G9); 

.4 scientific evaluation of any further information submitted 

(see paragraph 8.1.2.6 of G9); 

.5 scientific review of the risk characterization and analysis contained in the proposal 

for approval (see paragraph 5.3 of G9); 

.6 scientific recommendations on whether the proposal has demonstrated a potential 

for unreasonable risk to the environment, human health, property or resources 

(see paragraph 8.1.2.8 of G9); and 

.7 preparation of a Report addressing the above-mentioned aspects for consideration 

by MEPC (see paragraph 8.1.2.10 of G9). 

3 For Final Approval, the Group should review the discharge testing (field) data and 

confirm that the residual toxicity of the discharge conforms to the evaluation undertaken 

for Basic Approval and that the previous evaluation of the risks to the ship and personnel 

including consideration of the storage, handling and application of the Active Substance remains 

valid. The evaluation will be reported to MEPC (see paragraph 8.2 of G9). 

4 The Group should keep confidential all data, the disclosure of which would undermine 

protection of the commercial interests of the applicant, including intellectual property. 

*** 

 

∗ “G9” stands for the “Procedure for approval of ballast water management systems that make use 

of Active Substances (G9)” adopted by resolution MEPC.126 (53). 

GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

ANNEX 4 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

OceanSaver® Ballast Water Management System 

Submitted for Final Approval by Norway

0 SUMMARY 

0.1 Having considered the submission provided by Norway (MEPC 58/2/1) as well as 

information provided by the applicant, the Group recommends that MEPC 

grants Final Approval to the OceanSaver® Ballast Water Management System, subject to 

the Administration verifying that a number of recommendations be fully addressed prior to 

issuance of a Type Approval Certificate. 

0.2 The Group noted that the proposed system treats the ballast water on uptake and 

discharge. During uptake the ballast water is filtered and then treated by cavitation, nitrogen 

super-saturation and electrolytic disinfection. During discharge the ballast water is treated by the 

filtration and cavitation phases only. Additionally, the hypoxic conditions in the ballast water 

tanks are maintained by the use of pressure-vacuum valves in the ballast tank air vent-heads. 

0.3 The Group noted that the applicant calculated the concentrations of bromoform and 

dichloromethane in the air just above water surface based in Henry’s law and compared with 

the Occupational Exposure Limit value established by the Norwegian Administrative Norms for 

human exposure to these halogenated organic compounds. The Group noted that bromoform 

concentrations as representative of disinfection by-products are at levels similar to those 

observed in other ballast water management systems based on chlorine. 

0.4 Notwithstanding the above, the Group recommends that due to the measured bromoform 

in the treated ballast water at concentrations up to 294 μg/L, well above the WHO Guidelines 

for Drinking Water Quality (<100μg/L), risk mitigation measures should be put in place possibly 

through aeration, to minimize human exposure to this halogenated organic compound which may 

represent a genotoxic/carcinogenic health risk. 

0.5 The Group noted the maximum dosage of TRO measured in the ballast water line of the 

system is 2.5 mg/L. The Group further noted that the decay of TRO levels has been investigated 

in natural sea water environment after treatment under simulated ballast water conditions. 

Highest oxidant concentration measured after 5 days was 0.2 mg /L. The system has 

a TRO characteristic typically in the range of 0–0.3 mg/L at discharge and is below 0.2 mg/L for 

more that 85% of all tests undertaken. The applicant claimed that, taking into account the short 

voyages (e.g. 24 hours), the maximum allowable discharge concentration is 0.5 mg /L. 

0.6 The Group further noted that the applicant in accordance with the confidential dossier has 

foreseen the need to neutralize the treated ballast water before discharge in case the content 

of Total Residual Oxidants (TRO) exceeds a proposed limit of 0.5 mg/L. Various possible 

neutralization chemicals are discussed and the use of sodium thiosulfate pentahydrate is 

proposed. 
GESAMP-BWWG 7/9 

ANNEX 4 

Page 2 

I:\MEPC\58\2-8.doc 

0.7 The applicant has proposed a PNEC = 0.68 μg/L for TRO for the aquatic environment 

based on results of aquatic toxicity tests. The approach for deriving the PNEC as well as the 

value proposed is acceptable to the Group. 

0.8 In evaluating the environmental risk assessment carried out by the applicant, the Group 

had reservations regarding the assumption of a considerable further degradation 

of TRO immediately after discharge as proposed by the applicant. The level of TRO is stabilized 

in the ballast water after treatment at a low concentration and it is unlikely that further 

degradation through biological processes will take place during dilution shortly after discharge. 

The Group noted, however, that some further degradation through chemical processes 

(oxidative reaction) might be expected. 

0.9 Using some of the existing risk assessment models, the Group noted that a dilution 

of 735 times at discharge of treated ballast water with a concentration of TRO = 0.5 mg/L 

proposed as limit value by the applicant, is required to avoid effects in the aquatic environment. 

Furthermore, the Group noted that the proposed limit of 0.5 mg/L refers to the content 

of TRO accepted by the MEPC as a discharge limit for sewage. Furthermore, according to 

the Rotterdam scenario of the MAMPEC model, a dilution of only approximately 140 times can 

be assumed. This would correspond to a concentration in treated ballast water at discharge of 

approximately 0.1 mg/L if no degradation of TRO after discharge is taken into account. 

Considering that the MAMPEC model is recommended by MEPC 56 as an interim measure and 

that some degradation may take place as a result of the chemical oxidative properties of TRO, an 

interim discharge limit value of 0.1-0.2 mg/L TRO is proposed. 

0.10 Based on the above deliberations, the Group is of the opinion that the concentration 

of TRO in the treated ballast water needs to be controlled and kept at a level not 

exceeding 0.1 0.2 mg/L. 

0.11 In conclusion, having reviewed all the information provided by the applicant, the Group 

agreed to recommend to the MEPC that Final Approval be given to the OceanSaver® Ballast 

Water Management System, subject to the Administration verifying that all the following 

recommendations have been fully addressed prior to issuance of a Type Approval Certificate: 

 .1 maximum allowable dosage of Active Substances at 2.5 mg/L as TRO 

should be monitored and recorded during uptake by TRO sensors adequately 

maintained; 

 .2 maximum allowable discharge concentrations of Active Substances 

at 0.1-0.2 mg/L as TRO should be ensured, monitored and recorded during 

discharge by TRO sensors adequately maintained; 

 .3 a neutralization system should be further developed and type approved by 

the Administration; 

 .4 the health toxicological properties for the handling and application of the proposed 

neutralizing agent be assessed in order to ensure safety for crew; and 

 .5 the treated ballast water be aerated before discharge in order to reduce the 

concentration of bromoform. 
GESAMP-BWWG 7/9 

ANNEX 4 

Page 3 

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1 INTRODUCTION 

1.1 The proposed OceanSaver® Ballast Water Management System (BWMS) was given 

a Basic Approval by the MEPC 57 (MEPC57/2/10) based on a favourable opinion issued by 

the GESAMP Ballast Water Working Group at its 5th meeting in January 2008 after reviewing 

the application submitted by Norway. 

1.2 Following Basic Approval, Norway submitted an application for Final Approval 

to MEPC (MEPC 58/2/1) and the applicant has submitted a full application dossier. 

2 COMPLETENESS OF THE DOSSIER 

2.1 The Group noted that the following documents have been included in the application 

dossier for Final Approval: 

 .1 Reports on land-based testing of the OceanSaver BWMS; 

 .2 Corrosion testing with cavitation and nitrogen treated ballast water; 

 .3 A Quality Assurance Plan; 

 .4 An environmental risk assessment including MAMPEC and Dispersion model; 

 .5 Safety data sheets and Human Exposure Assessment (HEA); 

 .6 Operation and maintenance instructions results and user manuals; and 

 .7 Technical information and drawings of the system components. 

2.2 The Group noted that for the data set required for Active Substances, Preparations 

or Relevant Chemicals, the applicant refers to the submission for Basic Approval. 

2.3 The Group further noted that all corrosion tests have been undertaken applying filtration, 

cavitation (C3T) and nitrogen super-saturation only. 

2.4 In reviewing the application dossier submitted, the Group had a number of clarifying 

questions which were directed to the applicant. The applicant provided a written response to the 

questions raised which was taken into account in the finalization of the review. 

3 DESCRIPTION OF OCEANSAVER® BALLAST WATER MANAGEMENT 

SYSTEM 

3.1 Overview of the system 

3.1.1 The Group noted that the OceanSaver® Ballast Water Management System (OS BWMS) 

consists of the following treatment units: automatic back-flushing filter, cavitation, nitrogen 

super-saturation and electrolytic disinfection. The treatment sequence according to the Group’s 

understanding is illustrated in Figure 1 below and described in the following text. 
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ANNEX 4 

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Figure 1: The OS BWMS: Main Components 

3.1.2 The applicant informed that the following treatment sequence applies: 

.1 On ballast uptake the water enters a mechanical filtration unit with automatic back 

flushing to remove particles and organisms, the back-flush effluent is discharged 

at the point of uptake. 

.2 Following filtration, the ballast water is subjected to hydrodynamic cavitation in 

the C3T unit. 

.3 Following cavitation, the ballast water is supersaturated by the injection of 

nitrogen to cause oxygen deficiency in the ballast water. 

.4 Additionally, the system also incorporates an isolated electrodialytic process 

based on the principles of an electrochemical activation technology, the C2E 

process. The C2E unit applies the principle of electrochemical activation to a side 

stream of the main flow, producing a disinfectant which is returned to the main 

flow at a point following the cavitation and supersaturation phases. The C2E unit 

SEA 

Filtration Cavitation 

C3T 

Electrolysis 

C2E 

N2- 

Supersaturation

BWtanks 

Ballasting 

Deballasting 

BWtanks Cavitation 

C3T 

SEA 

Neutralization Filtration 

OceanSaver 
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does this by generating controlled amounts of Active Substances in-situ without 

adding any Preparations to the water. The applicant states that the efficacy of the 

disinfectant is enhanced by cavitation since the cavitation causes fragmentation 

and separation of bacterial colonies. To meet a various range of flow rates, 

the C2E unit is modularly composed and consists of a number of identical cells 

powered by a number of identical rectifiers. 

.5 The ballast water tanks are equipped with conventional tank ventilation 

arrangements that include pressure-vacuum devices to evacuate the released 

oxygen and surplus nitrogen, and to help maintain nitrogen levels and to prevent 

air entering the tanks. 

.6 During ballast water discharge, the ballast water is treated with the automatic 

back-flushing filter and the cavitation unit (C3T) again. 

3.1.3 The C2E unit cells are maintained by flushing with AWACLEAN, a 7% solution of acetic 

acid. Flushing takes places after ballasting or after approximately 10-12 hours of use. The 

applicant states that the C2E flushing system is a relatively simple device. The system consists of 

a 100 L tank in addition to valves and a small pump. The flushing system is integrated in 

the OS BWMS and controlled by the OS automation with its own start/stop sequences. 

3.1.4 The Group noted that the introduction of the OS BWMS may have impacts that may 

introduce requirements to other on board ship systems as follows: 

.1 Pressure losses due to the treatment uses may require an additional boosting pump 

and increased pressures may adversely affect piping arrangements that may be 

specified to a lower design pressure specification. 

.2 The OS BWMS has an integral automation, calibration and data monitoring, 

storage and reporting system. This administrates and controls overall performance 

between all components/processes within the system and records all measured 

data in accordance with the requirements as specified in Guidelines for approval 

of ballast water management systems (G8). 

.3 Comprehensive corrosion and coating impact studies including literature 

assessments, small scale and laboratory studies as well as full scale studies have 

been conducted. The main objectives of these studies have been to verify that 

the OS BWMS does not accelerate corrosion nor the ageing of corrosion 

protection systems (coatings) and also that the system is compliant with the 

intentions of Performance standard for protective coatings for dedicated seawater 

ballast tanks in all types of ships and double-side skin spaces of bulk carriers 

adopted by resolution MSC.215(82). It may be noted that the full scale studies 

included all treatment stages with the exception of the addition of the disinfectants 

produced by the C2E unit (filtration, cavitation and super-saturation). 

An additional theoretical study has since been undertaken including this treatment 

stage. 
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ANNEX 4 

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3.1.5 The Group noted that the OS BWMS has some operational implications. 

.1 The performance of the electrolytic disinfection is limited to a salinity >0.7% 

(7 g/L). In cases where the ballast water has a lower salinity, feed water will be 

automatically supplied from the aft-peak tank(s) that will be filled with seawater 

to ensure that the saline level in the feed water to the unit remains within 

prescribed levels. 

.2 The electrochemical activation technology applied within the C2E unit will 

generate a limited quantity of hydrogen (H2). For this reason a safe gas evacuation 

system has been specified and developed to maintain the hydrogen concentration 

<1%. The system rests upon the principles of collection at source, dilution by air 

to safe concentration levels and evacuation to open air. 

3.1.6 The Group noted that the non-confidential information stated that no neutralization 

substances are added to the system. However, the confidential application dossier informs that a 

neutralizing procedure is available as an option; adding a neutralization agent (sodium thiosulfate 

pentahydrate) at discharge when monitored TRO levels exceed 0.5 mg/L in the discharged ballast 

water. The precise description of this component was not included in either the confidential 

application or in subsequent supplementary information provided. The Group cannot evaluate 

how the TRO concentration in the ballast water discharge is to be monitored and how the 

neutralization chemical mixing rates are to be controlled under high volume discharge 

(such as >1,000 m3

/h). After further communication with the applicant, the Group concluded that 

this component of the system has not yet been fully developed. Also, the applicant claimed that 

this mitigation system is used only for rare extreme conditions. The Group has the opinion that in 

case of emergency where ballast water may need to be discharged not having sufficient exposure 

time for TRO degradation, the reliability of this neutralizing component is key to ensure that a 

maximum allowed discharge concentration of TRO is not exceeded. 

3.1.7 The Group also noted that the system incorporated a salinity sensor to control the power 

to the electrolytical cell and a monitoring of the TRO concentration to maintain the required level 

of TRO (spectrophotometric measurement with DPD reagent) and a salinity sensor to maintain 

the required level of TRO, which is dependant on salinity, but also to avoid discharge of 

excess TRO. 

3.2 Active Substances, Relevant Chemicals and Other Chemicals 

3.2.1 The Group noted that the C2E unit of the OS BWMS creates Active Substances and 

relevant by-products. Active Substances are produced in the anode chamber (anolyte) and to some 

extent in the cathode chamber (catholyte) of the C2E unit. The Active Substances formed are 

primarily hypochlorous acid (HClO), chlorine gas (Cl2), ozone (O3), hydrogen peroxide (H2O2), 

chlorine dioxide (ClO2) and hypochlorite (ClO-

). In seawater, these oxidants react with bromide (Br-) 

and generate hypobromous acid and hypobromite ion. The resulting mixture of oxidants 

(mainly hypochlorous acid, hypochlorite ions, hypobromous acid and hypobromite ion) are 

named Free Residual Oxidant (FRO) in the literature while Total Residual Oxidant (TRO) also 

includes the halogenamines and other less effective oxidants with N-C link. The applicant stated 

that the maximum dosage of TRO in the OS BWMS measured in the ballast water line 

is 2.5 mg Cl/L. 
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3.3 Active Substances 

3.3.1 The Active Substances identified during Basic Approval are listed in the following 

two tables: 

Treated water 

High salinity 

34 PSU 

Brackish water 

17 PSU 

Surface water 

20 PSU 

Total chlorine (Cl2) mg/L 1010 870 970 

Free chlorine (Cl2) mg/L 980 800 930 

Combined chlorine (Cl2) mg/L 30 70 40 

Ozone (O3) mg/L 13.7 5.4 10.9 

Hydrogen peroxide (H2O2) mg/L 2.7 2.1 3.6 

Component 

Chemical Name 

CAS 

Number 

UN 

Number 

Molecular 

Weight 

(g/mol) 

Empirical 

formula 

Structural 

formula 

Hypochlorous acid 7790-92-3 n/a 52.460 HOCl 

Hydrogen peroxide 7722-84-1 2015 34.015 H2O2

Ozone 10028-15-6 47.998 O3

Chlorine dioxide 10049-04-4 9191 69.5 ClO2

3.3.2 In addition, also hypobromous acid (HOBr) and hypobromite ion (OBr-

) are 

considered Active Substances being part of the TRO as described above in section 3.2.1. 
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ANNEX 4 

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3.4 Relevant Chemicals 

Component 

Chemical Name 

CAS 

Number 

UN 

Number 

Molecular 

Weight 

(g/mol) 

Empirical 

formula 

Structural 

formula 

Bromoform 75-25-2 2515 252.731 CHBr3

Dibromochloromethane 124-48-1 2810 208.290 CHBr2Cl 

Dichlorobromomethane 75-27-4 8027 163.83 CHBrCl2

2,4,6 – tribromophenol 118-79-6 2811 330.82 C6H3Br3O 

Dibromoacetonitrile 3252-43-5 2810 198.86 C2HBr2N 

Monobromoacetic 

acid 

79-08-3 1938 138.94802 C2H3BrO2

3.5 Other chemicals 

Component 

Chemical Name 

CAS 

Number 

UN 

Number 

Molecular 

Weight 

(g/mol) 

Empirical 

formula 

Structural 

formula 

Nitrogen gas 7727-37-9 1066 28.013 N2

Sodium thiosulfate 

pentahydrate 

10102-17-

7 

 248.18 Na2S2O3

5H2O 

4 HUMAN HEALTH ASSESSMENT

4.1 The Group noted that the human health risk assessment of the OS BWMS is based on the 

work processes under normal operation as well as under accident situations in which exposure to 

humans may occur. Further, the assessment covers the crew on board the ship, and the general 

public. The applicant addresses nitrogen exposure, exposure to Active Substances 

(hypochlorous acid (HClO), ozone (O3), hydrogen peroxide (H2O2), chlorine dioxide (ClO2) and 

hypochlorite (ClO-

) and Relevant Chemicals (TRO and DBP) used in the electrolytic treatment 

process (C2E), and exposure to the halogenated by-products in treated ballast water 

(VOX, AOX). The applicant assessed the frequency and duration of exposure to halogenated 
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ANNEX 4 

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by-products and made the characterization of the risk for human health in comparison to 

the WHO guideline values for drinking water quality (WHO, 2003). 

4.2 The Group noted that bromoform was detected at concentrations up to 294 μg/L which is 

well above the WHO Guidelines for Drinking Water Quality (<100μg/L). If mitigation measures 

are not put in place namely through aeration, human exposure to this halogenated organic 

compound may represent a genotoxic/carcinogenic health risk under long-term scenario. 

4.3 The Group recommends that in case sodium thiosulphate is to be used in the 

neutralization process and stored onboard ship as undiluted chemical, its human toxicological 

hazards, namely, the irritative properties towards the respiratory tract will have to be taken into 

consideration in the HES and a complete MSDS ought to be developed. 

4.4 The Group noted that the OS BWMS can either be operated by deck officers or engineers 

and that exposure of humans to anolyte (AWAC), catholyte (AWAL) or nitrogen can occur as a 

result of pipe leakage. Possible nitrogen leakage and indirect oxygen depletion will be detected 

by oxygen sensors, which are installed in all rooms affected by piping connecting 

the N2 generator to the ballast water pipeline as well as in the area where the N2 generator is 

located. If the sensors detect a leakage of N2, the system automation will record an alarm and the 

system will enter shutdown mode. Any individual O2 sensors will activate system shutdown 

should the O2 level fall below 19%. 

4.5 The Group was informed that during ballasting, the air in the empty ballast tanks will 

gradually be vented out of the tanks as the air is replaced by the rising water and residual N2. The air 

can contain halogenated compounds found in the ballast water that could imply a health risk if 

inhaled. The tank air is released through vent-heads usually located on the deck edge, along the deck 

hatch frame or, less commonly, on the side of the ship (for instance on car carriers and RO/RO ships). 

Crew on deck can be exposed to the vented tank air. The maximum duration of the exposure 

equals the duration of the ballasting, which is 10-12 hours for large ships. The assessment is 

done by comparing the WHO drinking water guidelines with measured concentrations in 

treated ballast water. The compounds in question are bromodichloromethane, bromoform, 

chlorodibromomethane, dichloromethane and vinyl chloride. The table below 

gives WHO guidelines and concentrations in treated ballast water (maximum and mean 

concentrations) for each of the compounds in question. 

BromodichloroMethane Bromoform Chlorodibromomethane Methylene 

bromide 

Dibromomethane 

Dichloromethane Vinyl 

Chloride 

CAS NR 75-27-4 75-25-2 124-48-1 74-95-3 75-09-2 75-01-4 

WHO Guideline 

Value (mg/L) 

0.06 0.1 0.1 0.02 0.0003 

Highest measured 

concentration in 

Ballast water 

(mg/L) 

0.0009 0.3 0.02 0.0004 0.9 0.0003 

Mean value of 

measured 

concentration in 

ballast water 

(mg/L) 

0.00004 0.2 0.01 0.0002 0.1 0.0002 
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4.6 The Group noted that bromoform and dichloromethane were found in concentrations 

higher than the WHO guideline. The applicant calculated the concentration of bromoform and 

dichloromethane in the air just above the water surface using Henry’s law and compared these 

calculated values with the Norwegian administrative norm for 8 hours work 

(Occupational Exposure Limit). The concentration of bromoform in the air was calculated 

to 0.004 mg/m3 and the administrative norm is 5 mg/m3. The concentration of dichloromethane 

was calculated to 0.056 mg/m3 and the administrative norm is 50 mg/m3

. Thus, the calculated 

concentration values in the vented air for these two compounds are much lower than the 

Norwegian administrative norms, in what occupational exposure threshold values are concerned. 

4.7 The Group noted that swimmers could be exposed to treated ballast water via skin 

contact, inhalation (of vapours) and swallowing of seawater. Two compounds in treated ballast 

water have been found in concentrations higher than the WHO guideline; bromoform (5 times) 

and dichloromethane (45 times). When discharged to sea, the dilution in the plume has been 

modelled to be 1:20 within 50 metres from the discharge. Only if a person gets very close to the 

point of discharge (a few metres away) there is a risk of human exposure to dichloromethane and 

bromoform concentrations above WHO guidelines for drinking water. 

4.8 The Group noted that as a part of maintaining the cells in the C2E unit, the cells are to be 

flushed with AWACLEAN, a 7% solution of acetic acid, which is stored in a 100 L tank. 

Flushing takes places after ballasting or after approximately 10-12 hours of use. The storage tank 

is filled manually, however, dilutions of acetic acid <10% are not classified as a hazardous 

chemical according to the current legislation for classification and labelling in Europe 

(Dir. 2001/59/EC). 

4.9 The Group noted that according to SOLAS regulation strict requirements apply to testing 

for safe breathable atmospheres before personnel are allowed to enter enclosed spaces on board 

ships. This involves ventilating tanks. Personnel shall monitor the tank's atmosphere during the 

entering process, using hand-held oxygen content monitors. When a ballast water tank is full 

and N2 is accumulated in the headspace, oxygen levels will be low. Opening and inspection of 

the tank will be strictly controlled when the vessel is operating in this mode. It is noted that, 

under normal operations, there will be no releases from the vent-heads except during ballasting 

due to the use of P/V (pressure /vacuum) valves. 

4.10 The Group noted that human exposure to the C2E solutions (anolyte (AWAC), catholyte 

(AWAL)) or to N2 can occur in the case of breakage in the piping. According to the applicant, 

this type of fault would be detected by the automation system as it includes internal leakage 

detection (inside the C2E cabinet) and pressure loss monitoring (piping) that monitors the 

process. In the case of detected leakage, alarms are recorded and an immediate shutdown 

procedure of the C2E is activated. If the breakage is located outside the C2E cabinet the amount 

of AWAC and AWAL fluid spilled is limited to the amount within the pipes. According to the 

applicant, AWAC and AWAL are classified as non-dangerous (Dir. 1999/45/EC); however due 

to the high pH of AWAL (pH~12) this solution is regarded as corrosive and therefore risk 

mitigation measures have to be implemented by the use of engineering controls and personal 

protective equipment (PPE). 
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4.11 The Group noted that in case of ventilation breakdown or leakage, there is a risk of vapor 

or fumes to be released. These fumes may cause dizziness and nausea and inhalation should be 

avoided. Respiratory protection should be available. The ventilation performance is actively 

monitored. Any failure will institute an alarm and consequently system shutdown. The risk to 

human health is therefore considered to be low. If the breakage is inside the C2E cabinet, this is a 

sealed compartment with a built-in detection system and the risk of exposure is considerably 

limited. 

4.12 The Group considers that there are safety procedures in place to minimize the health risk 

for crew and other persons on the ship in connection with N2 leakage from the N2 generator or 

piping. Due to possible leakage, sensors detecting O2 levels are installed in all rooms affected by 

piping connecting the N2 generator to the ballast water pipeline as well as in the area where 

the N2 generator is located. If the sensors detect a leakage of N2, the system will enter shutdown 

mode. An alarm will be activated if the oxygen level is reduced to 19%, and access to the rooms 

will be denied. The safety procedures will ensure that also adjacent spaces and areas under 

potential nitrogen migration are closed, secured and warning signs posted. Each of the adjacent 

spaces will be ventilated to secure that any N2 that has migrated from the leakage point is 

vented out. 

5 RISK TO SAFETY OF SHIP 

5.1 Hydrogen 

5.1.1 The Group appreciated the detailed study about hydrogen generation, distribution/dilution 

in the ballast tanks and safety installations. Hydrogen is flammable at concentrations of 4% and 

explosive at levels above 18%. The safe gas evacuation system includes continuous dilution to 

less than 1%. The Group noted that risk mitigation measures are employed to ensure reliable 

collection of hydrogen at source, continuous dilution and evacuation that are considered will 

ensure that this risk remains acceptable. 

5.2 Nitrogen Generator 

5.2.1 The Group noted that the BWMS user manual provided, identifies risks that may be 

encountered during operation of the Nitrogen Generator and specifies risk mitigation measures 

that are considered appropriate. It is also noted that spaces that could be subject to the leakage of 

nitrogen gas are to be fitted with low oxygen content alarms for the protection of personnel. 

5.3 Corrosion 

5.3.1 The Group noted that the applicant carried out two different corrosion tests: one coated 

test panel exposure in a ballast tank on board of a ship, and a lab test. Both tests were carried out 

with de-oxygenated water (nitrogen saturation) without electrolytic disinfection and untreated 

seawater. 

5.3.2 The applicant informed that since Basic Approval was granted, two additional corrosion 

tests have been carried out: one lab test with corrosion and coating studies and, in addition, two 

shipboard tests over a period of more than 15 months in the ballast tanks of two vessels. 

All testing has been undertaken applying filtration, cavitation (C3T) and nitrogen supersaturation only. 
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5.3.3 It was noted that no corrosion tests have been carried out with the complete OceanSaver® 

treated ballast water for the system proposed, which would include electrochemical activation 

and cavitation. 

5.3.4 The Group noted that there was no increased corrosion rate of steel due to cavitation and 

nitrogen super-saturation. The ballast tank coatings showed no increase of rusting, blistering and 

no loss of adhesion strength. However, as the tests were carried out without the electrolytic 

disinfection (C2E unit), the corrosion tests are not representative for the whole OS BWMS. 

5.3.5 The Group noted that a theoretical study was provided dealing with the potential effect of 

electrochemical activation by the C2E unit to cause corrosion/coating impacts in ballast tanks 

when integrated with the remainder treatment stages. The work was based on the understanding 

that TRO would be present over a period of time approximated to 24 hrs with an initial 

free residual oxidant (FRO) concentration in the treated seawater is ca. 2 ppm., after 5 h, 

the FRO concentration is typically below 0.25 ppm and after a day TRO concentrations are 

typically between 0.05 and 0.25 ppm. 

5.3.6 Based on the identified rapid degradation of TRO and on general available literature and 

experience, the applicant concludes that it is unlikely that the introduction of the C2E component 

will have any effect on the coatings applied for corrosive protection of ballast water tanks. 

Similarly, it is unlikely that the additional treatment component will affect corrosion of steel. 

The Group can agree that it is unlikely that the introduction of the electrolytic disinfection phase 

at the levels of TRO specified for this system will affect either the ballast tank coatings or 

increase substantially the corrosive effect on steel components. However, it is recommended that 

this evaluation be confirmed valid by monitoring such effects during operation for a suitable 

period of time. 

6 RISKS TO THE AQUATIC ENVIRONMENT 

6.1 Assessment of persistence (P), bioaccumulation (B) and toxicity (T) 

6.1.1 During Basic Approval, the Group concluded that none of the Active Substances 

or Relevant Chemicals fulfilled the PBT criteria. 

7 ASSESSMENT OF TREATED BALLAST WATER 

7.1 Measured concentrations in treated ballast water 

7.1.1 The Group noted that the applicant delivered a detailed degradation study 

for Active Substances and relevant by-products during 5 days after treatment of seawater of 

medium (<22 PSU) and high salinities (>32 PSU). Free Residual Oxidants (FRO) 

and Total Residual Oxidants (TRO) were measured with the DPD method. Results are shown in 

the figures below. 
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Medium salinity - high organic concentration

0,00

0,25

0,50

0,75

1,00

1,25

1,50

1,75

2,00

2,25

2,50

0 20 40 60 80 100 120 140 160 180 200 220 240 260 280 300 320

Time (min)

Total residual oxidant (mg Cl/L)

Test 6 Test 7 Test 8 Test 9 Test 10 Test 11 Test 12

Figure 2: Decay of Total Residual Oxidant in treated water from land-based approval tests with 

the OceanSaver BWMS measured by the DPD method. Measurements were done in a sample 

(50 L) taken out immediately after treatment. 

Medium salinity water - high organic concentration

0,00

0,25

0,50

0,75

1,00

1,25

1,50

1,75

2,00

0

250

500

750

1000

1250

1500

1750

2000

2250

2500

2750

3000

3250

3500

3750

4000

4250

4500

4750

5000

5250

5500

5750

6000

6250

6500

6750

7000

7250

7500

Time (min)

Total residual oxidant (mg Cl/L)

Test 6 Test 7 Test 9 Test 10 Test 11 Test 12

1 day 2 days 3 days 4 days 5 days

Figure 3: Decay of Total Residual Oxidant in treated water with medium salinity 

(around 22 PSU) from land-based approval tests with the OceanSaver BWMS measured by 

the DPD method. Measurements from 0 to 2 hours are done in a sample (50 L) taken out 

immediately after treatment. 
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7.1.2 The maximum concentrations of TRO were found to be 2.5 mg/L in the ballast water line. 

The concentration decreased rapidly to a maximum concentration of 0.2 mg/L after 5 days. 

To account for discharge of ballast water after 1 day, the applicant proposed 0.5 mg/L as 

maximum allowable discharge concentration. 

7.1.3 The applicant delivered a detailed study on formation of disinfection by-products (DBPs), 

which include both organic and inorganic substances formed when TRO reacts with naturally 

occurring compounds in the water. DBPs are normally formed in reactions where organic 

chemicals play a major part. They are called organohalogens and are further divided into volatile 

organohalogens (POX) and extractable organohalogens (EOX), shown in the figure below. 

Figure 4: An outline of chemical reactions upon electrochlorination treatment of natural 

seawater (figure from Taylor 2006). 

7.1.4 The Group noted that the dominating halogenated organic compound, and THM, was 

bromoform. Bromoform was detected in concentrations up to 294 μg/L. Bromate was not found 

in any of the samples. The applicant expected to find some bromate, but explained that the 

analysis is a challenge in seawater. High salinity content may interfere with some of the 

analytical procedures used. The following table shows the measured concentrations 

of AOX, EOX and oxidation by-products in control and treated water (day 0 and day 5) 

from Tests 5 and 7. 
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Table: Measured DBP in control and treated Ballast Water. 

 

Test 5, 

day 0, 

Treated 

Test 5, 

day 0, 

Control

Test 5, 

day 5, 

Treate

d 

Test 5, 

day 5, 

Control

Test 7, 

day 0, 

Treated 

Test 7, 

day 0, 

Control 

Test 7, 

day 5, 

Treated

Test 7, 

day 5, 

Control

AOX mg/L 2.9 1.63 0.84 3.74 0.64 3.48 5.04 0.75 

Bromate μg/L <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 <0.003 

EOX μg/L <0.01 <0.01 0.07 <0.01 <0.01 <0.01 <0.01 <0.01 

Trichloromethane μg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 

Dibromochloromethane μg/L 4.6 <0.5 5.5 <0.5 17 <0.5 15 <0.5 

Tribromomethane 

(Bromoform) μg/L 110 <1 120 <1 200 <1 230 2.5 

Dibromomethane μg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 

Dichlorobromomethane μg/L 0.51 <0.5 <0.5 <0.5 0.93 <0.5 1 2.6 

1,2,3-Trichloropropane μg/L 2.5 2.1 2.3 4.1 2.2 2.6 1.5 1.5 

1,2-Dibromo-3-

Chlorpropane μg/L <1 <1 <1 <1 <1 <1 <1 <1 

Phenols 

2-Chlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

3-Chlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

4-Chlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3-Dichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,4-Dichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,5-Dichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,6-Dichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

3,4-Dichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

3,5-Dichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3,4-Trichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3,5-Trichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3,6-Trichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,4,5-Trichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,4,6-Trichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

3,4,5-Trichlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3,4,5-

Tetrachlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3,4,6-

Tetrachlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2,3,5,6-

Tetrachlorophenol μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

PCP μg/L <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 

2-Chlorotoluol μg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 

4-Chlorotoluol μg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 

1,2,4-Tribromobenzol μg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 

1,3,5-Tribromobenzol μg/L <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 <0.5 
GESAMP-BWWG 7/9 

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7.2 Acute and chronic toxicity of treated ballast water 

7.2.1 The Group noted that acute and chronic aquatic toxicity tests with species from three 

trophic levels have been carried out with treated ballast water after a 5-day holding period 

(see table below). Some samples showed a remaining toxicity. 

Table: Overview of results of aquatic toxicity tests with treated ballast water 

 Species Effect concentration 

A Skeletonema costatum 

(11 tests, day 5) 

EC50 (72h) = 39-100% 

EC10 (72h) = 62% (26-100%) 

A Skeletonema costatum 

(numerous tests, day 0) 

EC50 (72h) = 16-100% 

EC10 = 5.3-65% 

C Acartia tonsa 

(day 5) 

LC50 (48h) >100% 

NOEC (48h) >100% 

C Nitocra spinipes 

(chronic reproduction test, day 5) 

NOEC (14d) <100% 

20% reduction in fecundity 

F Scophthalmus maximus 

(turbot) 

LC50 (96h) >100% 

NOEC (28d) ≥100% 

7.2.2 The Group noted that algae seem to be the most sensitive among the species tested with 

an average EC10 (NOEC) = 62% (26-100%) for treated ballast water samples after 5 days’ 

holding period. 

8 ENVIRONMENTAL RISK ASSESSMENT 

8.1 Derivation of a Predicted No Effect Concentration (PNEC) 

8.1.1 The Group accepted the PNEC of 0.62% corresponding to a dilution of 160 times, which 

was calculated on the basis of 11 tests of treated ballast water with Skeletonema costatum

for EC10 and an assessment factor of 100 considering that this species was the most sensitive 

species tested in acute and chronic tests with species from three taxonomic groups. 

0.622

100

62.2%

100

10 = = = averageEC PNEC 

8.1.2 The Group also accepted the proposed PNEC for TRO = 0.68 μg/L derived from an 

average measured concentration of TRO = 0.10 mg/L in the treated ballast water tested as 

proposed in the revised risk assessment. 

8.1.3 Noting that the applicant proposed a PNEC = 29 μg/L for bromoform, the Group recalled 

that lower values of PNEC for bromoform had been used in other assessments of BWMSs. 

8.2 Calculation of the Predicted Environmental Concentration (PEC) for the 

Active Substance and Relevant Chemicals 

8.2.1 The Group appreciated that the applicant had conducted modelling of various scenarios 

by use of both the MAMPEC model and the DREAM model. 
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8.2.2 The MAMPEC v.2.0 model was used for modelling steady-state concentrations for two 

harbours (Port of Rotterdam, Port of Mongstad) based on concrete port statistics. For the Port of 

Rotterdam, an average dilution of the ballast water at steady-state of 142 times is estimated. 

Resulting concentrations of TRO and Relevant Chemicals are shown in the table below. 

Table: Maximum Allowable Concentrations and calculated emission of disinfection by-products 

modelled for Port of Rotterdam and Port of Mongstad 

Compound Concentration in 

treated BW 

[mg/L] 

100% Load 

Emission 

[g/d] 

40% Load Emission 

[g/d] 

Port of Rotterdam 

TRO Maximum allowable 

concentration at discharge 

0.5 198461 79384 

TRO Maximum allowable 

concentration after 

treatment 

2.0 793844 317538 

Bromoform 0.294 116695 46678 

Dibromochloromethane 0.017 6747 2699 

Bromodichloromethane 0.001 397 159 

THMs 0.312 123839 49536 

Port of Mongstad 

TRO Maximum allowable 

concentration at discharge 

0.5 26959 10784 

TRO Maximum allowable 

concentration after 

treatment 

2.0 107836 43135 

Bromoform 0.294 15852 6341 

Dibromochloromethane 0.017 917 367 

Bromodichloromethane 0.001 54 22 

THMs 0.312 16822 6729 

8.2.3 In modelling the resulting concentrations of TRO, degradation after discharge of ballast 

water with a concentration of 0.5 mg/L was included in the model with a proposed degradation 

rate of 2.77 d-1. The Group had concerns about this degradation rate bearing in mind that 

degradation has already taken place during at least 5 days prior to discharge 

(cf. Figure 3 in section 7.1). 

8.2.4 Further, the DREAM model was used for predicting the fate of the plume of discharged 

ballast water in terms of PEC/PNEC ratios for discharge of ballast water in two harbours 

(Port of Mongstad, Port of Fredrikstad). 

8.3 Calculation of PEC/PNEC ratios 

8.3.1 In all scenarios modelled with the MAMPEC model, PEC/PNEC ratios <1 were 

estimated. However, the estimations for TRO are based on the assumption that further 

degradation will take place in the environment after discharge during a relatively long time 

period. However, considering that any effects of the discharge of ballast water are considered to 
GESAMP-BWWG 7/9 

ANNEX 4 

Page 18 

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be local, it is normally not relevant to include degradation in the estimations of the local exposure 

concentrations. The Group had concerns regarding the assumption that degradation will take 

place immediately after discharge and the model results for TRO. The Group considers that a 

concentration of TRO of 0.5 mg/L in the discharged ballast water would require a dilution 

of 735 times to reach the PNEC at 0.68 μg/L, while only a dilution of approximately 140 times 

according to the model used can be assumed. 

8.3.2 The results of the DREAM modelling of the fate of the plume of ballast water in 

two harbour scenarios showed the areas affected with PEC/PNEC ratios > 1, which for 

the Port of Mongstad scenario covers a large area. For the two scenarios, the models estimated 

that risks to the aquatic environment would appear in 1 to 37 million m3

 depending on scenario 

and inclusion of oxidant decay in the environment in the modelling. 

8.4 Other effects of discharge of ballast water 

8.4.1 The ballast water treatment process includes a step where the water is super-saturated 

with nitrogen in order to prevent growth of surviving oxygen dependent organisms after the 

cavitation step. The remaining oxygen level is measured to approximately 2 mg/L. 

8.4.2 Modelling of the oxygen content has been conducted for six scenarios and the oxygen 

content in the plume 50 m away from the point of discharge after approximately 20 times dilution 

is calculated to 5.8 mg/L. The Group noted that the applicant concluded that the discharge will 

have a local effect on seawater quality in terms of oxygen content. 

9 CONCLUSIONS AND RECOMMENDATIONS 

9.1 Risks to the safety of the ship 

9.1.1 The Group concluded that sufficient risk mitigation measures have been incorporated in 

this BWMS system to reduce the risk to the ship and crew during operation to an acceptable 

level. 

9.1.2 The Group agreed that it is unlikely that the introduction of the electrolytic disinfection 

phase at the levels of TRO specified for this system will affect either the ballast tank coatings or 

increase substantially the corrosive effect on steel components. However it is recommended that 

this evaluation is confirmed valid by monitoring such effects during operation for a suitable 

period of time. 

9.2 Risks to the crew and general public 

9.2.1 The Group concluded that the concentrations of AWAC/AWAL in the treated ballast 

water in association with the foreseen risk mitigation measures indicate that the health risk 

related to inhalation of tank air for the crew and general public is not to be considered relevant. 

9.2.2 The Group recommends that due to measured bromoform at concentrations up 

to 294 μg/L, well above the WHO Guidelines for Drinking Water Quality (<100μg/L), risk 

mitigation measures should be put in place namely through aeration, to minimize human 

exposure to this halogenated organic compound which may represent a genotoxic/carcinogenic 

health risk under long term scenario. 
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9.2.3 The Group recommends that in case sodium thiosulfate is to be used in the neutralization 

process and stored onboard ship as undiluted chemical, its human toxicological hazards regarding 

the irritative properties towards the respiratory tract will have to be taken into consideration in 

the HES and a complete MSDS ought to be developed. 

9.3 Risks to the environment

9.3.1 The Group noted that for TRO a PNEC at 0.68 μg/L is derived. According to 

the Rotterdam scenario of the MAMPEC model, a dilution of approximately 140 times can be 

assumed. This would correspond to a concentration in treated ballast water at discharge of 

approximately 0.1 mg/L if no degradation of TRO after discharge is taken into account. 

Considering that the MAMPEC model is recommended by MEPC 56 as an interim measure and 

that some degradation may take place as a result of the chemical oxidative properties of TRO, an 

interim discharge limit value of 0.1-0.2 mg/L TRO is proposed. 

9.3.2 The Group further noted that the system has a TRO characteristic typically in the range 

of 0–0.3 mg/L at discharge and is below 0.2 mg/L for more that 85% of all tests undertaken. The 

highest TRO measured after 5 days was 0.2 mg /L. Furthermore, the Group noted that the limit 

of 0.5 mg/L proposed by the applicant refers to the content of TRC accepted by the MEPC as a 

discharge limit for sewage. However, the Group believed that such a limit should not be used for 

the much greater volumes of treated ballast water. Instead an interim discharge limit value 

of 0.1-0.2 mg/L should be used for treated ballast water. However, the proposed interim 

discharge limit value for TRO should be re-visited when an agreed Emission Scenario for 

discharge of ballast water becomes available. 

9.3.3 The Group noted that bromoform concentrations as representative of disinfection byproducts are at levels similar to those observed in other ballast water management systems based 

on chlorine. However, the Group had some concern regarding the concentration of bromoform in 

treated ballast water at discharge. In the documentation submitted for Basic Approval, 

concentrations of up to 400 μg/L were measured. In the documentation submitted 

for Final Approval, concentrations in two samples of treated ballast water immediately after 

treatment and after 5 days were from 110 to 230 μg/L. Considering that a PNEC value for 

bromoform would probably be in the μg/L range, considerable dilution would be required before 

no risks can be assumed. 

9.3.4 Due to nitrogen super-saturation of the ballast water, the concentration of dissolved 

oxygen is relatively low at discharge (~2 mg/L). The applicant has modelled 6 various scenarios 

for discharge of ballast water and concluded that the discharge of the ballast water with an 

oxygen content of 2 mg/L will have a local effect on seawater quality limited to a 50 m distance 

from the ship. 

9.3.5 Based on whole effluent testing, it is concluded that a PNEC for the treated ballast water 

can be set at 0.62% corresponding to a dilution of 160 times. Using the DREAM model for 

different scenarios, the applicant estimated that risks to the aquatic environment would appear 

in 1 to 37 million m3

 depending on scenario and inclusion of oxidant decay in the environment. 
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9.3.6 The applicant indicates that the content of toxic oxidants in the ballast water before 

discharge may be mitigated by use of a neutralizing agent, sodium thiosulfate pentahydrate. 

The Group noted, however, that this component has not yet been tested in a full-scale system, nor 

have details about the system automation been provided. Furthermore, the system seems to be 

designed to reduce the concentration of TRO by 0.5 mg/L irrespective of which concentration 

of TRO before neutralization. Therefore, the Group considers that confidence in the maintenance 

of a maximum allowable discharge concentration of TRO at any given time needs to be ensured. 

9.4 Conclusions and Recommendations

9.4.1 In conclusion, having reviewed all the information provided by the applicant, the Group 

agreed to recommend to the MEPC that Final Approval be given to the OceanSaver® Ballast 

Water Management System, subject to the Administration verifying that all the following 

recommendations have been fully addressed prior to issuance of a Type Approval Certificate: 

 .1 maximum allowable dosage of Active Substances at 2.5 mg/L as TRO 

should be monitored and recorded during uptake by TRO sensors adequately 

maintained; 

.2 maximum allowable discharge concentrations of Active Substances

at 0.1-0.2 mg/L as TRO should be ensured, monitored and recorded during 

discharge by TRO sensors adequately maintained; 

 .3 a neutralization system should be further developed and type approved by 

the Administration; 

 .4 the health toxicological properties for the handling and application of the proposed 

neutralizing agent be assessed in order to ensure safety for crew; and 

 .5 the treated ballast water be aerated before discharge in order to reduce the 

concentration of bromoform. 

*** 
GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

ANNEX 5 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Ecochlor® Ballast Water Treatment System 

Submitted for Basic Approval by Germany 

0 SUMMARY 

0.1 Having considered all the information summarized below, the Group recommends 

that MEPC grant Basic Approval to the Ecochlor Ballast Water Treatment System. 

0.2 The Group noted that the Ecochlor® Ballast Water Treatment System uses Purate® and 

sulphuric acid to generate chlorine dioxide as Active Substance at a maximum allowable 

concentration of 5 mg/L. It was also noted from the supplementary information provided that the 

applicant has introduced a filtration phase prior to treatment by chemical to this BWMS. 

0.3 Having considered the information provided, the Group agreed that: 

.1 after the injection of chlorine dioxide to the ballast water, chlorite ion is produced 

as a reaction between seawater and chlorine dioxide and is considered by 

the Group to be an Active Substance in addition to the chlorine dioxide in need of 

full evaluation in the application for Final Approval; 

.2 Purate® containing 40% by weight sodium chlorate (NaClO3) and 8% by weight 

hydrogen peroxide (H2O2) is considered to be a Preparation; and 

.3 sulfuric acid is considered to be a Relevant Chemical. 

0.4 The maximum allowable discharge level of the Active Substances (chlorine dioxide and 

chlorite) needs to be defined in the application for Final Approval. 

0.5 The Group considers the Level of Quantification (LOQ) for the THMs and HAAs used in 

the analyses of treated ballast water too high. It is common to determine these contaminants in 

surface waters at levels of 0.01 – 0.05 μg/L. It remains to be confirmed that the potential amount 

of by-products produced by the system is sufficiently low and meets the international standards 

on these substances. This uncertainty should be <0.1 μg/L. 

0.6 The Group noted that whole effluent ecotoxicity testing still has to be carried out 

for Final Approval. Samples should be taken during the land-based efficacy tests to 

meet G8 standards (Ref. G9, 5.2.1) and should include samples taken at day 0, 2 and 5 after 

treatment to demonstrate conclusively eventual remaining ecotoxicity at discharge after varying 

holding time in ballast tanks. Chemical analyses with a sufficient low LOQ should be carried out 

on the samples in order to identify substances responsible for any toxic effects encountered. 
GESAMP-BWWG 7/9 

ANNEX 5 

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I:\MEPC\58\2-8.doc 

0.7 A full environmental risk assessment is required for the application for Final Approval. 

This should apply model calculations of environmental concentrations using defined emissions 

scenarios and include the use of the maximum allowable discharge level of 

both Active Substances and the Relevant Chemicals in the treated ballast water as well as the 

eventual toxicity of the whole effluent sample. 

0.8 For Final Approval the Group recommends additional long-term (at least three months 

duration) corrosion tests with the treated ballast water to be carried out and also to confirm that 

epoxy ballast tank coatings commonly in use will not be adversely affected by the use of 

this BWTS. 

0.9 The Group recommends the provision of appropriate chemical resistant saveall protection by way of the storage tanks and any other locations considered necessary to 

provide protection to the ship in the event of leakage or spillage of the chemicals used. 
GESAMP-BWWG 7/9 

ANNEX 5 

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I:\MEPC\58\2-8.doc 

1 INTRODUCTION 

1.1 The data for this document were extracted from the original data supplied by Germany to 

support its submission MEPC 58/2/2 and the confidential dossier submitted to the Organization. 

2 COMPLETENESS OF THE DOSSIER 

2.1 The application dossier contained detailed information about Active Substances, the 

preparation (Purate) and Relevant Chemicals including their physicochemical and biological 

properties. Further, the applicant submitted MSDS sheets, quality control sheets, a drawing 

of Ecochlor® BWTS and references. 

2.2 The Group noted that the submission did not contain any original reports on corrosion 

studies on ballast tank coatings. A theoretical derivation of why no corrosion is expected was 

submitted in the confidential dossier, and in the non-confidential dossier (section 6.1.2.2) a brief 

presentation of results from two corrosion studies was included. Appropriate corrosion studies 

should be provided in the application for Final Approval. 

2.3 Additional tests have to be performed for effect of the treatment system on epoxy 

coatings used in ballast tanks. 

3 DESCRIPTION OF RESOURCE BALLAST TECHNOLOGIES SYSTEM 

3.1 Overview of the system 

3.1.1 The Group noted that Ecochlor® BWTS treats ballast water with chlorine dioxide in situ

using the Eka Chemicals Purate® technology. The applicant informed the Group that following 

submission of the application, a filtration stage has been included in the proposed system. 

3.1.2 For the generation of chlorine dioxide, Purate® and sulfuric acid are mixed under 

controlled conditions. The produced chlorine dioxide is injected into the main ballast water line 

resulting in a concentration of 5 mg/L. 

3.1.3 The applicant informed that the Ecochlor® BWTS consists of self-contained chemical 

storage modules for Purate® and sulfuric acid, two separate precursor chemical pumps, a chlorine 

dioxide generation module (housing for the reactor column), a booster pump, a programmable 

logic controller (PLC), an operator interface terminal (OIT), a system status/start-up panel, and 

piping to inject chlorine dioxide solution into the ballast water line. Ancillary equipment includes 

pipelines for chemical vents and re-supply, and in-line sampling valves. 
GESAMP-BWWG 7/9 

ANNEX 5 

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I:\MEPC\58\2-8.doc 

Figure: Ecochlor® process diagram 

3.1.4 The applicant informed that individual chemical pumps transfer the Purate® and 

sulphuric acid to the reactor column within the chlorine dioxide generation module. The optical 

sensor is not included in the diagramme, but described briefly in the dossier. 

3.1.5 The reactor column is under vacuum and is continuously monitored using a pressure 

transmitter. Loss of vacuum for any reason (loss of water flow, power, etc.) will automatically 

shut down the system and stop chlorine dioxide production. An alarm is given and the condition 

resulting in the alarm is displayed on the OIT. 

3.1.6 The Group noted that at no time during the production or injection of chlorine dioxide are 

any chemicals open to the atmosphere. All chemicals are completely contained in appropriate 

storage vessels or pipelines during the entire treatment process. 

3.2 Active Substances, Relevant Chemicals and Other Chemicals 

3.2.1 The Group considered Purate as a Preparation. Purate® contains 40% by weight sodium 

chlorate (NaClO3) and 8% by weight hydrogen peroxide (H2O2); the remainder being water. 

3.2.2 The applicant considers chlorine dioxide that is generated on board as the 

only Active Substance. The Group has identified the chlorite ion as an additional 

Active Substance in need of full evaluation, as chlorine dioxide has a very short half-life and the 

aquatic toxicity of the treated ballast water is determined by the content of the chlorite ion 

present. 

3.3 Relevant Chemicals 

3.3.1 The applicant identified sulfate ions and chlorite ions as Relevant Chemicals. However, 

the Group regarded chlorite ions as Active Substance and sulfate as not relevant due to its 

ubiquitous presence in seawater. Further, the Group considered the sulfuric acid (78%) as 

a Relevant Chemical. 
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ANNEX 5 

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I:\MEPC\58\2-8.doc 

3.3.2 The Group noted that the applicant states that the application of chlorine-free chlorine 

dioxide results in oxidation without the direct formation of organic by-products such as 

trihalomethanes (THMs), and that other unwanted by-products such as haloacetic acids (HAAs) 

are minimized. However, the Group recommends that the possible production of by-products is 

further investigated in the application for Final Approval. 

3.3.3 The table below provides an overview of the chemicals involved in the Ecochlor® Ballast 

Water Treatment System. 

Ingredient 

(IUPAC Name) 

Identification 

Numbers 

Chemical 

Formula 

Structural 

Formula 

Molecular 

Weight 

% 

(w/w) 

Applied 

Concentration 

Preparation Chemicals 

1. Purate®

a. Hydrogen 

peroxide 

b. Sodium 

chlorate 

CAS # 7722-84-1 

CAS # 7775-09-9 

 a. H2O2

b. NaClO3

a.

b. a. 34.01 

b. 106.44 

a. <8% 

b. 40% 

a. 0.05-2.9 M 

b. 0.5-3.2 M 

Active Substance in Ballast Water 

 Chlorine dioxide CAS# 10049-04-4 ClO2 67.45 -- 

<5 mg/L 

in ballast 

water 

2. Sodium chlorite 

 (present as 

 chlorite ion) 

CAS # 7758-19-2 NaClO2 90.45 

<5 mg/L 

in ballast 

water 

Relevant Chemicals in Ballast Water 

Sulfuric acid CAS# 7664-93-9 H2SO4 98.08 78% 0.75-4 M 

4 HUMAN HEALTH ASSESSMENT

4.1 The Group considered Purate®, sulfuric acid, and chlorine dioxide as chemicals of 

potential toxicological concern associated to Ecochlor® BWTS. In addition, low levels of chlorite 

ion may persist in treated ballast water and sources of direct exposure to this reaction product 

have been identified for two different population groups: Ecochlor technicians and ship’s crew. 

4.2 Purate® (40% w/w NaClO3 + ≤ 8% w/w H2O2 + 52% Water w/w): The Group considered 

sodium chlorate and hydrogen peroxide to be the critical toxicants in terms of human health 

effects and therefore addressed the hazards of these substances in the preparation Purate® and 

the further elaboration on risk. In this context the Group noted the classification according to the 

current European system for classification and labelling of this preparation as shown in 

the MSDS provided by the applicant:

O, Xn, N; R9, R22, R36, R51/53 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 6 

I:\MEPC\58\2-8.doc 

4.3 The Group has identified the following health hazards:

.1 Inhalation of Purate® vapours and/or mists are irritating to the mucous 

membranes, and may cause nausea, headache and/or weakness. Inhalation 

exposure can have an oxidizing effect, and oxidizes haemoglobin in the blood to 

methaemoglobinemia, causing a reduced ability to transport oxygen. This can 

lead to a lack of oxygen in body tissues. 

.2 Inhalation of sulfuric acid mists or sprays can cause pulmonary irritation, irritation 

of the mucous membranes, coughing and sore throat. Inhalation of high 

concentrations may cause respiratory tissue damage, causing lung disorders 

(chemical pneumonitis and pulmonary edema) and erosion of tooth enamel. 

.3 Chlorine dioxide is a strong, corrosive respiratory irritant, and the respiratory tract 

appears to the primary target of toxicity in human and animal studies. Reported 

symptoms include cough, wheezing, headache, nausea, pulmonary oedema and 

shortness of breath. 

.4 Direct exposure to Purate® may cause moderate irritation to the skin, and can 

cause severe eye irritation. 

.5 Direct exposure to sulfuric acid of the skin or eyes can cause severe irritation, 

burns and permanent tissue damage. Absorption through the skin is not 

anticipated to be a significant route of exposure. 

.6 Direct exposure to chlorine dioxide solution may cause redness and skin burns and 

may cause severe eye irritation. 

4.4 The Group noted that the on board areas, or sources of chemicals, with potential for 

exposure to Purate®, sulfuric acid and chlorine dioxide are limited to the areas where the BWTS 

and chemical storage tanks are located, where pipelines traverse, and where chemical re-supply 

operations take place. 

4.5 The potential exposure relating to the Ecochlor® BWTS that have been identified are 

direct exposure of skin and eye and air containing volatiles of the chemicals of potential concern 

within enclosed ship spaces. Treated ballast water is not considered as a potential pathway for 

exposure to Purate® and sulfuric acid because these substances are consumed in the chlorine 

dioxide generation reaction. Further, chlorine dioxide degradation behaviour indicates that 

chlorine dioxide will not persist in the environment. However, because chlorine dioxide in 

solution readily volatilizes, a potentially complete exposure pathway by inhalation of chlorine 

dioxide from treated ballast water exists. 

4.6 The persons with the greatest potential for primary exposure are Ecochlor technicians 

and, to a lesser extent, ships crew and/or other personnel. Chemical exposure will only occur in 

the event of a pipeline or storage tank failure, or an emergency situation in the same space where 

ship crew may be working. In this unlikely event, the most probable exposure route would be 

inhalation rather than direct exposure to skin and eye. 
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4.7 During routine system maintenance and chemical re-supply operations chlorine dioxide 

would not be generated. Thus, these operations will only involve potential exposure to Purate®

and/or sulfuric acid for Ecochlor technicians. 

4.8 The human exposure assessment (HES) submitted by the applicant identified that there is 

a potential risk of exposure to Purate®, sulfuric acid and chlorine dioxide by inhalation and direct 

exposure to skin and eye. Exposure risks are present during system maintenance and chemical 

re-supply operations, or during emergency situations involving the Ecochlor BWTS. According 

to the applicant, preventative maintenance will require approximately 6 hours per year and 

chemical re-supply operations will occur two - three times per year. 

4.9 The Group noted that the applicant, in order to address the identified risks, will 

implement risk mitigation measures namely the use of PPE consisting of eye protection 

(chemical goggles), and/or a face shield, along with chemical resistant clothing and gloves 

designed for use with Purate® and sulfuric acid. In addition, these operations are to be conducted 

in well-ventilated areas or with the use of appropriate engineering controls to prevent inhalation 

risks. In the event of an emergency situation where inhalation exposure may occur, respiratory 

protection devices would be added to the required PPE. 

4.10 In conclusion, and according to the information submitted for the HES 

and Human Health Risk Characterization, the Group considered that the unit operations where 

potential human exposure risks exist, e.g. maintenance and refilling operations, are limited in 

duration and frequency and risk mitigation measures were satisfactorily addressed by the 

applicant. As these operations are to be performed by the manufacturer’s own personnel, it may 

be anticipated that all appropriate risk mitigation measures will be fully considered and addressed 

in the technician training standard procedures. 

5 RISK TO SAFETY OF SHIP 

5.1 The Group noted that Ecochlor® BWTS is designed as a self contained module 

interconnected to the ship’s ballast water system by a side stream loop in the case where ballast 

water is used as motive water for the gas generation module or only by the delivery line/injection 

point for delivering the chlorine dioxide solution into the ballast water main. The connecting 

lines are fitted with valves that isolate the BWTS from the ship’s systems in case of an 

emergency. The applicant informs that the combination of failsafe measures in the 

programmable logic controller, that shut down the BWTS in the event of malfunction of the 

system and the isolation valves assure safe conditions during operation of this BWMS. 

The submission confirms that the system isolation valves provided have the appropriate 

approvals by the ship’s classification society and are constructed of materials appropriate for the 

application. 

5.2 The Group noted that corrosion studies with a limited number of test panels and for a period 

of approximately 30 days were carried out (Section 6.1.2.2 in MEPC 58/2/2). The original test 

reports were not provided and details about conditions (e.g. exposure time, ballast operations) 

during the test were therefore not available. 

5.3 A theoretical derivation of why no corrosion is expected was submitted in the confidential 

dossier. This was based on pH, salt and dissolved oxygen content of the seawater and biofouling, 

instead of ClO2. This was not considered to be relevant by the Group. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 8 

I:\MEPC\58\2-8.doc 

5.4 The Group considers that there may be an increased risk of corrosion arising in the ballast 

tanks and ballast water piping from the oxidizing properties of chlorine dioxide injected and 

chlorite produced. It is recommended that the applicant carries out appropriate corrosion tests 

with at least 3 months duration and provides these for Final Approval. 

5.5 The Group noted that the supplementary information provided by the applicant contained 

confirmation from a paint supplier that application of these Active Substances at the levels 

indicated in the dossier would not have a negative effect on coatings commonly used for ballast 

tank protection. 

5.6 The Group noted that the applicant had identified the following fire and explosion risks: 

.1 As a solution, Purate® is non-flammable and does not have explosive properties. 

Organic materials (i.e. wood, leather) that become contaminated with Purate® can 

ignite by a heat or friction source if they are allowed to dry. If evaporation 

of Purate® solution is allowed, solid sodium chlorate crystals could form. 

Solid sodium chlorate does not burn, but if exposed to fire it decomposes 

to give off oxygen, which can feed a fire. Decomposition of Purate® 

(in contact with certain metals or alkalis, or upon thermal decomposition) 

generates oxygen gas, and has the potential to increase explosion risk. 

.2 Sulfuric acid is non-flammable. Although sulfuric acid is not flammable or 

combustible and is not sensitive to static discharge, it is a strong oxidizing agent 

and is highly reactive. Concentrated sulfuric acid is capable of igniting 

combustible materials, and contact with water or strong bases can result in a 

strong exothermic reaction. Contact with common metals can evolve flammable 

and potentially explosive hydrogen gas. Sulfur oxides may be produced under fire 

conditions. 

.3 These risks are mitigated through proper training, system engineering, 

identification of a suitable location for the BWTS, the use of chemical storage 

tanks specifically designed for the chemicals they hold, and proper tank 

ventilation. Additionally, the space where the BWTS is located is kept clean and 

free of incompatible materials that can react with the precursor chemicals. 

Regular inspection and maintenance of the BWTS further reduce any potential 

risks. The mitigation measures and engineering controls in place for the precursor 

chemicals stored on board make the risks of fire and/or explosion extremely low. 

.4 Gaseous chlorine dioxide can present explosion hazards under specific conditions. 

In solution, chlorine dioxide is stable and does not present fire or explosion 

hazards. Additionally, chlorine dioxide is generated on demand, injected 

immediately, and never stored on board. Therefore, the risk of fire and/or 

explosion presented by the Active Substance is extremely low. 

5.7 The Group noted that Purate® and sulfuric acid require the use of incompatible fire 

fighting medium and therefore recommends that the Authority approving any installation of this 

system on board ships for further testing performs an appropriate risk evaluation to ensure that 

protection in the event of a fire situation is appropriate. It is recommended that any fire fighting 

and fire mitigation measures considered necessary for the safe installation of this ballast water 

management system are clearly specified in any submission for Final Approval. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 9 

I:\MEPC\58\2-8.doc 

5.8 Chemical storage 

5.8.1 The precursor chemicals (preparations) are the only BWTS chemicals stored on board at 

any time. The applicant reasons that although 78% sulfuric acid is IMDG Code classified, 

the BWTS is ship’s equipment and therefore the chemicals are consumables rather than 

dangerous cargo and so the provisions of the IMDG Code are not applicable. The Group 

recognizes this reasoning but, however, recommends that the stowage requirements stipulated in 

the IMDG Code for these chemicals are followed as far as is practicable when considering 

appropriate location of this BWTS. 

5.8.2 The Group noted that storage containers designed and engineered specifically for Purate®

and sulfuric acid are utilized with the Ecochlor® BWTS and therefore the risk of unintended 

release, contact with incompatible materials, or direct personnel chemical exposure is reduced. 

The applicant informs that to ensure proper chemical storage, temperature control device(s) can 

be installed if the BWTS is to be located in an area or on a ship where there is potential for 

temperature extremes. 

5.8.3 The Group recommends that a “worst case scenario” should be taken into account when 

assessing the need for risk mitigation measures related to the storage and use of the applied 

chemicals. This may be particularly relevant when assessing the need for temperature control 

devices. The Group further noted that the provision of appropriate chemical resistant save-all 

protection by way of the storage tanks and any other locations considered necessary to provide 

protection to the ship in the event of leakage or spillage of the chemicals used, is recommended 

in the safety data sheets provided and recommends that this requirement is followed. 

5.9 The Group noted that the applicant considers proper training and implementation of 

standard operating procedures as mitigation of the potential risks of chemical storage on board, 

and that chemical spill containment kits are to be kept on board for use in the event of spillage or 

leakage. The applicant states that the potential for unintended release of chemicals associated 

with the BWTS relates to storage tank failure, delivery pipe failure, and chemical re-supply 

operations and that the areas for potential release are limited to the areas where the storage tanks 

are located, where pipelines traverse, and where chemical re-supply operations take place. 

The Group noted that the safety data sheets stipulate the requirement for provision of shower and 

eye wash facilities near to the storage area for personnel use in the event of contact. It should be 

ensured that such facilities are provided in an accessible space adjacent to the storage 

arrangements. Furthermore, any enclosed space where this equipment is located should be 

provided with a mechanical extraction ventilation system as recommended in the safety data 

sheets provided. 

5.10 The Group further noted that a number of additional safety measures were included in the 

system. 
GESAMP-BWWG 7/9 

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Page 10 

I:\MEPC\58\2-8.doc 

6 ASSESSMENT OF PERSISTENCE (P), BIOACCUMULATION (B) AND 

TOXICITY (T) 

6.1 The products identified as Active Substances were assessed regarding their Persistence (P), 

Bioaccumulation potential (B) and their Toxicity (T). The assessment of these products is shown 

below: 

Criteria

Persistence (P) 

Half-life: 

>60 d in marine water, or 

>40 d in freshwater, or 

>180 d in marine 

 sediment 

>120 d in freshwater 

 sediment

Bioaccumulation (B) 

BCF >2,000 or Log 

Kow ≥3 

Toxicity (T) 

Chronic NOEC 

<0.01mg/L 

Chlorine 

dioxide 

3.9 min, 

clear freshwater at 5 m 

Criteria fulfilled - No 

-3.22 

Criteria fulfilled - No 

Lowest chronic 

NOEC = 0.09 mg/L 

Criteria fulfilled - No

Chlorite 

ion 

4 d in seawater 

Criteria fulfilled – No 

-7.17 

(as sodium chlorite) 

Criteria fulfilled - No 

Lowest chronic 

NOEC = 0.18 mg/L 

Criteria Fulfilled - 

No 

6.2 The Group noted that based on the data presented under 6.1, none of these chemicals 

should be considered as fulfilling the PBT criteria. 

7 ASSESSMENT OF TREATED BALLAST WATER 

7.1 The Group considered that the primary reaction product in ballast water after disinfection 

with chlorine-free chlorine dioxide, Ecochlor®, is chlorite ion (ClO2

-

), or sodium chlorite 

(NaClO2). Chlorite is considered as an additional Active Substance. Chemical analysis and 

known chemical principles of disinfection using chlorine dioxide that is generated in the 

chlorine-free method used with the Ecochlor® BWTS indicate that no other reaction by-products 

are present at environmentally relevant concentrations. However, biocide treatment of water can 

raise questions regarding the formation of THMs and/or HAAs. 

7.2 The Group noted that experiments to determine the concentrations of Active Substances 

and Relevant Chemicals (THM) were carried out on board the M/V Moku Pahu, San Francisco 

Bay Area (Richmond, CA) and yielded the following results:

Parameter 

Control Ballast 

Water 

Ballast Water 

Treated On 

board 

+ 3 Day 

13 Feb 2008 

Ballast Water 

Treated On 

board 

+ 5 Day 

15 Feb 2008 

PH 7.6 7.3 7.3 

FAC <0.05 mg/L <0.05 mg/L -- 

ClO2 -- <0.05 mg/L <0.05 mg/L 

ClO2

-

 <0.05 mg/L 0.91 mg/L 0.24 mg/L 

ClO3

-

 <0.10 mg/L 0.49 mg/L 0.49 mg/L 

Br - 50 mg/L -- -- 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 11 

I:\MEPC\58\2-8.doc 

Parameter 

Control Ballast 

Water 

Ballast Water 

Treated On 

board 

+ 3 Day 

13 Feb 2008 

Ballast Water 

Treated On 

board 

+ 5 Day 

15 Feb 2008 

BrO3

-

<0.02 mg/L -- <0.02 mg/L 

(+11 Day) 

SO4

-2

1902 mg/L -- 1826 mg/L 

(+ Day 8) 

THMs 

Bromodichloromethane 

Bromoform 

Chloroform 

Dibromochloromethane 

<1 μg/L 

<1 μg/L 

<1 μg/L 

<1 μg/L 

-- 

<1 μg/L 

<1 μg/L 

<1 μg/L 

<1 μg/L 

HAAs 

Dibromoacetic acid 

Dichloroacetic acid 

Bromoacetic acid 

Monochloroacetic acid 

Trichloroacetic acid 

<1 μg/L 

<1 μg/L 

<1 μg/L 

<1 μg/L 

<1 μg/L 

-- 

12 μg/L 

<1 μg/L 

<1 μg/L 

<1 μg/L 

<1 μg/L 

7.3 Assessment of treated ballast water was carried out with water samples collected 

immediately (within 1 hour) after chlorine dioxide treatment. Samples were packed in dark 

coolers with ice, and sent for express next day delivery to the laboratory. 

7.4 The Group considers the Level of Quantification (LOQ) for the THMs and HAAs used in 

the analyses of treated ballast water as too high. It is common to determine these contaminants in 

surface waters at levels of 0.01 – 0.05 μg/L. The potential levels may therefore be understated, 

but may as well remain within acceptable limits. It remains to be confirmed that the potential 

amount of by-products produced by the system is sufficiently low and meets the international 

standards on these substances. This uncertainty should be clarified and verified in additional 

analyses during the full scale testing on land and/or onboard ships. 

7.5 A full assessment of the degradation and half-life for chlorite and chlorate ions is 

required for FA. 

7.6 The Group noted that a number of ecotoxicity tests of treated ballast water were provided 

in the dossier. For toxicity testing on treated ballast water from shipboard studies (data presented 

in Tables T2.9 and T2.10 of MEPC 58/2/2), the ballast water remained in the ballast tanks until 

samples were collected 5 days after treatment. Water samples were then stored in the dark, in 

coolers at 4oC while onboard the ship. For delivery to the laboratory, the samples were packed 

on ice in coolers and shipped express for next day delivery. However, the documentation 

contained no information about water qualities such as content of organic matter in the test water. 

A full evaluation of the remaining ecotoxicity in treated ballast water at varying holding time in 

ballast water tanks should be provided in the application for Final Approval. 
GESAMP-BWWG 7/9 

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I:\MEPC\58\2-8.doc 

8 ENVIRONMENTAL RISK ASSESSMENT 

8.1 Derivation of Predicted No Effect Concentrations (PNEC) 

8.1.1 For chlorine dioxide, a PNEC for the aquatic environment can be derived from aquatic 

toxicity data provided in the summary of the proposal as well as in the documentation. 

The lowest reported acute aquatic toxicity for freshwater organisms was reported for juvenile 

fathead minnows (Pimephales promelas) with a LC50 = 0.02 mg/L. For marine species, the 

lowest reported acute aquatic toxicity was for brine shrimp (Artemia) with a LC70 = 0.047 mg/L 

and a NOEC = 0.024 mg/L. The Group noted that the effect concentrations reported in the 

summary of the proposal for tests conducted by Nautilus Environmental (2005, 2006) showing 

higher acute and chronic effect concentrations were based on measured concentrations of 

chlorine dioxide at the start of the exposure periods. Considering the rapid breakdown of chlorine 

dioxide, these values might underestimate the aquatic toxicity of chlorine dioxide. Consequently, 

the lowest reliable toxicity data to be used for derivation of a PNEC are the above mentioned 

acute toxicity data. Applying an application factor of 1000 leads to PNEC = 0.02-0.05 μg/L. 

8.1.2 For chlorite, the lowest reported acute toxicity data for freshwater species are 0.022 mg/L 

for Ceriodaphnia dubia and 0.0146-1.4 mg/L for Daphnia magna. The lowest reported 

toxicity data for marine species are for Mysidopsis bahia with LC50 = 0.576 mg/L and 

a NOEC = 0.18 mg/L for 7-day growth. The latter test is not considered a chronic test. Applying 

an application factor of 1000 leads to PNEC = 0.6 μg/L. 

8.1.3 In a toxicity testing of two samples of treated ballast water, the lowest acute LC50 

was 37.7% (v/v) for Mysidopsis bahia and the lowest chronic EC50 was >81% (v/v) 

for Mytilus sp. Chlorite was measured in the two samples to 0.41 and 2.35 mg/L. By calculation, 

these values compare well with the chlorite ion toxicity observed for M. bahia. Considering 

the PNEC derived for chlorite ions at 0.6 μg/L, a dilution of the ballast water at discharge 

of 680-3,900 times will be needed to avoid long-term risks to aquatic organisms. 

8.2 Calculation of the Predicted Environmental Concentration (PEC) for the 

Active Substance and Relevant Chemicals 

8.2.1 The Group noted that the ballast water treated with 5.0 mg/L of chlorine dioxide 

contained chlorite ion concentrations ranging from <0.1 to 2.37 mg/L. Therefore, the PEC for 

chlorite ion in treated ballast water is <0.1 - 2.37 mg/L. This range is a result of the varied 

chlorite ion demand of different waters and factors such as organic load, pH and temperature that 

affect the decay rate. 

8.2.2 The applicant did not apply any model to predict environmental concentrations. However, 

a dilution factor of 100 could be applied corresponding to the recommended value for estimating 

dilution of discharges to the marine environment in the EU Technical Guidance document for 

risk assessment. 

8.2.3 Further the Group noted that the PEC for chlorine dioxide is 0 mg/L, as the ballast water 

treated with Ecochlor® BWTS had concentrations of chlorine dioxide <0.05 at the time of 

discharge. 

8.2.4 The Group noted that the PEC for the chlorite ion in the worst case could be estimated 

to be 24 μg/L. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 13 

I:\MEPC\58\2-8.doc 

8.3 Calculation of PEC/PNEC ratios 

8.3.1 The Group noted that for chlorine dioxide, it was not relevant to consider 

a PEC/PNEC ratio. 

8.3.2 For chlorite, the estimated PEC/PNEC ratio based on the available assumptions is 

estimated to be approximately 40. Thus, a risk to the local aquatic environment may be 

anticipated. 

8.3.3 The applicant states that a situation where the PEC/PNEC ratio is >1 at discharge is 

not anticipated. However, this cannot be substantiated from the information provided in the 

application documentation. 

9 CONCLUSIONS AND RECOMMENDATIONS 

9.1 Risks to the safety of the ship

Provided the risks identified in section 5 are mitigated by the implementation of appropriate risk 

mitigation measures the Group considers that the risks that can be foreseen as inherent to this 

system should be acceptable so as to allow further testing and development. All risk mitigation 

measures required for the safe use of this system should be detailed in any application 

for Final Approval. 

9.2 Risks to the crew and general public 

According to the information submitted in the HES and Human Health Risk Characterization, 

the Group is able to conclude that the operations where potential human exposure risks exist, 

e.g. maintenance and refilling operations, are limited in duration and frequency and the 

concerned risk mitigation measures were satisfactorily addressed by the applicant. As these 

operations are to be performed by the manufacturer’s own personnel, it may be anticipated that 

all appropriate risk mitigation measures will be fully considered and addressed in the technician 

training standard procedures. 

9.3 Risks to the environment

Based on the available information, the Group considers that the Active Substance chlorine 

dioxide degrades very quickly after application and will not be present in treated ballast water at 

discharge. The reaction product, the chlorite ion, will however normally be present in the treated 

ballast water at discharge. The chlorite ion is probably the main toxic component in treated 

ballast water. 

The applicant did not derive a PNEC for chlorite ion and neither did he estimate the PEC for 

relevant scenarios. Based on the information available, the Group conducted a preliminary risk 

assessment, which showed a possible risk to the aquatic environment after discharge of ballast 

water applying Ecochlor BWTS. 

The Group recommends that in a possible application for Final Approval, the database for 

deriving the PNEC for chlorite should be improved and that PECs should be estimated for 

relevant scenarios in order to better assess the possible risks to the aquatic environment. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 14 

I:\MEPC\58\2-8.doc 

9.4 Conclusion and recommendation

Based on the information submitted by the applicant, the Group recommends that MEPC 

grant Basic Approval to the Ecochlor Ballast Water Treatment System. 

* * * 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 15 

I:\MEPC\58\2-8.doc 

APPENDIX 1 

PHYSICOCHEMICAL AND BIOLOGICAL PROPERTIES OF PURATE, SULFURIC ACID, 

CHLORINE DIOXIDE, SULFATE AND SODIUM CHLORITE 

1 CHEMICAL IDENTIFICATION

1.1 The Group recognized that Purate and sulfuric acid were preparations which generate 

chlorine dioxide as Active Substance. Sulfate and chlorite ions are Relevant Chemicals. 

2 EFFECTS ON AQUATIC ORGANISMS 

2.1 Acute aquatic toxicity 

Information on acute toxicity to aquatic organisms is summarized below. The Group noted that 

only some of this information was included in the summary of the proposal for basic approval, 

and that further information was provided in the confidential documentation. 

Test 

Substance 

F 

C

A

Species Test Type EC50 

mg/L 

NOEC 

mg/L 

Reference/ 

comments 

Preparations 

1. Purate® -- -- -- -- 

See 

Section 2.0.1.1 

for justification 

of not providing 

data 

2. Sulfuric 

 acid 

-- -- -- -- 

See 

Section 2.0.3.1 

for justification 

of not providing 

data 

Active Substance 

F Menidia beryllina 96 hr 

survivala >0.4 0.4 Nautilus Env. 

2005 

F Clupea payáis 96 hr 

survival 0.35 0.22 Nautilus Env. 2005 

F Pimephales promelas

(juvenile) 

96 hr 

survival 0.02 Wilde et al. 1983 

C Mysidopsis bahia 48 hr 

survivala 0.4 0.14 Nautilus Env. 

2005 

C Artemia salina

(nauplii) (EC70) 0.047 0.024 Puente et al.

1992 

A Skeletonema 

costatum 

96 hr 

growth 3.09 - Nautilus Env. 

2006 

1. Chlorine 

 dioxide 

A Macrocystis pyrifera 48 hr 

germination 0.20 0.14 Nautilus Env. 2006 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 16 

I:\MEPC\58\2-8.doc 

Test 

Substance 

F 

C

A

Species Test Type EC50 

mg/L 

NOEC 

mg/L 

Reference/ 

comments 

Relevant Chemicals 

F Cyprinidon 

variegatus 

96 hr 

survival 75.0 13.9 Env. Sci. Eng. 1994b 

C Mysidopsis bahia 96 hr 

survival 0.58 NR Env. Sci. Eng. 

1994a 

C Ceriodaphnia dubia NR 0.022 NR Cited in Nautilus 

Env. 2007 

C Daphnia magna NR 0.0146

-1.4 NR Cited in Nautilus 

Env. 2007 

A Selenastrum 

capricornutum 

96 hr 

growth 0.8 Wijk et al. 1998 

2. Chlorite 

 Ion 

(Sodium 

chlorite) 

A Macrocystis pyrifera 48 hr germ. >15.4 15.4 Nautilus Env. 

2007 

Treated Ballast Water 

C Mysidopsis bahia 48 hr 

survival 38.7% 25% Nautilus Env. 

5.0 mg/L 2006 

dose of ClO2 C Mysidopsis bahia 48 hr 

survival 37.7% 25% Nautilus Env. 2006 

 F = Fish, C = Crustacean, A = Algae, NR = Not Reported. 

 a Calculated on the basis of data from the chronic toxicity test with this species. 

 b Reported NOEC is highly conservative because the next concentration tested was 10-times higher 

 (see discussion in section 2.1.2.1). 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 17 

I:\MEPC\58\2-8.doc 

2.2 Chronic aquatic toxicity 

Test 

Substance 

F 

C 

A 

M 

Species Test Type EC50 

mg/L 

NOEC 

mg/L 

Reference/ 

Comments 

Preparations 

1. Purate® -- -- -- -- 

See section 2.0.1.1 for 

justification of not 

providing data 

2. Sulfuric 

 acid 

-- -- -- -- 

See section 2.0.3.1 for 

justification of not 

providing data 

Active Substance 

F Menidia beryllina 7 d 

surv/growth >0.4 0.4 Nautilus Env. 2005 

F Clupea pallasi 18 d embryo 

development >0.33 0.33 Nautilus Env. 2005 

C Mysidopsis bahia 7 d 

surv/growth ~ 0.4 0.04a

 Nautilus Env. 2005 

A Macrocystis pyrifera 48 hr 

germination 0.20 0.14 Nautilus Env. 2006 

A Skeletonema costatum 96 hr growth - 2.09 Nautilus Env. 2006 

Chlorine 

dioxide 

M Mytilus edulis 48 hr 

development 0.22 0.09 Nautilus Env. 2005 

Relevant Chemicals 

1. Sulfate 

 ion/sulfuric 

 acid 

-- -- -- -- 

See section 2.0.3.1 for 

justification of not 

providing data 

F Atherinops affinis 7 d 

surv/growth >13.8 6.9 Nautilus Env. 2007 

C Mysidopsis bahia 7 d 

surv/growth 0.25 0.18 Nautilus Env. 2007 

A Macrocystis pyrifera 48 hr germ. >15.4 15.4 Nautilus Env. 2007 

E Strongylocentrotus 

purpuratus 

Development

 10.4 5.0 Nautilus Env. 2007 

2. Chlorite 

 ion 

 (sodium 

 chlorite) 

M Crassostrea virginica Development

 21.4 14.3 Env. Sci. Eng. 1994c 

Treated Ballast Water 

M Mytilus sp. Development

 

>81% 81% Nautilus Env. 2006 

M Mytilus sp. Development >84% 84% Nautilus Env. 2006 

C Mysidopsis bahia 48 hr survival -- 12%b

 Nautilus Env. 2006 

5.0 mg/L 

dose of ClO2

C Mysidopsis bahia 48 hr survival -- 11.7%b

 Nautilus Env. 2006 

 F = Fish, C = Crustacean, A = Algae , M = Mollusk, E = Echinoderm 

 a

 Reported NOEC is highly conservative because the next concentration (NOEC) tested 

 was 10-times higher. 

 b

 Chronic NOEC calculated using acute-to-chronic ratio of 3.22. 
GESAMP-BWWG 7/9 

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Page 18 

I:\MEPC\58\2-8.doc 

2.3 Information on Endocrine Disruption 

Substance Information on Endocrine Disruption

Preparation Chemicals 

1. Purate® 

 a. Hydrogen peroxide 

 b. Sodium chlorate 

a. Physical and chemical properties present 

no evidence to suggest endocrine disruption. 

b. Physical and chemical properties present 

no evidence to suggest endocrine disruption. 

2. Sulfuric acid Physical and chemical properties present no 

evidence to suggest endocrine disruption. 

Active Substance in Ballast Water 

Chlorine dioxide Physical and chemical properties present no 

evidence to suggest endocrine disruption. 

Relevant Chemicals in Ballast Water 

1. Sulfate ion 

 (as sodium sulfate or sulfuric acid) 

Physical and chemical properties present no 

evidence to suggest endocrine disruption. 

2. Sodium chlorite 

 (as chlorite ion) 

Physical and chemical properties present no 

evidence to suggest endocrine disruption. 

2.4 Sediment toxicity/bioavailability/biomagnification/bioconcentration/foodweb-population 

effects 

2.4.1 Sediment toxicity

Substance Information on Sediment Toxicity

Preparation Chemicals 

1. Purate®

 a. Hydrogen peroxide 

 b. Sodium chlorate 

a. Physical and chemical properties present no 

evidence to suggest accumulation in sediment. 

See sections 2.1.4 and 2.4. 

b. Physical and chemical properties present no 

evidence to suggest accumulation in sediment. 

2. Sulfuric acid Physical and chemical properties present no 

evidence to suggest accumulation in sediment. 

Active Substance in Ballast Water 

Chlorine dioxide Physical and chemical properties present no 

evidence to suggest accumulation in sediment. 

Relevant Chemicals in Ballast Water 

1. Sulfate ion 

 (as sodium sulfate or sulfuric acid) 

Physical and chemical properties present no 

evidence to suggest accumulation in sediment. 

2. Sodium chlorite 

 (as chlorite ion) 

Physical and chemical properties present no 

evidence to suggest accumulation in sediment. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 19 

I:\MEPC\58\2-8.doc 

2.4.2 Bioavailability, Biomagnification, Bioconcentration/Food Web Effects 

Substance Log Kow

Bioaccumulation 

BCF >2,000 

Cause for 

concern? 

(yes/no) 

Comments

Chlorine 

dioxide -3.22 No available data No 

Chlorite ion 

-7.17 

(as sodium 

chlorite) 

No available data No 

Neither chemical would be 

expected to bioaccumulate 

or persist in the food web. 

Justification for not supplying data 

Purate® 

Not Relevant – chlorine dioxide and chlorite are the only constituents 

potentially present in treated ballast water that will be discharged to the 

environment. 

Sulfuric acid 

Not Relevant – chlorine dioxide and chlorite are the only constituents 

potentially present in treated ballast water that will be discharged to the 

environment. 

3 MAMMALIAN TOXICITY

3.1 Acute mammalian toxicity 

Test Substance Exposure Route Species Value range Reference/ 

comments

Preparations 

 

Purate® 

Sodium chlorate 

a. Acute Oral 

 LD50 

b. Inhalation 

 LC50 

a. Rat 

b. Rat 

a. >5000 mg/kg 

b. 5.6 mg/L/4hr 

Purate® MSDS, Eka 

Chemicals 

Hydrogen 

peroxide 

 (10%) 

a. Acute Oral 

 LD50 

b. Inhalation 

 LC50 

a. Rat 

b. Rat 

a.1500 - >5000 

 mg/kg 

b. 122 mg/L/4hr 

Purate® MSDS, Eka 

Chemicals 

Sulfuric acid 

a. Acute Oral 

 LD50 

b. Inhalation 

 LC50 

a. Rat 

b. Rat 

a. 2140 mg/kg 

b. 0.375 

 mg/L/4hr 

OECD SIDS SIAR, 

SIAM 11 (January 

2001), UNEP 

Publications 

Active Substance 

Chlorine 

dioxide 

a. Acute Oral 

 LD50 

 (EPA OPPTS 

 Method 

 870.1100) 

b. Inhalation 

 (nose) LC50 

a. Rat 

b. Rat 

a. 292 mg/kg 

 (males) 

 340 mg/kg 

 (females) 

b. 32 mg/L 

 (90 mg/m3

) 

a. USEPA RED for 

chlorine dioxide and 

sodium chlorite 

b. Schorsch (1995) 

cited in IPCS 

chlorine dioxide 

(Gas) 2002) 

CICADS 37. 
GESAMP-BWWG 7/9 

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Page 20 

I:\MEPC\58\2-8.doc 

3.1.1 Sodium chlorate and hydrogen peroxide are classified under GHS as acute tox 4 via the oral 

route, in addition, chlorine dioxide is toxic if swallowed (acute tox 3), whereas hydrogen peroxide is 

harmful if inhaled (acute tox 4) (GHS classification, Annex VI, COM (2007) 355 final). According 

to the OECD SIDS for sulfuric acid, the LC50 values observed in acute inhalation studies are all 

low and most likely due to the corrosive/irritant effect of the substance. 

3.2 Corrosion/irritation 

Test Substance Skin Eye Sensitization Reference/ 

Comments

Preparations 

 

Purate® 

Sodium 

chlorate 

Not irritating to 

rabbits 

Mildly irritating 

to rabbits 

Not 

sensitizing to 

guinea pigs. 

Purate®

MSDS, Eka 

Chemicals 

Hydrogen 

peroxide 

At concentrations 

<35%, not a skin 

irritant 

Highly corrosive/ 

irritating at 

concentrations 

>8 % 

Not 

sensitizing to 

guinea pigs at 

6% 

concentration 

Purate®

MSDS, Eka 

Chemicals 

Sulfuric acid 

Severely 

irritating to 

contaminated 

tissue 

Severe irritant Not known to 

be a sensitizer 

Sulfuric acid 

MSDS, 

Basic 

Chemical 

Solutions 

Active Substance 

Chlorine dioxide Irritant Strong irritant Not located 

Chlorine 

dioxide 

MSDS, Eka 

Chemicals 

3.2.1 Hydrogen peroxide, sulfuric acid and chlorine dioxide are all classified under GHS as 

corrosive (categories 1A for hydrogen peroxide and sulfuric acid, category 1B for chlorine dioxide) 

(GHS classification, Annex VI, COM (2007) 355 final). 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 21 

I:\MEPC\58\2-8.doc 

3.3 Sensitization 

 n.d. 

3.4 Repeated Dose Toxicity 

Test Substance Exposure 

Route Species Value range Reference/ comments

Preparations 

 

Purate® 

Sodium 

chlorate 

a. Oral, 90- d 

subchronic 

b. Oral, 90- d 

subchronic 

a. Rodent 

b. Dog 

a. NOAEL 100 mg/kg/ d 

b. NOAEL 360 mg/kg/ d 

EKA Study 86-

3112 EPA 

Guideline 82-1 

(1987) EKA 

Study 863114 

EPA Guideline 

82-1 (1987) 

Hydrogen 

peroxide 

(10%) 

a. Oral, 90- d 

subchronic 

b. Oral, 90- d 

subchronic 

a. Rodent 

b. Other 

mammal 

a. NOEL 30-56.2 mg/kg 

b. Not located 

Ito et al. 1976 

and Kawasaki 

et al., 1969, 

cited by SCCP 

Sulfuric acid 

28 d, 

inhalation 

(nose only) 

Rat NOEL/NOAEL not 

identified 

 OECD SIDS 

SIAR, SIAM 

11 (January 

2001), UNEP 

Publications 

Active Substance 

Chlorine 

dioxide 

a. Inhalation, 

60 d 

b. Oral, 90- d 

subchronic 

a. Rat 

b. Rat 

a. LOAEL – 1 mg/L 

(2.8 mg/m3

) 

b. 2-15 mg/kg in drinking 

water.No treatment related 

deaths, clinical signs or 

effects on hematology, 

clinical chemistry or organ 

weights. Dose-related 

decrease in water 

consumption and food 

consumption in high dose 

only. Nasal cavity was 

identified as the target tissue 

with hyperplasia, squamous 

metaplasia and inflammatory 

responses 

USEPA Tox. 

Review of 

Chlorine 

dioxide and 

chlorite, 2000 

Daniel, 1990, 

cited in IPCS 

Chlorine 

dioxide (Gas) 

2002) 

CICADS 37. 

3.4.1 According to the presented and existing data there seems to be a concentrationdependent development of thyroid lesions in rodents exposed to sodium chlorate in drinking 

water. The relevance of these findings to human exposure needs to be elucidated 

(Toxicologic Pathology, 2001). Most of the potential adverse effects are associated with blood 

oxidation (i.e. EPA study, 1987). 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 22 

I:\MEPC\58\2-8.doc 

3.4.2 According to the presented data, there seemed to be relevant toxicological concerns 

towards repeated exposure to hydrogen peroxide. This is also confirmed in the RAR on 

hydrogen peroxide. 

3.4.3 In numerous repeated inhalation studies with sulfuric acid aerosol, toxicity was confined 

to changes in the structure and function of the respiratory tract, suggesting that it has a local 

effect and no systemic effects (OECD SIDS). 

3.4.4 According to the presented data subchronic studies with chlorine dioxide suggest the 

same kind of findings as with sulfuric acid (local inflammatory response rather than systemic 

effects). 

3.5 Chronic and long-term toxicity 

3.5.1 The Group noted that there are no data presented with regards to chronic and long-term 

toxicity. 

3.6 Developmental and Reproductive Toxicity 

Test Substance Exposure 

Route Species Value range Reference/ Comments

Preparations 

 

Purate® 

Sodium chlorate 

Oral, 1,000 

mg/kg d, 

6-15 d 

gestation 

Rat Not teratogenic 

Purate®

MSDS, Eka 

Chemicals 

Hydrogen peroxide -- -- 

Sufficient data 

not available 

Purate®

MSDS, Eka 

Chemicals 

Sulfuric acid -- -- 

Not reported or 

expected to 

cause 

teratogenic or 

reproductive 

toxicity. 

OECD 

SIDS SIAR, 

SIAM 11 

(January 

2001), 

UNEP 

Publications 

Active Substance 

 

Chlorine dioxide 

a. Gavage, 

(0, 2.5, 5.0 

or 10 mg/kg 

doses in water, 

prior to and 

during mating) 

Rat NOAEL: 10 

mg/kg- d 

USEPA 

Tox. 

Review of 

chlorine 

dioxide and 

chlorite, 

2000 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 23 

I:\MEPC\58\2-8.doc 

3.6.1 According to the presented data (MSDS), sodium chlorate is not teratogenic. 

3.6.2 According to existing data ((RAR, hydrogen peroxide), there are no appropriate animal 

studies available for a complete evaluation of reproductive and developmental toxicity. 

Two limited studies with mice and rats exposed to hydrogen peroxide in drinking 

water suggested no grave disturbances on the male or female reproductive functions 

(Wales et al., 1959, Hankin, 1958). With regards to developmental toxicity a decision was reached on 

the presumption that conventional study protocols (e.g., administration in drinking water) were 

unlikely to show specific embryonal or foetal effects, firstly, because it is doubtful whether 

hydrogen peroxide (as opposed to its degradation products oxygen and water) would reach the 

foetus and, secondly, because local effects in the mother possibly causing nutritional disturbances 

and general toxicity, are expected. 

3.6.3 Since sulfuric acid is a direct-acting toxicant, and since it is not likely that it will reach the 

reproductive organs, reproductive effects in mammals are not likely to occur following exposure 

to sulfuric acid by any route. In a developmental toxicity/teratogenicity study conducted by 

inhalation with sulfuric acid aerosol, the NOAEL for maternal toxicity appears to be 20 mg/m3

 in 

mice and rabbits. No evidence of foetotoxicity or teratogenicity was seen in either species 

(OECD, SIDS). 

3.6.4 In the USEPA Tox review of chlorine dioxide there is a reference to a developmental 

study on rats. In this study, a NOAEL of 20 mg/L was established based on decreased 

exploratory and locomotor activities in the offspring. Chlorine dioxide has been shown to impair 

neurobehavioural and neurological development in rats exposed perinatally. Significant 

depression of thyroid hormones has also been observed in rats and monkeys exposed to it in 

drinking-water studies. A guideline value has not been established for chlorine dioxide because 

of its rapid hydrolysis to chlorite and because the chlorite provisional guideline value is 

adequately protective for potential toxicity from chlorine dioxide. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 24 

I:\MEPC\58\2-8.doc 

3.7 Carcinogenicity, Mutagenicity/Genotoxicity 

Test Substance Exposure 

Route Species Value range Reference/ Comments

Preparations 

Purate® 

Sodium 

chlorate -- -- Not considered to be 

carcinogenic or mutagenic. 

Purate® MSDS, 

Eka Chemicals 

Hydrogen 

peroxide -- -- 

Mutagenicity, in vitro: 

mutagenic without 

metabolic activation, not 

mutagenic with metabolic 

activation. In vivo: no 

mutagenic effect after oral 

administration. 

Carcinogenicity: animal 

experiments do not show 

clear evident in different 

species. 

Purate® MSDS, 

Eka Chemicals 

Sulfuric acid - - Not considered 

carcinogenic or mutagenic. 

Sulfuric acid 

MSDS, Basic 

Chemical 

Solutions 

Active Substance 

Chlorine dioxide -- -- 

Carcinogenicity: Sufficient 

data not available. 

Genotoxicity: both positive 

and negative results. See 

Section 2.2.6 of dossier. 

USEPA RED 

for chlorine 

dioxide and 

sodium chlorite; 

USEPA Tox. 

Review of 

chlorine dioxide 

and chlorite, 

2000 

3.7.1 According to the presented data (MSDS) sodium chlorate is not mutagenic or 

carcinogenic. 

3.7.2 According to existing data ((RAR, hydrogen peroxide) it can be concluded that the 

special nature of demonstrated carcinogenicity of hydrogen peroxide, and the overall evidence 

available, cast some doubt on whether hydrogen peroxide should be regarded as a carcinogen of 

practical significance. The weak effect found in complete carcinogenesis studies in mice as well 

as in some promotion studies suggest promotion type of activity and possible underlying 

genotoxic mechanisms. Given the fact that mammalian cells have of necessity built defenses 

against reactive oxygen species arising in endogenous metabolism, the injuries caused by 

hydrogen peroxide may well be non-stochastic, i.e. have a dose/dose rate threshold. 

This evidence, however, is not sufficient to trigger classification. 

According to a conclusion in existing literature (RAR on hydrogen peroxide) hydrogen peroxide 

is a mutagen and genotoxicant in a variety of in vitro test systems. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 25 

I:\MEPC\58\2-8.doc 

3.7.3 According to the presented data (OECD, SIDS), sulfuric acid has been shown to be 

without effect in genetic toxicity studies in vitro (bacterial test). It has been shown to cause 

chromosomal aberrations in a non-bacterial test in vitro. The chromosomal effects are well 

known to be a consequence of reduced pH, being seen using any strong acid. There are no in vivo 

mutagenicity studies available. 

No carcinogenic effect was observed in carcinogenicity studies conducted by inhalation with 

sulfuric acid aerosol using 3 different animal species. Small increases in tumor incidence were 

reported in rats and mice after chronic gastric intubation or intratracheal instillation of sulfuric 

acid solution, but no clear conclusion can be drawn from these studies. 

IARC has concluded that “occupational exposure” to strong inorganic mists containing 

sulfuric acid is carcinogenic for humans (Group 1). Concerns have been raised that confounding 

factors could not be fully excluded. 

3.7.4 From USEPA RED for chlorine dioxide: Chlorine dioxide has not been assessed for its 

carcinogenic potential. The available dermal carcinogenicity studies do not definitely 

characterize the carcinogenicity of chlorine dioxide. One subchronic rat study examined the 

effects of administration of chlorine dioxide at dose levels of 0, 25, 50, 100 or 200 mg/L 

for 90 days in drinking water. In this subchronic rat study a significant increase in the incidence 

of nasal lesions was found at all dose levels tested. The significance of these findings is 

uncertain, as they have not been observed in other long-term studies of chlorine dioxide. 

3.7.5 Data on the mutagenicity of chlorine dioxide indicate that negative effects were reported 

in one study from a 400-fold drinking water concentrate of chlorine dioxide, whereas a 4000-fold 

concentrate was mutagenic only in the absence of metabolic activation. In another study, chlorine 

dioxide was positive for forward mutations under non-activated conditions. Chlorine dioxide was 

positive for structural chromosomal aberrations under non-activated and activated conditions and 

was negative for increased transformed foci up to cytotoxic levels. In one mouse study on 

chlorine dioxide, in vivo micronucleus and bone marrow chromosomal assays were negative as 

was a sperm-head abnormality assay. 

4 ENVIRONMENTAL FATE AND EFFECT UNDER AEROBIC AND ANAEROBIC 

CONDITIONS 

4.1 Environmental fate 

Test Substance Test Reason for not supplying the data

Active Substance 

Chlorine dioxide Hydrolysis at 

pH 5, 7, 9; 

Chlorine dioxide does not hydrolyze to 

an appreciable extent; remains in 

solution as a dissolved gas. See 

Section 2.3.1. Degradation is through 

oxidative reactions. 

Chlorite ion 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 26 

I:\MEPC\58\2-8.doc 

4.2 Partition Coefficients 

Test Substance Log Kow Reference/Comments

Active Substance 

Chlorine dioxide -3.22 

USEPA Reregistration Eligibility Decision 

(RED) for Chlorine dioxide and sodium 

chlorite (Case 4023), August 2006 

Chlorite ion 

-7.17 

(as sodium 

chlorite) 

USEPA Reregistration Eligibility Decision 

(RED) for Chlorine dioxide and sodium 

chlorite (Case 4023), August 2006 

4.3 Persistence and Identification of Main Metabolites 

Test Substance Test Reason for not supplying the data

Active Substance 

Chlorine dioxide -- 

Physical and chemical properties 

(highly soluble, inorganic, decay behaviour) 

do not indicate persistence. 

Chloride is the primary urinary metabolite 

(see section 2.2.8). 

Chlorite ion -- 

Physical and chemical properties 

(highly soluble, inorganic, decay behaviour) 

do not indicate persistence. 

Chloride is the primary urinary metabolite 

(see section 2.2.8). 

4.4 Reaction with Organic Matter 

Test 

Substance

Discussion of the reaction, including 

formation of hazardous byproducts Reference/Comments 

Active Substance 

Chlorine 

dioxide 

Chlorine dioxide is an oxidizing agent. 

Chlorine dioxide does not chlorinate 

organic matter, thus its use does not 

promote the formation of trihalomethanes 

(THMs). The primary product of chlorine 

dioxide reduction is chlorite ion. 

USEPA Office of 

Water, 

http://www.epa.gov/ 

safewater/ 

mdbp/pdf/alter/ 

chapt_4.pdf 

Chlorite ion 

The reaction of chlorite ion with organic 

matter does not produce harmful organic 

chemical species and typically results in a 

chemical reduction of chlorite ion to 

chloride ion, which is ubiquitous in the 

marine environment. Therefore, the 

production of harmful organic byproducts is not anticipated. 

Review of the 

Environmental Fate 

and Effects of 

Chlorine dioxide and 

chlorite, Nautilus 

Environmental, 2007 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 27 

I:\MEPC\58\2-8.doc 

4.5 Potential Physical Effects on Wildlife and Benthic Habitats 

Test 

Substance Physical Description Discussion of Potential Effects

Reference/ 

Comments

Preparations 

Purate®

Purate® is an aqueous solution 

with water-like viscosity. 

Purate® is non-organic and the 

sodium chlorate and hydrogen 

peroxide components of Purate®

are both soluble in water. 

Based on the 

chemical properties 

in Table T2-10, 

Purate® is not 

expected to 

accumulate in 

sediments, form 

surface slicks or 

deposit on the 

seabed. 

Compared 

physical and 

chemical 

properties to 

criteria used in 

GESAMP 

Reports and 

Studies 

No.64. 

Sulfuric 

acid 

Sulfuric acid is a clear, dense, 

odorless liquid. Sulfuric acid is 

miscible and completely ionizes 

in water. 

Based on the 

chemical properties 

in Table T2-10, 

sulfuric acid is not 

expected to 

accumulate in 

sediments, form 

surface slicks or 

deposit on the 

seabed. 

Compared 

physical and 

chemical 

properties to 

criteria used in 

GESAMP 

Reports and 

Studies 

No.64. 

Active Substance 

Chlorine 

dioxide 

When dissolved in water, 

chlorine dioxide generated with 

the Ecochlor® BWTS forms a 

pale green solution. The solution 

has a viscosity and solubility 

similar to water and an odor 

similar to chlorine. 

Based on the 

chemical properties 

in Table T2-10, 

chlorine dioxide is 

not expected to 

accumulate in 

sediments, form 

surface slicks or 

deposit on the 

seabed. 

Compared 

physical and 

chemical 

properties to 

criteria used in 

GESAMP 

Reports and 

Studies 

No.64. 

Chlorite 

ion 

The chlorite ion present in 

treated ballast water is 

completely soluble, and has a 

viscosity similar to the treated 

water. At the low concentration 

present in treated water chlorite 

will not have an identifiable 

color or odor. 

Based on the 

chemical 

properties in Table 

T2-10, chlorite is 

not expected to 

accumulate in 

sediments, form 

surface slicks or 

deposit on the 

seabed. 

Compared 

physical and 

chemical 

properties to 

criteria used in 

GESAMP 

Reports and 

Studies 

No.64. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 28 

I:\MEPC\58\2-8.doc 

Treated Ballast Water 

Treated 

Ballast 

Water 

The properties of the treated 

water are generally unaffected 

by chorine dioxide treatment. pH 

ranges from 6.7 to 7.6. 

Based on the 

chemical properties 

in Table T2-10, 

treated ballast water 

is not expected to 

have an effect on 

marine sediments, 

form surface slicks 

or deposits on the 

seabed. 

Compared 

physical and 

chemical 

properties to 

criteria used in 

GESAMP 

Reports and 

Studies 

No. 64. 

4.6 Potential Residues in Seafood 

Substances Discussion

Purate®, Sulfuric acid , 

Chlorine dioxide, chlorite 

Ion, Treated Ballast Water 

Physical and chemical properties (highly soluble, 

inorganic, and/or decay behavior) of all substances used 

with the Ecochlor® BWTS or created by the treatment 

process to not indicate the potential for residues in 

seafood. 

4.7 Any Known Interactive Effects 

Substances Discussion

Purate®, sulfuric acid , 

Chlorine dioxide, chlorite 

Ion, Treated Ballast Water 

There are no other known or anticipated interactive 

effects expected with any substance involved with the 

Ecochlor® BWTS process. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 29 

I:\MEPC\58\2-8.doc 

5 PHYSICAL AND CHEMICAL PROPERTIES: PREPARATIONS, ACTIVE 

SUBSTANCE, RELEVANT CHEMICALS AND TREATED BALLAST WATER 

Physical/Chemical 

Property 

(with units & 

reference) 

Preparations 

 1. Purate® 

 2. Sulfuric acid 

 (78% by weight)

Active 

Substance 

Chlorine dioxide 

(solution)

Relevant 

Chemical 

Sodium chlorite

Treated 

Ballast 

Water 

Melting point (oC) 1. -29 

2. -11.3 

Same as water 

(0oC) 

 

Boiling point (oC) 1. 111 

2. 193 

Same as water 

(100oC) 

 

Flammability 

(flash point for 

liquids; oC) 

1. Non flammablea 

2. Non flammable 

Not applicable 

Density 

(20oC; kg/m3

) 

1. 1370 ca. 

2. 1708 

1000 - 1035 ca 

(for dilute sol’n 

in seawater) 

 

Vapor pressure 1. 6700 Pa (40oC, 

40% sodium 

chlorate sol’n) 

2. <133.32 

 Pa (37.8oC) 

399.9 Pa (30oC)

 

Vapor density 

(air=1) 

1. Similar to waterb 

2. 3.4 @ boiling 

 Point 

2.3 

 

Water solubility 

(temp; effect of pH; 

mg/L) 

3.0 g/L @ 25oC 

and 34 mmHg 

39 g/100 ml at 

17°C (from 

solid form) 

pH in solution 1. 2 ca 

2. <1 (1% aq.sol’n) 

 ca 6.7 - 7.6 

Dissociation constant 

(pKa) 1.72i 1.72i 

Oxidation-reduction 

potential 

1. Strong Oxidizer 

2. Strong Oxidizer 0.95 V @ pH 4-7 ca 100 – 700 

mVk 

Corrosivity to 

material or 

equipment 

1. See notec

 

2. Corrosive 

Produced in situ

and delivered to 

ballast tanks with 

materials 

designed for 

ClO2. 

Similar to 

untreated ballast 

water (see 

Section 6.1.2) 

Similar to 

untreated 

ballast water 

(see section 

6.1.2) 

Reactivity to 

container material 

1. Yesd 

2. Yese

Produced in situ, 

not stored 

 

Autoignition 

temperature (oC) 

1. Not applicable 

2. No Data 

 Available 

Not applicable 

 

Explosive properties Stable as an 

aqueous sol’nj 

 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 30 

I:\MEPC\58\2-8.doc 

Physical/Chemical 

Property 

(with units & 

reference) 

Preparations 

 1. Purate® 

 2. Sulfuric acid 

 (78% by weight)

Active 

Substance 

Chlorine dioxide 

(solution)

Relevant 

Chemical 

Sodium chlorite

Treated 

Ballast 

Water 

Oxidizing properties 1. Strong oxidizerf 

2. Strong oxidizerg 

Intended for use 

as disinfectant/ 

oxidizer 

 

Surface tension 1. See noteh 

2. Not Available Similar to intake 

water

 

Viscosity (20oC) 1. 1.8 mPa.s 

2. 26.7 mPa.s Same as treated 

seawater 

The low 

concentration 

will not affect 

typical seawater 

viscosity 

1060 cP 

(20oC) (same 

as seawater) 

Thermal stability 

and identity of 

breakdown products 

Avoid elevated 

temps to 

avoid/reduce 

evolution of 

ClO2 gas. 

 

Other physical or 

chemical properties 

1. Liquid slight blue 

colour w/ slightly 

pungent odour. 

2. Dense, viscous, 

colourless, 

odourless liquid 

Pale 

green/yellow 

solution with an 

odour similar to 

chlorine. 

-- -- 

Salinity 

23.8 – 24.7 

PSU 

TOC/DOC, 

% Particulate Matter 

3271 μg/L 

(TOC) 

3073 μg/L 

(DOC) 

6.05%l 

a

 Contact with organic materials e.g. textiles, wood or leather may cause fire, if allowed to dry. Contamination from 

various metals or organic materials may cause rapid decomposition, resulting in oxygen gas release and pressure 

build-up if not properly vented. 

b Purate® is a solution of sodium chlorate and hydrogen peroxide containing 52% water. The only relevant vapour 

present is water vapor. 

c Purate® is corrosive to carbon steel, copper, and brass. Stainless steel 316 and 316L are suitable. Non-metal materials 

such as CPVC, PVDF, PTFE, ECTFE, and vinyl ester resins offer excellent performance. Polyethylene and 

polypropylene offer good performance, typically for storage tanks. 

d

 Materials to Avoid: Incompatible materials and chemicals such as organic materials, alkaline substances, strong acids, 

phosphorus, sulfur, sulfides, sulfites, and metal/ammonium salts. Contaminated organic materials ignite readily if 

allowed to dry. Decomposes in contact with certain metals and alkalis, which generates oxygen gas. Risk of explosion. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 31 

I:\MEPC\58\2-8.doc 

e Do not store near bases, halides, sulfides, picrates, nitrates, chlorates, carbides, fulminates, cyanides, and reducing 

agents. Do not allow water to enter containers. Sulfuric acid may be safely stored in properly designed bulk storage 

tanks. 

f

 Contamination from various metals or organic materials may cause rapid decomposition, resulting in oxygen gas 

release. Assists combustion. Contaminated clothing will become highly combustible if allowed to dry, and may be 

ignited by friction or heat. 

g

 Sulfuric acid is not flammable or combustible. However, it is highly reactive. Concentrated sulfuric acid is a strong 

oxidizer capable of igniting combustible materials on contact. 

h No test data is available. Expect it to be similar to a water solution of ionic salts, like sodium chloride. 

i The pKa for chlorous acid (HClO2) is 1.72. HClO2 ↔ ClO2-

 + H+ 

j BWTS chlorine dioxide solution (5 mg/L) is >99.5+% water and is generally water-like. Highly concentrated solutions 

(>8000 mg/L) can be explosive. 

k At higher end of range immediately after chlorine dioxide treatment, then decreases to values similar to untreated 

ballast water. 

l

 % Particulate matter calculated as follows: 100*(TOC-DOC)/TOC. 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 32 

I:\MEPC\58\2-8.doc 

6. OTHER INFORMATION 

6.1 Material Safety Data Sheets and GHS Classification 

Substance

MSDS 

Provided 

(Yes/No)

Classification Reference/ 

Comments

Preparations 

Purate® Yes 

O, Xn, N 

R-phrases: R9, R22, R36, R51/53 

S-phrases: S3/4, S36/37/39, S46, S61 

European 

Union 

directive on 

classification 

of hazardous 

preparations 

(1999/45/EC) 

Sulfuric acid Yes 

Health: 

 Acute Tox: Category 3 (oral, dermal) 

 Eye Effects: Category 1 

 Skin Corrosion: Category 1 

 Skin Sensitization: No category 

 proposed 

 Mutagenicity: No category proposed 

 Carcinogenicity: Not a suspected 

 cancer-causing agent 

 Reproductive/Developments: 

 No category proposed 

 Target Organ Toxicity (repeated): 

Category 3 Environmental: 

 Acute Aquatic Tox: Acute 2 

 Chronic Aquatic Tox: Chronic 2 

Physical: 

 Corrosive to Metals: Category 1 

GHS 

Classification 

System 

(United 

Nations, 1st

Revised 

Edition, 

2005) 

Active Substance 

Chlorine 

dioxide Yes R-phrases: R20, R36/37/38 S-phrases: S24/25, S26, S36/37/39 

European 

Union 

directive on 

classification 

of hazardous 

substances 

(2001/59/EC) 

Annex I 
GESAMP-BWWG 7/9 

ANNEX 5 

Page 33 

I:\MEPC\58\2-8.doc 

6.2 Risk Characterization 

Substance 

Persistent 

(Yes/No) 

Half-life: >60 d in marine 

water, or 

>40 d in freshwater, or 

>180 d in marine sediment 

>120 d in freshwater sediment 

Bioaccumulative 

(Yes/No) 

BCF >2,000 or Log 

Kow ≥3 

Toxic 

(Yes/No) 

Chronic 

NOEC 

<0.01mg/L 

Chlorine 

dioxide No No No 

Chlorite ion No No No 

6.3 Analytical Methods at Environmentally Relevant Concentrations 

Test 

Substance Analytical Methods Sensitivity

Active Substance 

Chlorine 

dioxide 

Chlorine dioxide residuals are measured 

using the lissamine green B (LGB) 

chemistry (USEPA Method 327) 

0.1 to 20 mg/L 

Chlorite ion 

Chlorite ion residuals are measured 

by ion chromatography (IC) 

(USEPA method 300.1) 

5.0 μg/L to 

concentrations in excess 

of 5.0 mg/L 

Treated Ballast Water 

Treated 

Ballast Water 

See above methods for analysing chlorine 

dioxide and chlorite ion in treated ballast 

water. 

-- 

***

GESAMP-BWWG 7/9 

I:\MEPC\58\2-8.doc 

ANNEX 6 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

NK-O3 Blue Ballast Water Treatment System 

Submitted for Final Approval by the Republic of Korea 

0 SUMMARY 

0.1 Final Approval of the NK-O3 Blue Ballast Water Treatment System using ozone, based 

on the submission provided by the Republic of Korea is not recommended. 

0.2 The Group noted that the proposed system applies onboard ozone generation without any 

chemicals carried on board the ship. A maximum dosage of 2.5 mg/L ozone is then injected into 

the incoming ballast water for treatment. No dedicated filtration unit is included in the system. 

Ozone and TRO are classified as Active Substances for this system. 

0.3 The applicant states that dosage of ozone is monitored and controlled automatically with 

a TRO sensor in the ballast water line after injection of ozone controlling the flow of injected 

gas. The Group, however, considered that an improved control system would be necessary to 

ensure correct dosing. 

0.4 During review at the GESAMP-BWWG-7 meeting, the Group noted that no report on the 

results of chemical analyses was available in the dossier. After requesting supplementary 

information, the applicant had submitted one page with results of the chemical analyses. 

However, no information on which samples had been analysed, how the analyses had been 

carried out, which laboratory that had been carried out the analyses, and which quality control 

system that was in place was submitted, and neither was the report dated and signed. The Group 

noted that this report submitted did not meet standard requirements and that it was not possible to 

assess the validity of the results presented. 

0.5 The Group noted that degradation within a period of 48 h of TRO was presented based on 

results from four of the land-based G8 tests showing that most of the TRO has been degraded in 

this period. Based on these results the applicant proposed a holding time for ballast water treated 

with NK-O3 to be 2 days at minimum. However, this is not acceptable for the Group as no 

ecotoxicity testing has been carried out on samples from such holding time and no exact values 

for remaining TRO from the land-based tests were presented. The Group additionally noted that 

the dossier included information, which indicated that TRO levels were well above detectable 

levels after 2 days. 

0.6 A figure presenting the degradation rates of TRO in the 48 h period is comparable to 

other applications and data from open literature using ozone to treat water with high organic 

content. The Group noted, however, that half-life of 15 hours has been reported for 

another BWMS using ozonation resulting in concentrations at 160 μg/L at de-ballasting 

after 5 days. Further, the Group noted that a half-life of 1–2 days was presented by the applicant 

in the Basic Approval dossier. This leads to a calculated 0.13 mg/L of TRO at discharge 

after 5 days tank holding. The Group recommends that further analysis and tests on degradation 

rates of TRO in the ballast tanks should be conducted to verify the actual conditions attained. 
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0.7 The Group noted that Whole Effluent Toxicity (WET) tests based on samples from two 

land-based G8 tests were included in the dossier. Samples were taken at discharge after 5 days 

holding time. However, the dossier was inconsistent in the presented dates of tests and samples 

received at laboratory and the Group is therefore uncertain about the QA procedures 

implemented in the sample handling. 

0.8 The Group considered that halogenated DBPs (Disinfection By-Products) are the relevant 

substances generated by the process including halogenated acetic acids (HAA) and 

trihalomethanes (THM). 

0.9 The Group noted that the applicant conducted new in vivo studies to evaluate the Whole 

Effluent Toxicity (WET) for the endpoints of acute toxicity and genotoxicity/mutagenicity. In 

this context, the Group wants to inform that it disapproves of animal testing for the purpose of 

generating new data, being not required to be submitted for Whole Effluent Toxicity. 

Unnecessary testing of animals should be discouraged by all means. 

0.10 The Group noted that the applicant carried out corrosion tests using a limited number of 

test coupons exposed to treated and untreated ballast water in the G8 land-based tests. 

An exposure time of approximately 100 h was used in the tests and based on these samples 

average corrosion rates were calculated. The Group recommends additional longer duration tests 

are carried out with both uncoated and coated samples to verify the corrosive effect to steel and 

that the effect of using this BWTS on epoxy coated ballast tanks remains acceptable. 

0.11 The Group concludes that the dossier submitted by the applicant is inconsistent and 

incomplete as regards: 

 .1 tracking of samples of treated ballast water sent for chemical analyses and 

ecotoxicological testing; 

 .2 reporting of results of chemical analyses; 

 .3 explaining the remarkable differences between previous results and current results; 

 .4 estimation and/or assessment of Predicted Environmental Concentrations for 

Active Substances and Relevant Chemicals; and 

 .5 environmental risk assessment (calculation of PEC/PNEC). 

0.12 Due to the above-mentioned inconsistencies and missing information, the Group is not 

able to conduct a thorough assessment of risks to the aquatic environment of discharge of treated 

ballast water. Consequently, the Group cannot recommend that a Final Approval be given 

to NK-O3 Blue Ballast Water Treatment System. 
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1 INTRODUCTION 

1.1 The proposed NK-O3 Blue Ballast Water Treatment System using ozone was 

given a Basic Approval by MEPC 56 based on a favourable opinion issued by 

the GESAMP-Ballast Water Working Group at its third meeting in February 2007 after 

reviewing the application submitted by the Republic of Korea. 

1.2 The data for this document were extracted from the original data supplied by 

the Republic of Korea to support its submission MEPC 58/2/3 and the confidential dossier issued 

to the Organization. 

2 COMPLETENESS OF THE DOSSIER 

2.1 A full confidential dossier, including the application for Final Approval with detailed 

information about Active Substances and Relevant Chemicals, results from G8 tests and 

ecotoxicity tests, and the supporting technical manuals and references have been submitted to 

the GESAMP-BWWG. In detail, these were: 

- Summary of Key Data; 

- Human exposure assessment; 

- MSDS; 

- One corrosion test; 

- Generic Quality Management Plans and testing reports for G8 and G9 testing; 

- Standard operation procedure; 

- Manuals for the NK-O3 system; and 

- References.

2.2 Within the application dossier presented, the Group identified that some information was 

missing and also identified topics where a further clarification was needed. The Group 

established a list of questions for which the answers were needed for a sound evaluation of the 

system presented by the Korean Administration. The questions and answers as well as 

the Group’s comments to these answers are presented in appendix 2 to this document. 

3 DESCRIPTION OF NK-O3 BLUEBALLAST SYSTEM 

3.1 Overview of the system 

3.1.1. The Group noted that the NK-O3 BlueBallast System uses a shipboard oxygen generator, 

which takes ambient air and strips away the nitrogen, concentrating the oxygen content – which 

is then passed through a high frequency electrical field to produce ozone (O3). The ozone is then 

injected into the incoming ballast water as treatment. 

3.1.2 The NK-O3 System is composed of four integrated modules: oxygen generator, 

ozone generator, ozone injector, and monitoring and control system. 
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3.1.3 The ozone generator passes the incoming oxygen through a high frequency electrical field 

to produce ozone. 

3.1.4 The ozone injector is based on a purpose-built patented ‘side-stream injector’. This diverts 

incoming ballast water from the main ballast pipes into a ‘side-stream’, where it is injected with 

ozone before re-entering the main ballast water stream. The applicant stated that the BWMS was 

optimized through use of the side-stream injector design and venture. The Group noted that this 

change would alter the ratio of production of TRO from ozone gas and this would also change the 

generation of other Relevant Chemicals. Also, the Group noted that the applicant claims that this 

change in design would increase the TRO degradation rate and lower the production of bromoform 

in ballast tanks. The Group considers that further measurement and analysis is necessary to confirm 

the effects of changing the injection design on the Relevant Chemicals. 

3.1.5 It was noted that the submission states that the monitoring and control system uses 

standard technology, and includes a variety of sensors, alarms, meters, valves and switches 

connected to central control software, and integrated with the ship’s overall ballast management 

system. This allows all aspects of the system to be monitored and controlled and all data on 

system operation to be kept electronically and printed as required by inspectors. The system 

includes safety alarms and automatic cut-off switch. 

3.1.6 Ancillary equipment consist of a power supply unit, a compressor to feed air to the 

oxygen generator, refrigerated dryer to de-humidify air being fed to the oxygen generator, a 

chiller, which keeps the ozone generator cool, and an ozone destruct system to convert any 

unused ozone back to oxygen before being released to the atmosphere. 

Schematic of overall Layout of the NK-O3 BlueBallast System 

OXYGEN GENERATOR OZONE INJECTOR OZONE GENERATOR
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3.2 Active Substances, Relevant Chemicals and Other Chemicals 

3.2.1 The applicant describes the system as follows: when ozone (O3) is injected into the ballast 

water, it reacts with bromide that occurs naturally in seawater to produce bromide ions. 

In this process the ozone is destroyed extremely rapidly, and the TRO becomes the 

main Active Substance. 

Chemical name ozone TRO (Total Residual Oxidants) 

(Triatomic Oxygen) Hypobromous acid Hypobromite ion 

CAS number 10028-15-6 13517-11-8 - 

UN number & name 1956 - - 

Molar mass 48.00 96.91 95.90 

Empirical formula O3 HOBr OBrStructural formula 

Purity 10~15 wt% By-product By-product 

3.2.2 Relevant Chemicals: In seawater the formed bromide ions rapidly form hypobromous 

acid and hypobromite ions, which also react with any organic matter that may be present in the 

ballast water to form bromoform. Other possible bromide related by-products include 

bromate ions, dibromoacetic acid and bromochloroacetic acid. 

Chemical name Bromate ion Bromoform 

(Tribromomethane) 

CAS number 15541-45-4 75-25-2 

Molar mass 127.90 252.73 

Empirical formula BrO3

-

 CHBr3

Structural formula 

Chemical name Bromochloroethanoic acid 

(Bromochloroacetic acid) 

Dibromoethanoic acid 

(Dibromoacetic acid) 

CAS number 5589-96-8 631-64-1 

Molar mass 173.39 217.84 

Empirical formula C2H2O2BrCl C2H2O2Br2

Structural formula 

3.2.3 The Group noted that in cases where ships take on fresh-water ballast, brominated 

compounds are not formed, and the ozone alone is the Active Substance. For seawater ballast, 

ozone and TRO are the two Active Substances of relevance to the NK-O3 System. The 

by-products bromoform, dibromoacetic acid and bromochloroacetic acid are collectively referred 

to as disinfection by-products (DBPs), and may be considered as Relevant Chemicals. 
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3.2.4 The discharge characteristics of ballast water treated by the NK-O3 System are indicated 

by the test results from the chemical analysis conducted during the land-based (barge) testing, as 

follows: 

Table: Results of chemical analyses of treated ballast water 

Active Substance and 

Relevant Chemicals 

Unit Control Treated MDL1)

Ballasting 

Ozone (Calculated) mg/L - 2.06~ 2.35 (avg 2.20) - 

TRO mg/L ND 2) 3.62~ 4.84 (avg 4.24) 0.02 

 

Deballasting (n=10) 

Ozone mg/L ND ND 0.01 

TRO mg/L ND ND 0.02 

Bromate ion μg/L ND ND 1.00 

Trichloromethane μg/L ND ND 5.00 

Bromodichloromethane μg/L ND ND 0.70 

Dibromochloromethane μg/L ND ND 0.70 

Tribromomethane μg/L ND ND-28.4 (avg 6.38) 1.00 

Monochloroacetic acid μg/L ND ND 2.13 

Dichloroacetic acid μg/L ND -8.09 (avg 1.38) ND -0.85 (avg 0.20) 0.08 

Trichloroacetic acid μg/L ND -0.36 (avg 0.02) ND -0.70 (avg 0.02) 0.03 

Bromochloroacetic acid μg/L 0.30-9.32 (avg 4.17) 0.78-11.9 (avg 5.97) 0.03 

Dibromoacetic acid μg/L ND -2.64 (avg 0.65) 0.43-8.05 (avg 3.97) 0.04 

1) MDL: Method Detection Limit (unit not indicated: mg/L or μg/L) 

2) ND: Not detected (< MDL) 

3) For the calculation average values, the ND values are used. 

3.2.5 The applicant stated that all samples for chemicals analysis of treated ballast water were 

taken after 5 days holding time in the ballast water tank. However, in the one-page report on the 

results of the chemical analyses submitted by the applicant, there was no statement of the timing 

of sampling. Also, the Group noted that no information for the concentration between initial 

and 5 days were provided, so that the Group cannot evaluate the degradation rate of TRO only 

from these results. Lastly, the Group noted that the assumption of average values for the 

substances including ND values is not adequate. 

3.2.6 During Basic Approval the applicant clearly stated that TRO has a half-life of 

between 1 and 2 days in the ballast water tank (in dark conditions). The Group noted that when 

calculating a half-life of TRO of one day, this would lead to a residual content of 

at least 0.13 mg/L TRO in the ballast water tank, and consequently in the discharge after a 5-day 

tank holding with an initial TRO level of 4.24 mg/L. The Group noted that this calculated value 

is greater than the detection limit of TRO (0.02 mg/L) provided by applicant. Therefore, 

the Group was of the opinion that the degradation of TRO in ballast tank using the same natural 

seawater in the Port of Busan port has changed significantly between Basic and Final Approval. 

The Group recognizes that, theoretically, there is the possibility that design changes in the ballast 

water management systems between Basic and Final Approval could have resulted in 

two different compositions of oxidant with similar initial TRO values, but completely different 

degradation rates. However, the Group recommends that additional analysis and validation would 

be required to enable it to have confidence in the evaluation of chemical identification and 

degradation rate. 
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4 HUMAN HEALTH ASSESSMENT 

4.1 The Group considered the relevant toxicological data that were submitted by the 

applicant for ozone, TRO and DBP in the confidential version (3.4). Additionally, 

the Whole Effluent Toxicity (WET) was tested in new in vivo studies for the endpoints of acute 

toxicity and genotoxicity/mutagenicity. 

4.2 In this context, the Group wants to inform that it disapproves of animal testing for the 

purpose of generating new data that are not required to be submitted for Whole Effluent Toxicity. 

Unnecessary testing of animals should be discouraged by all means. 

4.3 The Group noted that MSDS for ozone, bromoform, bromochloroacetic acid, 

dibromoacetic acid have been provided and that the Human Exposure Assessment (HEA) was 

elaborated by the applicant. 

4.4 The Group noted that safety systems have been foreseen by the applicant to prevent 

contact of ship personnel to ozone in the vicinity of the NK-O3 System. These are described in 

the section “5 Risk to Safety of Ship” below. 

4.5 During Basic Approval, the Group raised concerns about the possibility of free ozone gas 

being present in the ship’s ballast tanks when they are emptied and that personnel may be 

exposed when entering the tanks for inspection and maintenance purposes, and also about the 

possibility of gaseous ozone being emitted from the ballast tank air vents during ballasting. 

4.6 The applicant explains that it is highly improbable that ballast tanks would ever be 

opened and entered within a short time after the NK-O3 System having been operated, which 

occurs during ballasting. Ballast tanks need to be emptied prior to entry, giving more than 

sufficient time for the breakdown of ozone. To address the perceived concern of the Group, 

safety procedures have been supplemented to recommend an exclusion zone of 1 metre, to 

be painted on the ship’s deck around each ballast tank air vent with clear notice for 

personnel to keep out of these zones during ballasting. This will be included in crew 

induction and safety training in ships fitted with the NK-O3 System, as reflected in the 

updated Operation and Maintenance Manual and Safety Manual for ozone system. 

4.7 The applicant suggests risk mitigation measures concerning bromoform, which could 

include periodic sampling of system effluent as part of port State control compliance procedures. 

5 RISK TO SAFETY OF SHIP 

5.1 Free Ozone in vicinity of the NK-O3 System 

5.1.1 The Group noted that the following safety precautions have been put in place to prevent 

exposure of ships crew with ozone: 

.1 The use of materials and construction that is designed to prevent any possible 

leakage of ozone from the system; 

.2 A gas separation unit together with a waste ozone destruction unit placed after the 

treatment unit, to destroy ozone produced during start up and testing of the ozone 

and convert it back to oxygen prior to release to the atmosphere; 
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.3 An ozone densitometer to detect any possible accidental leakage from the system; 

.4 Recommended inspection and maintenance procedures and clearly outlined safety 

procedures as contained in supporting operating manuals for personnel; 

.5 An automatic alarm and shut-down system linked to the ozone densitometer. This 

is designed to trigger if ozone levels in the vicinity of the system exceed 0.2 mg/L 

(the recommended safe level is 0.1 mg/L); and 

.6 Other events that will shut down the system immediately, close all valves 

and stop all pumps are high ambient oxygen concentration (25%), 

no Volumetric Oxygen Deficit (VOD) available, emergency stop push button 

pressed and fire alarm. 

5.2 Corrosion 

5.2.1 The Group noted that the corrosion tests performed with treated ballast water did not 

show any increased corrosion rates. The side-stream injector ensures a restricted high dosage 

area. This is stated to eliminate potential for corrosion, by concentrating the ozone in the injector 

area only, which is made from high-grade, non-corroding stainless steel. 

5.3 Fire and Explosion 

5.3.1 The Group was informed that a potential fire hazard associated with the NK-O3 System is 

the temporary storage of oxygen produced during operation of the system, which is used as the 

raw material to produce ozone. 

5.3.2 Where oxygen is stored in high pressure cylinders, the submission confirms these will be 

manufactured to international safety standards and placed within a fire-proof cabinet. Oxygen is 

purged from the storage system and released to atmosphere when the system is not in operation. 

In case of supplementary oxygen cylinders storage, the cylinders would be manufactured to 

international safety standards and placed within a fire-proof cabinet and/or located outside of the 

ship’s engine room. 

5.3.3 The Group noted that the whole system is equipped with fire alarm and shut-down 

systems linked to the ship’s fire alarm system. 

6 RISKS TO THE AQUATIC ENVIRONMENT 

6.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

6.1.1 The Group concluded already at Basic Approval that none of the chemicals involved in 

the NK O3 BlueBallast System fulfil the PBT criteria. 
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7 ASSESSMENT OF TREATED BALLAST WATER 

7.1 Measured concentrations in treated ballast water 

7.1.1 The Group noted that chemical analyses had been carried out on samples of treated ballast 

water taken at de-ballasting after 5 days’ holding time with the aim of identifying 

Active Substances and Relevant Chemicals. Additional information given by the applicant upon 

request stated that the samples were collected from the land based G8 tests performed. A table in 

the additional information indicated that samples for chemical analysis were collected from all 

land-based tests. 

7.1.2 During review at the GESAMP-BWWG-7 meeting, the Group noted that no report on the 

results of chemical analyses was available in the dossier. After requesting supplementary 

information, the applicant had submitted one page with results of the chemical analyses. 

However, no information on which samples had been analyzed, how the analyses had been 

carried out, which laboratory that had been carried out the analyses, and which quality control 

system that was in place was submitted, and neither was the report dated and signed. The Group 

noted that this report submitted did not meet standard requirements and that it was not possible to 

assess the validity of the results presented. 

7.1.3 The maximum expected concentration of TRO resulting from ozonation of ballast water 

has been reported to be maximum 5 mg/L. The Group noted that degradation of TRO in four of 

the 10 land-based tests were presented in the dossier (figure 6.1, page 212). Data for 48 h only 

was included in a figure showing that most of the TRO was degraded in this period. No data table 

followed the figure, but based on the figure, the Group understood that detectable levels of TRO 

were found in at least two of the tests at 48 h. 

7.1.4 The degradation rates in this period seem to be comparable to other applications and data 

from open literature using ozone and other oxidant systems to treat water with high organic 

content. The Group noted, however, that these other systems had reported a slower degradation 

rate after 48 h resulting in measurable TRO levels after 5 days. 

7.1.5 The Group noted that a considerably longer half-life was reported in the Basic Approval 

and that a half-life of 15 hours has been reported for another BWMS using ozonation resulting in 

concentrations at 160 μg/L at de-ballasting after 5 days. A high TRO demand may be the result 

of a high concentration of particulate or dissolved organic carbon or ammonium. However, the 

organic content of the test water used in NK-O3 land-based tests was in a comparable range to 

the levels used in the other system referred above. 

7.1.6 The Group noted that except for 5 days’ samples, no exact TRO values were presented in 

the dossier and no degradation rates were calculated based on the data. Based on the presented 

data, a 2 days’ holding time only in ballast tanks, as suggested by the applicant, is not acceptable 

for the Group without further documentation of TRO levels and ecotoxicity testing of the effluent 

after this period. 

7.1.7 Concentrations of bromate ion were below the MDL at 1 μg/L. This value corresponds to 

results presented in the documentation submitted for Basic Approval, where the concentrations 

were also below the detection limit at 2 μg/L. 
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7.1.8 Concentrations of bromoform (tribromomethane) were measured from below MDL 

(1 μg/L) to 28 μg/L with an average concentration calculated by the applicant of 5.6 μg/L. In the 

submission for Basic Approval, much higher concentration with a maximum of 255 μg/L was 

reported. The applicant should present a scientific explanation for this discrepancy as only 

reporting that no effects could be determined is not considered sufficient proof. In addition, it is 

not justified that an average is determined in the way as presented. 

7.1.9 The Group noted that in the additional information the applicant suggested that, as 

bromoform is a volatile compound, this could explain the lower level over time. However, 

evaporation of bromoform is only possible if the ballast water and/or the sample is exposed to 

air. If the land-based tests are performed with simulated ballast tanks, the venting and 

air exchange is too small for such loss to the atmosphere. 

7.2 Acute and chronic toxicity of treated ballast water 

7.2.1 The Group noted that a number of Whole Effluent Toxicity (WET) tests had been 

performed on samples from two of the land-based (barge) tests with marine water and brackish 

water (Test cycle 1-2 marine water, and Test cycle 2-1 brackish water). In each test run, one part 

of the ballast water was treated with ozone while another part was untreated. The dossier stated 

that the samples were taken at discharge after 5 days’ holding time. In the additional information 

provided by the applicant, it was stated that the samples were delivered to the laboratory one day 

after collection and that ecotoxicity tests started the same day. Test 1-2 was carried out 

from 14th to 19th September 2007 while the ecotoxicity laboratory reports have 18th September 

as reception date for the samples. The Group, therefore, is uncertain about the sampling date and 

the handling of the samples of the ballast water used in the test. 

7.2.2 The results of the WET tests showed that none of the samples showed any difference in 

toxicity between treated and untreated ballast water. However, the Group noted that for some of 

the tests conducted, the ballast water (treated and untreated) showed a toxic effect compared to 

the negative control test with unpolluted sea water. 

7.2.3 The Group noted that no ecotoxicity tests were carried out on samples with shorter 

holding time than 5 days. The Group can therefore not recommend discharge of ballast water 

with shorter holding time than 5 days. 
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8 ENVIRONMENTAL RISK ASSESSMENT 

8.1 Derivation of a Predicted No Effect Concentration (PNEC) 

8.1.1 Data on aquatic toxicity are included in the dossier submitted. Based on these data, the 

following PNEC values can be derived: 

Substance Bromate ion 

[mg/L] 

Bromoform 

[mg/L] 

Data on toxicity 

Acute fish 404 7.1 

Acute crustaceans 176 24.4 

Acute algae >13.6 38.6 

Acute oyster 30 40 

Chronic fish 4.8 

Chronic algae 10 

Assessment Factor 1000 10 

PNEC 0.03 0.5 

8.1.2 The Group noted that in data sets submitted with other application dossiers, more 

extensive data sets had been provided for bromoform allowing a more detailed assessment of the 

aquatic hazards resulting in a PNEC for bromoform at the μg/L level. Thus, the data set provided 

is considered insufficient. 

8.1.3 The Group further noted that although no information had been provided in the dossier 

submitted by the applicant, a PNEC for TRO had been derived and justified to be 0.68 μg/L in 

another application submitted to MEPC. 

8.2 Calculation of the Predicted Environmental Concentration (PEC) for the Active 

Substance and Relevant Chemicals 

8.2.1 The Group noted that the applicant did not provide an assessment 

of Predicted Environmental Concentrations of the various Active Substances 

and Relevant Chemicals including results of use of an appropriate model. 

8.3 Calculation of PEC/PNEC ratios 

8.3.1 Due to the lack of an appropriate assessment of environmental concentrations 

of Active Substances and Relevant Chemicals after discharge of treated ballast water, only a 

tentative environmental risk assessment can be carried out. 

8.3.2 For bromate ions, the environmental risks cannot be estimated, as measured 

concentrations in the treated ballast water at discharge were below the DML at 1 μg/L. However, 

as the DML is below the PNEC, no risks to the aquatic environment are determined. 

8.3.3 For bromoform, the measured concentrations in treated ballast water at discharge were 

below the PNEC that could be derived from the data set provided in the dossier. However, as 

mentioned above, the Group is uncertain about the difference in concentrations of bromoform 

between the data submitted for Basic Approval and data submitted for Final Approval and, 
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furthermore, the Group is aware of additional data that would result in a PNEC-value lower than 

the measured concentrations in the treated ballast water. 

8.3.4 The Group noted that no risk assessment of TRO had been provided and that it was not 

possible for the Group to assess environmental risks, as no assessment of environmental 

concentrations had been provided. 

9 CONCLUSIONS AND RECOMMENDATIONS 

9.1 Risks to the safety of the ship

9.1.1 The Group considers that risks to the safety of the ship arising from the use of this BWTS 

have been appropriately identified by the applicant and that adequate risk mitigation measures 

have been incorporated to reduce the associated risk to an acceptable level. 

9.1.2 The Group recommends that additional longer term tests are carried out to confirm that 

the results of the short-term corrosion tests carried out and the assumptions made regarding 

no corrosive effect to steel and no effect to ballast tank coatings arising from the use of this 

system remain valid. 

9.2 Risks to the crew and general public 

9.2.1 Based on the submitted information related to toxicological data and human exposure 

assessment, the Group is able to conclude that the NK-O3 Blue Ballast does not pose an undue 

risk to human health. 

9.2.2 The Group recommends that human exposure when handling ballast water treatment 

operations (e.g. inspection and maintenance of ballast tanks) should be prevented by engineering 

control measures and use of adequate PPE/RPE. 

9.3 Risks to the environment

9.3.1 With the data presented by the applicant, the Group cannot reach a firm conclusion as to 

the environmental acceptability of this BWTS. Additional data is therefore required to enable 

the Group to perform an effective evaluation. This data should include information on the 

degradation of TRO, the proposed tank holding time before discharge, a clear and unambiguous 

tracking of samples of treated ballast water between sampling and chemical analysis and 

ecotoxicological testing, a report of the chemical analyses from a certified analytical laboratory, 

appropriate modelling of environmental concentrations in an appropriate scenario, and a 

scientific explanation for the low levels of THMs in the system. 

9.4 Conclusions and recommendations

9.4.1 The Group concludes that the dossier submitted by the applicant is inconsistent and 

incomplete as regards: 

 .1 tracking of samples of treated ballast water sent for chemical analysis and 

ecotoxicological testing; 

 .2 reporting of results of chemical analyses; 
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 .3 explaining the remarkable differences between previous results and current results; 

 .4 estimation and/or assessment of Predicted Environmental Concentrations 

for Active Substances and Relevant Chemicals; and 

 .5 environmental risk assessment (calculation of PEC/PNEC). 

9.4.2 Due to the above-mentioned inconsistencies and missing information, the Group is not 

able to conduct a thorough assessment of risks to the aquatic environment of discharge of treated 

ballast water. Consequently, the Group cannot recommend that a Final Approval be given 

to NK-O3 Blue Ballast Water Treatment System. 

* * * 
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APPENDIX 1 

PHYSICOCHEMICAL AND BIOLOGICAL PROPERTIES 

WHOLE EFFLUENT 

1 CHEMICAL IDENTIFICATION

1.1 The Active Substances in the NK-O3 Ballast water treatment system are ozone and TRO. 

1.2 Relevant Substances identified are bromate, bromoform, bromochloracetic acid and 

dibromoacetic acid. 

2 EFFECTS ON AQUATIC ORGANISMS 

2.1 Acute aquatic toxicity 

2.1.1 The tests were conducted on the whole-effluent from the NK-O3 System 

(WET testing by DAUH-CRC). The full range of tests required by Procedure (G9) was 

conducted and no acute aquatic toxicity was observed. 

 Species LC50

(%/duration) 

Reference/Comments/ 

Justification for missing data 

Fish Cyprinidon variegates 

Sheepshead minnow 

> 100% / 96 hours US EPA. (2002) 

Zooplankton Brachionus plicatilis 

Rotifer 

> 100% / 24 hours ASTM E1440-91 

Algae Skeletonema costatum 

Diatom 

> 100% / 96 hours ASTM E1218-97a 

2.2 Chronic aquatic toxicity 

2.2.1 The full range of tests required by Procedure (G9) was conducted and no chronic aquatic 

toxicity was observed. 

 Species LC50 (%/duration) 

or 

NOEC (%/duration)

Reference/Comments/ 

Justification for missing data 

Fish Cyprinidon variegates 

Sheepshead minnow

> 100% / 21 days US EPA. (2002) 

Zooplankton Brachionus plicatilis 

Rotifer 

> 100% / 4 days Janssen C.R. et al. (1994)

2.3 Endocrine disruption 

2.3.1 Endocrine effect screening was conducted with fish according 

to OECD Non-spawning Fish Screening Assay (Env/JM/MOINO (2004)18). No endocrine 

disruption was detected. Refer to appendix 3, section 3.3. 
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2.3.2 Endocrine effect screening was also conducted with Cell lining according 

to Standard Operating Procedure outlined by Aquatic Toxicology Laboratory Michigan State 

University 2003 – both treated and non-treated (control) ballast water showed TCDD-EQ 

significantly higher than the negative control solution but there was no significant difference 

between the both treated and non-treated (control) ballast water; so it is concluded that 

elevated TCDD-EQ relative to the negative control solution did not originate from the NK-O3 

treatment. 

 Species Information 

(GSI/duration) 

Reference/Comments/ 

Justification for missing data 

Fish Cyprinidon variegates 

Sheepshead minnow

No Toxicity / 21 days ENV/JM/MONO (2004) 18

2.4 Sediment toxicity 

2.4.1 Sediment toxicity was assessed using amphipods in accordance 

with USEPA.1994, 600/R-94/025 and no toxicity was observed. 

 Species Information 

(LC50 / duration) 

Reference/Comments/ 

Justification for 

missing data 

Crustacea Monocorophium acherusicum 

Amphipod 

> 100% / 10days US EPA. (1994) 

2.5 Bioavailability / biomagnification / bioconcentration 

As chemical analysis of ballast water treated by the NK-O3 System did not detect 

any Active Substances, TROs or DBPs, and given the very short half-lives of these substances 

plus given that the WET testing did not detect any significant toxicity, bioavailability, 

biomagnification and bioconcentration are not considered to be of relevance to this system. 

3 DATA ON MAMMALIAN TOXICITY 

4 ENVIRONMENTAL FATE AND EFFECT UNDER AEROBIC AND ANAEROBIC 

CONDITIONS 

4.1 Modes of degradation 

4.2 Partition Coefficients 

4.3 Persistence and Identification of Main Metabolites

4.4 Reaction with Organic Matter 

HOBr/OBr-

 will react with natural organic matter to form bromoform (CHBr3) by the haloform 

reaction. Besides bromoform, a number of disinfection products and other halogen containing 

compounds (THMs and HAAs) are produced when ozone and bromide are present in natural 

waters. All these Relevant Chemicals are naturally formed in (sea) water so any reaction 

products can be expected to be of a character similar to those of “natural” decomposition in 

water. 
GESAMP-BWWG 7/9 

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4.5 Potential Physical Effects on Wildlife and Benthic Habitats 

As chemical analysis of ballast water treated by the NK-O3 System did not detect 

any Active Substances, TROs or DBPs, and given the very short half-lives of these substances, 

plus given that the WET testing did not detect any significant toxicity, potential physical effects 

on wildlife and benthic habitats are not considered to be of relevance to this system. 

4.6 Potential Residues in Seafood 

4.7 Any Known Interactive Effects 

5 PHYSICAL AND CHEMICAL PROPERTIES: PREPARATIONS, ACTIVE 

SUBSTANCE, RELEVANT CHEMICALS AND TREATED BALLAST WATER 

5.1 This application considers the Whole Effluent from the NK-O3 System. The physical and 

chemical properties of Active Substances and Relevant By-products, which might occur in the 

treated ballast water are listed in the table below. 

 

Property Active Substance DBPs 

ozone Hypobromous acid Bromoform Dibromoacetic acid 

Bromochloroacetic acid

Melting point(°C) -192.5 Not available 8.0~8.5 49 27.5~31.5 

Boiling point(°C) -111.9 Not available 149~150 195 210~215 

Flammability Nonflammable Not available Nonflammable Not available Not available 

Density(kg/m3) 2.14 Not available 2,887 No data 1,980 

Vapour pressure(Pa) 

/vapour density 

5.46x106

/ 1.66 

Not available 747 

/ 8.72 

3 

/Not available 

11 

/Not available 

Water solubility(mg/L) 

/dissociation constant: 

3 

/Not applicable

Not available 

/ 9 

3,100 

/Not available 

2.20x104 

/ 1.48 

4.40x104 

/Not available 

Oxidation-reduction 

potential: 

2.07 E0(V) Not available Not available Not available Not available 

Corrosivity to 

materials/equipment 

Corrosive Not available Will attack 

some forms of 

plastic, 

rubber, and 

coatings 

Not available Not available 

Autoignition 

temperature(°C) 

Not applicable Not available No data Not available Not available 

Other known 

physical or 

chemical hazards: 

Colorless to 

blue gas, 

characteristic 

odour(freshly 

mown hay) 

Not available Colorless to 

yellow liquid, 

sweet, 

suffocating, 

chloroformlike odor 

Hygroscopic 

crystal 

Hygroscopic 

crystal 
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6 OTHER INFORMATION 

6.1 Material Safety Data Sheets and GHS Classification (YES) 

6.2 Risk Characterization 

6.2.1 Screening for persistency, bioaccumulation and toxicity 

No risk of persistency, bioaccumulation or toxicity has been identified. 

6.2.2 Toxicity testing of the treated ballast water 

No toxicity detected. 

6.2.3 Risk characterization and analysis 

6.3 Analytical methods at environmentally relevant concentrations 

The analytical methods at environmentally relevant concentrations used for the NK-O3 WET 

testing are as follows: 

 Method Applicability Sensitivity Reference/Comments 

/Justification 

Ozone Indigo Colorimetric 

Method 

Water 0.01 mg/L Standard Method 

4500-O3

TRO DPD Colorimetric 

Method 

Water 0.02 mg/L Standard Method 

4500-Cl G 

Bromate ion Ion chromatographic 

Method 

Water 1.0 μg/L EPA Method 317.0 

Bromoform Liquid-Liquid 

Extraction Gas 

Chromatographic 

Method 

Water 1.0 μg/L Standard Method 

6232B 

Bromochloroacetic 

acid 

0.03 μg/L 

Dibromoacetic acid 

Gas Chromatographic 

Method 

Water 

0.04 μg/L 

EPA Method 552.3 

Full details of each method are provided in the full application for Final Approval submitted to 

the GESAMP-BWWG in accordance with Procedure (G9). 

6.4 Tests carried out in accordance with internationally recognized guidelines 

All tests were carried out according to the Standard Operating Procedures (SOPs) of 

the Dong-A University Hospital Clinical Research Centre, which is certified 

to OECD Good Laboratory Practice (GLP) standards by: 

– Korea Food and Drug Administration. Certification No.16, 2005 

(http://www.kfda.go.kr); 
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– National Institute of Environmental Research. Certification No. 2007-12 

(http://eng.nier.go.kr); and 

– Rural Development Administrator. Certification No. 2007-2 

(http://www.rda.go.kr). 

Full details of all test methods are contained in the full application for Final Approval submitted 

to the GESAMP-BWWG in accordance with Procedure (G9). 

6.5 Quality control/quality assurance 

Combined Quality Management Plans (QMPs) and Quality Assurance Project Plans (QAPPs) 

were developed and applied for all aspects of both the G8 and G9 testing of the NK-O3 System. 

Extracts (heading structures) of both QMP/QAPPs are contained in Appendix 2 and the 

full QMP/QAPPs are contained in the full application for Final Approval submitted to 

the GESAMP-BWWG in accordance with Procedure (G9). 

6.6 Assessment Report 

The Korean Register of Shipping (KR) has performed an Assessment of quality of G9 test 

reports, risk characterization of any uncertainty associated with the test results as addressed 

by Assessment report annexed hereto. 

The test results found no significant levels of potentially toxic substances and no significant acute 

or chronic effects of the full strength effluent on aquatic organisms. Therefore, no apparent 

environmental risks could be identified. See appendix. 

* * * 
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APPENDIX 2 

QUESTIONS TO THE APPLICANT WITH ANSWERS AND COMMENTS TO 

THE ANSWERS FROM THE GROUP

1 Please confirm from which land based test cycle have the samples for ecotoxicity testing 

been taken? How and how long have the samples been stored before testing 

(File 5/14, G8 testing, page 6)? 

.1 Samples for eco-toxicity testing were taken from two land-based test cycles 

(one seawater test cycle 1-2, and one brackish water test cycle 2-1). 

Samples were handled, transported and stored as described in the QAPP for G8 

testing (Supporting Documents Vol. I – 2/14 A - Section 2) and in 

the G8 Testing Report (Supporting Documents Vol. I – 5/14 A – Section 4). 

Samples were delivered to Dong A University for eco-toxicity testing within 1 day 

of being collected. 

Once delivered to Dong A University, samples were kept in dark and cold storage 

and eco-toxicity testing was performed at the same time immediately on 

delivering to test facility, in accordance with the QAPP for G9 testing 

(Supporting Documents Vol. I – 2/14 A) and Standard Operating Procedures 

for G9 testing (Supporting Documents Vol. I – 3/14). 

.2 The Group considered the answer provided as acceptable, however, an additional 

question arose on the dates of the sampling regarding test cycle 1-2, because 

reception dates of the samples in all laboratory reports were 

dated 18th of September whilst the 5-day test cycle ended on 

the 19th of September. 

2 You state that the re-assessment of bromoform is not required as it was not detected, but 

the chemical analysis indicates that bromoform has been detected on average of 5.58 μg/L. 

Based on our experience this value is very low. 

.1 The main reason stated for not conducting a re-assessment of the toxicity of 

bromoform specifically is because it is the toxicity of the Whole Effluent, not 

specific elements – that should be considered, consistent with the approach 

applied to other oxidant-based BWMS that has been granted G9 Final Approval 

by MEPC. The lack (or extremely low level) of bromoform detected in the treated 

water is a secondary reason, and the extremely low level detected supports the 

primary argument. 

.2 The Group noted that the applicant did only perform preliminary WET tests 

at Basic Approval with Mysid shrimp and topsmelt. And the results clearly 

indicate effects on Mysid shrimp. Therefore, it is not possible to compare the 

similar concept by other applications that have been granted Final Approval. 

The levels of bromoform established during the Basic Approval 

(Confidential Dossier Application for Basic Approval of NK Ballast Water 

Treatment System that make use of Active Substances, p. 128, Table 6.3.8) would 
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certainly lead to effects on aquatic organisms. Therefore, the results of the 

currently presented results at Final Approval are not consistent with the earlier 

results. The applicant should present a scientifically based explanation for this 

discrepancy as only reporting that no effects could be determined is not 

considered sufficient proof. 

3 Can you explain the discrepancy between bromoform in the non-confidential submission 

(av. 5.58 μg/L) and confidential submission (225 μg/L) on page 215 Part C? 

.1 The figure of 225 μg/L is a typographical error and should actually be 255 μg/L. 

This figure was derived from observations by other parties as reported 

in GESAMP–BWWG 3/9 (MEPC 56/2/2), and we report it in our submission as a 

worst case as indicated by the literature. The figure of av. 5.58 μg/L was observed 

by our own direct testing – it is real data from our testing. 

We understand that the level of 255 μg/L reported in GESAMP-BWWG 3/9 was 

measured 12 hrs after treatment, whereas our figure of 5.58 μg/L was 

measured 5 days after treatment (in accordance with G8). As bromoform is a 

volatile compound this could explain the lower level over time. 

.2 The data here refer to Annex A. The Group is not surprised due to the volatile 

point of criticism. If the treated ballast water is contained in simulated ballast 

tanks with restricted ventilation evaporation of the THMs, it is not sufficient to 

reduce the concentration below detectable levels. In addition, it is not justified 

that an average is determined in the way as presented. 

4 Has the degradation rate and the maximum discharge concentration of TRO been 

confirmed during the land-based G8 testing programme? Also, please provide water quality 

parameters for the degradation rates presented. 

.1 Please refer Figure 6.1, page 212, file 1/14 A for TRO degradation rates as 

measured from land-based tests. No detectable TRO were measured in the 

discharge during the land-based G8 testing programme as reported 

in Table 3.1.3.2, page 39 of file 1/14 A and in Annex A attached to this 

report – the maximum discharge concentration of TRO from the G8 testing is 

therefore nil. Tables 13 and 14 of file 5/14 A present water quality data for the 

test cycles for which TRO degradation were measured, as presented in Figure 6.1, 

page 212, file 1/14 A. 

.2 The data mentioned in the answer is familiar to the Group. The problem is that, 

normally, degradation of TRO is occurring after deballasting but generally not at a 

rate as indicated in the submission leading to a concentration below the LOD so 

quickly. Therefore, the Group has some hesitation to accept these results obtained. 

So, the Group considers it a pity that no chemical analyses are accompanying the 

toxicity data. In addition, if these results would be accepted, then a tank holding 

time of at least 5 days should be taken into account. According to figure 6.1 at 

page 212, there are still measurable concentrations of TRO in the ballast water. 
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5 What is the maximum concentration of TRO in the ballast water after mixing the main 

and side streams? 

.1 A TRO sensor installed after the ozone injector in both the land-based and 

shipboard system routinely measured this – results for land-based tests are 

presented in Appendix 1 of the G8 test report (File 5/14 A) and the maximum 

concentration measured was 4.84 mg/L. Results for ship-based tests are presented 

in Appendix 2 of the G8 test report (File 5/14 A) and the maximum concentration 

measured was 5.22 mg/L. 

.2 The Group considered this answer as sufficient. 

6 How does the system ensure the appropriate dose of ozone without automatic control 

scheme using appropriate sensors? 

.1 If TRO sensors are damaged or inoperable, the monitoring and control system will 

automatically switch to alternative mode with the main control parameter 

becoming the flow-rate, with the dosage of ozone being regulated as follows: 

.1 Dose of ozone (mg/L) = Production of ozone (g/hr)/Flow-rate of ballast 

water (m3/hr); and 

.2 Production of ozone (g/hr) = Concentration of ozone (g/Nm3) x Flow-rate 

of ozone (Nm3/hr). 

Apart from the TRO sensors, if the monitoring and control system itself becomes 

inoperable, the overall ballast water management system simply will not operate. 

The monitoring and control system is integral and essential to the 

overall system – the system cannot and should not operate without it. 

.2 The Group agreed with the first option to control the TRO amount in the systems 

using the TRO-sensors. However, there is a problem with the second option. 

The Group is of the opinion that at a failure of the TRO-sensors, the application of 

the Active Substance to the ballast water tanks should be completely stopped. The 

Group recommends that the control schemes using TRO-sensors should be 

evaluated in operational on-board ballast water management systems. 

7 The Group notes that corrosion tests performed appeared to be of relatively short 

duration to what is normally expected and with a limited number of test plates 

(File 1/14 – Appendix 4, test report for corrosion). Is it intended to continue corrosion testing 

and monitoring before type approval? Please confirm if evaluation of the treated ballast water 

effect on Epoxy coatings has been performed and advise results. 

.1 The Korea Marine Equipment Research Institute (KOMERI), which undertook 

our 2007 corrosion tests, is a quality-certified and accredited government 

laboratory with extremely significant experience in the testing of marine 

equipment, including corrosion testing, for the major Korean shipyards and other 

clients. We are not quite sure of the reference for “what is normally expected” 

above, and understand that KOMERI’s testing procedures are based on 

international standards (inc. ISO 16276- 1). 
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It should be noted that the half life of Ozone in the ballast system is a matter of 

seconds – orders of magnitude less than the duration of the 2007corrosion tests 

conducted by KOMERI (>100 hrs), so the tests are a very conservative 

representation of actual exposure that would be experienced in a real-life 

operating system. 

In addition to the 2007corrosion tests conducted by KOMERI, original corrosion 

tests were conducted in 1999 by the La Que Institute of Corrosion Research 

in Wrightville Beach, North Carolina, USA – a highly specialized, world leader in 

corrosion research – using a model ballast tank rather than plates. These tests 

found no increased corrosion from sparging with Ozone, and in fact in some cases 

found decreased rates of corrosion, most likely due to the production of bromate 

ions from Ozone in seawater, which La Que Institute states may inhibit corrosion. 

Given the positive results to date, the extremely short half-life of ozone in ballast 

water (orders of magnitude within the corrosion test periods), and the 

anti-corrosion measures incorporated into the design and construction of the 

system – including the ozone destructor, the highly-restricted nature of the dosage 

area achieved with the side-stream injector and the use of corrosion resistant 

materials in the system as outlined in section 7.1.2 of file 1/14 A – we do not see 

the rationale for conducting further extended corrosion tests. 

However, should additional corrosion testing be deemed necessary, this can 

certainly be done under the G8 Type Approval testing procedure – which is 

intended to address such operational issues. 

With regard to evaluation of the treated ballast water effect on Epoxy coatings, 

all of the panels tested by KOMERI in 2007, as reported in Appendix 4 of 

File 1/14 A, had epoxy coatings tested according to ISO 16276-1 and no adverse 

effects were found. 

.2 The way the corrosion tests are performed for this ballast water management 

system is not considered acceptable to the Group. Firstly, normal corrosion 

experiments applying the method of weight loss of test coupons will 

take 3 to 6 months, according to the experience of the Group, whilst the KOMERI 

experiments take only about 100 hrs. Secondly, the Group does not consider 

ozone as the major corrosive agent in the ballast tank but the remaining TRO as a 

mixture of oxidants that will increase the corrosion rates compared to non–treated 

sea water. Thirdly, the Group does not consider the epoxy coating tests as 

corrosion tests according to the document referred to in Appendix 4. 
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8 There is no report on the chemical analysis of the disinfection by-products that is referred 

to in the non-confidential submission in the documentation presented. We note other 

technologies using ozone have different values. Can you please explain the difference? 

.1 The data in the non-confidential submission is derived from Active Substance 

analysis of the samples taken during land-based tests – as attached in Annex A to 

this response. 

We are not in a position to comment on why our test results may differ from 

others as we are not specifically aware of what other data is being referred to and 

we are not familiar with the basis from which such other was derived. 

.2 Here, the Group is referring to the reaction to question 3. 

________________