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\60\2-12.doc 

INTERNATIONAL MARITIME ORGANIZATION

IMO 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

60th session 

Agenda item 2 

MEPC 60/2/12

 1 December 2009

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

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

Note by the Secretariat 

SUMMARY

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

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

includes the evaluation of proposals submitted for approval by China, 

Denmark, Japan and the Republic of Korea. Following the decision 

of MEPC 58, only the main body of the GESAMP-BWWG’s reports is 

translated in all the three working languages with the annexes 

in English only. 

Strategic direction: 7.1 

High-level action: 7.1.2 

Planned output: 7.1.2.4 

Action to be taken: Paragraph 3 

Related document: GESAMP-BWWG 11/6 (attached) 

Introduction

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

was held at IMO Headquarters from 19 to 24 October 2009 and its report is attached to this 

document as GESAMP-BWWG 11/6. 

2 The main purpose of this meeting was to review the proposals for approval of ballast water 

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

into the marine environment. The findings of the Group are contained in annexes 4 to 8 of the 

attached report. 
MEPC 60/2/12 - 2 - 

I:\MEPC\60\2-12.doc

Action requested of the Committee

3 The Committee is invited to: 

 .1 agree that Basic Approval should not be granted to ATLAS-DANMARK Ballast 

Water Treatment System – ABTS (with onboard generated ANOLYTE oxidant) 

submitted by Denmark in document MEPC 60/2 (see annex 4); 

 .2 agree that Final Approval be granted to JFE Ballast Water Management System 

(JFE-BWMS) that makes use of “TG Ballastcleaner® and TG Environmentalguard®” 

submitted by Japan in document MEPC 60/2/2 (see annex 5); 

 .3 agree that Basic Approval be granted to Sunrui Ballast Water Management 

System submitted by China in document MEPC 60/2/3 (see annex 6); 

 .4 agree that Basic Approval be granted to DESMI Ocean Guard Ballast Water 

Management System submitted by Denmark in document MEPC 60/2/4 

(see annex 7); 

 .5 agree that Basic Approval be granted to Blue Ocean Guardian (BOG) Ballast 

Water Management System submitted by the Republic of Korea in document 

MEPC 60/2/5 (see annex 8); 

 .6 urge Administrations to thoroughly evaluate the application dossiers and confirm 

that they are satisfactory and complete before submitting their proposals to 

the Organization in accordance with Procedure (G9) (see paragraphs 4.1.2 and 5); 

 .7 request that, for the purpose of consistency, information on Total Residual 

Oxidants (TRO) or Total Residual Chlorine (TRC) should be provided in the form 

of mg/L TRO or TRC as Cl2, for those systems using or producing oxidants to 

treat ballast water (see paragraph 4.1.3); and 

 .8 approve the report in general. 

***
I:\MEPC\60\2-12.doc 

GESAMP-BALLAST WATER WORKING 

GROUP 

Agenda item 6 

GESAMP-BWWG 11/6

 24 October 2009

 Original: ENGLISH

REPORT OF THE ELEVENTH 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 ANY OTHER BUSINESS ........................................................................ 7 

6 CONSIDERATION AND ADOPTION OF THE REPORT .................... 7 
GESAMP-BWWG 11/6 - 2 - 

I:\MEPC\60\2-12.doc

ANNEXES 

Annex 1 List of members who attended the eleventh meeting of the GESAMP-BWWG 

Annex 2 Agenda for the eleventh meeting 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 – ATLAS-DANMARK Ballast Water Treatment System 

(ABTS) (with onboard generated ANOLYTE oxidant) 

– Submitted by Denmark for Basic Approval 

Annex 5 Review of proposals for approval of ballast water management systems that make 

use of Active Substances – JFE Ballast Water Management System (JFE-BWMS) 

that makes use of TG Ballastcleaner® andTG Environmentalguard® 

– Submitted by Japan for Final Approval 

Annex 6 Review of proposals for approval of ballast water management systems that make 

use of Active Substances – Sunrui Ballast Water Management System 

– Submitted by China for Basic Approval 

Annex 7 Review of proposals for approval of ballast water management systems that make use 

of Active Substances – DESMI Ocean Guard Ballast Water Management System 

– Submitted by Denmark for Basic Approval 

Annex 8 Review of proposals for approval of ballast water management systems that make use of 

Active Substances – Blue Ocean Guardian (BOG) Ballast Water Management System 

– Submitted by the Republic of Korea for Basic Approval 
 - 3 - GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

1 INTRODUCTION 

1.1 The eleventh meeting of the GESAMP-Ballast Water Working Group (GESAMP-BWWG) 

was held at IMO Headquarters, London, from 19 to 24 October 2009, under the chairmanship 

of Mr. Jan Linders. A list of members who attended this meeting 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 

informed that nine new proposals for approval had been submitted for consideration by MEPC 60 

in accordance with the agreed deadline of 28 August 2009. He conveyed the appreciation of 

the Director of Marine Environment Division for the effort made by the members of 

the GESAMP-BWWG to have an additional meeting (the twelfth meeting) in December 2009, 

and to extend the eleventh meeting over the weekend in the attempt to evaluate all the nine 

submissions. He drew the attention of the Group to the importance of reviewing the various 

proposals in the chronological order of their submissions to ensure complete transparency and a 

fair treatment for all the proponent Member States. It has been noted, in this context, that the 

outcome of the GESAMP-BWWG 11 and GESAMP-BWWG 12 will be reported to MEPC 60. 

1.3 Mr. Pughiuc expressed his appreciation for the effort made by the IMO Consultant, 

Mr. John Crayford, for his hard work in preparing this meeting and reviewing a large amount of 

documentation in a relatively short period of time. 

1.4 Finally, Mr. Pughiuc 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 Dr. Frank Stuer-Lauridsen, arrangements had been made for him to be excused when the 

proposal for approval of the DESMI Ocean Guard Ballast Water Management System (Denmark) 

is reviewed, due to his involvement in the development of this technology. Dr. Stuer-Lauridsen 

took no part in this evaluation and his contract was consequently reduced to 11 working days. 

2 ISSUES OF CONFIDENTIALITY 

2.1 Four proposals for Basic Approval of ballast water management systems that make use 

of Active Substances had been submitted by Denmark (two proposals, MEPC 60/2 

and MEPC 60/2/4), China (MEPC 60/2/3) and the Republic of Korea (MEPC 60/2/5), and one 

proposal for Final Approval had been submitted by Japan (MEPC 60/2/2). All five 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 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. 

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. 
GESAMP-BWWG 11/6 - 4 - 

I:\MEPC\60\2-12.doc

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

made available to the Consultant, at his 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 continued to conduct its work in accordance with the Terms of Reference 

approved by the MEPC as contained in annex 3 of this report. 

3.2 The Group used the table 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 

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

response/clarification by the working group 

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

the report 

(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-week deadline (bulk documents) for MEPC 

3.3 The Group reconfirmed that the next meeting of the GESAMP-BWWG, i.e. the 

twelfth meeting, will take place from 7 to 11 December 2009, to review the remaining 

four proposals received before the deadline of 28 August 2009. 

3.4 Bearing in mind that MEPC 61 was tentatively scheduled from 27 September 

to 1 October 2010 and considering the activities contained in the table above, the Group agreed 

to tentatively schedule its thirteenth meeting from 24 to 28 May 2010 with a deadline for 

submission of documents on Thursday, 1 April 2010. 
 - 5 - GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.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 noted that four proposals for Basic Approval had been submitted by China, 

Denmark (two proposals) and the Republic of Korea and one proposal for Final Approval had 

been received from Japan. 

4.1.2 The Group noted that, during this meeting, it was necessary to request additional 

information or clarification from all the applicants, as the dossiers were either incomplete or, 

more commonly, the information provided was unclear, so slowing down the evaluation process. 

As a result, the Group reiterated its request to MEPC to urge each Administration to check that 

all technical descriptions and specifications of the ballast water management systems (BWMS) 

and, in particular, those related to the operating conditions are included with each application. 

Equally important, all data pertaining to the safety of the ship and crew, human health and 

environmental exposure and risk need to be submitted with each application. Every application 

has to be fully evaluated by the Group and, whether it is recommended for approval or not, it is 

the Group’s experience that those applications finally assessed as not recommended for approval 

usually take up the greater proportion of the meeting’s time. An application that is not 

recommended for approval may, therefore, deny other potential applicant the chance of an early 

and possibly successful evaluation. 

4.1.3 Moreover, the Group requested that, for the purpose of consistency, information 

on Total Residual Oxidants (TRO) or Total Residual Chlorine (TRC) should be provided in the 

form of mg/L TRO or TRC as Cl2, for those systems using or producing oxidants to treat ballast 

water. 

4.2 Detailed review of the submissions

4.2.1 Details of the submissions reviewed by the Group can be seen in: 

Annex BWMS Administration 

4 ATLAS-DANMARK Ballast Water Treatment System 

(ABTS) (with onboard generated ANOLYTE oxidant) 

Denmark 

5 JFE Ballast Water Management System (JFE-BWMS) 

that makes use of “TG Ballastcleaner® and 

TG Environmentalguard®” 

Japan 

6 Sunrui Ballast Water Management System China 

7 DESMI Ocean Guard Ballast Water Management 

System 

Denmark 

8 Blue Ocean Guardian (BOG) Ballast Water Management 

System 

The Republic of 

Korea 
GESAMP-BWWG 11/6 - 6 - 

I:\MEPC\60\2-12.doc

4.2.2 Bearing in mind the criteria associated with Procedure (G9) and having reviewed all of 

the information associated with these submissions, the Group recommended that: 

 .1 Basic Approval should not be granted to ATLAS-DANMARK Ballast Water 

Treatment System (ABTS) (with onboard generated ANOLYTE oxidant) 

(Denmark); 

 .2 Final Approval be granted to JFE Ballast Water Management System 

(JFE-BWMS) that makes use of “TG Ballastcleaner® and 

TG Environmentalguard®” (Japan); 

 .3 Basic Approval be granted to Sunrui Ballast Water Management System (China); 

 .4 Basic Approval be granted to DESMI Ocean Guard Ballast Water Management 

System (Denmark); and 

 .5 Basic Approval be granted to Blue Ocean Guardian (BOG) Ballast Water 

Management System (the Republic of Korea). 

4.3 Specific comments related to ATLAS-DANMARK Ballast Water Treatment System 

(ABTS) (with onboard generated ANOLYTE oxidant) 

4.3.1 The Group noted the system was conceptual only although it was already being used to 

treat sewage water, apparently effectively, and that the data had been generated in association 

with this parallel application of the proposed technology. 

4.3.2 The Group considered that much of the data required for Basic Approval was either 

missing from the application and much of that which was provided was regarded by the Group as 

not relevant. 

4.4 Specific comments related to JFE Ballast Water Management System (JFE-BWMS) 

that makes use of “TG Ballastcleaner® and TG Environmentalguard®” 

4.4.1 The Group approved the approaches taken by the applicant to show that there would not be 

any unacceptable risks to the environment, the crew, the general public or the safety of the ship. 

4.4.2 Whilst recommending that Final Approval be granted to this system, the Group identified 

a number of issues that would require consideration by the Administration prior to issuing a 

Type Approval Certificate. 

4.5 Specific comments related to Sunrui Ballast Water Management System 

4.1 The Group approved the approaches taken by the applicant to show that there would not 

be any unacceptable risks to the environment, the crew, the safety of the ship or the general 

public eating seafood. However, the Group noted that other aspects of the Human Exposure 

Scenario had not been addressed and recommended that this should be taken into account in the 

application for Final Approval. 

4.2 The Group recommended that comprehensive corrosion testing should be addressed in the 

application for Final Approval. 
 - 7 - GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

4.6 Specific comments related to DESMI Ocean Guard Ballast Water Management 

System 

4.6.1 The Group noted that this system did not generate any significant quantities of chemical 

by-products and so it was not necessary to apply the usual processes of risk assessment. 

However, the Group recommended that, for Final Approval, any model used to estimate 

environmental or human exposures should be supported by all of the appropriate input data used 

by the applicant, even when such data are based on limits of detection. 

4.7 Specific comments related to Blue Ocean Guardian (BOG) Ballast Water 

Management System 

4.7.1 Due to the fact that none of the potential chemical by-products were found in the treated 

ballast water at levels greater than those in the control (untreated) water, the Group agreed that 

there would be no unacceptable risks to the environment, the crew and general public from 

chemicals produced by this system. In addition, the Group also agreed that it was unlikely that 

there would be unacceptable risks to the safety of the ship caused by corrosive effects of any 

associated chemicals. Nevertheless, the Group recommended that appropriate corrosivity testing 

be carried out and the results included in the application for Final Approval. 

5 ANY OTHER BUSINESS 

5.1 The Group requested MEPC to urge Administrations to check that all of the requirements 

of Procedure (G9) had been met before submitting an application for either Basic or Final 

Approval. In making such a request, the Group wished to point out that a considerable amount of 

time can be wasted in ascertaining this requirement, particularly when an application is based on 

a conceptual system, even when such a system might be being used in another, unrelated, 

application where seawater is not the base medium of the treatment. 

6 CONSIDERATION AND ADOPTION OF THE REPORT 

6.1 A draft report of the eleventh meeting of the GESAMP-BWWG was produced 

on Saturday, 24 October 2009 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. 

6.2 The Chairman expressed his appreciation for the long hours and substantial efforts made 

by the members of the Group throughout the week and closed the meeting at 17 h 30. 

*** 

GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 1 

LIST OF MEMBERS WHO ATTENDED THE ELEVENTH MEETING 

OF THE GESAMP-BWWG 

Mr. Jan Linders (Chairman) 

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 

Ms Teresa Borges 

Senior Technical Officer 

General-Directorate of Health 

(Environmental Health Division) 

Avenida Rio de Janeiro, no 58, 3o dto 

1700-338 Lisbon 

Portugal 

E-mail: 

Tel: 

Mobile: 

tborges@dgs.pt

+351 2 1843 0599 

+351 9 1779 8048 

Mrs. Annette Dock 

Director 

Adalia Toxicology Consultants 

Runslingan 3E 

SE-187 72 TÄBY 

Sweden 

E-mail: 

Tel: 

Fax: 

Mobile: 

“Adalia AB” <info@adalia.se>

+46 8 510 149 36 

+46 8 510 126 02 

+46 70 483 11 23 

Dr. Stephan Gollasch 

GoConsult 

Grosse Brunnenstr. 61 

22763 

Hamburg 

Germany 

E-mail: 

Tel: 

Mobile : 

sgollasch@aol.com 

+49 40 390 54 60 

+49 177 590 54 60 

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 
GESAMP-BWWG 11/6 

ANNEX 1 

Page 2 

I:\MEPC\60\2-12.doc

Mr. Edward Lemieux 

Director 

Center for Corrosion Science and Engineering 

Naval Research Laboratory, Code 6130 

4555 Overlook Avenue, SW 

Washington, DC 20375 

USA 

E-mail: 

Tel: 

Fax: 

Mobile: 

edward.lemieux@nrl.navy.mil 

(202)-404-2123 (Office) 

305-293-4213 

240-475-6918

Dr. Kitae RHIE 

Professor of Biology Department 

Kyung Hee University 

#1 Hoe-ki Dong 

Dong-dae-moon Ku 

Seoul 130-701 

Republic of Korea 

Current postal address: 

Dr. Kitae RHIE 

c/o Chesapeake Biology Laboratory-UMCES 

P. O. Box 38 

One Williams Street 

Solomons, MD 20688 

USA 

E-mails: 

Tel: 

Fax: 

Mobile: 

Tel: 

Mobile: 

rhiekt@khu.ac.kr 

+82 (2) 961-0603 

+82 (2) 961 0244 

+82 16-9343-3860 

410-326-7218 

310-626-7621 

Dr. Frank Stuer-Lauridsen 

LITEHAUZ ApS 

Diplomvej 381 

DK 2800 Lyngby 

Denmark 

E-mail: 

Tel: 

Mobile: 

fsl@litehauz.dk 

+45 8870 8675 

+45 2023 0202

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 

Mr. John Crayford 

2 Dunmow Hill 

Fleet 

Hampshire GU51 3AN 

United Kingdom 

E-mail: 

Tel: 

j.crayford@ntlworld.com 

+44 (0)1252 672245 
GESAMP-BWWG 11/6 

ANNEX 1 

Page 3 

I:\MEPC\60\2-12.doc 

GESAMP 

Mr. Martin Soderberg 

GESAMP Officer 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment, London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax 

Mobile: 

msoderbe@imo.org 

+44 (0)20 7463 4139 (Direct) 

+44 (0)20 7587 3210 

0755 269 9604

IMO SECRETARIAT 

Mr. Miguel Palomares 

Director 

Marine Environment Division 

International Maritime Organization 

4 Albert Embankment 

London SE1 7SR 

United Kingdom 

E-mail: 

Tel: 

Fax: 

mpalomares@imo.org 

+44 (0)20 7587 3218 

+44 (0)20 7587 3210

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. 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. 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 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 2 

AGENDA FOR 

THE ELEVENTH MEETING OF THE GESAMP-BWWG 

1 Introduction 

2 Issues of confidentiality 

3 Terms of reference and time frame 

4 Review of proposals for approval of Active Substances 

 .1 Denmark ATLAS-DANMARK Ballast Water Treatment System 

(ABTS) (with onboard generated ANOLYTE 

OXIDANT) for Basic Approval 

.2 Japan: JFE Ballast Water Management System (JFE-BWMS) 

that makes use of TG Ballastcleaner® and 

TG Environmentalguard® for Final Approval

 .3 China: Sunrui Ballast Water Management System 

 for Basic Approval 

 .4 Denmark: DESMI Ocean Guard Ballast Water Management 

System for Basic Approval 

.5 Republic of Korea: Blue Ocean Guardian (BOG) Ballast Water Management 

System for Basic Approval 

5 Any other business 

6 Consideration and adoption of the report 

*** 

GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 3 

TERMS OF REFERENCE 

FOR THE TECHNICAL GROUP (GESAMP-BWWG) 

1 Consideration of development of necessary methodologies and information requirements 

in accordance with the “Procedure for approval of ballast water management systems that make 

use of Active Substances (G9)” (adopted by resolution MEPC. 169(57)) for consideration 

by MEPC 60. 

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 Procedure (G9)); 

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

approval (see paragraph 4.3.1 of Procedure (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 Procedure (G9)); 

.4 scientific evaluation of any further information submitted 

(see paragraph 8.1.2.6 of Procedure (G9)); 

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

for approval (see paragraph 5.3 of Procedure (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 Procedure (G9)); and 

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

by MEPC (see paragraph 8.1.2.10 of Procedure (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 the MEPC (see paragraph 8.2 of Procedure (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. 

***

GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 4 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

ATLAS-DANMARK Ballast Water Treatment System (ABTS) 

(with onboard generated ANOLYTE oxidant) 

Submitted by Denmark for Basic Approval 

0 SUMMARY 

0.1 Having reviewed all of the data provided by Denmark with the application for 

Basic Approval together with additional information received from the applicant, the Group 

recommended that Basic Approval should not be granted to the ATLAS-DANMARK Ballast 

Water Treatment System (ABTS). 

0.2 The Group noted that this proposed system was conceptual only. However, it was 

recognized that such a system was already being used to treat sewage water, apparently 

effectively, and that data had been generated in association with this parallel application of the 

proposed technology. 

0.3 Whilst it was recognized that the analysis had been carried out on the treated sewage 

water in order to give some indication of the amount of chemical by-products, which might be 

expected from a system installed on board ship, the Group concluded that a more detailed 

analysis of such chemicals should be carried out before the system can be recommended for 

Basic Approval. 

0.4 The Group noted that the applicant did not provide information regarding the 

identification and description of the unit operations associated with this system. The Group also 

noted that information regarding the Human Exposure Scenario (MEPC 56/2/2, annex 9) had not 

been provided. 

0.5 The Group will require that this information should be fully supported and documented so 

that it can be taken into account should the system again be submitted for review for 

Basic Approval in the future. 

0.6 The Group had the following concerns with information in the dossier: 

.1 the dossier describes a conceptual treatment of ballast water based on the 

electrolysis of seawater. It described two stages of treatment; at uptake and during 

tank holding time. The dossier only provided information about the planned TRO 

concentration of ANOLYTE to be injected into the ballast water at uptake. 

Adequate information had not been provided to determine the intended TRO 

concentration during tank holding time. The dossier neither provided information 

on the intended control scheme nor the dosage of Active Substance concentrations 

during tank holding time. The applicant had provided a theoretical control scheme 

using an ORP sensor, for which the correlation with TRO had not been established 

and which is known to be affected by pH; 
GESAMP-BWWG 11/6 

ANNEX 4 

Page 2 

I:\MEPC\60\2-12.doc

.2 the chemical analysis provided was from a different treatment system to the 

proposed system and, therefore, could not be accepted as representative of the 

“Simulated Ballast Water Discharge” required for Basic Approval. 

Notwithstanding this observation, the chemical analysis report did not include 

Quality Control (QC)/Quality Assurance (QA) documentation (G9 4.2.4); 

.3 whole effluent ecotoxicity testing (WET) had not been performed (G9 5.2.1.1) on 

simulated ballast water discharge; and 

.4 the Group noted that the dossier lacked detailed information on the prediction of 

discharge and environmental concentration of the Active Substances and Relevant 

Chemicals identified.

0.7 The Group stressed that each application is evaluated on its own merits as a “stand-alone” 

dossier. 

0.8 The Group noted that the system is intended to maintain an ANOLYTE concentration in 

the ballast tanks to achieve an Oxidation Reduction Potential (ORP) of +400mV. This will 

require the further addition of oxidant to the tank throughout the holding time. As the system 

does not incorporate a neutralization step prior to discharge, the risks from residual TRO 

concentrations upon discharge need to be carefully assessed. 

0.9 The Group was not able to estimate the discharge concentration in the system with 

repeated treatment with confidence and so encouraged the applicant to consider the neutralization 

of the Active Substances before discharge through operational or technical measures. 

1 INTRODUCTION 

1.1 The data used to evaluate ABTS were extracted from the Danish submission to the 

sixtieth session of MEPC as document MEPC 60/2. 

2 DESCRIPTION OF THE SYSTEM

2.1 The Group noted that the system proposed will involve the following stages in the 

treatment of ballast water: 

 .1 filtration with a 50 μm filter; 

 .2 production and storage of ANOLYTE; 

 .3 injection of ANOLYTE into the ballast water to maintain an ORP of +400 mV in 

the ballast tank. The Group assumed that this to be approximately equal 

to 1 mg/L TRO; and 

 .4 dispensing of CATHOLYTE into the treated ballast tanks. 
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ANNEX 4 

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2.2 A simplified schematic representation of the system showing only the main aspects is 

shown in the diagram below: 

2.3 The Group noted that ANOLYTE is generated on board using electrolytic cells in which a 

weak solution of sodium chloride in fresh water, generated onboard, is treated by electrolysis. 

2.4 This process produces: 

 .1 ANOLYTE hypochlorous acid (HOCL) solution - < 158.4 mg/L 

 ozone (O3) - < 1.4 mg/L 

 hydrogen peroxide (H2O2) - < 0.5 % (wt) 

 various positive ions - <0.5 % 

 pH 5.5 - 7.0 

 ORP 850 ± 150 mV 

 Stable for 48 h 

 .2 CATHOLYTE water - 99.87% w/v 

 hydroxyl ion - <170 mg/L 

 sodium hydroxide - <230 mg/L 

 sodium chloride - <630 mg/L 

 hydrogen - 4 ml/L 

Filter Ballast tank 

ANOLYTE 

storage tank 

Ballast water 

uptake 

Ballast water 

discharge 

Fresh water supply 

Salt storage 

tank 

ANOLYTE 

generator 

CATHOLYTE (may also be discharged 

otherwise)
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2.5 The Group noted that chemical composition both of ANOLYTE and CATHOLYTE is 

likely to be constant because it was made from salted water, not from natural seawater with 

associated variable constituents 

2.6 The Group also noted that, in the process of generating ANOLYTE, CATHOLYTE is 

also generated, which is ~0.1% sodium hydroxide (NaOH) solution with a pH of ~11 and 

an ORP of -850 ± 150 mV. 

2.7 The Group noted that the system is intended to maintain an ANOLYTE concentration in 

the ballast tanks to achieve an ORP of +400mV. This will require the further addition of oxidant 

to the tank throughout the holding time. As the system does not incorporate a neutralization step 

prior to discharge, this will result in the discharge of an undetermined TRO concentration. 

2.8 The Group noted that this type of treatment has been used for several years for the 

sterilization of animal and human feedstuff, for disinfecting sewage water and potable water as 

well as disinfecting swimming pools and aquariums where no significant adverse effects on 

humans, animals and aquatic life have been observed. 

2.9 However, it was noted that the use of this process on board ship was conceptual at the 

time of application and that all reported data were obtained from non ballast water applications. 

In particular, efficacy test results and chemical analyses of treated water were reported from 

sewage treated with a similar technology. 

3 CHEMICALS ASSOCIATED WITH THE SYSTEM

3.1 The Group noted that the following chemicals had been identified, by the applicant, as 

being anticipated chemicals of ballast water treated with this system: 

Composition of ANOLYTE/CATHOLYTE 

Chemical Name CAS Number Concentration Type 

Hypochlorous acid 7790-92-3 < 158.4 mg/L AS 

Ozone 10028-15-6 < 1.4 mg/L AS 

Hydrogen Peroxide 7722-84-1 < 0.5 % (wt) AS 

Chlorine Dioxide 10049-04-4 < 2.5 mg/L AS 

Hydrogen 1333-74-0 < 4 mL/L RC 

Sodium Hydroxide 1310-73-2 < 230 mg/L RC 

List of potential by-products produced in ballast water 

Chemical Name CAS 

Number Concentration Biodegradation Half-life 

Chlorite (Sodium Hypochlorite) 7681-52-9 Assumed < 2.5 mg/L 35 h 

Bromate (Potassium Bromate) 7758-01-2 Assumed < 10 μg/L 12 h 

Trichloro Methane 67-66-3 4.0 μg/L – mean value < 48 h 

Bromodichloromethane 75-27-4 0.6 μg/L – mean value 1.6 h (River Water) 

Dibromochloromethane 124-48-1 0.04 μg/L – mean value ~ 1 d (Surface Water) 

Tribromomethane 75-25-2 0.1 μg/L – mean value 2.6 d (Surface Water) 

Halo-acetic acids No available information 
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3.2 Data associated with each of the chemicals associated with the treated ballast water 

3.2.1 The data, provided by the applicant and used by the Group in the Risk Assessment are 

shown for: 

 .1 hypochlorous acid and sodium hypochlorite (appendix 1); 

 .2 potassium bromate (appendix 2); 

 .3 ozone (appendix 3); 

 .4 hydrogen peroxide (appendix 4); 

 .5 trihalomethanes (appendix 5); 

 .6 hydrogen (appendix 6); and 

 .7 sodium hydroxide (appendix 7). 

4 QUESTIONS PUT TO THE APPLICANT WITH RESPONSES AND THE 

GROUP’S REACTIONS 

4.1 The following part of this section shows the questions put to the applicant by the Group, 

the applicant’s responses and the Group’s reactions. 

Question 1: 

The submission indicates that, in the case of organism re-growth, additional ANOLYTE is 

to be dosed. Please could you explain more clearly how re-growth is to be determined? 

Response 1: 

 .1 It has been observed in the application of the technology that the ORP will 

decrease significantly, when re-growth appears. Therefore, each of the ballast 

tanks will be equipped with a stationary ORP probe. The exact ORP potential 

reached, when re-growth may appear is yet to be determined – but it appears to be 

about 400 mV. 

Reaction: The Group was not satisfied with this response as the dose to be used was still 

not clear. 
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Question 2: 

The Group considered that the possibility of transferring the full contents of one ballast 

tank to another is extremely small due to stresses imposed on the ship. Please could you 

indicate how this is to be achieved? 

Response 2: 

 .1 We do not intend to move water between the ballast tanks. In case of re-growth 

detected, according to our comments in paragraph 1, the ballast water intake 

ANOLYTE injection point is used for forced injection of an amount 

corresponding to the amount of ballast water in the tank in question. The resulting 

“plug” of ANOLYTE is then forced by the ballast pump for the corresponding 

water intake line and is dispersed in the tank. 

Reaction: The Group was satisfied with the answer. 

Question 3: 

The submission indicates that the CATHOLYTE is to be dosed into the ballast tanks when 

produced. Please could you indicate how this is to be achieved, i.e. how is the CATHOLYTE to 

be directed to the individual ballast tanks as needed? 

Response 3: 

 .1 When discharging the CATHOLYTE to the ballast water, we anticipate that fixed 

pipes to one or two ballast tanks closest to the ANOLYTE generator will 

discharge all CATHOLYTE produced. 

 .2 According to Lloyds, the CATHOLYTE led to any of the ballast tanks will have 

any influence on the stability of the ship. 

Reaction: The Group was satisfied with the answer.

Question 4: 

In a previous response, it was indicated that there is a possibility that the CATHOLYTE 

may be directed to “Grey” or “Black” water tanks. What will be the effect of adding 

CATHOLYTE to either of these waste streams, particularly the effect on standard marine 

sewage treatment plant reactions? 

Response 4: 

 .1 The CATHOLYTE is a very weak solution (<0,1%) of NaOH, which is not 

anticipated to create any problems in sewage plants, which will have to cope with 

substantially higher concentrations of soap solutions, etc. 

Reaction: The Group was satisfied with the answer. 
GESAMP-BWWG 11/6 

ANNEX 4 

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Question 5: 

Is there any different effect or reaction with the use of this treatment with marine water 

rather than fresh water as usually experienced with shore-based sewage treatment plants? 

Response 5: 

 .1 There does not appear to be reasons, why the salt water should behave differently 

in connection with ANOLYTE, than experienced in the previous tests on land. 

Reaction: The Group was not satisfied with the answer as it believed that the resulting 

chemistry from the electrolytic chlorination is different in natural seawater 

due to variations in the concentrations of bromated ions, POC, and TSS. 

Question 6: 

Recognizing that this question has already been addressed, please could you confirm and 

clarify the apparent anomaly between the forecast degradation rate of ANOLYTE, i.e. 

“up to 48 hours stability” and “excess of two weeks” plus “4-5 weeks”. What is the actual 

situation? 

Response 6: 

 .1 “Up to 48 hours” is a guaranteed period, where the ANOLYTE maintains the 

performance. For the last month, we have stored samples of ANOLYTE with ORP 

of initially 900 mV – 1000 mV. For example, the ORP does not appear to degrade 

more than 50 mV during four weeks, when stored in darkness at room 

temperature. 

Reaction: The Group was satisfied with the answer. 

Question 7: 

No PEC values have been calculated and concentrations for Active Substances and 

Relevant Chemicals have not been identified under ballast water treatment conditions. 

However, there are data from a different matrix (sewage) in a system operating under 

presumably different conditions from ballast water treatment system (flow rate, filter size 

and type). The Group kindly requests you to clarify the expected PECs after ballast water 

treatment and relate to ecotoxicologically relevant criteria such as PNEC rather that solely 

drinking water and bathing water criteria, which may not be protective of the environment. 

Response 7: 

 .1 No modelling (using e.g. MAMPEC software) has yet been carried out – but is 

anticipated in a next phase – and therefore no PEC/PNEC ratios have been 

evaluated. 

Reaction: The Group noted the answer. 
GESAMP-BWWG 11/6 

ANNEX 4 

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Question 8: 

The ballast water concentrations given in table on p10 of annex of confidential material lists 

THMs of with an average value of 4.74 ug/L from MOOSBURG tests. In section 1.5.1.3 

of MEPC 60/2 a value of 9.0 ppm (mg/L) is mentioned, but in the report of IWB from 

MOOSBURG, a value of 9.0 ug/L is given (presumably the latter is correct). Kindly, clarify 

the proper range and average values from the 13 tests used for the application 

(MEPC 60/2, page 7). 

Response 8: 

 .1 This is an error on our part. The measurements in MOOSBURG report 1,6 

to 9,0 μg/liter THM (and not as our section 1.5.1.3 states “mg/liter”). Also in that 

paragraph we write that the drinking water limiting value (Germany) is 50 mg/liter 

– naturally, this should also be 50 μg/liter. 

Reaction: The Group was satisfied with the answer. 

Question 9: 

The chemical analysis performed in addendum 3 does not provide the information for 

chemical characterization of control water and treated water, such as salinity, temperature, 

bromated ion, pH, DOC, POC and TSS. Could you provide the additional information for 

that? Also are there any actual measurements of TRO of treated water during 

these 13 series? The Group cannot evaluate the statement without such information that 

the levels of by-products are compatible with drinking water requirement, so that no 

further risk assessment would be needed. 

Response 9: 

 .1 In connection with a later phase, these data are anticipated. In our application 

(section 1.4.4), the sterilization is anticipated finalized within two minutes – 

however, the exact level (apart from compatibility with drinking water 

regulations) of Residual Oxidant is not known. During the several years of using 

the ANOLYTE for disinfection of swimming pools, waste effluent and treatment 

of human foods for salmonella, campylobactor, etc., the TRO level is considered 

to be very low. 

Reaction: The Group was not satisfied with the answer as it believed that the resulting 

chemistry from the electrolytic chlorination is different in natural seawater 

with variations in the concentrations of bromate ions, POC, and TSS. 

Question 10: 

The Group considers that the system described in Addendum 3 appears to be different 

from the system proposed in this dossier. Is the same filtration component used as in the 

former case, with Amiad filter unit? Is it intended that the filter with 50μm diameter can 

eliminate all other organisms, rather than indicator microbes? If the answer is positive, 

can the filtration system be scaled up to 1000 m3/h (indicated in your non-confidential 

application) from 26 m^3/h (described in addendum 3)? 
GESAMP-BWWG 11/6 

ANNEX 4 

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Response 10: 

 .1 Initially, we anticipated using the AMIAD filter unit (like the system used by 

SINCERUS) or a similar system from the company BOLLFILTER. These are 

both mechanically based filters, where we consider that the potential for failure is 

present. In our present configuration, we are considering a ceramic porous filter 

developed by the company COMETAS. We have tested this filter (tests are still in 

progress) using very dirty and “slimy” harbour water during the late summer. We 

have found, that we can maintain a 30μm capacity when using a cyclic 

(PLC controlled) with pressure drop across the filters of 0,2 bar. When pressure 

drop increases to 0,4 bar across the individual units flushing is carried out (we 

further have an alarm at 0,6 bar pressure drop). The capacity is 160 m3/h per filter 

unit. The system is highly modular and consists of modules approximately 500 x 500 

mm cross-section and length 2000mm – weighing each about 95 kg. 

Reaction: The Group was satisfied with the answer. 

Question 11: 

The application states that the CATHOLYTE will be applied to ballast tank for 

sterilization. Are there any actual measurements of TRO changes before and after adding 

the CATHOLYTE to treated ballast water by ANOLYTE? 

Response 11: 

 .1 Such measurements have not been carried out. As mentioned in paragraph 3, the 

effect on the ballast water is anticipated to be minimal – due to the very low 

addition rate. It should be noticed that there is no oxidant in the CATHOLYTE. 

However, as mentioned in paragraph 4, we favour the solution with discharge to 

the “grey/black water” sewage system. 

Reaction: The Group was satisfied with the answer. 

Question12: 

In the section of “chemical hazards” in paragraph 3.2.1, it is stated that the ventilation 

could remove the chlorite and bromated ions and THMs. Could you provide more detailed 

explanation for this statement? The concentration of these chemicals in ballast water can 

be removed by aeration, however, ventilation for headspace of ballast tank is completely a 

different matter, we need clarification of this. 

Response 12: 

 .1 Ventilation in the ballast tanks will only be required in case of manual inspection 

and work carried out in the tanks at sea. 

Reaction: The Group was satisfied with the answer. 
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Question 13: 

You propose to maintain an ORP level of +400mV in the tank. Please could you identify 

what TRO dosage concentration this ORP corresponds to? Please could you provide the 

anticipated and/or measured TRO dosage concentration of the system when operated on 

ballasting. 

Response 13: 

 .1 In the ASI Electrolytic Cells, we produce ANOLYTE with a Free Active Chlorine 

(FAC) of 250 mg/Litre – 400 mg/Litre and acidity pH = 6,5 – 7,0 and because of 

the internal membrane system (which effectively separates the ANOLYTE and 

CATHOLYTE and prevents mutual neutralization with regard to electrical 

activity) we can maintain an ORP in excess of +900 mV. 

 .2 Thereby, the biocidal activity of the Hypochlorous acid in the ANOLYTE has 

been found to be about 300 times more active than the Sodium hypochlorite 

generated in earlier systems (as stated by Professor T. E. Cloete, Department of 

Microbiology and Plant Pathology, University of Pretoria, South Africa). 

 .3 Immediately after injection (dilution 1:250 to 1:500) the ABTS achieves a 

concentration of about 1 mg/Litre of Hypochlorous acid in the ballast water, 

which has proven to terminate all micro-organic life within about two minutes in 

previous land based application. 

 .4 After the disinfection has been carried out, the ANOLYTE will be degraded into 

compounds normally present in seawater and only the trace contaminants of 

by-products as mentioned in our application (paragraph 3.0) are anticipated. 

 .5 The presence of bulkheads and frames in real ballast tanks are not (as far as we 

know) realistically simulated in the tanks used for land-based testing (like NIVA, 

NIOZ, etc.) and this is the reason that we want a countermeasure against possible 

re-growth by using as indicator the level of electrical activity – after consulting 

with our Cell sub-supplier ASI selected as an ORP of +400mV. 

 .6 As mentioned above, we do not anticipate any TRO in the ballast water at that 

time but, as stated previously, we will use this as a signal for administering an 

extra dose of ANOLYTE to the offending tank. 

 .7 However, the precise way of carrying out this process and determining the ORP 

“trip point” would be part of full-scale tests. 

Reaction: The Group did not agree with the applicant’s conclusion that no TRO will be 

anticipated in the ballast water since, according to published literature, 

400mV roughly corresponds to 1 mg/L TRO as Cl2. The Group accepted this 

as the initial and maintained treatment concentration in this system. 
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Question 14: 

The Group has not been able to localize Whole Effluent Toxicity testing of the proposed 

system that has been carried out. Are such tests as per Procedure (G9), paragraph 5.3.2, 

and is the Methodology 6.2.1.1 available? 

Response 14: 

 .1 All toxicity data used in the application were derived from the open literature and 

from information provided by SINCERUS (Germany) and ASI (UK), who have 

marketed the electrolytic cells for production of ANOLYTE for many years. 

 .2 All these data are related to effects of the individual relevant active and 

by-product substances (Hypochlorous Acid, Bromate Ion, Ozone, Hydrogen 

Peroxide, Trihalomethanes, Hydrogen and Sodium Hydroxide). No whole 

effluent effects for real or simulated ballast water have been studied and we 

appreciate that this may be necessary in relationship to a Final Approval. 

 .3 However, in view of the previous widespread approved use of ANOLYTE for 

disinfection in connection with swimming pools, aquariums, human food and 

animal feed preservation and even medicinal use, the study on combined effluent 

influence on a marine environment was not considered crucial at the present stage. 

 .4 Furthermore, the company ASI (our electrolytic cell partner) worked with this 

technology for several years while a resident of South Africa. 

 .5 Also, the system from Resource Ballast Water (South Africa) uses as part of the 

BWMS process an earlier version of our technology and was previously granted 

Basic Approval by the GESAMP-BWWG (MEPC 57, annex 5). Another 

South Africa Company Radical Waters) also uses the basic electrolytic process 

commercially and several studies by Dr. Eugene Cloete (Department of 

Microbiology and Plant Pathology, University of Pretoria, South Africa) on the 

safety and efficiency of ANOLYTE are available in the open literature. 

 .6 Finally, we would like to draw your attention to the meeting in the European 

Commission – “32nd meeting of representatives of Members States Competent 

Authorities for the implementation of Directive 98/8/EC” (9 February 2009) – 

where our technology was evaluated to be “not covered by the EU Biocide 

Directive”. This was considered by the Danish Environmental Agency to be an 

indication that the concept is harmless to humans and the environment. 

Reaction: The Group was not able to substantiate the applicant’s last point. The Group 

noted the answer of the applicant and concluded that the tests required were 

not available. 
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ANNEX 4 

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5 HUMAN HEALTH ASSESSMENT

5.1 The Group noted that, whilst the ANOLYTE is generated onboard, it is also stored in a 

tank prior to treatment of the incoming ballast water. 

5.2 The Group noted the various chemicals identified in the ANOLYTE or CATHOLYTE 

(see section 3.1) and agreed that these presented the following potential hazards to the crew: 

 .1 Free Active Chlorine (FAC) - (hypochlorous acid, sodium hypochlorite, chlorine 

and chlorine dioxide) is: 

 .1 a skin and eye irritant; and 

 .2 may be corrosive at high concentrations. 

 .2 Ozone is: 

 .1 toxic when inhaled and, even at low doses; 

 .2 can be harmful to the upper respiratory tract and lungs; and 

 .3 irritating to the eyes. 

 .3 Hydrogen peroxide is: 

 .1 irritating to the eyes. 

 .4 Hydrogen :

 .1 can cause dizziness, headache, nausea and unconsciousness in 

concentrations from 8-10% and upwards; and 

 .2 is [explosive][flammable] in concentrations from 4%-74%. 

 .5 Sodium hydroxide is: 

 .1 very corrosive to skin and eyes; and 

 .2 harmful in contact with skin; and 

 .3 harmful via inhalation. 

5.3 In addition to those chemicals produced and/or stored onboard, the Group recognized that 

the following chemicals in the ballast water after treatment by the system have potential hazards 

as follows: 

 .1 Chlorite (sodium hypochlorite) is: 

 .1 a skin and eye irritant. 
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 .2 Potassium bromate is: 

 .1 toxic when ingested; 

 .2 irritant to skin, eyes and the respiratory system and; 

 .3 a probable human carcinogen. 

 .3 Trihalomethanes and in particular bromoform are:

 .1 toxic by inhalation; 

 .2 harmful if swallowed; 

 .3 irritating to the skin and eyes; and 

 .4 a probable human carcinogen. 

6 RISKS TO THE SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC 

6.1 The Group noted that the applicant had recognized that the ANOLYTE and 

CATHOLYTE concentrations are potentially corrosive, however, the applicant concludes that, 

since the exposure times are short, no increase in corrosion rates are anticipated. As no data were 

provided to validate the applicant’s assumption, the Group was not satisfied with the provided 

information. The Group recommended that comprehensive testing be conducted in accordance 

with the guidance provided in section 5.1 of the “Report of the eighth meeting of the 

GESAMP-BWWG”, contained in MEPC 59/2/16. In particular, the applicant should address the 

relatively high concentration of oxidants in the ANOLYTE storage tank and the downstream 

piping should provide data regarding the corrosiveness in that area. 

6.2 The Group noted that it was proposed to direct the output from a Fresh Water Generator 

directly to the electrolysis unit producing ANOLYTE and CATHOLYTE. The Group 

recognized that the Fresh Water Generator is normally used for producing potable water on the 

ship and that it is not usually permitted to use this plant in coastal waters due to the possibility of 

contamination with bacteria. The Group considered that this aspect has yet to be fully 

considered. 

6.3 The Group noted that the ANOLYTE is to be stored on board prior to use and that a 

stainless steel tank is to be used for this storage. It was also noted that the ANOLYTE has a high 

concentration of chlorine with a significant ozone content and that the usually expected safety 

consideration associated with such storage such as tank ventilation, inspection and maintenance 

had not been specifically identified and addressed. 

6.4 The Group noted, in the applicant’s responses, that, depending upon residual levels of 

chemicals in the ballast tank, it was also intended to inject more ANOLYTE into the ballast tank 

following the initial dose on uptake. It was also noted that the additional dosing was to be made 

by forcing a “plug of ANOLYTE” through the ballast water main to the tank by the ballast water 

pump. No indication of how this “plug of ANOLYTE” was to be metered was given. It was 

considered relevant to note that it is usual to fill a ballast tank to capacity to avoid “free surface 
GESAMP-BWWG 11/6 

ANNEX 4 

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effect” on stability and therefore the availability of space for such dosing may be limited. 

Furthermore, the corrosive effect of transit of “a plug of ANOLYTE”, with a very high 

concentration of chlorine, through the ballast main appears not to have been identified. 

The Group considered that such basic operational aspects of this system had not been given 

sufficient consideration in this application. 

6.5 The Group noted that no attempt had been made to quantify the risks to the crew or the 

general public from chemicals either used or being produced in the proposed system 

(Ref: Methodology, paragraph 2.3.1, BWM.2/Circ.13). 

6.6 The Group noted the applicant had stated that the concentrations of chemicals found in 

sewage treated with this system were regarded as good/excellent according to the EU Directive 

on bathing water. In addition, it was recalled that the Group had previously recommended that 

Basic Approval be granted to a system which produced greater concentrations of chlorine (AOX) 

than cited above. However, since the Group had not received sufficient information on the 

differences between the sewage treatment system and the proposed system, it was not possible to 

evaluate the inherent risks. 

6.7 The Group noted that the applicant did not provide information regarding the 

identification and description of the unit operations associated with this system where crew 

exposure could take place (e.g. production, storage and dosing of ANOLYTE/CATHOLYTE). 

Therefore, the Group considered that there was significant uncertainty regarding the potential 

exposure to chemicals which may be experienced by the ships’ crews. 

7 ENVIRONMENTAL RISK ASSESSMENT 

7.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

7.1.1 Although the applicant did not provide all of the information to indicate whether the byproducts in the treated ballast water would meet the PBT criteria, the Group agreed on the 

following information based on data provided in previous applications. 

Chemical Persistence (P) 

Yes/No 

Bioaccumulation (B) 

Yes/No 

Toxicity (T) 

Yes/No 

Bromoform Yes No No

Chloroform Yes No No

Bromodichloromethane Yes No No 

Dibromochloromethane Yes No No 

Sodium hypochlorite No No No 

Potassium bromate Yes No No 

Haloacetic acids Yes No No 

7.2 Calculation of Predicted Environmental Concentration (PEC) 

7.2.1 The Group noted that the applicant had not provided any PEC values for those chemicals 

identified in the treated ballast water. Furthermore, the chemical concentrations provided were 

from treated sewage which the Group considered may not be representative of those anticipated 

in treated ballast water. 
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7.2.2 The Group concluded that it was not possible to perform an appropriate environmental 

risk assessment. 

8 CONCLUSIONS AND RECOMMENDATIONS

8.1 The Group considered that, due to the lack of information and data, the dossier presented 

and reviewed did not demonstrate the necessary confidence that a safe and consistent application 

of the proposed system could be assured. 

8.2 The Group recommended that the comprehensive corrosion testing be conducted in 

accordance with the guidance provided in section 5.1 of the “Report of the eighth meeting of the 

GESAMP-BWWG” contained in MEPC 59/2/16. 

8.3 The Group recommended that information regarding the identification and description of 

the unit operations associated with this system and the Human Exposure Scenario 

(MEPC 56/2/2, annex 9) should be fully supported and documented. 

8.4 The Group concluded that it was not possible to perform an appropriate human risk 

assessment. 

8.5 The Group concluded that it was not possible to perform an appropriate environmental 

risk assessment. 

8.6 Due to the lack of required data, the Group was unable to carry out any meaningful risk 

assessment and so did not recommend that this system be granted Basic Approval. 

* * * 
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APPENDIX 1 

DATA ASSOCIATED WITH HYPOCHLOROUS ACID, SODIUM HYPOCHLORITE 

AND CHLORINE/CHLORINE DIOXIDE 

1 Acute aquatic toxicity 

1.1 Data on the acute aquatic toxicity from the US EPA [REF 3] database are reproduced 

below for representatives of four taxonomic groups (fish, mollusks, crustaceans and 

phytoplankton). 

Chemical Organism Scientific Name & 

Common Name 

Development 

Stage 

Toxicity 

Endpoint 

Effect 

Measure 

Exposure 

Duration 

Toxic 

Dose 

(μg/L) 

Salvenius fontinalis 

Brook Trout 

Fish 110-150 mm LC100 Mortality 9 h 350 

Marone saxatilis 

Striped Bass 

~ 1.0 g LC50 Mortality 6 h 610 

Crassostrea gigas 

Pacific Oyster 

Larvae/Velige

r 

Mollusks LC50 Mortality 1 h 556 

Mercenaria 

mercenaria 

Hard Clam 

Larvae LC50 Mortality 48 h 5 

Acellus aquaticus 

Aquatic Sowbug 

Mature, Nonreproducing Crustacea LC50 Mortality 24 h 754 

ns 

Calinectus sapidus 

Blue Crab 

Adult LC50 Mortality 48 h 750 

Cl2

Algae Chlorophyceae 

Green Algae 

Several 

species 

 Abundanc

e 

24 h 100 

Fish Ciupea pallasii 

Pacific Herring 

Juvenile LC50 Mortality 96 h 65 

Leopomis 

macrochirus 

Bluegill 

Juvenile LC50 Mortality 96 h 580 

Dreissena 

polymorpha 

Zebra Mussel 

Adult LC95 Mortality 17.7 h 90 

Crassostrea 

virginica 

American Oyster 

7 day Larvae LC50 Mortality 0.5 h 120 

Ciibanarius humilis 

Hermit Crab 

Several 

species 

LC50 Mortality 96 h 2500 

Mollusks 

Hemigrapsus nudus 

Shore Crab 

Adult LC50 Mortality 96 h 1418 

Chlorella 

sorokiniana 

Green Algae 

225 cells/mL Mortality 20 h 200 

HOCl 

Crustacea 

Plankton Various LC50 Mortality 96 h 90 

1.2 Endocrine disruption 

No information was found on endocrine disruption by chlorine. 
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1.3 Sediment toxicity 

Chlorine may react with soil and sediment components to form chlorides, which, depending on 

their water solubility, are easily washed out (US EPA database - [REF 3]). 

1.4 Bioavailability/biomagnification/bioconcentration 

There is no potential for the bioaccumulation or bioconcentration of chlorine. 

1.5 Food web/population effects 

As there is no potential for bioconcentration of chlorine, animals higher in the food chain will not 

be affected. 

1.6 Data on mammalian toxicity 

Sodium hypochlorite solution causes moderate mucosal irritation, the extent of which depends on 

the volume ingested, the concentration of the preparation and the duration of the contact. When 

swallowed it may cause gastrointestinal irritation, with nausea, vomiting and diarrhea. 

1.6.1 Acute toxicity 

In humans, oral doses of 2.5 mg chlorine/d, had no adverse effects for prolonged periods and no 

adverse effects were noted in persons ingesting water containing 50 ppm - 90 ppm of chlorine 

(~1.4 to 2.6 mg Cl/kg/d) for a short period of time. Drinking water concentrations of >90ppm 

chlorine caused irritation of membranes of throat and mouth in some studies and concentrations 

of chlorine in drinking water in excess of 25 ppm make the drinking water unpalatable. 

1.6.2 Effects on skin and eye 

1.6.2.1 Free active chlorine can cause mild skin irritation to corrosive injury depending on the 

duration of the contact, concentration and pH of the solution. An 8% sodium hypochlorite 

solution has been shown to not cause skin irritation. Mild eye irritation to corrosive injury can 

also be caused depending on the concentration and pH of the solution and the duration of contact. 

1.6.2.2 Chlorine itself is considered a primary irritant to the mucous membranes of the eyes, 

nose, and throat and to the linings of the entire respiratory tract. The extent of acute injury to 

humans depends on the concentration and duration of exposure as well as the water content of the 

tissue involved. 

1.6.2.3 Mild irritation is noticed at 1 ppm – 3 ppm, chest pains, vomiting and coughing 

at 30 ppm and death at 430 ppm for 30 minutes and at 1000 ppm for a few minutes. For animals 

(small rodents, cats, etc.) doses above 3000 ppm for more than 1 hour are considered critical. 

1.6.3 Repeated-dose toxicity 

See chronic toxicity. 
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1.6.4 Chronic toxicity 

1.6.4.1 The major target organs for the sub-chronic/chronic toxicity of chlorine in humans are 

the respiratory tract and the blood. The major target organs for the sub-chronic/chronic toxicity 

of chlorine in animals are the immune system, the blood, the cardiovascular system and the 

respiratory tract. The US EPA [REF 3] has derived an oral reference dose (RD) of 0.1 mg/kg/d 

for chlorine, based on a no-observed-adverse-effect level (NOAEL) of 14.4 mg/kg/d in a chronic 

drinking water study in rats. 

1.6.4.2 As an example 55 workers exposed to about 1.0 ppm of chlorine, 8 h/day for at 

least 90 days exhibited asthma, chronic bronchitis, tuberculosis, and emphysema. The 

concentration of 1 ppm is roughly equivalent to 0.415 mg/kg/d (i.e., 4 times the above stated RD 

of 0.1 mg/kg/day). 

1.6.4.3 Groups of 70 male and female rats were given drinking water containing up to 275 ppm 

of chlorine (14.4 mg/kg/d) for two years. No abnormalities were detected at interim sacrifices or 

at the end of the study (EPA to state the abovementioned RD used these results). 

1.6.4.4 Similar experiments have been carried out using rhesus monkeys, cats, hamsters and 

mice. 

1.6.5 Developmental and reproductive toxicity 

No conclusion on the developmental/reproductive toxicity of chlorine can be made based on the 

limited information available from human and animal studies. 

1.6.5.1 Humans – No information was found in the secondary sources searched to indicate that 

chlorine is a developmental/reproductive toxicant in humans. 

1.6.5.2 Animals 

1.6.5.2.1 Female rats were given chlorine concentrations of 0 mg/L, 1.0 mg/L, 10 mg/L, 

or 100 mg/L in the drinking water (as HOCl) for two-and-a-half months prior to conception and 

throughout gestation. They were killed on gestation day 20, and the fetuses were examined. 

1.6.5.2.2 Fetuses in the 100 mg/L group had soft tissue defects, including improper orientation 

of the heart and adrenal agenesis, and a slightly increased incidence of skeletal variants, such as 

incompletely ossified or missing sternebrae or rudimentary ribs. 

1.6.5.2.3 In other studies, chlorine administered to pregnant mice was not found for 

reproductive and teratogenic effects when given in drinking water as 10-13 ppm of sodium 

hypochlorite and hydrochloric acid (to maintain water pH of 2.5) or when given in heavily 

chlorinated municipal drinking water (US EPA – [REF 3]). 

1.6.6 Mutagenicity/genotoxicity 

In a US EPA [REF 3] investigation, chlorine was mutagenic in Salmonella typhimurium strains 

TA1530 and TA100, without metabolic activation; produced chromosome aberrations in human 

lymphocytes and other mammalian cells (at 20 ppm); interacted with DNA in E. coli test 

(as sodium hypochlorite); and was negative for the induction of erythrocyte micronuclei or 
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chromosome aberrations of bone marrow cells of mice (up to 8 mg/kg/day of NaOCl) for up to 

five days. 

1.6.7 Toxicokinetics 

No additional information is available on toxicokinetics for chlorine. 

1.7 Data on environmental fate and effects under aerobic and anaerobic conditions 

1.7.1 Modes of degradation (biotic; abiotic) 

1.7.1.1 Chlorine hydrolyzes very rapidly in water (half-life in natural waters, 0.005 s). In fresh 

and wastewaters at pH >6, complete hydrolysis occurs forming Hypochlorous acid (HOCl) and 

chloride ion (Cl–

). The Hypochlorous acid ionizes to hydrogen ion (H+) and hypochlorite ion 

(OCl–). At pH >5, OCl– predominates; at pH <5, HOCl predominates. Free chlorine (Cl2, HOCl, 

and OCl–

) reacts rapidly with inorganic material such as bromide and more slowly with organic 

material present in natural waters. 

1.7.1.2 These reactions yield chloride, oxidized organics, chloroganics (including 

trihalomethanes), oxygen, nitrogen, chlorate, bromate and bromoorganics. 

1.7.2 Bioaccumulation, octanol/water partition coefficient 

There is no potential for the bioaccumulation or bioconcentration of chlorine. 

1.7.3 Reaction with organic matter 

Chlorine will react slowly with organic material present in natural waters. These reactions yield 

chloride, oxidized organics, chloroganics (including trihalomethanes), oxygen, nitrogen, chlorate, 

bromate and bromoorganics. 

1.7.4 Potential physical effects on wildlife and benthic habitats 

1.7.4.1 Chlorine has been shown to have high acute toxicity to many organisms. Low-level 

chlorination (0.05 to 0.15 mg/L) results in significant shifts in the species composition of marine 

phytoplankton communities. Chlorine is phytotoxic but is also essential to plant growth; crops 

need around 5 pounds or more of chlorine per acre. 

1.7.4.2 Acute toxicity to plants is characterized by defoliation with no leaf symptoms and, in 

higher plant forms, by spotting of the leaves (at 1.5 mg/m3

) and marginal injury (at 150 mg/m3 

to 300 mg/m3). No data were found regarding the toxicity of chlorine to terrestrial animals; 

however, the data from experimental studies indicate that injury to animals would occur only in 

the presence of high concentrations of chlorine, either in drinking water or the ambient 

atmosphere. 

1.7.4.3 As chlorine and chlorine compounds do not persist in sediments it is not expected to 

affect benthic habitats unless directly applied in high concentrations. 
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1.7.5 Potential residues in seafood 

As there is no potential for the bioaccumulation or bioconcentration of chlorine, there is no risk 

of potential residues in seafood. 

1.7.6 Any known interactive effects 

No other effects have been identified. 

* * * 
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APPENDIX 2 

DATA ASSOCIATED WITH POTASSIUM BROMATE 

1 Introduction 

1.1 Ozone reacts with bromide in seawater to form the Bromate ion (BrO3

– ). The half-life of 

the Bromate ion is approximately 12 hours. Fresh water typically contains a very low 

concentration of the bromide ion and therefore the production of the Bromate ion does not occur 

in fresh water. 

1.2 It was noted that the data presented applies to Potassium Bromate for which compound 

data were more available. 

2 Acute aquatic toxicity 

2.1 The PAN (Pesticide Action Network) pesticides database includes data on the acute 

toxicity of Bromate to aquatic organisms. Effects of Bromate (in seawater) on representatives of 

three different taxonomic groups (fish, mollusks, and Crustaceans) are summarizedin the table 

below [REF 4]: 

Organism Scientific Name 

and 

Common Name 

Development 

Stage 

Toxicity 

Endpoint 

Effect 

Measure 

Exposure 

Duration 

Toxic 

Dose 

(μg/L) 

Cymatogaster 

aggregata 

Shiner Perch 

25 – 60 

mm 

Fish LC100 Mortality 72 h 880000 

Onchorhynchus 

keta 

Chum Salmon 

~ 30 mm LC50 Mortality 96 h 512000 

Crassostrea gigas 

Pacific Oyster 

Mollusks Larvae EC50 Mortality 48 h 30000 

Macoma inquinata 

Bent-nosed Clam 

20 - 30 

mm 

LC100 Mortality 72 h 880000 

Pandalus danae 

Coon Stripe Shrimp 

40 - 50 

mm 

Crustaceans LC100 Mortality 72 h 880000 

Neomysis 

awatschensis 

Opossum Shrimp 

1.5 - 3.0 g LC50 Mortality 24 h 176000 

3 Endocrine disruption 

No examples have been reported for the endocrine disruptive properties of Bromate ions. 
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4 Sediment toxicity 

4.1 The soil absorption factor of Bromate ion is estimated as follows from the relation with 

the octanol/water partition coefficient, Pow: Koc = 0.41 · log Pow (– 7.18)8

 = 2.7 · 10– 8 L/kg 

4.2 This estimate of Koc is below the value of anticipated toxicity to benthic organisms and 

therefore no risk of toxicity to benthic organisms is foreseen. 

5 Bioavailability/biomagnification/bioconcentration 

5.1 The octanol/water partition coefficient log value of Bromate ion is -7.18 (see above). 

Therefore the Bromate is not considered having a risk of concentration in organisms. 

6 Food web/population effects 

6.1 The bromate ion does not accumulate and therefore will not affect organisms at higher 

levels in the food chain. 

7 Data on mammalian toxicity 

7.1 The toxicity of the Bromate ion to mammals is based on the strong oxidizing properties. 

Bromate ions may affect skin and eyes by exposure and cause coughing, pharynx pain, nausea, 

vomiting, abdominal pain, diarrhea or central nervous system disturbance if taken orally. 

7.2 Acute toxicity 

7.2.1 Experiments on rats have shown a single dose of Potassium Bromate of concentration 

LD50 300 - 350 mg/kg bodyweight given orally is lethal [REF 5]. 

7.3 Effects on skin and eye 

7.3.1 Bromate ions will cause skin and eye inflammation and pain. 

7.4 Repeated-dose toxicity 

7.4.1 The exposure of rats to Bromate for 15 weeks demonstrated a NOAEL (No Observed 

Adverse Effect Level) of 30.0 mg/kg bw/d. 

7.5 Chronic toxicity 

7.5.1 The issue has been intensively discussed in the reports from other ballast water 

Basic Approval processes, where several experiments are recorded (e.g. previously mentioned 

IARC monograph 73) using mice, rats and hamsters. The results appear to be, that when oral 

intake exceeds about 2 mg/kg bodyweight per day tumors are beginning to develop after 

typically 100 days of experiments. 

7.5.2 In the ABTS, a maximum concentration of Bromate ion below 10 μg/L is anticipated in 

the ballast water. This implies, that a risk could be present at an oral intake of 200 L/kg bw/d of 

ballast water – which is unlikely to happen. Furthermore, the halftime of Bromate ion decay is 
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about 12 hours, where indeed the toxic processes are desired. Therefore, chronic toxicity is not 

considered relevant for mammalian toxicity hazards at these low concentrations. 

7.6 Developmental and reproductive toxicity 

7.6.1 The issue has been intensively discussed in the reports from other ballast water 

Basic Approval processes and it was noted, that only limited data are available on the 

reproductive or developmental effects of Bromate by oral intake or by inhalation. 

7.6.2 The few results (for rats) indicated that Sodium Bromate treatment did not produce any 

adverse signs of general toxicity in any of the dose levels tested (which ranged from 0 mg/kg to 

about 25 mg/kg bodyweight). With reference to the chronic toxicity data above, such large intake 

is improbable. 

7.7 Mutagenicity/genotoxicity 

7.7.1 The issue has been intensively discussed in the reports from other ballast water Basic 

Approval processes and it was noted that several experiments have been conducted (typically 

over 80 weeks). 

7.7.2 Under the conditions of the study, Potassium Bromate single doses (corresponding to a 

Bromate ion dose of 154 mg/kg bw by injection) had no potential for carcinogenic damage in 

newborn male or female rats or mice, even using a higher single dose (corresponding to 

orally 231 mg/kg bw of Bromate ion) does not initiate renal tumors within a 104-week of 

treatment over 104 weeks (oral daily dose 32.3/kg bw Bromate ion dose) that resulted in renal 

Aden carcinomas in 15% and renal adenomas in 30% of the rats. However, with reference to the 

chronic toxicity data above, such large intake is improbable. 

7.8 Toxicokinetics 

7.8.1 Bromate may be converted into hypobromic acid by hypochloric acid in the stomach. 

Liver and kidney tissues may degrade Bromate to bromide by a process involving glutathione, 

although only a small amount appears to be reduced in this way. 

7.8.2 Bromate is excreted mainly by urine as faeces may also eliminate Bromate and bromide. 

Bromate concentrations in urine peaks after about 1 hour, and Bromate is not detectable in 

plasma after 2 hours. 

8 Data on environmental fate and effects under aerobic and anaerobic conditions 

8.1 Modes of degradation (biotic; abiotic) 

8.1.1 Bromine is reportedly removed from seawater by several mechanisms. 

8.1.2 HOBr/OBr– reacts with natural organic matter to form Bromoform (CHBr3) by the 

Haloform reaction. Also, in the presence of ammonia, HOBr/OBr– will react rapidly to form 

monobromamine which can subsequently disproportionate to NHBr2 and NH3 or with excess 

HOBr/OBr- it can react further to form N2 and bromide. The rate of these reactions varies light 

incidence and water salinity. 
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8.2 Bioaccumulation, octanol/water partition coefficient 

8.2.1 Small amounts of bromine (1-2 ppm) were detected in the adipose (fat-storing) tissues of 

mice, but not of rats, fed bread treated with Potassium Bromate in a lifetime study. 

8.3 Reaction with organic matter 

8.3.1 Bromate will not volatilize and is only slightly adsorbed onto soil or sediment. Because it 

is a strong oxidant, its most likely fate is reaction with organic matter, leading to the formation of 

bromide ion. Potassium bromide is also reportedly harmful if ingested in large amounts and may 

cause skin and eye irritations. 

8.4 Potential physical effects on wildlife and benthic habitats 

8.4.1 As noted previously, the half-life of the Bromate ion in seawater is fairly short (~12 h) 

and its estimated absorption coefficient is very low (about 2.7 · 10– 8 L/kg). Therefore, no 

potential of effects on benthic organisms is probable. Furthermore, the Bromate ion is not 

accumulated and therefore will not affect high-order organisms in a food chain. 

8.5 Potential residues in seafood 

8.5.1 The Bromate ion is not accumulated and therefore there will be no potential residues in 

seafood. 

8.6 Any known interactive effects 

8.6.1 Under normal environmental conditions, it is difficult for the Bromate ion to be reduced. 

However, it may be reduced to the bromide ion in the presence of ferrous ions, activated carbon 

or other carbonaceous substances. 

* * * 
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APPENDIX 3 

DATA ASSOCIATED WITH OZONE 

1 Background 

1.1 Ozone is an unstable gas that cannot be stored. In pure (fresh) water Ozone has a half-life 

of 10-30 minutes. In seawater the half-life is reduced to 5.3 seconds. Ozone decomposition rate 

increases in accordance with the increase of temperature and pH. The rate increases fast in the 

neutral to alkaline range at any temperature. This tendency accelerates with the increase of 

temperature. The pH value of ballast water is generally between 5 and 8, in which range the 

decomposition of Ozone progresses quickly. Therefore, it is highly unlikely that Ozone will have 

an effect on any ecosystem by the time the ballast water is discharged. 

1.2 Basic Approval has previously been recommended by the GESAMP-Ballast Water 

Working Group for use of systems designed for the treatment of ballast water with considerable 

higher content of ozone and several of the data below are retrieved from the documents of these 

processes [ADD. 4]. 

2 Acute aquatic toxicity 

2.1 The PAN (Pesticide Action Network - [REF 6]) pesticides database was used to obtain 

data on the acute toxicity of Ozone to aquatic organisms. The effect of Ozone on representatives 

of two taxonomic groups (fish and molluscs) is reproduced below. 

Organism Scientific Name & 

Common Name 

Development 

Stage 

Toxicity 

Endpoint 

Effect 

Measure 

Exposure 

Duration 

Toxic 

Dose 

(μg/L) 

Lepomis macrochirus 

Bluegill 

3.82 g LC50 Mortality 24 h 60 

Morone saxatilis 

Striped Bass 

Larvae 20 

mm 

LC50 Mortality 6 h 150 

Fish 

Pimephales promelas 

Fathead Minnow 

Larvae LC50 Mortality 0.03 h 100 

Molluscs Dreissena polymorpha 

Zebra Mussel 

Adult LC50 Mortality 5.78 h 520 - 

530 

3 Chronic toxicity 

3.1 There are only limited data on the chronic aquatic toxicity of Ozone. 

3.2 It is reported that the concentration of Ozone will break down to <11 μg/L 

within 40 seconds in seawater and within 3.5 hours in fresh water, and to <0.14 μg/L (which is 

considered as the natural background level) within 75 seconds in seawater and 6.5 hours in 

fresh water. Therefore, it may be assumed that Ozone has no chronic aquatic toxicity. 

4 Endocrine disruption 

4.1 There have been no documented studies on the endocrine disruptive properties of Ozone. 

Due to its rapid dissolution (see above), it is considered not to be an endocrine disruptor. 
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5 Sediment toxicity 

5.1 The decomposition rate of Ozone is high enough so that there is no concern of toxicity to 

benthic organisms (see above). 

6 Bioavailability/biomagnification/bioconcentration 

6.1 Ozone decomposes very rapidly in natural water. Therefore there is no risk that Ozone 

may become concentrated in organisms. 

7 Food web/population effects 

7.1 Ozone does not persist or concentrate in organisms therefore there is no concern of effect 

on any animal higher up the food chain. 

8 Data on mammalian toxicity 

8.0 The toxicity of Ozone to mammals is based on its strong oxidizing property. Ozone 

causes irritation to the eyes and to the pharynx, trachea, bronchi and bronchiole when inhaled. 

8.1 Acute toxicity 

8.1.1 Acute toxicity data for Ozone is available from test conducted on mice 

(CHEMINFO-Canadian Center for Occupational Health and Safety [REF 7]). Data have been 

submitted for inhalation only and not for oral and dermal toxicity as Ozone is a gas and thus 

inhalation is the main exposure route of concern. 

8.1.2 The acute toxicity of Ozone (4 hours, LD50) is 5.9 ppm - 6.8 ppm. 

8.2 Effects on skin and eye 

8.2.1 Ozone gives no effect to the skin but causes irritation to the eyes at levels of 2 ppm or 

more when exposed for several minutes. 

8.3 Repeated-dose toxicity See chronic toxicity. 

8.4 Chronic toxicity 

8.4.1 In a series of studies, mice and rats exposed to 0.01 mg/kg -0.02 mg/kg bw/d for 105 

weeks to 130 weeks displayed increased incidence of non-carcinogenic lesions of the nose and 

lungs. Several studies also examined the effects of long-term exposure to monkeys. Exposures 

ranging from 0.003 mg/kg – 0.013 mg/kg bw/d for 3-18 months consistently showed significant 

structural alterations to lungs. Many of the changes seemed irreversible six months after exposure 

had stopped. 

8.5 Developmental and reproductive toxicity 

8.5.1 A study on offspring of rats continuously exposed to 0.020 mg/kg or 0.03 mg/kg bw/d for 

four days during middle or late pregnancy produced reduced growth rates after birth and delayed 

behavioral development. Maternal toxicity was not reported. 
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8.5.2 Another study reported a decrease in fetal body weight gain in the offspring of mice 

exposed to 0.024 mg/kg but not to 0.008 mg/kg or 0.016 mg/kg bw/d, on days 7 to 17 of 

pregnancy. Signs of maternal toxicity were observed. 

8.5.3 Embryo toxicity in the form of increased resorption was observed in rats exposed 

to 0.03 mg/ and 0.04 mg/ bw/d, but not 0.013 mg/kg -0.025 mg/kg bw/d. Maternal toxicity was 

not reported. 

8.5.4 Continuous exposure of mice from six days prior to mating to postnatal day 22 resulted in 

reduced body weight and slight effects in neurobehavioral development of the offspring. 

8.5.5 Maternal toxicity was not evaluated. No effects on reproductive performance (proportion 

of successful pregnancies, litter size, offspring viability and sex ratio) were noted. 

8.6 Mutagenicity/genotoxicity 

8.6.1 From a study with rats and mice exposed to 0.0021 mg/kg, 0.01 mg/kg and 0.02 mg/kg 

bw/d of Ozone for 105 weeks -130 weeks, there was no evidence of carcinogenicity in male and 

female rats, inconclusive evidence in male mice and some evidence in female mice. Ozone 

showed no tumor promoter properties in these studies. 

8.6.2 There are a number of studies, which examine the potential for mutagenicity of Ozone in 

humans but due to some deficiencies not all of them seem to be conclusive. 

8.6.3 However cytogenetic aberrations have been observed in the lymphocytes of hamsters 

exposed to 0.0048 mg/kg - 0.086 mg/kg bw for 5 hours and in the macrophages of female rats 

exposed to 0.0024 mg/kg - 0.016 mg/kg bw for 6 hours. Several studies have also shown 

that Ozone is mutagenic in bacteria and in human and mammalian cells in vitro following 

inhalation exposure. 

8.7 Toxicokinetics 

8.7.1 Ozone is absorbed in both the upper and lower respiratory tract. It is a potent oxidant that 

reacts with protein and lipids, particularly within biological membranes. A small amount 

of Ozone is absorbed into the blood. The extreme reactivity of Ozone limits its ability to 

accumulate. 

9 Data on environmental fate and effects under aerobic and anaerobic conditions 

9.1 Ozone reacts with both organic and inorganic compounds when present in the ballast 

water. The Ozone molecule is an unstable substance and higher temperatures and higher pH 

promote its decomposition in water. In seawater, Ozone degradates as mentioned previously with 

a half-life of between 5 seconds and 30 seconds. It is finally decomposed to oxygen and water. 

9.2 Therefore, it will not be possible to find Ozone in the ballast water when discharged – 

normally several days after the ABTS treatment. 
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9.3 Modes of degradation (biotic; abiotic) 

9.3.1 Because of the rapid disintegration, this issue is not important. 

9.3.2 Bioaccumulation, octanol/water partition coefficient 

9.3.1 Because of the rapid disintegration, this issue is not important. 

9.4 Reaction with organic matter 

9.4.1 Because of the rapid disintegration, this issue is not important. 

9.5 Potential physical effects on wildlife and benthic habitats 

9.5.1 Because of the rapid disintegration, this issue is not important. 

9.6 Potential residues in seafood 

9.6.1 Because of the rapid disintegration, this issue is not important. 

9.7 Any known interactive effects 

9.7.1 Ozone produces oxygen when decomposed in water. As a result, it increases the amount 

of oxygen dissolved in the water, which helps aquatic organisms. In a closed system, such as a 

seawater aquaculture system, Ozone removes nitrogen in the form of ammonia that is discharged 

from fish. 

* * * 
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APPENDIX 4 

DATA ASSOCIATED WITH HYDROGEN PEROXIDE

1 Background 

1.1 Hydrogen Peroxide is a known oxidant, which is normally used in considerable higher 

concentrations (generally 3% or higher in household applications for wound treatment and 

general disinfection and typical in 20% - 40% solution for various industrial applications) than 

anticipated in the ballast water (less than 0.5 %) immediately after addition of the ANOLYTE by 

the ABTS, considered in this proposal. No Material Safety Data Sheets (MSDS) appears to be 

available for the low concentration, considered here but an MSDS for a considerably higher 

concentration (30%) is reproduced in [ADD. 5]. Furthermore, the concentration will be 

substantially reduced after a few hours interaction with the organic material contained in the 

ballast water. When discharged (after a few days), the concentration of Hydrogen Peroxide will 

be close to zero. 

1.2 From several sources the half-life is listed as typically 8 hours in fresh water 

(up to 20 days in chemically clean water). It is further stated, that half-life decreases to a range 

from a few minutes to a few hours in soil depending upon microbiological activity and metal 

contaminants. No information was found for degradation in biologically contaminated seawater. 

1.3 Therefore, even if Hydrogen Peroxide is relatively unimportant with relation to (medium, 

long-term) ecological hazards, some data will be provided. 

2 Acute aquatic toxicity 

2.1 The PAN [REF 6] pesticides database was used to obtain data on the acute toxicity of 

Hydrogen Peroxide to aquatic organisms and the effects of Hydrogen Peroxide on representatives 

of four taxonomic groups (fish, mollusks, crustaceans and phytoplankton) are listed below: 

Organism Scientific Name 

and 

Common Name 

Development 

Stage 

Toxicity 

Endpoint

Effect 

Measure 

Exposure 

Duration 

Toxic 

Dose 

(μg/L) 

Lepomis 

macrochirus 

Bluegill 

Fish Juvenile LC50 Mortality 96 h 26700 

Salmo salar 

Atlantic Salmon 

107 g LC50 Mortality 0.33 h 1230000

Mollusks Dreissena 

polymorpha 

Zebra Mussel 

Adult > 20 

mm 

 Mortality 0.50 h 29600 

Crustaceans Lepeophtheirus 

salmonis 

Salmon Louse 

Different 

Stages 

 Mortality 0.41 h 1500000

Phytoplankton Oscillatoria 

rubescens 

Blue-Green 

Algae 

Mixed 

Species 

 Mortality < 12 h 1750 
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Furthermore, the MSDS (from PAN) state the following Ecotoxical data: 

Channel catfish 96-hour LC50 = 37.4 mg/L 

Fathead minnow 96-hour LC50 = 16.4 mg/L 

Daphnia magna 24-hour EC50 = 7.7 mg/L 

Daphnia pulex 48-hour LC50 = 2.4 mg/L 

Fresh water snail 96-hour LC50 = 17.7 mg/L 

However, Hydrogen Peroxide is generally rated as “Not acutely toxic” and “Slightly toxic”. 

3 Endocrine disruption – No information has been available. 

4 Sediment toxicity 

4.1 No information has been found, but materials in the sediments would quickly degrade the 

small amounts, which might reach them. Therefore, there is no concern of toxicity to benthic 

organisms. 

5 Bioavailability/biomagnification/bioconcentration 

5.1 Because of the short half-life, there is no danger that Hydrogen Peroxide might 

concentrate in organisms. 

6 Food web/population effects 

6.1 Hydrogen Peroxide does not persist or concentrate in organisms, therefore, there is no 

concern of effect on any animal higher up the food chain. 

7 Data on mammalian toxicity 

7.1 Background 

7.1.1 Toxicity of Hydrogen Peroxide is generally not considered at the low concentration 

(< 0.5%) in the ANOLYTE produced by the ABTS. However, for higher aqua concentrations 

(20% - 40% solution), some information is available. 

7.2 Acute toxicity 

7.2.1 Because Hydrogen Peroxide is classified as “Not acutely toxic” and “Slightly toxic”, this 

does not need to be considered. 

7.3 Effects on skin and eye 

7.3.1 Hydrogen Peroxide will not affect the skin (at low concentrations), but may irritate the 

eyes if exposed for several minutes. 

7.4 Repeated-dose toxicity – See chronic toxicity. 
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7.5 Chronic toxicity 

7.5.1 In the PAN MSDS [REF 6], Hydrogen Peroxide has been classified as not carcinogenic to 

humans, but as confirmed carcinogenic to smaller mammals. However, at the small 

concentrations (in the ABTS ANOLYTE) and the short half-life, this needs hardly to be 

considered. 

7.6 Developmental and reproductive toxicity – No information was available. 

7.7 Mutagenicity/genotoxicity – No information was available. 

7.8 Toxicokinetics 

7.8.1 Hydrogen Peroxide reacts quickly and for this reason the ability to accumulate is limited. 

7.9 Data on environmental fate and effects under aerobic and anaerobic conditions 

7.9.1 Modes of degradation (biotic; abiotic) 

7.9.1.1 Because of the rapid disintegration of Hydrogen Peroxide, its short half-life and its 

limited concentration, this issue is not important. 

7.9.2 Bioaccumulation, octanol/water partition coefficient 

7.9.2.1 Because of the rapid disintegration of Hydrogen Peroxide, its short half-life and its 

limited concentration, this issue is not important. 

7.9.3 Reaction with organic matter 

7.9.3.1 Because of the rapid disintegration of Hydrogen Peroxide, its short half-life and its 

limited concentration, this issue is not important. 

7.9.4 Potential physical effects on wildlife and benthic habitats 

7.9.4.1 Because of the rapid disintegration of Hydrogen Peroxide, its short half-life and its 

limited concentration, this issue is not important. 

7.9.5 Potential residues in seafood 

7.9.5.1 Because of the rapid disintegration of Hydrogen Peroxide, its short half-life and its 

limited concentration, this issue is not important. 

7.9.6 Any known interactive effects 

7.9.6.1 Hydrogen Peroxide produces oxygen when decomposed in water. As a result, it 

increases the amount of oxygen dissolved in the water, which helps aquatic organisms. In a 

closed system, such as a seawater aquaculture system, Hydrogen Peroxide removes nitrogen in 

the form of ammonia that is discharged from fish. 

* * * 
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APPENDIX 5 

DATA ASSOCIATED WITH TRIHALOMETHANES 

1 Background 

1.1 The chemicals treated here are the so-called Trihalomethanes, which are formed, when 

three of the Hydrogen atoms of methane are exchanged with halogen atoms. The relevant 

compounds are: 

.1 Tribromomethane (bromoform) CHBr3

.2 Trichloromethane (chloroform) CHCl3

.3 Bromodichloromethane CHBrCl2 

.4 Dibromochloromethane CHBr2Cl 

1.2 The Trihalomethanes are by-products generated through the interaction of Ozone with 

organic material contained in the water. The production is fairly limited for ABTS and well 

within the limits allowed for international standards for potable water. 

1.3 Basic Approval has previously been recommended by the GESAMP-Ballast Water 

Working Group for use of similar systems designed for the treatment of ballast water that also 

produce these compounds and several of the data below are retrieved from the documents of 

these processes [ADD. 4]. 

2 Acute aquatic toxicity 

2.1 The PAN [REF 6] pesticides database was used to obtain data on the acute toxicity of 

Bromoform to aquatic organisms and the effects of Bromoform on representatives of four 

taxonomic groups (fish, mollusks, crustaceans and phytoplankton) are listed below: 

Organism Scientific Name and 

Common Name 

Development 

Stage 

Toxicity 

Endpoint 

Effect 

Measure 

Exposure 

Duration 

Toxic 

Dose 

(μg/L) 

Brevoortia tyrannus 

Atlantic Menhaden 

 Mortality 96 h 9000 

Cyprinodon varigatis 

Sheepshead Minnow 

8 - 15 mm LC50 Mortality 48 h 16000 

Fish 

Leopomis 

Macrochirus 

Bluegill 

0.32 - 1.2 g LC50 Mortality 24 h 33000 

Crassostrea Virginica 

American Oyster 

Mollusks 75 g LC50 Mortality 96 h 40000 

Mercenaria 

mercenaria 

Hard Clam 

141 g Mortality 96 h 140000 

Crustaceans Penaeus aztecus 

Brown Shrimp 

3.3 g Mortality 96 h 20000 

Phytoplankton Selenastrum 

capricornutum 

Green Algae 

 EC50 Chlorophyll 24 h 18700 
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2.2 Endocrine disruption 

No information is available on disruption of endocrine functions by Bromoform or the other 

Trihalomethanes. 

2.3 Sediment toxicity 

2.3.1 Bromoform and Dibromochloromethane have a minor tendency to be adsorbed by soils 

and sediments. Calculated and measured values of Koc (the organic carbon/water partition 

coefficient, an index of the relative mobility of a material in water-soil systems) for Bromoform 

range from 62 to 126 [REF 8]. These relatively low values imply that Bromoform will exhibit 

only a minor affinity for soil materials and will tend to be highly mobile [REF 9]. This low 

tendency for adsorption to soil has been confirmed in laboratory studies and in field studies. 

2.4 Bioavailability/biomagnification/bioconcentration 

2.4.1 Bioaccumulation potential of the trihalomethanes appears to be low, compared to many 

chlorinated organic compounds. A test of 28 days’ uptake and depuration were conducted on 

five commercially and recreationally important species. These included three species of Penaeid 

shrimp and one species of fish. It was found that both uptake and depuration were rapid, with an 

equilibrium reached after 24 hours. Bioconcentration factors were relatively low 

(between <1 and 10 times the water concentration). Experiments using the marine oyster 

Crassostrea virginica have shown that exposure to 90 μg/L Bromoform for 24 hours resulted in a 

bioconcentration factor of 7.6. Uptake and depuration of Bromoform were both rapid, both being 

essentially completed after 24 hours – 48 hours. However, it was concluded that the rate of 

uptake and depuration was dependent on the individual, the species and the concentration of 

Bromoform in the water. 

2.5 Food web/population effects 

2.5.1 There is no evidence as to whether Bromoform is concentrated upwards in the food chain 

but it appears unlikely that Bromoform persists in organisms. The same may be assumed for the 

other Trihalomethanes mentioned. 

2.6 Data on mammalian toxicity 

2.6.1 Background 

2.6.1.1 Bromoform has been considered to be a moderately toxic chemical that can be absorbed 

through the lungs, gastrointestinal tract, and skin. The oral LD50 value for Tribromomethane 

is 1,400 mg/kg and 1,550 mg/kg in male and female mice and 1,388 mg/kg and 1,147 mg/kg in 

male and female rats. 

2.6.1.2 Tribromomethane was slightly less acutely toxic than Chloroform, Bromodichloromethane, or Chlorodibromomethane in rats and mice. 

2.6.1.3 Exposure to bromoform vapours may cause irritation to the respiratory tract, 

lacrimation, and liver damage. The liver and kidney have been identified as target organs of 

trihalomethane toxicity in single exposure and short-term studies. Liver changes, described as 

variation in size of hepatocytes and vesiculation of biliary epithelial nuclei, were observed in 
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female rats that survived a single oral dose of Tribromomethane (1,071 mg/kg bodyweight or 

higher. Kidney changes were observed in rats that survived single oral doses of chloroform, 

Bromodichloro-methane, or Chlorodibromomethane, however, these changes were not observed 

in rats exposed to Tribromomethane. 

2.6.1.4 No pathologic changes were observed in rats exposed to Tribromomethane 

at 5 ppm, 50 ppm, or 500 ppm (which is equivalent to 0.13 mg, 1.5 mg, and 14 mg per rat per 

day, respectively) in drinking water for 28 days. 

2.6.2 Acute toxicity 

2.6.2.1 Oral LD50 values for Bromoform are 1,388 mg/kg and 1,147 mg/kg for male and female 

rats, respectively, and 1,400 mg/kg and 1,550 mg/kg for male and female mice, respectively. The 

principal cause of death in the laboratory animals following acute oral exposure is Central 

Nervous System failure. Clinical signs recorded for rats were e.g. hypothermia and enlargement 

of the livers and kidneys. 

 

2.6.2.2 At doses of 1,000 mg/kg bw, ataxia, sedation, and anesthesia occurred in mice 

within 60 minutes, with sedation persisting for about 4 hours. In rats, a single dose 

of 1,000 mg/kg bodyweight produced reductions in liver cytochrome and increases in porphyrin 

content, suggesting disturbances in hepatic heme metabolism. 

2.6.3 Effects on skin and eye 

2.6.3.1 Direct contact with Bromoform in liquid form causes redness and pain and may also be 

absorbed. 

2.6.4 Repeated-dose toxicity 

2.6.4.1 In a force-feeding study, rats and mice were treated 5 times weekly for 13 weeks 

with Bromoform at doses: 

Rats: 0, 12, 25, 50, 100, 200 mg/kg bw 

Mice: 0, 25, 50, 100, 200, 400 mg/kg bw 

2.6.4.2 All male rats treated with 100 mg/kg or 200 mg/kg/d and all female rats treated 

with 200 mg/kg mg/kg/d were lethargic. Bromoform was administered to male and female mice 

by force-feeding at daily doses of 50 mg/kg, 125 mg/kg, or 250 mg/kg/d for 14 days. 

2.6.4.3 Liver weights and serum glutamate oxaloacetate transaminase (SGOT) levels were 

increased and serum glucose and blood urea nitrogen (BUN) levels were decreased in the highdose animals. In a similar study, 72 mg/kg, 145 mg/kg, or 289 mg/kg/d of bromoform was fed by 

force-feeding to mice for 14 days. BUN levels and serum creatinine values were not altered, but 

serum glutamate-pyruvate transaminase (SGPT) levels were elevated in high-dose animals. 

2.6.4.4 Histological changes were seen in the kidneys and liver in the mid and high-dose groups 

and included hyperplasia of tubular epithelial cells, and hypertrophy and degenerative changes of 

the glomeruli in the kidney, and centrilobular cytoplasmic pallor and slight focal inflammation of 

the liver. 
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2.6.5 Chronic toxicity 

2.6.5.1 Rats were exposed to Tribromomethane at 5 ppm, 50 ppm, 500 ppm or 2,500 ppm in 

drinking water for 90 days. Liver lesions were observed and the severity was increased in male 

rats dosed with 2500 ppm Tribromo Methane and in female rats dosed with 500 ppm 

or 2,500 ppm Tribromo Methane. 

2.6.5.2 Tribromo Methane was force-fed to mice for 14 days at doses of 0 mg/kg, 72 mg/kg, 

145 mg/kg or 289 mg/kg/d. Blood urea nitrogen (BUN) and serum creatinine levels were not 

altered, however, active uptake of p-aminohippurate into renal cortical slices was reduced, and 

serum glutamate-pyruvate transaminase (SGPT) levels were elevated in the high dose animals. 

Similar effects were observed in animals administered Chloroform, Bromodichloromethane, or 

Chlorodibromo-methane. 

2.6.5.3 Histopathologic changes in the kidney (hyperplasia of tubular epithelial cells and 

hypertrophy and degenerative changes in the glomerular mesangium) and liver (centrilobular 

cytoplasmic pallor and slight focal inflammation) were observed in the mid dose and high dose 

groups. 

2.6.6 Developmental and reproductive toxicity 

2.6.6.1 Teratology studies (on birth defects) of organic concentrates were prepared from the 

drinking water of five cities in the United States. In addition, because low molecular weight 

organohalides may be lost during the concentration procedure, a synthetic mixture was prepared 

based on the EPA monitoring survey [REF 3] of the concentrations of these compounds 

in 110 cities in the United States. The latter mixture contained 68.9% Chloroform, 16.4% 

Bromodichloromethane, 10.0% Chlorodibromo-methane, and 3.6% Tribromomethane. Each of 

these preparations, dissolved in dimethyl sulfoxide, was administered by force-feeding to groups 

of pregnant mice on gestation period of 7 days - 14 days at dose levels equivalent to 300, 1,000, 

and 3,000 times the anticipated human exposure. 

2.6.6.2 The mice that were administered the synthetic mixture at 3,000 times the human 

exposure level received 10.3 mg organohalide/kg bw/d (the Tribromomethane dose level 

was 0.37 mg/kg/d). No effects on fetal weight, mortality, or the occurrence of skeletal or visceral 

anomalies were observed in any of the exposed groups. 

2.6.6.3 Chloroform was administered to pregnant rats by force-feeding from day 6 to day 15 of 

gestation at doses of 100 mg/kg, 200 mg/kg, or 400 mg/kg bw/d and Tribromomethane, 

Bromodichloro-methane and Chlorodibromomethane at doses of 50 mg/kg, 100 mg/kg, 

or 200 mg/kg bw/d. Corn oil was used as the vehicle for all studies. Only Tribromomethane did 

not have an effect on maternal body weight gain. No histopathologic changes were observed for 

any of the four Trihalomethanes in any of the dams or fetuses, nor were there any changes in the 

number of fetuses per dam, average fetal weight, or occurrence of visceral anomalies. 

2.6.7 Mutagenicity/genotoxicity 

Human data are considered inadequate in providing evidence of cancer by exposure to 

bromoform, while animal data indicate that long-term oral exposure can cause liver and intestinal 

tumors. Bromoform has been classified as a Group B2, probable human carcinogen. 
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2.6.8 Toxicokinetics 

2.6.8.1 Inhalation, ingestion and dermal routes of exposure can absorb Bromoform 

and Dibromo-chloromethane and in humans and laboratory animals, Bromoform is generally 

absorbed quickly. 

2.6.8.2 Although Bromoform and Dibromochloromethane are lipophilic, they do not appear to 

accumulate in adipose tissue. 

2.6.8.3 Bromoform and Dibromochloromethane are believed to metabolize by at least two 

route-independent pathways: Oxidation by cytochrome mixed function oxidase system and 

conjugation via glutathione S-transferase. Bromoform is primarily excreted via exhalation as the 

parent compound or carbon dioxide. 

3 Data on environmental fate and effects under aerobic and anaerobic conditions 

3.1 Modes of degradation (biotic; abiotic) 

3.1.1 Bromoform tends to volatilize from water when exposed to the air, where it is relatively 

stable with a half-life of 1 month - 2 months. Most measurements of the concentration of 

bromoform in air indicate that levels are quite low (<10 ppm). 

3.2 Bioaccumulation, octanol/water partition coefficient 

3.2.1 Bromoform may be slightly bioconcentrated by aquatic organisms. The octanol/water 

partition coefficient (Kow) (an index of the partitioning of a compound between octanol and 

water) is approximately 2.38 for bromoform [REF 10]. The magnitudes of these values suggest 

that the chemicals will tend to partition to fat tissues of aquatic organisms. 

3.3 Reaction with organic matter 

Trihalomethanes such as Bromoform are formed as a by-product when chlorine or bromine is 

used to treat ballast water. They result from the reaction of chlorine and/or bromine with organic 

matter in the water being treated. However, once the Bromoform is formed it does not appear to 

have any further reactions with organic matter. 

3.4 Potential physical effects on wildlife and benthic habitats 

No information is available on the effects of Bromoform on wildlife or benthic habitats. 

3.5 Potential residues in seafood 

No information is available on Bromoform residues in seafood. 

3.6 Any known interactive effects 

No other effects have been identified. 

* * * 
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APPENDIX 6 

DATA ASSOCIATED WITH HYDROGEN 

1 Background 

1.1 Hydrogen gas is produced in the electrolytic cells of the ABTS as a by-product of 

hydroxyl radicals. Basic Approval has previously been recommended by the GESAMP-Ballast 

Water Working Group for use of similar electrolytic systems designed for the treatment of ballast 

water that also produce hydrogen gas. Also, some of the following data originates from these 

proposal processes [ADD. 4]. 

1.2 Most of the hydrogen gas will be ventilated directly from the electrolytic cell modules 

during production of ANOLYTE. A very small fraction of the hydrogen gas will be present as 

micro-bubbles is the treated ballast water and will eventually be vented from the ballast tanks. 

2 Acute aquatic toxicity – No data on acute aquatic toxicity of hydrogen have been found. 

3 Endocrine disruption – None of the available data indicate toxicity for exposures of any 

duration. 

4 Sediment toxicity – There is no data on sediment toxicity of hydrogen. 

5 Bioavailability/biomagnification/bioconcentration – Hydrogen does not bioconcentrate 

in the tissues of organisms. 

6 Food web/population effects 

6.1 Hydrogen does not bioconcentrate or accumulates in the tissues of organisms. Therefore, 

no risk to organisms upwards in the food chain is present. 

7 Data on mammalian toxicity 

7.1 Acute toxicity 

High concentrations of hydrogen in the air can cause a deficiency of oxygen with risk of 

unconsciousness or death. Ingestion is not an observed route of exposure to gaseous hazardous 

materials. Exposure to moderate concentrations may cause dizziness, headache, nausea and 

unconsciousness - probably related to oxygen deficiency. 

7.2 Effects on skin and eye 

7.2.1 No detrimental effects of skin or eye contact have been reported. However, when ignited 

a risk of thermal burns is present. 

7.3 Repeated-dose toxicity 

7.3.1 None of the available data indicate toxicity for exposures of any duration. 
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7.4 Chronic toxicity 

7.4.1 None of the available data indicate toxicity for exposures of any duration. 

7.5 Developmental and reproductive toxicity

7.5.1 None of the available data indicate toxicity for exposures of any duration. 

7.6 Mutagenicity/genotoxicity 

None of the available data indicate toxicity for exposures of any duration. 

7.7 Toxicokinetics 

None of the available data indicate toxicity for exposures of any duration. 

8 Data on environmental fate and effects under aerobic and anaerobic conditions 

8.1 Modes of degradation (biotic; abiotic) 

8.1.1 Hydrogen exists as a natural compound in the atmosphere and will be dissipated rapidly 

in well-ventilated areas. 

8.2 Bioaccumulation, octanol/water partition coefficient 

8.2.1 Hydrogen will dissipate rapidly so there is no bioaccumulation. 

8.3 Reaction with organic matter 

8.3 Hydrogen has not been reported to react with organic matter. 

8.4 Potential physical effects on wildlife and benthic habitats 

8.4.1 No adverse ecological effects are anticipated. Hydrogen does not contain any Class I or 

Class II ozone depleting chemicals and no listing as a marine pollutant has been identified. 

8.5 Potential residues in seafood 

Hydrogen does not bioaccumulate so there is no risk of hydrogen residues in seafood. 

8.6 Any known interactive effects 

No other effects have been identified. 

* * * 
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APPENDIX 7 

DATA ASSOCIATED WITH SODIUM HYDROXIDE 

1 Background 

1.1 Sodium Hydroxide is present in the CATHOLYTE produced in the ABTS at an 

extremely low concentration (< 230 ppm). The concentration considered here is substantially 

lower, than considered in available Material Safety Data Sheets – however, a representative 

MSDS for concentrated NaOH is shown in [ADD. 6]. 

1.2 The Sodium Hydroxide solution does not itself participate in the disinfection process but 

is produced in a quantity which is discharged to the ballast tanks after the disinfection with 

ANOLYTE has been carried out and will increase the ballast water pH value to normal level 

(about 7 - 8). After this, the Sodium Hydroxide will also attack remaining organic material (and 

possible surviving organisms) and thereby reduce the amount of sludge in the tanks. 

2 Acute aquatic toxicity 

2.1 Sodium Hydroxide is a toxic material, which is listed by PAN as a “Bad Actor” – 

implying, that it has probable carcinogenic properties. The PAN [REF 6] pesticides database was 

used to obtain data on the acute toxicity of Sodium Hydroxide to aquatic organisms and the 

effects of Bromoform on representatives of four taxonomic groups (fish, mollusks, crustaceans 

and plankton) are listed below: 

Organism Scientific Name 

and 

Common Name 

Development 

Stage 

Toxicity 

Endpoint 

Effect 

Measure 

Exposure 

Duration 

Toxic 

Dose 

(μg/L) 

Notropis sp. 

Shiner 

 Mortality 120 h 100000 

Lepomis 

macrochirus 

Bluegill 

30 mm – 

60 mm 

 Mortality > 7 d 50000 

Fish 

Agonis 

cataphractus 

Hooknose 

Adult LC50 Mortality 48 h 33000 – 

100000 

Mollusks Cerastoderma 

edule 

Cockle 

Adult LC50 Mortality 48 h 330000 – 

1000000 

Crangon crangon 

Common Shrimp 

Adult LC50 Mortality 48 h 33000 – 

100000 

Crustaceans 

Palaemon 

adspersus 

Baltic Prawn 

200 mg – 

360 mg 

 Mortality 30 d 10000 – 

100000 

Zooplankton Ceriodaphnia 

dubia 

Water Flea 

 EC50 Mortality 48 h 100000 
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3 Endocrine disruption – No information was found. 

4 Sediment toxicity – No information was found and not considered important because of 

the weak solution involved. 

5 Bioavailability/biomagnification/bioconcentration 

5.1 The Sodium Hydroxide will not concentrate in the organisms. 

6 Food web/population effects 

6.1 Sodium Hydroxide does not persist or concentrate in organisms and there is no concern of 

effects higher up in the food chain. 

7 Data on mammalian toxicity 

7.1 Acute toxicity 

7.1.1 The Sodium Hydroxide MSDS reports an acute dermal dose (LD50) for rabbits 

of 1,350 mg/kg bw. 

7.2 Effects on skin and eye 

7.2.1 From the MSDS it is observed, that even weak solutions of Sodium Hydroxide will 

irritate the eyes and that a 0.04 % solution (corresponding to about 20 times the concentration in 

the CATHOLYTE, before diluted in the ballast water. Therefore, the effects on skin and eye are 

not considered important. 

7.3 Repeated-dose toxicity – No information on effects was found. 

7.4 Chronic toxicity – No information on effects was found. 

7.5 Developmental and reproductive toxicity – No information on effects was found. 

7.6 Mutagenicity/genotoxicity – No information on effects was found. 

7.7 Toxicokinetics 

7.7.1 Sodium Hydroxide is absorbed in the respiratory tract and through the skin and reacts 

with both protein and lipids. The effects are limited to the description previously. 

8 Data on environmental fate and effects under aerobic and anaerobic conditions 

8.1 Background 

8.1.1 Sodium Hydroxide is strongly alkaline. If released to surface water, this compound will 

cause the pH to increase dependent on the buffering capacity of the water body. Aquatic 

organisms become increasingly stressed as pH exceeds 9, with many aquatic species being 

intolerant of pH in excess of 10. 
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8.2 Modes of degradation (biotic; abiotic) 

8.2.1 The pH of the water body will locally increase only slightly (because of the weak 

solution) and the Hydrogen Peroxide will quickly be dispersed. 

8.3 Bioaccumulation, octanol/water partition coefficient – No bioaccumulation is possible 

in organisms. 

8.4 Reaction with organic matter 

8.4.1 Sodium Hydroxide reacts primarily with proteins and lipids, but – because of the low 

concentration from a ballast water discharge – this will give no concerns. 

8.5 Potential physical effects on wildlife and benthic habitats – No information was 

available. 

8.6 Potential residues in seafood 

8.6.1 Because Sodium Hydroxide does not bioaccumulate, it will not appear in seafood. 

8.7 Any known interactive effects No other information was available. 

*** 

GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 5 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

JFE Ballast Water Management System (JFE-BWMS) that makes use of TG Ballastcleaner 

and TG Environmentalguard 

Submitted by Japan for Final Approval 

0 SUMMARY 

0.1 Having reviewed the application details related to all aspects of the JFE-BWMS, 

the Group recommended that this Ballast Water Management System (BWMS) should be 

granted Final Approval. 

0.2 The Group concurred with the applicant following the use of the model MAMPEC to 

achieve the Predicted Environmental Concentrations (PECs) that the resulting concentrations, in 

the scenario defined by the applicant, would not result in any unacceptable risks for the 

environment. 

0.3 The Group recognized that the risk to the crew and general public was adequately 

assessed by using EUSES model 2.1. 

0.4 The recommendation that Final Approval be granted to the JFE-BWMS is subject to 

the Administration verifying that all the following recommendations have been fully addressed 

prior to issuance of a Type Approval Certificate: 

 .1 the neutralization step described by the manufacturer when using 

TG Environmentalguard should always be applied during discharge. The Group 

considered this step of great importance to ensure the safety of the marine 

environment, recognizing the importance of the neutralization process as an 

environmental risk mitigation measure; 

 .2 the maximum allowable dosage of Active Substances (TG Ballastcleaner) should 

be 20 mg/L as Cl2, expressed as the maximum injection rate. This injection rate 

and the relevant parameters needed for the calculation of the dosage rate should be 

monitored and recorded when the BWMS is in use. In addition, the actual TRO 

concentration monitored by adequately maintained TRO sensors should be 

recorded during ballasting; 

 .3 the maximum allowable discharge concentration of Relevant Substances 

(TG Environmentalguard) should not exceed 22 mg/L as sodium sulfite, which is 

expressed as maximum residual concentration after consumed in neutralization. 

The dosage and relevant parameters should be continuously monitored and 

recorded during discharge; 

 .4 the maximum allowable discharge concentrations of Active Substances 

(the concentration of TRO after neutralization) should be kept to the level 

proposed by the applicant, that is not exceeding 0.03 mg/L under any 

circumstances, as monitored by a suitably high sensitivity TRO sensor which is to 

be adequately maintained. This parameter should be continuously recorded during 

ballast water discharge; and 
GESAMP-BWWG 11/6 

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.5 having reviewed the information provided on corrosive effects, the Group did not 

agree with the applicant’s conclusions. The Group recommended that all of the 

corrosivity and coating degradation testing be repeated with adequate control 

throughout the testing to maintain the TRO concentrations between 15 mg/L 

and 20 mg/L. Furthermore, the Group invited the applicant to consider the 

guidance provided in section 5.1 of the “Report of the eighth meeting of the 

GESAMP-BWWG”, contained in MEPC 59/2/16. 

1 INTRODUCTION 

1.1 The Group recalled that, at its sixth meeting, it had recommended that Basic Approval be 

granted to TG Ballastcleaner and TG Environmentalguard and that MEPC 58 had granted such 

approval. 

1.2 Data used to evaluate this system were extracted from MEPC 60/2/2 (Japan) and were 

supplemented by additional information provided to the Group. 

2 DESCRIPTION OF THE SYSTEM 

2.1 The Group noted that the JFE-BWMS comprised: 

 .1 a 50 μm filter which is backflushed into the sea at point of uptake; and 

 .2 chemical treatment with TG Ballastcleaner, which is thoroughly mixed with the 

ballast water in a Venturi device. 

2.2 It was also noted that a surplus of TG Ballastcleaner remains in the ballast tanks 

following the initial treatment in order to prevent re-growth and hatching of any eggs associated 

with marine organisms. When the ballast water is discharged during loading in port, the TRO in 

the treated ballast water is neutralized using TG Environmentalguard. 

2.3 It was noted that the applicant claimed that this ensured that the ballast water is always 

non-toxic when discharged. 

2.4 It was also noted that, in the application for Basic Approval, the maximum chemical 

dosage rate proposed was 30mg/L TRO as Cl2. However, in the application for Final Approval, 

the applicant indicated that the maximum dosage rate has been reduced 

to 20 mg/L . 

2.5 The Group noted that the actual TRO measured after 5 days remained above 15 mg/L, 

shown as in the table below, the treated ballast water would have significant risks to marine 

ecosystem, if it were discharged without neutralization. 
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TRO concentration (mg/L Cl2) in ballast water at land-based test 

after 5 days’ holding time 

Test cycle Measured 

date 

Salinity TRO concentration 

Measured by sensor 

(mg/L) 

TRO concentration 

Measured by sensor 

(mg/L) 

after neutralization 

Cycle1 1st Dec 33.5 15.52 -0.200 

Cycle2 8th Dec 21.0 17.70 -0.200 

Cycle3 19th Jan 20.9 16.94 -0.200 

Cycle4 26th Jan 21.5 17.55 -0.200 

Cycle5 2nd Feb 20.5 17.96 -0.200 

Cycle6 9th Feb 21.3 17.89 -0.200 

Cycle7 16th Feb 32.2 18.06 -0.200 

Cycle8 23rd Feb 32.5 18.04 -0.200 

Cycle9 2nd Mar 32.4 17.87 -0.200 

Cycle10 9th Mar 32.3 17.97 -0.200 

2.5.1 In the documentation provided to the Group, it was noted that the TRO measured by the 

two methods was significantly different on one occasion. It was recommended that the 

appropriate QA/QC procedures of the land-based test facility should be reviewed to ensure that 

inconsistencies do not occur. 

2.6 The Group confirmed that the MADC of TRO after neutralization was maintained at the 

level of ND (or excess neutralizer was maintained). Considering that potential risk by neutralizer 

(sulfite) was in the level of acceptable level even with maximum discharge concentration (22 

mg/L), the Group concluded that the neutralization process and scheme was acceptably reliable to 

mitigate the risk to environment caused by a high concentration of TRO. 

2.7 A schematic diagram of the JFE-BWMS is shown below which shows: 

 .1 TG Ballastcleaner is injected into the incoming filtered seawater at the lowest 

possible level to be effective with the amount of Free Available Chlorine (FAC) to 

be not greater than 20 mg/L. Should this level be exceeded, the system is shut 

down; 

 .2 mixing takes place in a Venturi tube that causes rapid agitation and mixing which 

facilitates the effect of the Active Substance on the organisms; and 

 .3 in situations where the Active Substances have not had sufficient time to decay, 

the treated ballast water is treated with TG Environmentalguard during discharge. 

The TG Environmentalguard is dosed prior to the ballast pump used for discharge 

to ensure complete mixing. The amount of TRO present in the ballast water is 

measured and used to determine the amount of TG Environmentalguard necessary 

to neutralize/reduce the TRO. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 4 

I:\MEPC\60\2-12.doc

Simplified schematic representation of the JFE Ballast Water Management System 

3 CHEMICALS ASSOCIATED WITH THE SYSTEM 

3.1 The Group noted that the disinfectant/biocidal agent (trade name: TG Ballastcleaner®), which 

is used in JFE-BWMS, is an aqueous solution of sodium hypochlorite. 

3.2 In addition, it was noted that TG Ballastcleaner can have a Free Available Chlorine (FAC) 

content of either 5% to 10%, or 10% to 13%. 

3.3 Also, the Group noted that the TG Environmentalguard®, can be either an aqueous 

solution with a concentration of 10% to 13%, or a solid form of sodium sulphite. 

3.4 A list of chemical identification of the above Active Substances, other components and 

Relevant Chemicals is shown in Table 2.5.1. 

Filter 

Ballast tank 

TG 

Ballastcleaner

Ballast water 

uptake 

Ballast water 

discharge

TG 

Environmentalguard 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 5 

I:\MEPC\60\2-12.doc 

List of Chemical Identification 

Name of chemical 

substance IUPAC CAS No. Molecular weight 

Chemical 

formula 

Structural 

formula 

Active Substances 

AS Sodium 

hypochlorite 

Sodium hypochlorite 7681-52-9 74.45 NaClO Na-Cl-O 

Other Components 

OC1 Sodium hydroxide Sodium 

hydroxide 1310-73-2 40.00 NaOH NaOH

OC2 Sodium chloride Sodium chloride 7647-14-5 58.44 NaCl NaCl

OC3 Sodium sulfite Sodium sulfite 7757-83-7 126.06 Na2SO3

NaO

NaO

S O

OC4 Sodium sulfate Sodium sulfate 7757-82-6 142.04 Na2SO4

S

O

O

NaO ONa

Relevant Chemicals 

RC1 Hypochlorous acid Hypochlorous 

acid 7790-92-3 84.64 HClO H-O-Cl 

RC2 Chloroform Trichloromethane 67-66-3 119.4 CHCl3 H C

Cl

Cl

Cl

RC3 Dichlorobromomethane 

Dichlorobromomethane 75-27-4 163.82 CHBrCl2 C Cl

Br

H

Cl

RC4 Dibromochloromethane 

Dibromochloromethane 124-48-1 208.27 CHBr2Cl C

Cl

Br

Br

H

RC5 Bromoform Tribromomethane 75-25-2 252.7 CHBr3 H C Br

Br

Br

RC6 Hydrobromous acid Hypobromous 

acid 

13517-11-

8 96.91 HBrO H-O-Br 

RC7 Sodium 

hypobromite 

Sodium 

hypobromite 

13824-96-

9 118.89 NaBrO Na-O-Br 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 6 

I:\MEPC\60\2-12.doc

Name of chemical 

substance IUPAC CAS No. Molecular weight 

Chemical 

formula 

Structural 

formula 

RC8 Bromate ions (see 

sodium bromate.) Bromate 7789-38-0 150.9 NaBrO3 Br

O

O

NaO

RC9 Monochloro 

acetic acid 

Monochloroacetic acid 79-11-8 94.5 CH2ClC

OOH C

O

Cl

C OH

H

H

RC 

10 

Dichloro 

acetic acid 

Dichloroacetic 

acid 79-43-6 128.9 CHCl2COOH C

O

Cl

H C OH

Cl

RC 

11 

Trichloroacetic acid Trichloroacetic acid 76-03-9 163.4 CCl3CO

OH C

Cl O

Cl

Cl C OH

RC 

12 

Bromochloroacetic acid Bromochloroacetic acid 5589-96-8 173.39 CBrClH

COOH C

O

H C OH

Cl

Br

RC 

13 

Bromodichloroacetic acid Bromodichloroacetic acid 71133-14-

7 207.84 CBrCl2COOH C

O

C OH

Cl

Cl

Br

RC 

14 

Dibromochloroacetic acid Dibromochloroacetic acid 5278-95-5 138.95 Br2ClCC

OOH C

O

C OH

Br

Cl

Br

RC 

15 

Monobromoacetic acid Monobromoacetic acid 79-08-3 138.95 BrCH2C

OOH C

O

C OH

H

H

Br

RC 

16 Dibromoacetic acid Dibromoacetic acid 631-64-1 217.84 CHBr2COOH C

O

C OH

Br

H

Br

RC 

17 

Tribromoacetic 

acid 

Tribromoacetic 

acid 75-96-7 296.74 Br3CCOOH C

O

C OH

Br

Br

Br

RC 

18 

Chloroacetonitrile Chloroacetonitrile 107-14-2 75.47 CH2ClC

N H C C

Cl

N

H

RC 

19 

Dichloroacetonitrile Dichloroacetonitrile 3018-12-0 109.94 CHCl2C

N C

Cl

H C

Cl

N
GESAMP-BWWG 11/6 

ANNEX 5 

Page 7 

I:\MEPC\60\2-12.doc 

Name of chemical 

substance IUPAC CAS No. Molecular weight 

Chemical 

formula 

Structural 

formula 

RC 

20 

Trichloroacetonitrile Trichloroacetonitrile 545-06-2 154.39 CCl3CN C

Cl

C

Cl

Cl N

RC 

21 

Dibromoacetonitrile Dibromoacetonitrile 3252-43-5 198.84 CHBr2C

N H C C N

Br

Br

RC 

22 

Bromochloroacetonitrile Bromochloroacetonitrile 83463-62-

1 154.39 CHBrClCN H C C

Cl

N

Br

RC 

23 Monochloramine Chloramide 10599-90-3 51.48 NH2Cl N

H

Cl

H
GESAMP-BWWG 11/6 

ANNEX 5 

Page 8 

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3.5 The Group also noted the following results of chemical analysis for these chemicals in 

both treated brackish ballast water and sea ballast water: 

Analytical values of Relevant Chemicals in the land-based test 

maximum

value

mean

value

standard

deviation

maximum

value

mean

value

standard

deviation

μg/l μg/l μg/l μg/l μg/l μg/l μg/l

RC2 Chloroform 0.1 LT.DL.* LT.DL LT.DL. - LT.DL. LT.DL. LT.DL. -

RC3 Bromodichloromethane 0.1 0.88 0.81 0.08 3,4,5,6 0.70 0.33 0.25 7,8,9,10

RC4 Dibromochloromethane 0.1 16.00 13.00 2.16 3,4,5,6 6.60 4.50 1.45 7,8,9,10

RC5 Bromoform 0.1 330.00 310.00 21.60 3,4,5,6 180.00 122.50 38.62 7,8,9,10

RC6 Hydrobromous acid - -

RC7 Sodium hypobromate - -

RC8 Bromate ion 1.0 18.00 12.00 7.62 3,4,6 46.00 34.00 14.45 7,8,9,10

RC9 Monochloroacetic acid 0.5 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC10 Dichloroacetic acid 0.3 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC11 Trichloroacetic acid 0.2 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC12 Bromochloroacetic acid 0.1 0.47 0.39 0.08 3,4,5,6 0.43 0.24 0.17 9,10

RC13 Bromodichloroacetic acid 0.1 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC14 Dibromochloroacetic acid 0.1 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC15 Bromoacetic acid 0.2 LT.DL. LT.DL. LT.DL. - 5.70 1.58 2.75 7

RC16 Dibromoacetic acid 0.1 47.00 23.98 19.06 3,4,5,6 8.70 5.80 2.97 7,8,9,10

RC17 Tribromoacetic acid 0.1 LT.DL. LT.DL. LT.DL. - 0.10 0.10 0.00 9,10

RC18 Chloroacetonitrile 1.0 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC19 Dichloroacetonitrile 1.0 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC20 Trichloroacetonitrile 1.0 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC21 Dibromoacetonitrile 1.0 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC22 Bromochloroacetonitrile 1.0 LT.DL. LT.DL. LT.DL. - LT.DL. LT.DL. LT.DL. -

RC23 Monochloroamine - -

* : LT.DL.. = less than detection limit

Bold character indicate the measured maximum value

Detected substances are indicated in the shaded cells

Measured as TRO

Haloacetic acids Halo- acetonitriles

Measured as TRO Measured as TRO

Relevant Chemicals

Trihalomethanes Bromate

Measured as TRO

Detection

Limit.

Brackish Water Seawater

Test Cycle 3,4,5,6

Detected

Test

Cycle

Test Cycle 7,8,9,10

Detected

Test

Cycle

Class

No. Name of

chemical species

3.6 Chemical, physical and biological properties associated with pertinent chemicals and 

treated ballast water are shown in: 

 .1 appendix 1 – Treated ballast water; 

 .2 appendix 2 – Aquatic toxicity of Active Substances, Relevant Chemicals and 

Other Chemicals; and 

 .3 appendix 3 – Mammalian toxicity of Active Substances, Relevant Chemicals and 

Other Chemicals. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 9 

I:\MEPC\60\2-12.doc 

4 CONSIDERATION OF CONCERNS EXPRESSED BY THE GROUP DURING 

ITS PREVIOUS REVIEW FOR BASIC APPROVAL AND SUBSEQUENT 

QUESTIONS PUT TO THE APPLICANT 

4.1 Concerns expressed during the application for Basic Approval and reactions of the 

Group to the applicant’s responses 

 Original Concern Applicant’s Response Group’s Reaction 

1 Considering corrosion, the Group agreed that 

the applicant’s response was insufficient to 

quantitatively assess the corrosion impact to 

relevant metallic and non-metallic materials 

likely to be used in ballast water tanks, 

piping and fixtures. 

For non-metallic gasket materials, the 

applicant responded that tests were not 

started since they have sufficient information 

for suitable materials but no details or data 

were provide.

The data are stated briefly 

in 7.1.1.5 of this summary, 

and additional corrosion 

tests necessary for 

evaluation were performed. 

(The detailed data are given 

in the confidential part of 

the assessment report.)

The Group noted the 

response, but did not 

concur with the 

applicant’s 

conclusions 

2 The applicant should provide appropriate 

QAs and QCs and indicate why there are 

different detection limits for the same 

substance being analysed. 

In order to ensure Quality 

Assurance/Quality Control 

for chemical experiments 

and chemical analyses 

when applying for Final 

Approval, a decision was 

made to organize a Quality 

Assurance Committee 

including members of all 

related companies, and to 

carry out all drafting and 

implementation of plans 

and reporting and 

verification of the results in 

accordance with a Quality 

Assurance Project Plan 

(QAPP) audited and 

approved by the 

Committee. 

Regarding detection limits, 

these were unified 

simultaneously with the 

improvement of making 

lower detection limits. 

When some substances 

have different limit values, 

the reason for this is 

described separately. 

The Group was 

satisfied with the 

applicant’s statement. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 10 

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 Original Concern Applicant’s Response Group’s Reaction 

3 Further measurement and analysis of 

discharge concentration of THMs and HAAs 

with adequate QA/QC should be taken during 

the full-scale land-based test before the 

submission for Final Approval.

As mentioned in .2 above, 

for the application for 

Final Approval, appropriate 

Quality Assurance/Quality 

Control were performed in 

accordance with the QAPP, 

and this obligation was also 

imposed in commissioned 

tests (e.g., test contracted out 

to Ballast Tech –NIVA AS). 

Standard Operation 

Procedures (SOP) which 

are capable of assuring 

quality were prepared for 

all tests, and audits as to 

whether the test were 

carried out as specified in 

the SOP were carried out in 

accordance with the quality 

assurance system.

The Group was 

satisfied with the 

applicant’s statement. 

4 The chemical analyses for THMs were not 

performed under adequate QAPPs and so 

recommended that all chemical measurement 

and analyses should be performed under 

QAPPs.

As mentioned in .2 and .3 

above for the application 

for Final Approval, 

measurements and analyses 

of all chemical substances 

were conducted based on 

the QAPP. 

The Group was 

satisfied with the 

applicant’s statement. 

5 Final Approval submission should provide 

full details of the dosing control 

arrangements so as to ensure certainty of 

maintaining specified dosage levels of Active 

Substances.

During ballasting, injection 

control of 

TG Ballastcleaner® is 

performed. Regarding 

TG Ballastcleaner® 

injection control, at a set 

after the start of operation 

of the JFE-BWMS, a set 

amount of 

TG Ballastcleaner® 

corresponding to a free 

available chlorine (FAC) 

concentration of 20 mg/L is 

injected. Thereafter, the TG 

Ballastcleaner® supply rate 

is controlled so that the 

value of the residual 

chlorine concentration in 

The Group was 

satisfied with the 

additional responses 

provided during the 

evaluation for 

Final Approval. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 11 

I:\MEPC\60\2-12.doc 

 Original Concern Applicant’s Response Group’s Reaction 

 the ballast water will fall 

within a target range of 

residual chlorine 

concentrations which has 

been set in advance. 

On the other hand, during 

deballasting, discharge 

neutralization control is 

performed using the 

chemical TG 

Environmentalguard®. 

In discharge neutralization 

control using TG 

Environmentalguard® at a 

set time after the start of 

operation of the JFEBWMS, a set amount of 

TG Environmentalguard®, 

which will neutralize the 20 

mg/L FAC concentration of 

TG Ballastcleaner® that was 

supplied during ballasting, 

is injected. Thereafter, the 

supply rate of 

TG Environmentalguard®

necessary for neutralization 

is calculated and adjusted 

based on the residual 

chlorine concentration 

value in the ballast water at 

the outlet of the ballast 

tank, and the ballast water 

is discharged into the sea 

after 

neutralization/reduction 

treatment. 

Those are brief explanation 

of control system and more 

details of the control system 

are explained in 2.2.3 

above. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 12 

I:\MEPC\60\2-12.doc

 Original Concern Applicant’s Response Group’s Reaction 

6 The Group was satisfied that the flow 

diagram provided was suitable 

for Basic Approval. It is appreciated that 

further details for evaluation be supplied for 

review during any Final Approval.

The piping system diagram, 

system composition 

diagram, single line 

diagram (skeleton diagram), 

control flowchart, and 

protective interlock diagram 

of the JFE-BWMS and the 

operational procedure of the 

JFE-BWMS are described 

in the confidential part of 

the assessment report. 

The Group was 

satisfied with the 

information provided. 

7 The applicant indicated to continue gathering 

information related to the two chemicals, 

bromochloroacetic acid and 

bromodichloroacetic acid and, if no 

additional data were to be found, they would 

carry out further algal tests as required.

As data on 

dibromochloroacetic acid 

and bromodichloroacetic 

acid were required in the 

the GESAMP-BWWG 

report (MEPC 58/2/7, 

annex 5, paragraph 2.10), a 

toxicity test (Algal Growth 

Inhibition Test) was 

performed, and NOEC was 

obtained. The test results 

were added to the 

confidential part of the 

assessment report. 

The Group was 

satisfied with the 

information provided. 

8 The Group was satisfied that the applicant 

had given due preliminary consideration to 

the concerns concerning temperature control 

put forward but requested that these safety 

mitigation measures and requirements should 

be fully detailed in the operating manual 

presented for any Final Approval. 

In order to prevent selfdegradation of TG 

Ballastcleaner®, it is 

necessary to control the 

temperature to 20°C or less. 

In onboard tests, the TG 

Ballastcleaner® tank was 

covered with thermal 

insulation, and external heat 

inputs were prevented as 

much as possible. The very 

small amount of input heat 

which was transmitted 

through the insulation was 

radiated to the outside by a 

water cooling method 

through cooling tubes 

arranged between the tank 

wall and the insulation 

using an independently 

controlled electric chiller. 

The Group was 

satisfied that the 

concerns had been 

addressed. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 13 

I:\MEPC\60\2-12.doc 

 Original Concern Applicant’s Response Group’s Reaction 

 Regarding the temperature 

control procedure with this 

chiller, temperature control 

is performed automatically 

when the power is turned 

on, the set temperature is 

inputted, and operation 

begins. In the temperature 

control, cooling operation 

begins when the 

temperature exceeds the set 

temperature by 1°C and 

ends when the temperature 

of 1°C lower than the set 

temperature, is reached. 

As another possible 

method, the tank can be 

installed in an area where it 

is air-conditioned to 20°C 

or less. 

9 Whilst recognizing the validity of the 

pressure monitoring/control, the Group 

considered that further verification of this 

should be made during the ship board testing 

and included in the documentation for 

Final Approval. 

PV(Pressure-vacuum) 

valves are provided in the 

chemical storage tanks. 

When the tank internal 

pressure exceeds the 

external atmospheric 

pressure by 100 mmAq, PV 

valve opens and reduces the 

pressure, and when the 

internal pressure decreases 

to 100 mmAq less than the 

external atmospheric 

pressure, PV valve opens 

and increases the pressure. 

In onboard tests, the 

internal pressure increased 

and decreased due to the 

loading and use of the 

chemicals, respectively. It 

was confirmed that the PV 

valves operated normally, 

and the tank internal 

pressure was kept within 

the set range. 

Normal operation of the 

level gauges and high level 

alarms was also confirmed 

in shipboard experiments. 

The Group was 

satisfied that the 

concerns had been 

addressed. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 14 

I:\MEPC\60\2-12.doc

 Original Concern Applicant’s Response Group’s Reaction 

10 The Group is of the opinion that the acute 

toxicity testing for treated ballast water and 

the information for acute toxicity testing by 

simulated ballast water in a laboratory scale 

and full-scale land-based system are needed 

for evaluation. 

In addition, the Group requested that 

quantification analysis and degradation rates 

of sodium sulphite in various conditions 

should be carried out for the submission for 

Final Approval. 

These were performed in 

land-based tests carried out 

by Ballast Tech-NIVA. 

The evaluation is described 

in Chapter 3. 

The Group was 

satisfied with the 

applicant’s statement. 

11 The Group recommended that the following 

human exposure information related to 

TG BallastCleaner® should be addressed: 

.1 in advance identification of all 

leaking points; these are to be considered 

critical points for the HSE (due to the 

corrosive properties of the preparation); 

.2 foreseen safety measures for 

spills/leaks in the wastewater collection tank; 

.3 manual handheld (residual chlorine 

meter) measurements of residual chlorine 

concentration in the waste water tank. 

All locations where leaks 

can be expected were 

designated in advance, and 

those positions were 

indicated on the piping 

system diagram. 

Because the periphery of 

the tank is surrounded by a 

coaming, there will be no 

effect on the surrounding 

area in the unlikely event of 

a leak. It should also be 

noted that the collected 

wastewater is discharged 

immediately after 

confirming with a simple 

sensor that it does not 

contain residual chlorine, 

and is not stored in the tank. 

The operation procedure for 

the portable residual 

chlorine meter was attached 

to the appendix of the 

assessment report. 

The Group was 

satisfied that the 

concerns had been 

addressed. 

4.1.1 Having considered each of the above responses, the Group still had the following 

concern: 

 .1 the evaluations of the degradation of epoxy paints, non-metallic seal materials and 

the corrosion rate of bare steels were considered insufficient since the TRO 

concentration of the treated test waters were below 0.05 mg/L at the conclusion of 

the test period and not comparable to the results of the land-based testing in which 

discharge TRO concentrations above 15 mg/L were realized prior to 

neutralization. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 15 

I:\MEPC\60\2-12.doc 

4.2 Questions put to the applicant during evaluation for Final Approval

Question 1: 

Please could you provide an electronic version of the EUSES 2.1 spreadsheets with the 

input values used in the assessment of the specific exposure scenarios for crew and general 

public? 

Response 1: List of the EUSES 2.1 spreadsheets 

 .1 Health risk to crew of ballast water (primary treatment water) left in ballast tank 

(Table 7-2-7) 

No. Test substance Word file name 

AS Sodium hypochlorite STUDY_AS(Crew).doc 

RC3 Bromodichloromethane STUDY_ RC3 (Crew).doc 

RC4 Dibromochloromethane STUDY_ RC4 (Crew).doc 

RC5 Bromoform STUDY_ RC5 (Crew).doc 

RC8 Bromate ion STUDY_ RC8 (Crew).doc 

RC12 Bromochloroacetic acid STUDY_ RC12 (Crew).doc 

RC15 Monobromoacetic acid STUDY_ RC15 (Crew).doc 

RC16 Dibromoacetic acid STUDY_ RC16 (Crew).doc 

RC17 Tribromoacetic acid STUDY_ RC17 (Crew).doc 

 .2 Health risk to general public of discharged ballast water (secondary treatment 

water) (Table 7-2-8) 

No. Test substance Word file name 

RC3 Bromodichloromethane STUDY_ RC3 (General Public).doc 

RC4 Dibromochloromethane STUDY_ RC4 (General Public).doc 

RC5 Bromoform STUDY_ RC5 (General Public).doc 

RC8 Bromate ion STUDY_ RC8 (General Public).doc 

RC12 Bromochloroacetic acid STUDY_ RC12 (General Public).doc 

RC15 Monobromoacetic acid STUDY_ RC15 (General Public).doc 

RC16 Dibromoacetic acid STUDY_ RC16 (General Public).doc 

RC17 Tribromoacetic acid STUDY_ RC17 (General Public).doc 

Reaction: The Group noted the response which enabled it to verify the findings of the 

applicant. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 16 

I:\MEPC\60\2-12.doc

Question 2: 

Please could you clarify if, for the crew exposure assessment a worst case scenario was used 

and, if so, could you provide details? 

Response 2: (Answer to Question 2, please see attached file, “Answer number 2”. [3] Answer 

to Questions related to JFE BWMS – 2. 

 Clarification of the worst case scenario of the crew exposure assessment) 

 .1 The crew exposure scenarios are shown in the Table 7-2-1 of the application for 

the Final Approval. Because the exposures to “A, Chemicals (TG Ballastcleaner, 

TG Environmentalguard)” are avoided with personal protective equipment (PPE), 

as stated in paragraph 7.2.4.3, the exposures to “B, Treated ballast water stored in 

ballast tanks before neutralization (primary treatment water)” were investigated. 

 .2 There are two scenarios related with crew which are shown in Table 7-2-1: 

 (a) Normal operation (ballasting); and 

 (e) Maintenance of ballast tanks and equipment. 

 .1 Descriptions of the Exposure 

 (a) Normal operation (ballasting) – During ballasting (uptake of 

ballast water to ballast tanks) the air in the headspace of ballast tank is 

released from the air vent and this air contains vapors of Active Substance 

and Relevant Chemicals in B, primary treatment water. The concentrations 

of Relevant Chemicals in the air depend on the duration of time after the 

air is taken into the ballast tank, however, the maximum concentrations are 

saturated condition and are used for the HES assessment for the crew. 

 (e) Maintenance of ballast tanks and equipment – During the 

operation of ships, the internal surface of all ballast tanks is visually 

inspected periodically by crews. The purpose of this inspection is to check 

the soundness of the structure and the amount of sludge accumulated in the 

ballast tanks. The visual inspection is to check the protective coating and 

dent. This inspection is normally conducted about twice a year in many 

large shipping companies and this interval of 6 month is considered as the 

most frequent case. With confirmation to shipping companies the 

following assumption was made: 

 The inspection of a ballast tank requires 2 hours. 

 Four tanks are inspected each month. 

 In total, the exposure to the air in the headspace of the ballast tanks is 

calculated as: 2 hours x 4 times/month = 8 hours/month. 

 .2 Clarification of Worst Case Scenario 

 In the application for the Final Approval, the exposure shown in (e) is 

described as the worst case scenario after both assessment results of 

exposure (a) and (e) were compared and MOS/MOSref values in (e) were 

tabulated in Table 7-2-7. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 17 

I:\MEPC\60\2-12.doc 

 After submission of the application, we had a lot of discussions with 

shipping companies and we recognized that this exposure is avoided in the 

ordinary procedures in the ship operation. For the safety of the crews, 

whenever a crew enters into ballast tanks, the concentration of oxygen in 

the tank is checked and in most cases the fresh air is blown into the tank to 

replace the air to secure the crew’s respiration. We consider that this 

operation of air exchange decreases the crew’s risk of exposure and decide 

this air exchange as a mandatory procedure for the ballast tank inspection. 

This worst case scenario of exposure (e) is avoided in practical operation. 

Therefore, exposure (a), the second worst case scenario is described below. 

 .3 Details of Exposure (a) During Ballasting, Second Worst Case Scenario 

 During ballasting, the headspace air in the ballast tank of the same amount 

of loaded ballast water is released through air vents to the deck. It is 

assumed that the air is saturated with Relevant Chemicals in the 

equilibrium with the concentrations in the primary treated ballast water. 

The air released from air vents are diffused into the atmosphere and the 

concentration at the accommodations where crews are staying most of the 

time on their duty and off duty were calculated. 

 The diffusion was calculated with the Puff Model and the Plume Model 

which are broadly used in environmental effect assessments. The Puff 

Model was used for the condition without wind and the Plume Model was 

used for the condition with wind. 

 .3.1 Simulation Model 

 (1) Ship Model 

 A large ship of 200,000 DWT is assumed with the following 

configurations: 

 Length: 300 m 

 Breadth: 50 m 

 Number of ballast tanks: 5 on each side x 2 : 10 

 Size of ballast tanks: 50 m long x 20 m wide 

 Location of air vents: x, y coordinates 

 Two air vents on each ballast tanks are assumed 

BWT No. No. 5 BWT 

(P) 

No. 4 BWT 

(P) 

No. 3 BWT 

(P) 

No. 2 BWT 

(P) 

No. 1 BWT 

(P) 

Loc. of 

Vent 

Aft Fore Aft Fore Aft Fore Aft Fore Aft Fore 

x (m) 5 45 55 95 105 145 155 195 205 245 

y (m) 15 15 15 15 15 15 15 15 15 15 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 18 

I:\MEPC\60\2-12.doc

BWT No. No. 5 BWT 

(S) 

No. 4 BWT 

(S) 

No. 3 BWT 

(S) 

No. 2 BWT 

(S) 

No. 1 BWT 

(S) 

Loc. of 

Vent 

Aft Fore Aft Fore Aft Fore Aft Fore Aft Fore 

x (m) 5 45 55 95 105 145 155 195 205 245 

y (m) -15 -15 -15 -15 -15 -15 -15 -15 -15 -15 

(P): Port side, (S): Starboard side 

 (2) Calculation 

 During ballasting, a pair of ballast tank on port side and starboard side are 

loaded at the same time, therefore, the nearest ballast tanks of No. 5 are 

considered producing highest exposure. The simulations were conducted 

under the conditions without wind and with wind at speed of 1 m/sec from 

bow to aft. 

 Exposure of 24 hours a day on 365 days in a year was assessed by dividing 

NOAEL with each concentration obtained by the simulation and MOS was 

calculated. 

 .3.2 Calculation results 

 The simulations were conducted on Sodium hypochlorite as an Active 

Substance and eight Relevant Chemicals and the calculated MOS and 

MOS/MOSref are shown in the following tables. 

Air vents of ballast tanks 

Accomodation 

Point of exposure assessment 

x

y

No. 5 BWT 

Accommodation 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 19 

I:\MEPC\60\2-12.doc 

Table 1 : Health risk to crew of ballast water (primary treatment water) 

in ballast tank, no wind 

No. Test substance MOS MOSref RCR(MOS/MOSref)

AS Sodium hypochlorite 2181 100 22 

RC3 Bromodichloromethane 2.356x104 100 236 

RC4 Dibromochloromethane 2.064x104 100 206 

RC5 Bromoform 3.678x104 100 368 

RC8 Bromate ion 6.293x104 100 629 

RC12 Bromochloroacetic acid 4.128x109 100 4.128x107

RC15 Monobromoacetic acid 1.159x109 100 1.159x107

RC16 Dibromoacetic acid 2.073x108 100 2.073x106

RC17 Tribromoacetic acid 1.289x1011 100 1.289x109

Note: For the atmosphere stability coefficient in the Plume Model, the value at stable condition 

which yields higher concentration was used. 

Table 2 : Health risk to crew of ballast water (primary treatment water), 

with wind of 1 m/sec 

No. Test substance MOS MOSref RCR(MOS/MOSref)

AS Sodium hypochlorite 1.182x104 100 118 

RC3 Bromodichloromethane 1.276x105 100 1276 

RC4 Dibromochloromethane 1.118x105 100 1118 

RC5 Bromoform 1.993x105 100 1993 

RC8 Bromate ion 3.409x105 100 3409 

RC12 Bromochloroacetic acid 2.236x1010 100 2.236x108

RC15 Monobromoacetic acid 6.278x109 100 6.278x107

RC16 Dibromoacetic acid 1.123x109 100 1.123x107

RC17 Tribromoacetic acid 6.986x1011 100 6.986x109

Note: According to these results, all RCR (MOS/MOSref) are greater than 1 and it is confirmed 

that there are no health risk to crew of ballast water (primary treatment water) in ballast tank. 

.3 Additional assessment during voyage 

Although it is not included in the single operation conditions in 

GESAMP-BWWG 6/9, annex 52.15.1(A), the health risk of ballast water (primary 

treatment water) in ballast tank during voyage was also assessed in addition to 

Table 7-2-1. 

Although there are no active exchange of air in ballast tanks, diffusion through air 

vents were considered. The amount of diffusion is calculated for a tank without a 

cover, which is very conservative though, by multiplying the (mass) transfer 

coefficients with ballast water surface area in ballast tanks. In this calculation 

contributions of all ten ballast tanks were considered. The ship speed of 15 knots 

(7.717 m/sec) was assumed and the Plume Model is used. Even with this over 

estimation, the calculation results shown in Table 3 are far less than those in 

Tables 1 and 2 and the safety during voyage is confirmed. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 20 

I:\MEPC\60\2-12.doc

Table 3 : Health risk to crew of ballast water (primary treatment water) 

during voyage at 15 knots 

No. Test substance MOS MOSref RCR(MOS/MOSref)

AS Sodium hypochlorite 4.547x105 100 4547 

RC3 Bromodichloromethane 4.911x106 100 4.911x104

RC4 Dibromochloromethane 4.303x106 100 4.303x104

RC5 Bromoform 7.667x106 100 7.667x104

RC8 Bromate ion 1.312x107 100 1.312x105

RC12 Bromochloroacetic acid 8.604x1011 100 8.604x109

RC15 Monobromoacetic acid 2.416x1011 100 2.416x109

RC16 Dibromoacetic acid 4.321x1010 100 4.321x108

RC17 Tribromoacetic acid 2.688x1013 100 2.688x1011

Reaction: The Group was satisfied with this response. 

Question 3: 

In paragraph 3.1.1.2, it is stated that “a larger amount of TG Environmentalguard than 

what is stoichiometrically needed is injected to neutralize TRO completely”. Could you 

kindly provide the factor of Environmentalguard injection from the stoichiometrical 

amount calculated from TRO concentration monitored by the sensor? 

Response 3: 

 .1 In this system, 1.6 times the stoichiometrical amount of TG Environmentalguard 

for the TRO measured by the sensor is injected. The Summary, paragraph 3.1.1.2, 

states that “a larger amount of TG Environmentalguard than what is 

stoichiometrically needed is injected to neutralize TRO completely” because this 

value is considered know-how, and as such, we wish to maintain its 

confidentiality. This value is stated in the application for the Final Approval on 

page 2.4-28(3). 

 .2 In the application for the Basic Approval 1.2 times the stoichiometrical amount 

was described to be injected, however, it was changed because 1.6 times of the 

stoichiometrical amount was required in the neutralization which was recognized 

in the experiments using JFE-BWMS equipment later. 

Reaction: The Group was satisfied with this answer. 

Question 4: 

In Table 6.1.3 among pargraph 6.1.5, the maximum discharge concentration of Sodium 

sulfite is set as 22 mg/L (same as the input in Basic Approval). Is it the calculated value 

theoretically introduced from the factor above and TRO maximum condition or maximum 

dosage value limited from the capacity of injector? 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 21 

I:\MEPC\60\2-12.doc 

Response 4: 

 .1 As you pointed out, the maximum concentration of sodium sulfite shown in 

Table 6.1.3 is the calculated value and not the actual measured value. 

 .2 After sodium hypochlorite is injected, and the concentration of TRO in the treated 

ballast water reaches 20 mg/L, which is the maximum dosage, the amount of 

injected sodium sulfite is 1.6 times relative to the theoretical amount required to 

neutralize TRO (20 mg/L). Accordingly, the maximum detected concentration of 

sodium sulfite in the ballast water after neutralization is considered to be equal to 

the 0.6 times relative to the theoretical amount which does not react with TRO. 

This concentration was obtained by using the following equation: 

 20 mg/L / 71 x 0.6 x 126.06 = 21.3 Æ 22 mg/L 

 71: Molecular weight of chlorine 

 126.06: Molecular weight of sodium sulfite 

 .3 In the application for the Basic Approval, the same concentration of 22 mg/L was 

described for the dosage of sodium hypochlorite in the following assumption: 

 .1 The concentration of TRO at the dosage of 30 mg/L is decreased 

to 10 mg/L in the treated ballast water. 

 .2 In order for the remaining TRO in the ballast water sodium sulfite of 1.6 

times relative to the theoretical amount required to neutralize TRO, which 

is calculated as 22 mg/L in concentration, in the following equation: 

 10mg/l / 71 x 1.2 x 126.06 = 21.3 Æ 22 mg/L 

 Therefore, we consider that the logic used in the application for the Final 

Approval is more rational, although the concentration values in both 

applications coincide incidentally. 

Reaction: The Group was satisfied with this answer. 

Question 5: 

In relation to question 2, are there any possibility that only Sodium sulfite will be discharged to 

receiving water? In that case, not only direct toxic effect but also reduction of DO should be 

assessed, could you provide the worst case scenario, which will cause such high sulfite ion 

discharge and the assessment for DO reduction around the discharge point regarding with self 

distraction of sulfite ion (paragraph 3.1.1.2 only stated the result)? 

Response 5: 

 .1 Because an excess amount of sodium sulfite is injected as a neutralizing agent, 

there may be cases in which only sodium sulfite is discharged into the 

environmental water. 

 .2 Because the amount of addition is controlled, the maximum concentration in the 

case mentioned above can be estimated at 22 mg/L. This is the worst case of 

discharge into environmental water as mentioned in A2. 

 .3 Sodium sulfite changes rapidly to sodium sulfate as a result of reaction with the 

dissolved oxygen in the water. For this reason, “chronic toxicity” of sodium sulfite 

is not considered possible. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 22 

I:\MEPC\60\2-12.doc

 .4 Sodium sulfate is one of the main natural components of seawater. Therefore, it is 

judged that the increased amount due to oxidation of sodium sulfite is not toxic, 

and is not a problem. 

 .5 Due to the speed with which sodium sulfite changes to sodium sulfate in seawater, 

the calculation using the MAMPEC model gave a dilution factor of 442,656 (see 

the application for the Final Approval, 6.1.3). 

 .6 On the other hand, the theoretical and experimental results showed that the 

amount of dissolved oxygen (DO) consumed in the process of change from 

sodium sulfite to sodium sulfate is not large. 

 .7 Theoretically, the change in these substances in water can be expressed as follows: 

 2Na2SO3 + O2 Æ 2Na2SO4

The molar mass of Na2SO3 is 126.06 g/mol. Therefore, the amount of oxygen 

consumed by one mol of Na2SO3 is a half mol of oxygen, representing a decrease 

of 16g in DO. 

Accordingly, for example, assuming 10 mg/L of sodium sulfite reacts completely 

in water, 1.27 mg/L of oxygen is consumed. 

If sodium sulfite is discharged at its maximum discharge rate of 22 mg/L in 

seawater without dilution, the reduction in oxygen will be 2.79 mg/L. However, 

assuming the discharged water is diluted off-board the ship, DO is not reduced to 

a level that would affect marine life. 

 .8 Experiments were also conducted in order to verify these points. For example, 

when the DO of test water was measured over time with test water adjusted 

to Na2SO3 43 mg/L, using coastal seawater containing no TRO, a DO reduction of 

from 7.0 mg/L to 4.8 mg/L was confirmed. 

 .9 In the land-based test, DO was measured at various stages. The decrease in the DO 

of the discharged water before dilution (i.e., 100% discharged water) was on the 

order of 20% at maximum, and as a measured value, the effect was judged to be 

small. (The value of approximately 10% shown in the Summary, paragraph 3.1.1.2 

was the result of the land-based test.) A detailed explanation was presented in the 

application for the Final Approval, 2.4.1.4(3). 

Reaction: The Group was satisfied with this answer. 

Question 6: 

The Group considered that the discharge concentration of Bromoform from this system was 

higher than that from other BWMS which used oxidant as an Active Substance. In the 

application for Final Approval, the value was set at 330 ug/L, however, the Group noted in the 

Basic Approval report that the maximum concentration of bromoform was 460 ug/L. 

Additionally, in appendix 25, the applicant stated that measured TRO concentration, using 

seawater from Nagoya Port, reached 390 ug/L. Could you clarify which value is representative 

as a “worst case maximum concentration” for bromofrom? 

Response 6: 

 .1 The maximum concentration of bromoform in the Basic Approval was 460 μg/L. 

This value is observed under the injected TRO concentration of 30 mg/L. The 

value of 330 μg/L in this Final Approval is observed under the injected TRO 

concentration of 20 mg/L. (The maximum value of the TRO concentration was 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 23 

I:\MEPC\60\2-12.doc 

set at 20 mg/L, which is lower than the 30 mg/L in the Basic Approval, in order to 

reduce the concentration of system by-products, considering the fact that the 

concentration of 20 mg/L is a condition which can also satisfy the D2 standard.) 

 .2 The value of 390 μg/L obtained with seawater from Nagoya Port was the result of 

a laboratory test. We consider that the maximum value obtained in 10 cycles of 

the land-based test, 330 μg/L, in which a continuous treatment test was performed 

at the treatment capacity of 350 m3/h, is the value of the “worst case maximum 

concentration” of bromoform with the JFE-BWMS. 

Reaction: The Group was satisfied with this answer. 

Question 7: 

The PEC calculation in dossiers shows a different “dilution ratio” against the same 

substances. For example, 418 in the main report (Table 6.1.3) and 145 in appendix 25 

(Table 4) was calculated as the ratios for bromoform, respectively. Could you clarify which 

parameter settings for MAMPEC would be representative for Final Approval? 

Response 7: 

 .1 Regarding the different dilution ratios, according to the MAMPEC calculations, the 

maximum value in harbour of bromoform for a discharge concentration of 330 μg/L 

was 2.28 μg/L, and the average value in harbour was 0.789 μg/L. The abovementioned figures of 145 and 418 were obtained by dividing the discharge 

concentration of 330 μg/L by these values, respectively. 

 .2 We are attaching the parameters and input/output data used in this MAMPEC 

simulation. (Please see the attached file, 330 μg/L (1998data) Bromoform V4 to 

Default commercial harbor.rtf.) 

 .3 The dilution ratio using the maximum value in harbour was listed in Table 4 of 

appendix 25. The reason for using the maximum value here is to maintain the 

compatibility with the application for the Basic Approval in which the maximum 

values were provided in the supplementary data. 

Reaction: The Group was satisfied with this answer. 

Question 8: 

Because the TRO concentration remains higher than 15 mg/L even after 5 days’ tank holding 

time, the reliability of neutralization process is the key for preventing environmental risks to 

aquatic ecosystem. The Group considers that the feedback loop for Environmentalguard 

injection by TRO sensors is a key component for the neutralization process. Could you provide 

the algorithm for controling Environmentalguard injection, when TRO sensors have 

malfunctioned? If the fail-safe setting is to fix the dose of Environmentalguard injection as 

maximum rate and it does not cause significant concerns, what is the advantage of choosing a 

feedback loop for Environmentalguard injection by TRO sensors? 

Response 8: 

 .1 In discharge control in the JFE-BWMS, the TRO value at the outlet of the ballast 

tank is measured with a TRO meter (1), and an amount of TG Environmentalguard 

capable of neutralization treatment of that TRO is injected. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 24 

I:\MEPC\60\2-12.doc

 .2 In addition, neutralization/reduction of the TRO in the ballast water at the 

discharge outlet is confirmed by measurement with a high sensitive TRO 

sensor (2). 

 .3 Regarding detection of malfunctions of the TRO sensors, over-scale reading values and 

hunting are judged by a control device (PLC), and a warning is displayed. 

 .4 In case injection of TG Environmentalguard is inadequate due to reduced 

sensitivity of TRO sensor (1), and the reading value of TRO sensor (2) becomes 

positive, the amount of TG Environmentalguard is controlled so that injection is 

automatically increased. 

 .5 If the reading of TRO (2) does not become a minus value as a result of this action, 

the system is designed so that the device is automatically stopped. 

 .6 This protective safety interlock circuit is described in item 2 of the “Explanation 

of safety interlock circuit” in appendix 11 (see below). 

 .7 These control functions were selected by considering to minimize the effect to the 

environment by avoiding over use of chemicals. 

Reaction: The Group was satisfied with this answer and the other information related 

achieved from the applicant. 

Question 9: 

Could you kindly provide the relation between the TRO concentration monitored by high 

sensitive sensor and that by manually measurement with “high resolution analytical 

method”, such as calibration curve under high salinity, brackish and fresh water condition 

(laboratory measurement could be acceptable)? This information would be needed for 

evaluation of reliability for TRO sensors. Also are there any data for long-term degradation 

of sensors sensitivities during onboard testing? 

Response 9: 

 .1 We do not have calibration data between the TRO concentration monitored by high 

sensitive sensor and that by manually measurement with “high resolution analytical 

method”. The purpose of measuring by “high resolution analytical method” is to prove 

that the TRO concentration of treated ballast water after neutralization is lower than the 

detection limit of Hach DPD, which is 0.02mg/L. 

 .2 On the other hand, high sensitive sensor (TRO sensor) is used to confirm that ter is 

in reduction condition when the reading value is negative, while the positive 

reading value shows the concentration of TRO. 

 .3 In the land-based test, the concentration of the TRO in the neutralized seawater 

and brackish water is measured with High Resolution analytical method and High 

Sensitive sensor (TRO sensor). The results obtained show that when the reading 

value of High sensitive sensor (TRO sensor) is negative, which shows that water is 

in reduction condition, all the measured values of High Resolution analytical 

method are less than 0.02mg/L. 

 .4 These data is shown in the Table 2-4-18 “Result of the immediate analysis of 

TRO” in section 2.4.1.4 and appendix-15 “TRO monitoring trend data for test 

cycle 1-11 during Deballasting” of the application for the Final Approval. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 25 

I:\MEPC\60\2-12.doc 

 .5 The TRO meters used in the JFE-BWMS have an extensive record of practical use 

in waterworks and other applications, and were also used for approximately 6 

months in the shipboard test with no problems. 

 .6 Regarding maintenance of the TRO meters, as mentioned in the Instruction 

Manual of Tro Meter in appendix 6, the 0-30 mg/L TRO meter sensor is to be 

exchanged at a cycle of approximately 300 hours (however, because no current 

passes through when the BWMS is not in use, 300 hours actually refer to the total 

time when ballast water is being treated). The recommended exchange cycle of the 

0-3 mg/L TRO meter sensor is approximately one year. 

Reaction: The Group was not satisfied with this answer. However, the applicant 

provided additional information (see below) which with the above answer, 

satisfied the Group. 

Question 10: 

Is there an option and/or plan to set each TRO sensors in parallel to ensure the system’s 

reliability with redundancy? 

Response 10: 

 .1 As an option, installation of ORP meter or additional TRO sensor is also available. 

 .2 As explained in the reply to question 6, discharge control in the JFE-BWMS is 

performed by an automatic control function which increases the supply of 

TG Environmentalguard when a TRO meter malfunctions, and in parallel with this, also 

includes a protective safety interlock circuit which stops the BWMS if abnormal 

conditions occur. This is considered to provide the fail-safe characteristics. 

Reaction: The Group was satisfied with this answer. 

Question 11: 

In their corrosion analysis given in appendix 14, they show that the TRO dosage decays 

from 20 ppm at the start to some lower value over the course of the seven-day exposure. 

Can you provide quantitative information on the level of TRO over the course of the sevenday immersion? 

Response 11: 

 .1 TRO decay data including start, end and intermediate value are shown in 

“Durability Test of Paint Film with Simulated Defect” and “Dew Condensation. 

 .2 Test” of appendix 14. Data of other tests are shown in attached data sheet in page 

2 but unfortunately we have only the data for start and 7 days after. Only the data 

for “Test (Accelerating Test) of Synthetic Rubber” were conducted under constant 

TRO concentration at 20 ppm. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 26 

I:\MEPC\60\2-12.doc

Table 1 : Table of TRO decay data for all corrosion tests 

Report name TRO Data 

Durability Test of Paint Film with Simulated Defect Shown in Table10 on pages 25 

and 26 

Dew Condensation Test Shown in Table10 on page 24 

Corrosion Test on uncoated steel plate See attached data sheet 

Cathodic Protection Performance Test on Zinc Anode See attached data sheet 

Test of Durability of Piping Packing See attached data sheet 

Corrosion Check Test of Butterfly Valve Components See attached data sheet 

Test (Accelerating Test) of Synthetic Rubber TRO was kept at about 20 ppm 

during whole test period. 
I:\MEPC\60\2-12.doc 

Test of Durability of Piping Packing

Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days 

21.0 0.32 20.0 0.18 21.0 <0.05 21.0 0.10 20.0 0.07 20.0 0.07 21.0 0.06 

Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days 

19.0 <0.05 19.0 <0.05 19.0 <0.05 21.0 <0.05 21.0 <0.05 20.0 <0.05 20.0 0.08 

Corrosion Test on uncoated steel plate

Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days 

21.0 <0.05 21.0 <0.05 20.0 <0.05 21.0 <0.05 20.0 <0.05 20.0 <0.05 19.0 <0.05 

Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days 

20.0 <0.05 21.0 <0.05 19.0 <0.05 20.0 <0.05 21.0 <0.05 21.0 <0.05 20.0 0.06 

Cathodic Protection Performance Test on Zinc Anode

Test Specimen No. Start 7days

No.6 20.0 2.06No.7 20.0 0.57No.8 20.0 1.63No.9 20.0 0.33

No.10 20.0 2.01

Corrosion Check Test of Butterfly Valve Components

Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days 

SCS13 19.0 0.16 19.0 0.14 20.0 0.14 21.0 0.11 21.0 0.1 19.0 0.16 21.0 0.13 

SUS403 19.0 0.15 19.0 0.09 20.0 0.13 21.0 0.11 21.0 0.09 19.0 0.15 21.0 0.11 

S25C 19.0 <0.05 19.0 <0.05 20.0 <0.05 21.0 <0.05 21.0 <0.05 19.0 <0.05 21.0 <0.05 

FC250 19.0 <0.05 19.0 0.05 20.0 <0.05 21.0 <0.05 21.0 <0.05 19.0 <0.05 21.0 <0.05 

Painted Specimen(S25C) 19.0 0.09 19.0 0.09 20.0 0.06 21.0 <0.05 21.0 <0.05 19.0 0.06 21.0 0.05 

Painted Specimen(FC250) 19.0 0.06 19.0 0.05 20.0 0.05 21.0 <0.05 21.0 <0.05 19.0 0.07 21.0 0.06 

Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days Start 7days 

SCS13 20.0 0.12 20.0 0.14 21.0 0.12 19.0 0.09 20.0 0.13 21.0 0.13 20.0 0.1 

SUS403 20.0 0.11 20.0 0.10 21.0 0.05 19.0 0.08 20.0 0.10 21.0 0.1 20.0 <0.05 

S25C 20.0 <0.05 20.0 <0.05 21.0 <0.05 19.0 <0.05 20.0 <0.05 21.0 <0.05 20.0 <0.05 

FC250 20.0 <0.05 20.0 <0.05 21.0 <0.05 19.0 <0.05 20.0 <0.05 21.0 <0.05 20.0 <0.05 

Painted Specimen(S25C) 20.0 <0.05 20.0 <0.05 21.0 <0.05 19.0 <0.05 20.0 <0.05 21.0 0.05 20.0 <0.05 

Painted Specimen(FC250) 20.0 0.05 20.0 0.05 21.0 <0.05 19.0 <0.05 20.0 <0.05 21.0 <0.05 20.0 <0.05 

Kind of

Test Specimen

1 2 3 4 5 6 7

Kind of

Test Specimen

1 2 3 4 5 6 7

Natural Seawater

+ 20ppmNaClO

10 11 12 13 14 15 16

Test cycle 1 2 3 4 5 6 7

Natural Seawater

+ 20ppmNaClO

10 11 12 13 14 15 16

4 5 6 7 Test cycle 1 2 3
GESAMP-BWWG 11/6 

ANNEX 5 

Page 28 

I:\MEPC\60\2-12.doc 

Reaction: The Group was satisfied with this response. 

Question 12: 

Please could you provide the EUSES spreadsheets which could not be found in the 

confidential section. 

Response 12: 

 .1 We believe that the 17 spreadsheets in Word file which we sent in reply to the first 

question have the full contents of information including all manually input data 

such as characteristics and NOAELs of each chemical species and calculated 

output data. 

 .2 If “the confidential section” means “??” in the spreadsheets, that show no default 

values in the system when no data are inputted we presume. If our understanding 

is wrong, will you kindly let us know “the confidential section”. For reference, 

we attach the exported files of EUSES 2.1. 

Reaction: The Group was satisfied with this response. 

5 HUMAN HEALTH ASSESSMENT 

5.1 The Group noted the various chemicals associated with this system and agreed that these 

presented the following potential hazards to the crew and/or general public: 

 .1 Sodium hypochlorite (in TG Ballastcleaner) is: 

 .1 corrosive at concentrations above 10%*; 

 .2 irritant to skin and eyes at concentrations from 5-10%* 

 ________________ * The classification according to GHS (CLP, 1272/2008/EC, in Europe) will change the 

current classification of sodium hypochlorite. According to CLP concentrations ≥ 5% will 

lead to a classification as Skin Corrosive Category 1B (H314; Causes severe skin burns 

and eye damage). The specific concentration limits (5%≤ conc < 10% and conc ≥ 10%) 

have been removed from the harmonized classification and are no longer applicable. 

 .2 Trihalomethanes and, in particular, bromoform are: 

 .1 toxic by inhalation; 

 .2 harmful if swallowed; 

 .3 irritating to the skin and eyes; and 

 .4 may also be a human carcinogen. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 29 

I:\MEPC\60\2-12.doc 

 .3 Halo-acetic acids and in particular dibromoacetic acid are: 

 .1 acutely toxic if swallowed; 

 .2 acutely toxic if inhaled; 

 .3 acutely toxic in contact with skin; and 

 .4 corrosive to skin. 

6 RISKS TO THE SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC 

6.1 Risk associated with exposure of the crew to the Active Substances, Relevant 

Chemicals and Other Chemicals 

6.1.1 The Group agreed that the risks to the crew from this system were primarily associated 

with: 

 .1 chemical storage on board (TG Ballastcleaner®, TG Environmentalguard®); 

 .2 leakage during the chemicals dosage operations and maintenance of the BWMS; 

.3 ballast water which has been treated by the BWMS and is stored in the ballast 

tanks before neutralization (primary treatment water); and 

 .4 treated ballast water which has been withdrawn from the ballast tanks and is 

discharged from the ship after neutralization (secondary treatment water). 

6.1.2 The Group noted that the applicant had identified the following exposure scenarios for 

personnel: 

 .1 persons on onboard (crew, 8 hours/day x 5 days/week). Exposure routes: 

respiration and dermal contact ; and 

 .2 general public (persons in port while ship is at anchor, persons in area near shore). 

Exposure routes: Oral ingestion, respiration and dermal contact. 

6.1.3 The Group recommended that the scenarios for occupational exposure assessment to be 

considered were the following (MEPC 58/2/7, annex 5, paragraph 2.15.1 (A)): 

.1 Resupply of chemicals 

.2 Ballasting (taking on ballast water) 

.3 Deballasting (discharging ballast water) 

.4 Inspection and maintenance of equipment and chemical tanks 

.5 Inspection and maintenance of ballast tanks 

.6 Trouble and emergency states (this assumes breakdowns of the system and accidents) 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 30 

I:\MEPC\60\2-12.doc

6.1.4 The following individual unit operations to address crew exposure were proposed by 

the applicant for Final Approval: 

Individual operations for crew exposure assessment 

Crew General public 

(a) Normal operation (ballasting) B -- 

(a) Normal operation (deballasting) -- C 

(b) Resupply of chemicals A -- 

(c) Equipment breakdown A -- 

(d) Ship accident or other emergency A -- 

(e) Maintenance of ballast tanks and equipment A and B -- 

Here, A: Chemicals (TG Ballastcleaner®, TG Environmentalguard®) 

 B: Treated ballast water store in ballast tanks before neutralization 

 C: Treated ballast water discharged from ship after neutralization 

6.1.5 The Group noted that the applicant considered that the exposures to “A, Chemicals 

(TG Ballastcleaner, TG Environmentalguard)” are minimized by using PPE (personal protective 

equipment) and therefore do not need to be considered further. On the other hand, the exposures 

to “B, Treated ballast water stored in ballast tanks before neutralization (primary treatment 

water)” were investigated. 

6.1.6 The Group also noted that the applicant initially identified two scenarios as worst-case 

scenarios to address crew exposure associated with B: (a) Normal operation (ballasting) 

and (e) Maintenance of ballast tanks and equipment. Furthermore, the applicant considered this 

scenario as non-applicable during ordinary procedures in the ship operation due to mitigation 

measures put in place when crew entering the ballast tanks. Therefore the only scenario to be 

developed was (a). 

6.1.7 The Group noted that the applicant, in order to address a), assumed the crew being 

exposed to the air released from air vents during their duty and off duty time. The diffusion in to 

the atmosphere was calculated with the Puff Model (Table 1 – Condition without wind) and 

the Plume Model (Table 2 – Condition with wind). 

6.1.8 The Group noted that the applicant had used EUSES 2.1 to estimate crew exposure levels 

and risks. Oral NOAELs values were extrapolated to inhalation NOAELs by using conversion 

default values according to EUSES 2.1 Background Report, Model Calculation assuming a 

worker respiration rate of 10 m3

/d (eight hour exposure). 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 31 

I:\MEPC\60\2-12.doc 

Table 1 : Health risk to crew of ballast water (primary treatment water) in ballast tank, 

no wind (Puff model) 

No. Test substance MOS MOSref RCR(MOS/MOSref)

AS Sodium hypochlorite 2181 100 22 

RC3 Bromodichloromethane 2.356x104

 100 236 

RC4 Dibromochloromethane 2.064x104 100 206 

RC5 Bromoform 3.678x104 100 368 

RC8 Bromate ion 6.293x104 100 629 

RC12 Bromochloroacetic acid 4.128x109 100 4.128x107

RC15 Monobromoacetic acid 1.159x109 100 1.159x107

RC16 Dibromoacetic acid 2.073x108 100 2.073x106

RC17 Tribromoacetic acid 1.289x1011 100 1.289x109

Table 2 : Health risk to crew of ballast water (primary treatment water), 

with wind of 1 m/sec 

No. Test substance MOS MOSref RCR(MOS/MOSref)

AS Sodium hypochlorite 1.182x104 100 118 

RC3 Bromodichloromethane 1.276x105 100 1276 

RC4 Dibromochloromethane 1.118x105 100 1118 

RC5 Bromoform 1.993x105 100 1993 

RC8 Bromate ion 3.409x105 100 3409 

RC12 Bromochloroacetic acid 2.236x1010 100 2.236x108

RC15 Monobromoacetic acid 6.278x109 100 6.278x107

RC16 Dibromoacetic acid 1.123x109 100 1.123x107

RC17 Tribromoacetic acid 6.986x1011 100 6.986x109

6.1.9 The Group concurred with the applicant’s view that calculated results of the obtained 

RCR (Risk Characterization Ratio = MOS/MOSref) are larger than 1 and judged that there is no 

health risk to humans, and it is not necessary for the crew to wear additional personal protective 

equipment (PPE) as a routine when working on deck. 

6.4 Risks to the general public from potential exposure to Relevant Chemicals 

6.4.1 It was noted that a EUSES 2.1 simulation had been performed to estimate the exposure of 

the general public to bromoform, bromate ion, bromochloroacetic acid, monobromoacetic acid, 

and dibromoacetic acid which are components of the treated ballast water. 

6.4.2 The calculated results of the obtained Risk Characterization Ratio 

(RCR) = MOS/MOSref) are shown in the table below. As the risk characterization are larger 

than 1, it can be judged that there is no unacceptable risk to the general public. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 32 

I:\MEPC\60\2-12.doc

Health risk to general public of discharged ballast water 

Risk Characterization Ratio (MOS/MOSref) 

Local Regional No. Chemical substance 

Inhalatory Total 

Exposure 

Inhalatory Total 

Exposure 

RC3 Dichlorobromomethane 9.16 x106

 5.92 x106 9.48 x106 6.55x106

RC4 Dibromochloromethane 1.27x107

 3.01 x106 1.29 x107 3.38x106

RC5 Tribromomethane 4.89x105

 9.85x104 4.96x105 1.11x105

RC8 Bromate ion 1.58x1010 9.41x104

 6.24x1012 1.06x105

RC12 Bromochloroacetic acid 1.50x109

 1.32x107 1.58x109 1.46x107

RC15 Monobromoacetic acid 1.85x108

 1.87x105 2.01x108 1.89x105

RC16 Dibromoacetic acid 1.20x106

 1.56x105 1.25x108 1.79x105

RC17 Tribromoacetic acid 5.60x1012 5.60x107

 9.66x1012 6.11x107

6.5 Risks to the safety of the ship 

6.5.1 The Group noted that the applicant had indicated that tanks and pipes must be coated or 

lined with chlorine and salt water resistant epoxy resins when exposed to TG Ballastcleaner. The 

Group recommended that this is considered prior to fitting this BWMS on the ship. 

6.5.2 The Group noted that the applicant carried out a comprehensive corrosion evaluation of 

epoxy-coated steel, bare steel, galvanized steel and non-metallic seals. In addition, two alloys of 

stainless steel were evaluated for susceptibility to crevice corrosion. The testing 

included 18 exposures to a 10-day cycle which was comprised of an initial seven days’ 

immersion, followed by three days in air. The treatment solutions included both natural seawater 

and seawater dosed with 20 ppm of sodium hypochlorite (TG Ballast Cleaner). The applicant 

indicated that the actual TRO concentration during the seven-day immersion decays from the 

initial dosage of 20 ppm to less than 0.05 ppm at the end of the immersion period, in most cases. 

The evaluations of coated steels included an examination coating hardness and adhesion. 

Galvanized steel and uncoated steel was evaluated on the basis of weight loss and the resulting 

uniform corrosion rate. Crevice corrosion was evaluated using the depth of penetration and the 

number of incidences. Non-metallic degradation was evaluated on the basis of visual appearance 

and percent elongation. The applicant concluded from these test that: 

 .1 the effect of sodium hypochlorite on the epoxy painted specimens was limited to 

slight discoloration with no significant difference in coating physical properties 

compared to natural seawater; 

 .2 regarding the Zn-coated specimens (galvanized), no effect due to sodium 

hypochlorite addition was found; 

 .3 for uncoated steel exposures, the average corrosion rate was 0.059 mm/year in 

seawater dosed with 20 ppm sodium hypochlorite vs. 0.052 mm/year in natural 

seawater; and 

 .4 the effect of sodium hypochlorite on seal materials had not been determined as the 

testing is incomplete. 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 33 

I:\MEPC\60\2-12.doc 

6.5.3 The Group could not agree with the applicant’s conclusions regarding the corrosivity of 

natural seawater dosed to an initial TRO concentration of 20 mg/L. While the Group considered 

that the test results showed no difference between treated and natural seawater, the experimental 

procedure is in question. Specifically, the Group noted, from the data set provided by the 

applicant that the TRO concentration in the discharge from the land-based testing prior to 

neutralization was 15 mg/L. This is significantly higher than the <0.05 mg/L TRO concentration 

at the end of the experiments for the evaluation of corrosion. As a result, the Group did not agree 

with the applicant’s conclusion that the testing indicates that no significant difference in the 

corrosion rate of bare steel, non-metallics or the degradation of epoxy paints versus exposure to 

natural seawater. The Group recommended that all of the corrosivity and coating degradation 

testing be repeated with adequate control throughout the testing to maintain the TRO 

concentrations between 15 mg/L and 20 mg/L. Furthermore, the Group invited the applicant to 

consider the guidance provided in section 5.1 of the “Report of the eighth meeting of 

the GESAMP-BWWG”, contained in MEPC 59/2/16. 

6.5.4 The Group noted that the use of PPE is recommended as a risk mitigation measure for 

personnel performing specific tasks in the operation and maintenance of the BWMS. The ship 

specific operational manual should contain clear instructions as to where and when the use 

of PPE is required. 

6.5.5 The Group noted that the applicant had identified risk mitigation measures to be 

incorporated in the system together with routine procedures for risk mitigation. Such measures 

and procedures should be clearly identified in the operational manual. 

7 ENVIRONMENTAL RISK ASSESSMENT 

7.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

PBT criteria for 8 chemical substances 

 Object chemical 

substances of PBT 

criteria 

Persistence 

P (Yes or No) 

Bioaccumulation 

B (Yes or No) 

Toxicity 

T (Yes or No) 

OC Sodium hypochlorite No No No 

RC3 Dichlorobromomethane Yes No No 

RC4 Dibromochloromethane Yes No No 

RC5 Bromoform Yes No No 

RC8 Sodium bromate Yes No No 

RC12 Bromochloroacetic acid Yes No No 

RC15 Monobromoacetic acid Yes No No 

RC16 Dibromoacetic acid Yes No No 

RC17 Triibromoacetic acid Yes No No 

7.1.1 Substances which are evaluated “Yes” for all of the items Persistence, Bioaccumulation, 

and Toxicity in this table are identified as PBT substances. 

7.1.2 The Group agreed with the applicant that, as shown in the table, none of the chemicals are 

PBT substances. However, for chemical substances which are evaluated as displaying 

persistence, PEC/PNEC values were calculated in order to evaluate the effects on the aquatic 

environment, and this evaluation was made. 
GESAMP-BWWG 11/6 

ANNEX 5 

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I:\MEPC\60\2-12.doc

7.2 Calculation of Predicted Environmental Concentration (PEC) 

7.2.1 The MAMPEC Model was used to calculate the degree of dilution of ballast water in the 

port. The input data used in MAMPEC Model assumes higher ballast water amount so as not to 

underestimate actually discharged ballast water in a year in the Rotterdam port. 

7.2.2 The Group noted that the applicant used worst-case assumptions as no degradation of 

Relevant Chemicals had been taken into account except for sodium sulfite, as this substance is 

assumed to be converted very quickly to sodium sulfate. 

7.3 Calculation of PEC/PNEC Ratios 

7.3.1 The Group noted that, because the acute toxicity values were used, the factor 1000 was 

taken from Table 2 in the Methodology (BWM.2/Circ.13, 10 June 2008) and was selected as the 

assessment factor for use in the calculations. 

7.3.2 An average GRT in the table is recalculated for daily basis to generate 1,067 kt/day for 

the number of arriving ships, which is then multiplied by 0.5 for a ratio of the ballast water 

discharging ship for evaluation, resulting in a GRT of 533.5 kt/day. Using the above, calculation 

results in 280.1 kt/day for the amount of ballast water per day. 

7.3.3 The Group noted that to estimate the emission into the receiving waters, the applicant 

used an estimation of the ballast water based on the port of Rotterdam in the years 1996-1997 

and the results of the concentration of the WET tests. 

PEC/PNEC values 

Yes: Effect on aquatic organism, No: No effect on aquatic organism 

Test substance Species 

Maximum 

measured 

value 

PEC PNEC PEC/ 

PNEC Evaluation 

 (mg/L) (mg/L) (mg/L) 

RC3 

Dichlorobromo 

-methane 

Other life forms 

(Ciliates) 

(Tetrahymena 

pyriformis) 

0.88×10-3 0.00232 

×10-3

240×10-3 9.7 

×10-6

No 

RC4 

Dibromochloro 

-methane 

Other life forms 

(Ciliates) 

(Tetrahymena 

pyriformis) 

16×10-3 0.0344 

×10-3

65×10-3 5.3 

×10-4

No 

RC5 

Bromoform 

Fish (acclimatization to seawater) 

Sheepshead 

minnow 

(Cyprinodon 

variegatus) 

330×10-3 0.789 

×10-3

7.1×10-3 0.111 No 

RC8 

Sodium 

bromate 

Mollusks 

Pacific oyster 

(Crassostrea 

gigas) 

46×10-3 0.250 

×10-3

25.4×10-3 0.0098 No 
GESAMP-BWWG 11/6 

ANNEX 5 

Page 35 

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Test substance Species 

Maximum 

measured 

value 

PEC PNEC PEC/ 

PNEC Evaluation 

 (mg/L) (mg/L) (mg/L) 

RC12 

Bromochloroacetic acid 

Not possible to 

obtain data. 

Based on 

structure, 

substituted with 

high toxicity 

bromodichloroace

tic acid. 

0.47×10-3 0.00258 

×10-3

53×10-3 4.9 

×10-5

No 

RC15 

Monobromoacetic acid 

Aquatic plant 

(algae) 

Green algae 

(Scenedesmus 

subspicatus) 

5.7×10-3 0.0313 

x10-3

1.4 

x10-3

0.022 No 

RC16 

Dibromoacetic 

acid 

Fish 

Fathead minnow 

(Pimephales 

promelas) 

47×10-3 0.258 

×10-3

69 

×10-3

3.74 

×10-3

No 

RC17 

Tribromoacetic 

acid 

Fish 

Java medaka 

(Oryzias 

javanicus) 

0.1×10-3 0.55x10

-6

101x10-3 5.4x10-6 No 

OC3 

Sodium sulfite 

Aquatic plant 

(algae) 

Green algae 

(Chlamydomonas 

reinhardtii, 

Chlorella 

vigaris, 

Scenedemus 

basiliensis) 

22 0.0497 

×10-3

63 

×10-3 

*1 

0.00080 

(Short 

term) 

No 

Note: 1 : Method of calculating PNEC for sodium sulfite. 

PNEC: The most sensitive species used for sodium hypochlorite is Aquatic plant (algae) 

(Chlamydomonas reinhardtii, Chlorella vulgaris, Scenedesmus basiliensis), EC50, 6.4 h-8.9 h, 

16-32 mg/L (as SO3-S). 

Accordingly, the value is 40 mg/L (=(16 x 80)/32) as SO3, that is, 63 mg/L (=(16 x 126)/32) as 

sodium sulfite. PNEC is obtained by dividing this value by the above-mentioned assessment 

factor of 1000, the result being PNEC=63 μg/L. 

7.3.5 The Group noted that the applicant used a scenario for the establishment of the PECs that 

is not adopted by the Group as the relevant emission scenario. However, this did not affect the 

conclusions reached. 

7.3.6 As a result, all of the substances to be designated as evaluation object were determined as 

having no unacceptable risk on aquatic organisms. 
GESAMP-BWWG 11/6 

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8 CONCLUSIONS AND RECOMMENDATIONS 

8.1 The Group concurred with the applicant’s view that calculated results of the 

obtained RCR (Risk Characterization Ratio = MOS/MOSref) were greater than 1 and judged that 

there is no unacceptable health risk to humans, and it is not necessary for the crew to wear 

additional personal protective equipment (PPE) as a routine when working on deck. 

8.2 The calculated results of the obtained Risk Characterization Ratio (RCR) 

= MOS/MOSref) were deemed acceptable and it can be judged that there is no unacceptable risk 

to the general public. 

8.3 Whilst not agreeing with all of the PBT assignments to the chemical by-products found in 

the treated ballast water, the Group agreed that none of these chemicals met the required PBT 

criteria that would result in the system not being recommended for Final Approval. 

8.4 Based on the PEC/PNEC ratio values shown in paragraph 7.3.4, the Group agreed that the 

chemicals produced in the treated water did not present a significant effect on the marine 

environment. 

8.5 The Group confirmed, from the results of onboard and land-based tests, that the treated 

ballast water, after neutralization, had no unacceptable effects on the aquatic environment. The 

maximum allowable discharge concentrations of Active Substances (the concentration of TRO 

after neutralization) should be kept to the level proposed by the applicant, i.e. not 

exceeding 0.03 mg/L as monitored by high sensitivity TRO sensor when adequately maintained. 

This parameter should be continuously recorded during ballast water discharge. 

8.6 Having considered the corrosion information, provided by the applicant, the Group 

agreed with the applicant’s recommendation to provide epoxy-lined/coated piping and tank 

structures which are exposed to Active Substance and Relevant Chemicals to prevent elevated 

corrosion rates. The Group noted that the applicant’s testing did not reveal significantly higher 

corrosion rates for uncoated steel natural seawater with 20 mg/L sodium hypochlorite. However, 

the applicant’s experiments were conducted with only 18 cycles of intermittent exposures 

to 20 mg/L sodium hypochlorite with a rapid decay in TRO, which may not be indicative of the 

long-term conditions or provide an adequate prediction of long-term corrosion rates. 

8.7 As a result, the Group did not agree with the applicant’s conclusion that the testing 

indicates that no significant difference in the corrosion rate of bare steel, non-metallics or the 

degradation of epoxy paints versus exposure to natural seawater. The Group recommended that 

all of the corrosivity and coating degradation testing be repeated with adequate control 

throughout the testing to maintain the TRO concentrations between 15 mg/L and 20 mg/L. 

Furthermore, the Group invited the applicant to consider the guidance provided in section 5.1 of 

the “Report of the eighth meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

8.8 As a result, the Group agreed that the system should be recommended for Final Approval 

provided that all recommendations contained within this assessment report are taken into 

account. 

* * * 
GESAMP-BWWG 11/6 

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APPENDIX 1 

DATA ASSOCIATED WITH TREATED BALLAST WATER 

1 Results of the growth inhibition test on marine algae (Skeletonema costatum) 

The following table shows the values of EC10 and EC50 obtained from the growth inhibition test. 

These results indicate that the effect on growth inhibition was not seen except in the case of 66% 

of EC10 on Day 5 during the test cycle 1 and 100% of EC10 on Day 5 during the test cycle 2. 

Results of the growth inhibition test on marine algae (Skeletonema costatum) 

Test 

cycle 

Test 

water 

Day 

No. Water condition EC10 (%) EC50 (%) 

0 Immediately after TGBC injection 2.0 2.3 1 Seawater 5 After TGEG neutralization 66 >100 

0 Immediately after TGBC injection 1.0 1.4 2 Brackish 

water 5 After TGEG neutralization 100 >100 

0 Immediately after TGBC injection 1.9 1.8 3 Brackish 

water 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 3.1 3.4 4 Brackish 

water 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 3.7 4.4 5 Brackish 

water 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 1.5 1.7 6 Brackish 

water 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 0.98 0.95 7 Seawater 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 0.15 0.27 8 Seawater 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection >1.8 >1.8 9 Seawater 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 0.42 0.70 10 Seawater 5 After TGEG neutralization >100 >100 

0 Immediately after TGBC injection 1.9 1.7 11 Brackish 

water 5 After TGEG neutralization >100 >100 

Note: (“>100%” means that no effect was seen in the test using the raw water for the secondary 

treated ballast water.) 
GESAMP-BWWG 11/6 

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2 Results of the acute toxicity test to marine copepods (Acartia tonsa) 

Acute toxicity test on Acartia tonsa, a type of marine copepods 

Acute toxicity test on invertebrate (Acartia tonsa) 

Test cycle Test water Collection 

date 

Test result 

48h-NOEC % Comment 

8 Seawater 2009.02.25 >100 % 

The death rate was zero in all test 

concentrations up to the 100% 

concentration of the secondary 

treated water. 

3 Reproduction toxicity (chronic toxicity) to Nitocra spinipes, a type of marine 

copepods 

Results of the chronic toxicity test on Nitocra spinipes, a type of marine copepods 

Results of reproducible toxicity test (chronic toxicity test) on Nitocra spinipes, a type of marine 

copepods 

Test cycle Test water Collection 

date 

Test result 

14d-NOEC % Comment 

3, 4 Brackish 

water 

2009.01.19 

2009.01.26 >100 % No significant effect was seen on 

reproducibility. 

4 Oyster embryo 

Table 3.1.5 : Results of the chronic toxicity test on oyster embryo 

5 Acute toxicity to juvenile turbot (Scophthalmus maximus) 

Results of the acute toxicity test on fish 

Results of the acute toxicity test on fish (juvenile turbot) 

Test cycle Test water Collection date 

Test result 

96h-NOEC 

(%) 

Comment 

6 Brackish 

water 2009.02.09 >100 % The limit test showed no effect 

7 Seawater 2009.02.16 >100 % The limit test showed no effect 

Results of the chronic toxicity test on oyster embryo 

Test cycle Test water Collection 

date 

Test result 

48h-LC50

(%) 

Test result 

48h-NOEC 

(%) 

Comment 

3 Brackish 

water 2009.01.19 >100 % ≥ 100 % No effect was seen at all 

concentrations. 

7 Seawater 2009.02.16 >100 % ≥ 100 % Ditto 
GESAMP-BWWG 11/6 

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6 Chronic toxicity to juvenile turbot (Scophthalmus maximus) 

Results of the chronic toxicity test on fish 

Results of the acute toxicity test on fish (juvenile fish) 

Test cycle Test water Collection date Test result 

28d-NOEC 

(%) 

Comment 

3-6 Brackish 

water 

2009.01.19 

-2009.02.17 >100 %

 The limit test showed no effect. 

Lack of weight increase at controlled 

section. 

7-10 Seawater 2009.02.16 

-2009.03.17 >100 % The limit test showed no effect. 

7 Chronic toxicity on Brachiomus plicatilis using a reproduction test 

Results of the chronic toxicity test on marine rotatoria 

Reproduction test using marine rotatoria (Brachiomus plicatilis)(chronic toxicity) 

Test 

cycle 

Test water Collection date Test result 

LC50 (%) 

Test result 

NOEC (%) Comment 

5 Brackish 

water 2009.01.26 >100 % ≥ 100 % No effect was seen at all 

concentrations. 

10 Seawater 2009.03.09 >100 % ≥ 100 % No effect was seen at all 

concentrations, 

The following conclusion was obtained from the results of these toxicity tests: 

 In the growth inhibitory experiments using Skeletonema costatum, only two out 

f 11 cases exhibited minor effects as measured utilizing EC10. No effects were observed 

in other organisms and in other test conditions. These results demonstrate ballast water 

after neutralization/reduction treatment in the present system has no effect against aquatic 

organisms. 

* * * 
GESAMP-BWWG 11/6 

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APPENDIX 2 

AQUATIC TOXICITY OF ACTIVE SUBSTANCES, RELEVANT CHEMICALS AND 

OTHER CHEMICALS 

1 ACUTE AQUATIC TOXICITY 

1.1 Active Substances - Sodium hypochlorite (main component of TG Ballastcleaner) 

Because the sodium hypochlorite (NaClO) contained in TG Ballastcleaner® partially forms 

hypochlorous acid (HClO) in ballast water, the acute toxicity value for the most sensitive 

species in free chlorine is for the Water flea (Ceriodaphnia dubia), which shows LC50 24 h 

with a concentration of 0.005 mg/L 1. The acute toxicity of many life forms is between 0.01 

and 0.1 mg/L. 

1.2 Other components 

1.2.1 The other components are sodium hydroxide (NaOH), sodium chloride (NaCl), sodium 

sulfite (Na2SO3) and sodium sulfate (Na2SO4). Sodium chloride is the main component of ballast 

water (seawater) and as sodium hydroxide exists only in a trace amount, sodium hydroxide does 

not cause changes in the pH of seawater. Therefore, these two substances were excluded from 

the scope of study in this section. Sodium sulfite, which is the main component 

of TG Environmentalguard®, and sodium sulfate were considered as object substances. 

1.2.2 The acute toxicity for aquatic organisms is described as follows: the most sensitive 

species of aquatic life for sodium sulfite at 16-32 mg/L (as SO3-S) are Green algae 

(Chlamydomonas reinhardtii) EC50 8.9 h, (Chlorella vulgaris) EC50 6.4 h, and (Scenedesmus 

basiliensis) EC50 8.2 h. On the other hand, the most sensitive species for sodium sulfate is the 

aquatic plant Diatom (Nitzschia linearis), which showed TLm 120 h = 1,900 mg/L. 

1.3 Relevant Chemicals 

1.3.1 Substances in this summary are limited to eight types of Relevant Chemicals detected in 

the land-based test, among which most sensitive species from the acute toxicity test are 

described. Other Relevant Chemicals are described in the full text or in appendix 1 (Key Data). 

1.3.2 Data on the toxity of RC12-bromochloroacetic acid is not available and was substituted by 

the data of dibromochloroacetic acid which has higher toxicity based on the chemical structure. 
GESAMP-BWWG 11/6 

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Acute toxicity of most sensitive species for Relevant Chemicals by class 

Class Species End point Period 

Concentration 

(mg/L) 

Reference 

RC3 Dichlorobromomethane 

 

Other life forms 

(ciliates) (Tetrahymena pyriformis) EC50 

Growth rate 24h 240 

Y.Yoshioka 

et al.

(1985) 

RC4 Dibromochloromethane 

Other organisms 

(ciliates) 

Ciliate 

(Tetrahymena pyriformis) EC50

24h 

(Growth 

rate) 

65 

Y.Yoshioka 

et al. 

(1985) 

RC5 Bromoform (tribromomethane) 

Fish (seawater 

acclimation) 

Sheepshead minnow 

(Cyprinodon variegatus) LC50 96h 7.1 G.S.Ward et al.

(1981) 

RC8 Sodium bromate 

Invertebrate 

(molluscan) 

Pacific Oyster 

(Crassostrea gigas) LC50 96h >30 E. A. Crecelius

RC12 Bromochloroacetic acid 

 - - - - No data 

RC15 Monobromoacetic acid 

Aquatic plants 

(algae) 

Green algae 

(Scenedesmus 

subspicatus) 

EμC50 

Growth rate 72h 1.4 R. Kuhn et al. .(1990) 

RC16 Dibromoacetic acid 

Fish Fathead minnow 

(Pimephales promelas) LC50 96h 69 M. A. Mayes et al. (1985) 

RC17 Tribromoacetic acid 

Fish Java medaka 

(Oryzias javanicus) LC50 96h 101 Appendix 13 9

2 Chronic aquatic toxicity 

2.1 Active Substances - Sodium hypochlorite 

2.1.1 Because the sodium hypochlorite contained in TG Ballastcleaner® partially forms 

hypochlorous acid (HClO) in ballast water, the chronic toxicity results for the most sensitive 

species in free chlorine was Cladoceran (Daphnia magna), NOEC 14d = 2-4 μg/L. Thus, other 

genera, not limited to the water flea, showed toxicity values on the order of 10 μg/L. 

2.2 Other components 

2.2.1 Although a search of the literature was carried out, chronic toxicity values for sodium 

sulfite and sodium sulfate could not be obtained. 
GESAMP-BWWG 11/6 

ANNEX 5 

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2.2.2 Sodium sulfite, which is the main component of TG Environmentalguard®, changes to 

sodium sulfate, and the second main component of seawater, in a short period of time 

(15 minutes: materials were submitted at time of Basic Approval). Therefore, it is judged that no 

chronic toxicity exists. 

2.3 Relevant Chemicals 

2.3.1 It was not possible to find chronic toxicity data for RC3-bromodichloromethane, 

RC4-dibromochloromethane, RC8-bromate ion, RC12-bromochloroacetic acid, and 

RC17 tricbromoacetic acid. The evaluations of the chronic toxicities of bromodichloromethane 

and dibromochloromethane were performed using data for bromoform, based its structural 

relationship with the aforementioned substances. 

2.3.2 The chronic toxicity values for bromate ion, bromochloroacetic acid, and tribromoacetic 

acid were evaluated considering a safety factor in the acute toxicity values.

Chronic toxicity of most sensitive aquatic life in Relevant Chemicals by class 

Class Species End 

point Period Concentration(mg/L) Reference 

RC5 Bromoform (tribormomethane) 

Fish 

Sheepshead 

minnow 

(Cyprinodon 

variegatus)

NOEC 4d 2.9 

P.T. 

Heitmuller 

et al. 

(1981) 

RC15 Monobromoacetic acid 

Invertebrate 

(crustaceans) 

Water flea 

(Daphnia magna) NOEC 21d 3.2 R.Kuhn et al. 

(1989) 

3 ENDOCRINE DISRUPTION 

3.1 The applicant confirmed that the Active Substances, four other chemical substances, 

and 23 Relevant Substances related to TG Ballastcleaner® and TG Environmentalguard® are not 

included in the Candidate list of 553 substances in the EC report, “Towards the establishment of a 

priority list of substances for further evaluation of their role in endocrine disruption”. 

3.1.1 In submitting this proposal, the applicant also confirmed that there have been no changes 

in the contents of the above-mentioned report from the time of Basic Approval. 

4 SEDIMENT TOXICITY 

4.1 For substances which have the potential property of accumulating or adsorbing in large 

quantity in sediments, toxicity with respect to organisms inhabiting sediments will be evaluated. 

4.2 As the evaluation standard, Log Kow has been adopted in accordance with 

the Methodology for information gathering and conduct of work of the GESAMP-BWWG 

(BMW. 2/Circ.13, 10 June, 2008), by referring Hazardous Substances Data Bank (HSDB), a 

database of the National Library of Medicine’s TOXNET system (http://toxnet.nlm.nih.gov/) and 

Syracuse Research Corporation’s database (http://www.srcinc.com/what-we-do/databaseforms.aspx?id=385). 
GESAMP-BWWG 11/6 

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5 BIOAVAILABILITY, BIOMAGNIFICATION, AND BIOCONCENTRATION 

5.1 Evaluation criteria are the bioconcentration factor (BCF) >2000 obtained in the 

experiment Methodology (BMW.2/Circ.13, 10 June. 2008). 

5.2 Therefore, these values are cited from HSDB and the Syracuse Research Corporation 

database. 

6 FOOD WEB AND POPULATION EFFECTS 

Because no data are available, it was evaluated by using the BCF values. 

* * * 
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APPENDIX 3 

MAMMALIAN TOXICITY OF ACTIVE SUBSTANCES, RELEVANT CHEMICALS 

AND OTHER CHEMICALS 

1 ACUTE TOXICITY 

1.1 Acute toxicity of Active Substances 

Acute toxicity and LD50 of Active Substances in mammals 

 Value Species Reference/Comments/Justification for 

missing data 

AS Sodium hypochlorite 

Oral LD50 (mg/L) 1.23-1.46g/kg 

12.5% FAC 

Rat Proposal for the Health Classification and 

Labelling of the ESR substance Sodium 

Hypochlorite,ECBI/14/05 

Dermal LD50 (mg/L) No data 

Inhalation LC50

(mg/L/4h) 

>10.5mg/L 

air rate 

10 L/min 

Rat IUCLID P.61 (95) 

1.2 Acute toxicity of Relevant Chemicals 

 

Acute toxicity and LD50 of bromoform in mammals 

 Value Species Reference/Comments/Justification for 

missing data 

RC5 Bromoform 

Oral LD50 (mg/L) 1147 mg/kg Rat female HSDB(2005) 

Dermal LD50 (mg/L) No Data 

Inhalation LC50

(mg/L/4h) 

No Data Can be substituted with data for chloroform, 

which displays high volatility. 

2 EFFECTS ON SKIN AND EYE 

2.1 Effects of Active Substances on skin and eye 

2.1.1 Skin and eye irritation 

2.1.1.1 The Group noted that, according to RAR EC (2007), with respect to corrosivity data 

from animal studies, it has been shown that 12.7% of hypochlorite solution produced severely 

irritant or corrosive effects to the eye. However, the same concentration applied to rabbit skin 

does not show corrosive effects, only moderate irritation was observed. Sodium hypochlorite 

aerosols may be an irritant to the respiratory tract. 
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2.1.2 Skin sensitization

2.1.2.1 Skin sensitization was not found in an animal test with an 8% hypochlorite solution 

according to a standard sensitization procedure. There are a few reports on cases of allergic 

contact dermatitis caused by skin sensitization to the hypochlorite and conclusive agreement has 

not been reached yet. No skin sensitization of sodium hypochlorite has been proposed based on 

these collected data. 

2.2 Effects of Other Components on skin and eye 

2.2.1 Irritation of the skin and eyes by sodium hydroxide is extremely strong. 

2.2.2 Regarding irritation of the skin and eyes by sodium sulfite, although based on limited 

study, the results have shown that this substance is not a strong irritant. Descriptions of the skin 

sensitization of sodium sulfite were not found in IUCLID or HSDB. 

2.2.3 With sodium sulfate, no irritation was observed, even when 500 mg was applied in a 

rabbit test. Regarding irritation of the eyes, the description states that this chemical causes very 

slight irritation in cases where it actually penetrates the eyes, but the affected part recovers.

Although no direct data were available for sensitization by sodium sulfate, as noted in the table, 

OECD SIDS has rejected the possibility that sodium sulfate causes increased sensitization.

2.3 Effects of Relevant Chemicals on skin and eye 

Effects of bromoform on skin and eye 

Species Method Results 

(including scores where available) 

Reference/Comments/ 

Justification 

for missing data 

RC5 Bromoform 

Skin Rabbit Single doses of 2, 000mg/kg under a cuff 

on the intact skin of rabbits were 

survived by two rabbits treated with 

undiluted bromoform. 

HSDB(2005) 

Eye Rabbit The undiluted liquid was moderately 

irritating to rabbit eyes. Healing 

appeared complete in 1 to 2 days. 

HSDB(2005)

3 REPEATED DOSE TOXICITY TESTS 

3.1 Repeated dose toxicity of Active Substances 

Repeated dose toxicity of the Active Substances in mammals was not available in the data listed 

in NOAEL. 
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3.2 Repeated dose toxicity of Relevant Chemicals 

Repeated dose of RC3-Dichlorobromomethane 

Exposure Route Oral administration 

Exposure Duration 102 weeks 

Exposure dose 0, 25, or 50 mg/kg/d 

Species 50 male B6C3F1 mice 

Method Gavage 

Results renal cytomegaly in male mice, an effect considered minimal in the 

absence of data demonstrating renal functional 

impairment 

NOAEL 1.79 mg/kg/d 

= LOAEL 17.9 mg/kg/d (25 mg/kg/d x 5 days/7 days) x 0.1 

NOEL No description 

Reference/Comments/ 

Justification for missing data EPA IRIS (2008) 

Repeated dose of RC4-Dibromochloromethane 

Exposure Route Oral administration 

Exposure Duration 13 weeks 

Exposure dose 0, 15, 30, 60, 125, or 250 mg/kg 

Species Fischer-344 rats and B6C3F1 mice 

Method Fischer-344 rats and B6C3F1 mice were administered 0, 15, 30, 60, 125, 

or 250 mg/kg chlorodibromomethane for 13 weeks by gavage. 

Results A Fisher Exact test showed that incidences of these liver lesions at doses 

of 60 mg/kg/d or above were elevated relative to the vehicle controls, 

thus 30 mg/kg/d is the NOEL. 

NOAEL 21.4mg/kg/d 

NOEL No description 

Reference/Comments/ 

Justification for missing data EPA IRIS (2008) 

Repeated dose of RC5-Bromoform 

Exposure Route Oral 

Exposure Duration 13w 

Exposure dose 0, 12, 25, 50, 100, 200 mg/kg/d (5 days/week) 

Species Rat 

Method Gavage Bioassy 

Results Hepatocellular vacuolization was observed in most male rats (10/l0 at 

200 mg/kg, 8/10 at 100 mg/kg, 8/10 at 50 mg/kg, 5/10 at 25 mg/kg, 6/10 

at 12 mg/kg, and 3/10 vehicle controls). 

NOAEL 17.9mg/kg/d (converted from 25mg/kg/d) 

NOEL No description 

Reference/Comments/ 

Justification for missing data EPA IRIS (2008) 
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Repeated dose of RC16-Dibromoacetic acid 

Exposure Route Oral (Gavage) 

Exposure Duration 2 to 79days 

Exposure dose No description 

Species Rats 

Method Rats were gavaged daily for 2 to 79 d with a by-product of water 

disinfection, dibromoacetic acid (DBAA). 

Results No abnormalities were detected at the dosage of 2 mg/kg. The changes 

suggest that the testicular effects of DBAA are sequelae to structural and/or 

functional changes in the Sertoli cell. 

NOAEL 2mg/kg/d 

NOEL No description 

Reference/Comments/ 

Justification for missing data HSDB(2009) 

4 CHRONIC TOXICITY

4.1 Chronic toxicity of Active Substances 

Chronic toxicity of AS-Sodium hypochlorite 

Exposure Route Oral 

Exposure Duration 2 years 

Exposure dose 0, 70, 140, 275 mg/L 

Species F344 rats 

Method Drinking water 

Results No effects seen at 14 and 66 weeks. 

NOAEL 14.4mg/kg/d 

NOEL No description 

Reference/Comments/ 

Justification for missing data

Proposal for the Health Classification and Labelling of the ESR 

substance Sodium Hypochlorite,ECBI/14/05 

4.2 Chronic toxicity of Relevant Chemicals 

Chronic toxicity of RC8-Bromate ion 

Exposure Route Oral 

Exposure Duration 100 weeks 

Exposure dose 0, 1.1, 6.1, 12.9, and 28.7 mg BrO3

-

/kg/d 

Species F344 rat male 

Method Drinking water 

Results Nonneoplastic kidney lesions were observed in rats. Although the 

severity of chronic nephropathy was comparable between control and 

treated rats, there was a significant dose-dependent increase in the 

incidence of urothelial hyperplasia in rats in dose groups of 6.1 mg/kg-d 

and higher. 

NOAEL 1.1 mg BrO3

-

/kg/d (converted from 1.5 mg KBrO3/kg/d) 

NOEL No description 

Reference/Comments/ 

Justification for missing data EPA IRIS (2001) 
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5 DEVELOPMENTAL AND REPRODUCTIVE TOXICITY 

5.1 Developmental and reproductive toxicity of Active Substances 

Data on developmental and reproductive toxicity of sodium hypochlorite is limited, but there is 

no direct evidence to indicate the adverse effect of sodium hypochlorite on development and 

reproduction. Similarly, there is no evidence of adverse effect in an epidemiological study on 

people drinking chlorinated water. These studies indicate sodium hypochlorite should not be 

classified into the substances adversely affecting reproduction. 

5.2 Developmental and reproductive toxicity of Relevant Chemicals 

Developmental and reproductive toxicity of RC5-bromoform 

Exposure Route Injection 

Exposure Duration 10 days 

Exposure dose 100-200 mg/kg/d 

Species Guinea pig 

Method Injection of 100-200 mg/kg/d to Guinea pig for 10 days 

Results Pathological change in kidney and liver 

NOAEL No description 

NOEL No description 

Reference/Comments/ 

Justification for missing data HSDB (2005) 

6 CARCINOGENICITY 

6.1 Carcinogenicity of Active Substances 

In a study on carcinogenicity of the drinking water in rats and mice, there was no evidence to 

demonstrate the incidence of tumor increase by Active Substances. Available data do not indicate 

that sodium hypochlorite has to be classified as carcinogenic. International Agency for Research 

on Cancer (IARC) presumes sodium hypochlorite belongs to Group 3 (not classifiable as 

carcinogenic to human). Sodium hypochlorite is therefore not treated as carcinogenic. 

6.2 Carcinogenicity of Relevant Chemicals 

Carcinogenicity of RC5-Bromoform 

Species Method Details Results Reference/Comments/ 

Justification for 

missing data 

F344/N 

rats 

2 year gavage 

studies 

There was no evidence of carcinogenic 

activity for male B6C3F1 mice given 

50 or 100 mg/kg bromoform or for 

female B6C3F1 mice given 100 or 200 

mg/kg; male mice might have been 

able to tolerate a higher dose. Survival 

of female mice was reduced, partly due 

to a utero-ovarian infection

HSDB(2005) 
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7 MUTAGENICITY AND GENOTOXICITY 

7.1 Mutagenicity and genotoxicity of Active Substances 

7.1.1 There was some data indicating in vitro mutagenic activity of sodium hypochlorite, but a 

detailed in vivo study using mice indicates this substance has no mutagenic activity (Hayashi et al., 

1988). Other in vivo study also showed no mutagenic effect of this substance. These data related 

to genetic toxicity of sodium hypochlorite did not indicate the final conclusion, but further data 

would not be required based on no effects on carcinogenicity. Data obtained indicate sodium 

hypochlorite does not exhibit mutagenicity so that this substance is not classified as mutagenic. 

7.2 Mutagenicity and genotoxicity of Relevant Chemicals 

Mutagenicity and genotoxicity of bromoform 

Species Method Details Results Reference/ 

Comments/ 

Justification for 

missing data 

Aroclorinduced rat 

liver S9 

fraction 

Based on preliminary bacterial 

toxicity determinations, 

bromoform was evaluated for 

mutagenicity at concentrations 

of 5, 10, 50, 100, 500, and 

1000 ug/plate using the direct 

plate incorporation method. 

The mutagenicity of bromoform 

was also tested for mutagenicity in 

Salmonella tester strains TA98, 

TA100 and TA1535, both with and 

without metabolic activation at dose 

levels of 0.02, 0.05, 0.1, and 0.2 

ml/dessicator. In this study, 

bromoform caused a reproducible 

positive response in all three 

strains. 

HSDB(2005) 

8 TOXICOKINETICS 

8.1 Toxicokinetics of Active Substances 

No data existed. 

8.2 Toxicokinetics of Relevant Chemicals 

Toxicokinetics of RC5-Bromoform 

Species Observation/Remarks 

Reference/ 

Comments/ 

Justification for 

missing data 

No description Bromoform metabolized to carbon monoxide by hepatic 

microsomal mixed function oxidases. HSDB(2005) 

*** 

GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 6 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Sunrui Ballast Water Management System 

Submitted by China for Basic Approval 

0 SUMMARY 

0.1 Having reviewed all of the data provided by the applicant, the Group recommended that 

the Sunrui Ballast Water Management System (BWMS) be granted Basic Approval. 

0.2 Notwithstanding this recommendation, the Group recognized that the risk to general 

public (HES via seafood consumption) was adequately assessed by using EUSES model 2.1. 

However, the HES for the general public via aggregated exposure (oral, skin and inhalation) 

when bathing in the areas close to the discharged ballast water had not been provided by 

the applicant. 

0.3 The Group also noted that the applicant did not provide information regarding the 

identification and description of the unit operations associated with this system. The Group also 

noted that information regarding the Human Exposure Scenario (MEPC 56/2/2, annex 9) had not 

been provided. The Group proposed that this information should be fully supported and 

documented so that it can be taken into account if the system has to be reviewed for Final 

Approval. 

0.4 The Group concluded that based on the risk assessment performed for the environment, it 

is not expected that the Sunrui BWMS would cause unacceptable risks for the environment. 

0.5 However, the Group considered that the system should not cause any unacceptable risk to 

the crew or the general public provided that the standard risk mitigation measures are applied. 

0.6 Furthermore, the Group recommended that the risks to the general public during 

recreational activities (swimming) should be assessed for consideration during Final Approval 

consideration. 

0.7 In addition the Group recommended that the comprehensive corrosion testing referred to 

in paragraph 9.6 should be addressed prior to application for Final Approval review. 

1 INTRODUCTION 

1.1 Data used to evaluate this system were extracted from MEPC 60/2/3 and were 

supplemented by additional information provided to the Group. 
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2 DESCRIPTION OF THE SYSTEM 

2.1 The Group noted that the Sunrui system comprised: 

.1 a filtration process using 50 μm filter; 

.2 electrolyzing seawater to produce disinfection at intake; and 

.3 a neutralization system to offset the residual TRO to the level below 0.1 mg/L 

when de-ballasting. 

2.2 The Group noted that, following filtration, a side stream from the ballast line of seawater 

is subjected to electrolysis which generates a solution of sodium hypochlorite. This side stream 

is then injected back into the main ballast stream following a de-gassing process. 

2.3 It was noted that the TRO level is measured and the concentration maintained 

between 8.0 mg/L and 9.5 mg/L by controlling the current according to the ballast water uptake 

flow rate and the Group evaluated this application based on these levels. 

2.4 It was also noted that the applicant stated that, if the salinity of the intake ballast water is 

below 3 PSU, then salt would be needed to be added to the water being subject to electrolysis. 

2.5 Schematic representation of the ballasting and de-ballasting processes, as provided by the 

applicant, are shown below: 

Schematic representation of the ballasting procedure 

Filter Ballast tank 

Electrolysis 

Ballast 

water uptake 

Ballast 

water 

side stream 

Neutralizer 
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2.6 The Group noted the following chemical reactions which take place as part of the 

electrolysis process: 

Anode: 2Cl- → Cl2 + 2e 

Cathode: 2H2O + 2e → 2OH-

 + H2↑

 Chlorine gas can be dissolved in water to produce hypochlorous acid and hydrochloric 

acid rapidly: 

 Cl2 + H2O → HOCl + Cl-

 + H-

 So the overall reaction is: 

 NaCl + H2O → NaOCl + H2↑

 Hypochlorous acid is a weak acid, which means that it tends to undergo partial 

dissociation as follows: 

 HOCl ⇋ H+ + OCl- 

 to produce a hydrogen ion and a hypochlorite ion. In water of pH between 6.5 and 8.5 the 

reaction is incomplete and both species are present to some degree. The extent of this 

reaction can be calculated from the equation: 

 Ki = 

( )

( ).( )

HOCl

H OCl + −

 where Ki is the ionization constant, varies in magnitude with temperature. 

The value of the constant ranges from 1.488x10-8 mole/L at 0°C to 3.175 x10-8

mole/L at 30°C. 

 Hypochlorous acid is the most germicidal of all chlorine compounds with the possible 

exception of chlorine dioxide. Undissociated HOCl species is a function of pH value and 

temperature. 

2.7 In addition to the normal chemical reactions, which take place between salt and water 

under electrolysis, the Group also noted the chemical reactions involving bromine and ammonia, 

as shown below: 

Normally, natural seawater contains bromine ions with a density of 50~70 mg/L. The 

oxidation reaction between hypochlorous acid and bromine ions will produce 

hypobromous acid: 

 HOCl + Br - → HOBr + Cl -

 
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 Hypobromous acid will dissociate, as does hypochlorous acid depending upon pH, 

temperature and ionic strength as follows: 

 K= 

( )

( ).( )

HOBr

H OBr + −

 Where K= 2 x 10-9 at 20°C

Hypobromous acid is also an effective biocide more stable than chlorine under alkaline 

seawater. It is calculated that at pH 8, the undissociated HOBr is 83 percent versus HOCl 

of only 28 percent. 

In addition, the reaction of hypochlorous acid and hypobromous acid with ammonia in 

seawater generate chloramines, including monochloramine, dichloramine, trichloramine 

and bromamines (including monobromamine, dibromamine, tribromamine). The reaction 

equations for generating chloramines are as follows: 

 HOCl + NH3 ⎯⎯→NH2Cl(monochloramine)+ H2O 

 NH2Cl + HOCl ⎯⎯→NHCl2(dichloramine)+ H2O 

 NHCl2 + HOCl ⎯⎯→NCl3(trichloramine)+ H2O 

Chloramines and bromamines are also germicidal agents, and it is generally considered 

that their bactericidal actions are much weaker than those of HClO/ClOand HOBr/OBr-

. 

However, recent studies indicated that if chloramines are allowed contact time of 45–60 

minutes they are able to match the efficiency of free chlorine based upon the destruction 

of coliform organisms. 

In this document, the substances with bactericidal action mentioned above are 

HClO/ClO-/Cl2, HOBr/OBr-/Br2, chloramines and bromamines, which are called by a 

joint name Total Residual Oxidants (TRO). 

3 CHEMICALS ASSOCIATED WITH THE SYSTEM

3.1 The Group noted that the applicant had identified the following chemical as Active 

Substance, Relevant Chemicals or Other Chemicals: 

Chemicals CAS No. Molecular 

weight 

Formula AS/

RC/

OC 

(bio)degradation 

rate or half-life 

Hypochlorous acid 

/hypochlorite 

7681-52-9 74.44 NaOCl AS 1.4 hour 

(at pH 8) 

Hypobromous acid 

/hypobromite 

13824-96-9 118.89 NaOBr AS 

Biodegrades fast 

Chloramines/ 

Bromamines 

Not 

available 

51.48 NH2Cl AS 9 to 420 hours 

(as 

monochloramine) 
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Chemicals CAS No. Molecular 

weight 

Formula AS/

RC/

OC 

(bio)degradation 

rate or half-life 

Dibromochloromethane 124-48-1 208.28 CHBr2Cl RC Water: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 280 days 

Tribromomethane 75-25-2 252.73 CHBr3 RC 1.7 years (Fresh 

water, at an aqueous 

concentration 

of 1X10-17 mole/l 

hydroxyl radicals) 

Monobromoacetic acid 79-08-3 167.01 CH2BrCOOH RC Half-life: 

Water: 8.7 days 

Soil: 17 days 

Sediment: 78 days 

Air: 22 days 

Bromochloroacetic acid 5589-96-8 138.95 CHBrClCOOH RC Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 24 days 

Dibromoacetic acid 631-64-1 217.86 CHBr2COOH RC Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 25 days 

Dibromochloroacetic 

acid 

5278-95-5 252.36 CClBr2COOH RC 

No data available 

Tribromoacetic acid 75-96-7 296.74 CBr3COOH RC Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 31 days 

Dibromoacetonitrile 3252-43-5 198.86 CHBr2CN RC Half-life: 

Water: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 540 days 

Bromate 7758-01-2 167.01 KBrO3 RC Half-life: 

Seawater: 12 hours 

Sodium thiosulfite 7772-98-7 158.09 Na2S2O3 OC 

Biodegrades fast 

3.2 In addition to the above chemicals, the Group noted that other chemicals are produced by 

this system including: 

 .1 hydrogen gas; 

 .2 oxygen gas; 
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 .3 hydrogen peroxide; and 

 .4 ozone. 

3.3 However, the Group recognized that both hydrogen and oxygen were removed by a 

degassing process immediately following electrolysis and that hydrogen peroxide and ozone have 

short half-lives and so need not be considered in the risk assessment process. 

3.4 Data, supplied by the applicant on those chemicals shown in the above table are shown in 

appendices as indicated below: 

 .1 appendix 1 – Aquatic toxicity data; 

 .2 appendix 2 – Mammalian toxicity data; 

 .3 appendix 3 – Environmental fate data; 

 .4 appendix 4 – Physical and chemical properties data; and 

 .5 appendix 5 – Chemical analysis of untreated and treated water. 

4 QUESTIONS SENT TO APPLICANT DURING EVALUATION WITH ANSWERS 

AND REACTIONS OF THE GROUP 

Question 1: 

The Group would like to be clarified in what concerns the application of EUSES 2.1 model 

to assess human risk – general public exposed via environment (oral intake of fish)? 

Therefore, we would like to know what were the assumptions made and the calculations 

performed by the applicant to set the input parameters for exposure assessment/effects 

assessment/risk characterization process (MRR). We would appreciate that a worst case 

scenario could be used to illustrate the reasoning. 

Response 1: 

.1 In assessing human risk – general public exposed via environment (oral intake of 

fish) by EUSES 2.1 model – it was assumed that when the ballast water is 

discharged into a port, the chemicals in the ballast water may accumulate in fishes 

and affect the health of the people who consume the fishes. 

.2 In the application of EUSES 2.1 model, the “man exposed via the environment” 

and the “local scale” mode was used. And the physico-chemical parameters and 

environmental data are from key data summaries or MAMPEC model calculation. 

Regarding the input parameters, please refer to the “Data sheet of EUSES for risk 

assessment” in appendix 8 in folder 4 of the confidential application dossier. 
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.3 The concentrations of the chemicals in fishes were calculated by the equation 

Cfish=BCFfish·Cwater,Cwater is the PEC, which was calculated by MAMPEC model. 

Then the human total intake exposure dose (DOSElocal) was calculated, and the 

MOSman-env was work out by following equation: 

 MOSman-env= Effects / Exposure= NOAEL/DOSElocal

.4 The worst case scenario has been used in the calculation and assessment. The 

MRR was calculated by the following equation: MRR=MOSman-env/MOSref., and 

according to the worst case scenario, the largest MOSref value was used to 

calculate MRR, the smallest MRR value was used to assesse human risk- general 

public exposed via enviroment (oral intake of fish). 

Reaction: The Group was satisfied with the response. 

Question 2: 

It is noted that the submission informs that in the case of water salinity below 3 psu, salt 

needs to be added. Please give details, otherwise, if the required component for addition of 

salt to the side stream electrolysis line has not been developed yet, is this to be furthered 

prior to Final Approval? 

Response 2: 

 .1 As for ballasting in water with salinity below 3 PSU, to add salt is one option that 

is under consideration. It has been noted that a number of similar systems have 

proposed to add salt when fresh water needs to be treated and this option has been 

endorsed by the Group. 

 .2 The other option, as we recommended in our application (see second paragraph of 

section 2.5 of the confidential application report), might be that if a ship has to 

ballast in fresh water areas, i.e. sea outfall of fresh water river, the ship in question 

may retain a certain amount of seawater in the ballast tanks from previous voyage 

(about 1%~2% of the ballast water needed for the voyage), which can be used as 

the electrolytic water. We think this method would be more economical and easy 

in operation. 

 .3 Investigation and further testing with regard to the above-mentioned two options 

are undergoing and the results and findings will be provided to the Group when 

applying for Final Approval. 

Reaction: The Group was satisfied with the response. 
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Question 3: 

The Group needs further explanation about “sig. of ANOVA” on the bottom of the Tables 

on pages 13 to 18 at appendix 4–3 to evaluate the results of toxicity test. 

Response 3: 

 .1 “Sig. of ANOVA” means the significance of difference between every group 

include treatments and control, using one-way analysis of variance, the method of 

analysis of variance. 

Reaction: The Group noted the response of the applicant. 

5 HUMAN HEALTH ASSESSMENT 

5.1 The Group noted the various chemicals associated with this system and agreed that these 

presented the following potential hazards to the crew and/or general public 

 .1 Sodium hypochlorite is: 

 .1 corrosive at concentrations above 10%*; and 

 .2 irritant to skin and eyes at concentrations from 5-10%*. 

Note: *The classification according to GHS (CLP, 1272/2008/EC, in 

Europe) will change the current classification of sodium hypochlorite. 

According to CLP concentrations ≥ 5 % will lead to a classification as Skin 

Corrosive Category 1B (H314; Causes severe skin burns and eye damage). The 

specific concentration limits (5%≤ conc < 10% and conc ≥ 10%) have been 

removed from the harmonised classification and are no longer applicable. 

 .2 Trihalomethanes and, in particular, bromoform are: 

 .1 toxic by inhalation; 

 .2 harmful if swallowed; 

 .3 irritating to the skin and eyes; and 

 .4 may also be a human carcinogen. 

 .3 Halo-acetic acids and in particular dibromoacetic acid are: 

 .1 acutely toxic if swallowed; 

 .2 acutely toxic if inhaled; 

 .3 acutely toxic in contact with skin; and 

 .4 corrosive to skin. 
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Page 9 

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5.2 The Group noted that the applicant considered the Human Exposure Scenario (HES) via 

seafood consumption to be the relevant scenario for general public risk assessment. 

5.3 However, the Group noted that the risks associated with such chemicals had been 

evaluated using EUSES (version 2.1) the results, of which, showed a MOS/MOSref of >1 for the 

general population in local and regional areas. Results from EUSES are shown in the table 

below which are different from those shown in MEPC 60/2/3 and were corrected following 

discussion with the applicant and, were corrected due to the wrong units for Henry’s constant 

being used by the applicant: 

MRR (MOS/MOSref) values 

Chemical Name PEC, 

μg/l 

BCFfish, 

m3/kgwwt

Cfish, 

mg/kg MRR 

Tribromomethane 1.06E+00 14.00 1.48E-02 7.36E+03 

Dibromochloromethane 2.41E-02 1.47 3.54E-05 1.89E+05 

Bromoacetic acid 3.03E-02 3.20 9.70E-05 3.14E+05 

Dibromoacetic acid 7.03E-01 0.17 1.20E-04 4.76E+05 

Tribromoacetic acid 3.81E-01 0.63 2.40E-04 1.01E+05 

Bromochloroacetic acid 1.96E-01 3.20 6.27E-04 1.94E+04 

Dibromochloroacetic acid 4.94E-02 3.16 1.56E-04 2.93E+05 

Dibromoacetonitrile 1.01E-01 3.00 3.03E-04 1.99E+03 

Sodium thiosulfite 7.89E+00 3.16 2.49E-02 1.34E+04 

5.4 The Group tentatively assessed the risk to the crew by using the HES – crew entering the 

ballast tank as a worst case scenario. The risk was found to be acceptable taking into 

consideration the concentration of tribromomethane (as being the critical relevant chemical in 

terms of human health risk) in the head space of the ballast tank and by comparing it with the 

OEL set for this substance. 

5.5 The Group noted that the applicant considered that the only chemical substance being 

handled and mixed by crew is sodium thiosulfate. The applicant stated that it is required that the 

operators should wear protective gloves, clean body-covering clothing and safety glasses. Safety 

procedure for handling of sodium thiosulfate is detailed in Technical Specification and Manual, 

in appendix 9 of the full application dossier. 

5.6 However, the Group noted that the applicant had not provided information regarding the 

identification and description of the unit operations associated with this system. Also, the Group 

noted that information regarding the Human Exposure Scenario (MEPC 56/2/2, annex 9) had not 

been provided. The Group proposed that this information should be fully supported and 

documented so that it can be taken into account if the system is to be reviewed 

for Final Approval. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 10 

I:\MEPC\60\2-12.doc

6 EVALUATION OF TREATED BALLAST WATER

6.1 The Group noted that the applicant had carried out the following aquatic toxicity tests 

with the results shown below: 

Type Organism Test Result 

A Skeleonema costatum 

Acute and Chronic 96 h 

Growth Inhibition 

(static condition) 

NOAEC > 100% 

Neomysis awatschenis 

Acute 96 h 

mortalities 

(static condition) 

NOEC > 100% 

LOEC > 100% 

C 

Neomysis awatschenis 

Chronic 7 d 

mortalities 

(semistatic condition renewal all 

volume everyday) 

NOEC > 100% 

LOEC > 100% 

Ctenogobius gymnauchen 

Acute 96h 

mortalities 

(static condition) 

NOEC > 100% 

LOEC > 100% 

F 

Ctenogobius gymnauchen 

Chronic 7d 

mortalities 

(semistatic condition, renewal 

85%-90% volume everyday) 

NOEC > 100% 

LOEC > 100% 

6.2 The Group noted that this WET testing used the simulated ballast water with 48 h tank 

holding time and the neutralization process after this holding time. 

6.3 The Group noted that the results of these testing show that all the ecotoxicity of 

discharged ballast water is in the range of acceptable level. 

7 RISKS TO THE SAFETY OF THE SHIP 

7.1 Flooding

7.1.1 The Group noted that the system is designed to shut down automatically in the event of 

any failure. 

7.2 Corrosion

7.2.1 The Group noted that the applicant cites corrosivity evaluations for ballast water treated 

by electrolysis which were reported by previous applicants and concluded that no significant 

increase in corrosion compared to natural seawater would result, and even less in some cases. 

In particular, the applicant noted that document MEPC 58/2/7, (GESAMP-BWWG 6, annex 7, 

paragraph 4.7.2) indicated an electrolysis system with an initial TRO concentration up 

to 10 mg/L did not have increased corrosion effect. However, the Group does not agree with 

the applicant’s inference as the full consideration and recommendations of the Group in these 

citations was not accounted for by the applicant. In all cases, and specifically in MEPC 58/2/7, 

(GESAMP-BWWG 6, annex 7, paragraph 4.7.4), the Group considered these conclusions to be 

insufficient and in conflict with published literature discussing the increased corrosion rates of 

steel in seawater with a TRO concentration >2 mg/L. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 11 

I:\MEPC\60\2-12.doc 

7.2.2 The Group recommended that the comprehensive testing be conducted in accordance with 

the guidance provided in section 5.1 of the “Report of the eighth meeting of 

the GESAMP-BWWG” contained in MEPC 59/2/16. Where intermittent exposures are utilized to 

predict long-term corrosion rates, as proposed by the applicant, the TRO in the sample containers 

should be recorded and reported over the period of the exposure. In addition, the Group 

recommended that some indication, with supporting data, of the long-term corrosion rates under a 

constant level of TRO at the maximum allowable dosage concentration should be provided to 

assess the potential impact on exposed ship systems more realistically. 

7.3 Hydrogen and Chlorine gases

7.3.1 It was noted that hydrogen is generated during electrolysis and at 9.5 mg/L 

TRO as Cl2 133.8 mols (267.6 g) of hydrogen gas is generated when treating 1000 tons of ballast 

water. 

7.3.2 However, it was also noted that the hydrogen gas is separated from the water in a degas 

tank and diluted, by air blowers, to a level below the Lower Explosive Level (LEL) after which it 

is vented overboard. There is a spark arrestor fitted to the discharge end of the vent pipe. 

7.3.3 It was also noted that the level of hydrogen gas in the air discharge from the degas unit 

was monitored and, should unsafe levels of hydrogen concentration arise, then the system is shut 

down. 

7.3.4 The Group noted that, during tests, no chlorine gas had been detected in the area around 

the electrolytic unit and the chlorine gas concentrations in the headspace of the tank holding the 

treated ballast water were <0.3 mg/L. 

7.3.5 It was also noted that the system had both chlorine gas and hydrogen gas sensors to be 

arranged in the spaces containing the treatment system to detect any leakage and alarms are 

triggered when the concentration of hydrogen exceeds 2% or the concentration of chlorine 

exceeds 0.4 mg/L. Furthermore, if levels detected exceed 3% or 0.55 mg/L respectively, the 

electrolytic units will be shut down automatically. The Group consequently considered that the 

risk mitigation measures to be put in place in this regard as sufficient to permit further 

development of this system. 

8 ENVIRONMENTAL RISK ASSESSMENT 

8.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

Chemical Persistenc 

(Y/N) 

Bioaccumulation 

(Y/N) 

Toxicity 

(Y/N) 

HOCl(NaClO) No 

Half-life:1.4 hour 

(at pH 8) 

No 

BCF: -2.19 

Log Pow: -3.42 

Yes 

134 d NOEC:0.005 mg/L/ 

HOBr(NaBrO) No 

Biodegrades fast 

No 

BCF: 1.24 

Log Pow: -1.03 

N. A. 

Monochloramine No 

Abiotic Degradation: 

Chloramine half-lives 

ranging from 9 to 420 hours 

N. A. N. A. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 12 

I:\MEPC\60\2-12.doc

Chemical Persistenc 

(Y/N) 

Bioaccumulation 

(Y/N) 

Toxicity 

(Y/N) 

Tribromomethane Yes 

Fresh water, Half-life: 1.7 

years (at an aqueous 

concentration 

of 1X10-17 mole/l 

hydroxyl radicals) 

No 

BCF: 14 

Log Pow: 2.4 

No 

28 d NOEC: 4.8 mg/L 

Dibromochloro 

methane 

Yes 

Half-life: 

Water: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 280 days 

No 

BCF: 0.74-1.47 L/kg 

Log Pow: 2.24 

No 

21 d NOEC: 3.2mg/L 

Bromoacetic acid No 

Half-life: 

Water: 8.7 days 

Soil: 17 days 

Sediment: 78 days 

Air: 22 days 

No 

BCF: 3.2 

Log Pow: 0.41 

No 

21 d NOEC: 1.6 mg/L 

Dibromoacetic acid No 

Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 25 days 

No 

BCF: 0.17 

Log Pow: 0.70 

No 

PBT Profiler 

Tribromoacetic acid No 

Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 31 days 

No 

BCF: 0.63 

Log Pow: 1.71 

No 

PBT Profiler 

Bromochloro 

acetic acid 

No 

Hal- life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 24 days 

No 

BCF: 3.2 

Log Pow: 0.61 

No 

PBT Profiler 

Dibromochloro 

acetic acid 

No 

Activated sludge: 

100%(aerobic), 28 days 

No 

Log Pow: 1.62 

N. A. 

Dibromoacetonitrile No 

Half-life: 

Water: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 540 days 

No 

BCF: 3 

Log Pow: 0.47 

No 

PBT Profiler 

Bromate No 

Half-life: 

Seawater: 12 hours 

No 

BCF: 3.7×10-7

Log Pow: -7.18 

No 

7 d NOEC:8 mg/L 

Sodium thiosulfite No 

Biodegrades fast 

No 

BCF: 3.162 

Log Pow: -4.53 

No 

18 m NOEC:600mg/L 

8.1.1 The value of 134 d NOEC of 0.005 mg/L, in the table above, should possibly be 

substituted by a NOEC of 0.003 mg/L (Cairns 1990 in table 4-2 in MEPC 60/2/3) based on TRC 

measurement. However, the Group decided not to pursue this since it has no practical 

consequence for the PBT classification or the PEC/PNEC calculations. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 13 

I:\MEPC\60\2-12.doc 

8.1.2 The Group agreed with the applicant that none of the above chemicals are classified as 

PBT substances 

8.2 Calculation of Predicted Environmental Concentration (PEC) 

8.2.1 The Group noted that the applicant had used the MAMPEC model (version 2.0) to 

calculate the PEC for chemicals employing: 

 .1 the OECD-EU commercial harbour; 

 .2 the physico-chemical properties for each chemical as shown in the appendices 

(assuming that the chemicals will not decay in the water); 

 .3 the concentrations of each chemical analysed in the treated ballast water; and 

 .4 and a ballast water discharge rate of 100,000 m3

/day. 

8.2.2 The results are shown in the table below: 

Chemicals Background conc 

μg/L 

BW Concentration 

μg/L 

Max PEC 

μg/L 

HOCl(NaOCl) 0 0 0 

HOBr(NaOBr) 0 0 0 

Chloramine 0 0 0 

Tribromomethane 0.19 157.98 1.06E+00 

Dibromochloromethane 0 4.32 2.41E-02 

Monobromoacetic acid 0 3.31 3.03E-02 

Dibromoacetic acid 0.52 19.98 7.03E-01 

Tribromoacetic acid 0 41.63 3.81E-01 

Bromochloroacetic acid 0.19 0.61 1.96E-01 

Dibromochloroacetic acid 0 5.4 4.94E-02 

Dibromoacetonitrile 0 11.09 1.01E-01 

Bromate 0 0 0 

Sodium thiosulphite 0 862 7.89E+00 

Note: The above table shows results corrected after consultation with the applicant. The original results, 

reported in MEPC 60/2/3 were calculated using the wrong Henry’s Law Constant. 

8.2.3 The Group concurred with the applicant, having used the MAMPEC model to achieve the 

Predicted Environmental Concentrations (PECs), that the resulting concentrations in the scenario 

defined by the applicant would not result in any unacceptable risks for the environment. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 14 

I:\MEPC\60\2-12.doc

8.3 Calculation of PEC/PNEC ratios

8.3.1 The Group agreed with the applicant’s assessment of PEC/PNEC ratios, after correction 

from the original results shown in MEPC 60/2/3 as shown below: 

Chemical name Toxicity 

(mg/L) 

Information factor PNEC 

(μg/L) 

PEC 

(μg/L) 

PEC/PNEC 

HOCl(NaOCl) 0.003 Lowest L(E)C50 from a fish, 

crustacean and alga and 

lowest NOEC from a algae, 

crustaceans and fish 

100 0.03 0 

Chloramine 0.012 Lowest LC50 from a fish and 

crustacean 1000 0.012 0 

Tribromomethane 4.8 Lowest L(E)C50 from a fish, 

crustacean and alga and 

Lowest NOEC from a algae 

and fish 

100 48 1.06 0.02 

Dibromochloromethane 3.2 Lowest L(E)C50 from a fish, 

crustacean and alga and 

Lowest NOEC from fish 

100 32 .0241 0.0008 

Monobromoacetic 

acid 

0.2 Lowest L(E)C50 from a 

crustacean and alga and 

Lowest NOEC from 

crustacean 

1000 0.2 .0303 0.15 

Dibromoacetic acid 6.9 Lowest LC50 from a fish 1000 6.9 .703 0.1 

Tribromoacetic acid 6.9 PNEC was assumed to be the 

same value as that for 

dibromoacetic acid 

1000 6.9 .381 0.06 

Bromochloroacetic acid 6.9 PNEC was assumed to be the 

same value as that for 

dibromoacetic acid 

1000 6.9 .196 0.03 

Dibromochloroacetic acid 6.9 PNEC was assumed to be the 

same value as that for 

dibromoacetic acid 

1000 6.9 .0494 0.007 

Dibromoacetonitrile 0.55 Lowest L(E)C50 from a fish, 

crustacean and alga 1000 0.55 .102 0.18 

Bromate 8 Lowest L(E)C50 from a fish, 

crustacean and alga and 

Lowest NOEC from fish and 

alga 

100 80 0 

Sodium thiosulphate 64 Lowest L(E)C50 from a fish 

and alga and Lowest NOEC 

from fish 

1000 

64 7.62 0.1

8.3.2 The Group agreed with the applicant that, as all of the above PEC/PNEC ratios 

were <1, the system has a low potential risk for the aquatic environment. 

8.4 Effects on sediment

8.4.1 The Group concurred with the applicant that, as the Koc values for the Relevant 

Chemicals were all <500 L/kg, these products would not readily partition into the sediment and 

so are not likely to be a significant risk to benthic organisms. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 15 

I:\MEPC\60\2-12.doc 

8.5 Estimation of Risks to the Environment

8.5.1 Based on the PEC/PNEC ratios and the PBT properties of those chemicals associated 

with the system, the Group agreed that this system should not present any undue risks to the 

environment. 

8.5.2 This view was supported by the results of the Whole Effluent Testing (WET) where no 

ecotoxicological effects were seen in 100% treated ballast water in both acute and chronic tests. 

9 CONCLUSIONS AND RECOMMENDATIONS 

9.1 Based on the PEC/PNEC ratios and the PBT properties of those chemicals associated 

with the system, the Group agreed that this system did not present any undue risks to the 

environment. 

9.2 This view was supported by the results of the Whole Effluent Testing (WET) where no 

ecotoxicological effects were seen in treated ballast water in both acute and chronic tests. 

9.3 The Group also agreed that the Sunrui Ballast Water Management System should not 

cause any unacceptable risks to the crew, the general public (HES via seafood consumption) or 

the safety of the ship, providing that standard risk mitigation measures are applied. 

9.4 The Group recommended that the HES general public via aggregated exposure (oral, skin 

and inhalation) when bathing in the areas close to the discharged ballast water should be 

provided by the applicant if the system is to be reviewed for Final Approval. The applicant 

should also identify and describe the unit operations associated with this system and information 

regarding the Human Exposure Scenario (MEPC 56/2/2 Annex 9). 

9.5 The Group recommended that the comprehensive corrosion testing be conducted in 

accordance with the guidance provided in section 5.1 of the “Report of the eighth meeting of 

the GESAMP-BWWG” contained in MEPC 59/2/16. Where intermittent exposures are utilized 

to predict long-term corrosion rates, as proposed by the applicant, the TRO in the sample 

containers should be recorded and reported over the period of the exposure. In addition, 

the Group recommended that some indication, with supporting data, of the long-term corrosion 

rates under a constant level of TRO at the maximum allowable dosage concentration should be 

provided to allow the potential impact on exposed ship systems to be assessed. 

9.6 The Group recommended that the neutralization system should include appropriate 

monitoring and control to ensure efficient reduction of TRO in the ballast water discharge and 

this should be fully described in an application for Final Approval. 

9.7 The Group, therefore, concluded that the system should be recommended for 

Basic Approval. For Final Approval, the Group recommended that all comments and 

recommendations made in this evaluation should be taken into account. 

* * * 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 16 

I:\MEPC\60\2-12.doc

APPENDIX 1 

AQUATIC TOXICITY DATA FOR ACTIVE SUBSTANCES, RELEVANT CHEMICAL 

AND OTHER CHEMICALS 

1 ACUTE AQUATIC TOXICITY 

F 

C 

Test 

Substance 

A 

Species Test 

Type 

LC50/EC50 

mg/L (duration) 

NOEC 

mg/L 

Reference/ 

Comments 

Active Substances 

Fresh 

water 

Oncorhynch

us 

gorbuscha

 0.023-0.052 

mg/L (96h) 

F ECB, IUCLID, 2000 

Salt 

water 

Oncorhynch

us kisutch

 0.032 mg/L 

(96h) (as TRO) 

 ECB, IUCLID, 2000 

Fresh 

water 

Ceriodaphni

a dubia

 0.005 mg/L 

(24h) for HOCl 

(pH 7) Flowthrough tests 

(without food) 

C Taylor, 1993 

Salt 

water 

B. plicatilis 0.01mg/L (30-

60min) The 

thermal stress 

 Capuzzo, 1976, 

ECB, IUCLID, 2000 

HOCl (NaOCl) 

A Saltw

ater 

Thalassiosir

a guilardii

 EC50:0.075 

mg/L (24h) 

 Gentile et al., 1976 

F No data found in 

literature 

C No data found in 

literature 

HOBr(NaOBr) 

A No data found in 

literature 

F Notropis 

atherinoides

(Emerald 

shiner) 

 0.63 mg/L 40 

min exposures at 

5 h intervals for 

24 h, 10 °C; 0.51 

mg/L, 20 °C; 

0.35 mg/L, 30°C

 HSDB, 2009 

C Ceriodaphni

a dubia

(Water flea) 

 0.012 mg/L (24 

h) 

 Taylor PA, 1993 

Chloramine 

A No data found in 

literature 

Relevant Chemicals 

F Cyprinodon 

variegatus

 7.1 mg/L (96h) Ward et al., 1981 

C Daphnia magna 46 mg/L (48 h) LeBlanc G.A, 1980 

Tribromo 

methane 

A Skeletonema 

costatum

 12.3mg/L 

(96h) (EC50) 

 U.S. EPA 1978 

F Cyprinus carpio 34mg/L (72 to 

120h) 

 Mattice 

et al., 1981 

C N.A. 27mg/L (48h) MEPC 58/2 

Dibromochloro

methane 

A Selenastrum 

caprocornutum 

 6.1mg/L (72h) MEPC 58/2 

F No data found in 

literature 

Monobromo 

acetic acid 

C Daphnia magna

(Water flea) 

EC50:65 mg/L 

for 24 h 

 HSDB, 2009 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 17 

I:\MEPC\60\2-12.doc 

 A Scenedesmus 

subspicatus (Green 

algae, log growth 

phase) 

EC50:0.2 mg/L 

for 72 h 

 Kuehn R and Pattard 

M, 1990 

F Pimephales 

promelas

 6.9 mg/L (96 h) Mayes 

et al., 1985 

C No data found in 

literature 

Dibromoacetic 

acid 

A No data found in 

literature 

F No data found in 

literature 

C No data found in 

literature 

Tribromoacetic 

acid 

A No data found in 

literature 

F No data found in 

literature 

C No data found in 

literature 

Bromochloro 

acetic acid 

A No data found in 

literature 

F No data found in 

literature 

C No data found in 

literature 

Dibromochloro 

acetic acid 

A No data found in 

literature 

F Pimephales 

promelas 

 0.55 mg/L (96 h) Mayes MA et al., 

1985 

C Daphnia magna 3,897.8mg/L 

(48h) 

 ECOSAR 

Dibromoaceto 

nitrile 

A green algae 2,231.3mg/L 

(96h) 

 ECOSAR 

F Morone 

saxatilis

 31mg/L (96h) Richardson et al., 

1981 

C Neomysis 

awatschnsis 

Opossum shrimp 

 176mg/L/ (24h) Crecelius, 1979 

Bromate 

A three seawater 

species 

 EC50: 13.6mg/L 

(72h) 

 Thomas H., 1997 

Other chemicals 

F Gambusia 

affinis(fresh water) 

 Ca. 24000 

mg/L 

(96h) 

 ECB, IUCLID, 2000 

C No data found in 

literature 

Sodium 

thiosulphate 

A Ankistrodesmus 

falcatus

 Ca. 64mg/L 

1h 

 Wodzinski R. S. et 

al, 1978 

F = Fish; C = Crustacean; A = Algae. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 18 

I:\MEPC\60\2-12.doc

2 CHRONIC AQUATIC TOXICITY 

F 

C 

Test 

Substance 

A 

Species Test 

Type 

LC50/

EC50 

mg/L 

NOEC 

mg/L 

(duration) 

Reference 

Comments 

Active Substances 

Fresh 

water 

Ictaluru

s 

punctatu

s

 NOEC:0.005 

mg/L (133d) 

Hermanutz 

et al.,1990 

F 

Salt 

water 

Menidia 

peninsul

ae

 NOEC:0.04 

mg CPO/L 

CPO= 

Chlorineproduced 

oxidants 

Goodman 

et al., 1983 

C Pandalu

s danae

(Saltwat

er) 

 NOEC:0.05 

mg/L FREE 

Active 

Chlorine 

Gibson et al., 

1976 

HOCl (NaOCl) 

A algal 

biomass 

 NOEC:0.003 

mg TRC/L 

Cairns, 1990 

F No data found 

in literature 

C No data found 

in literature 

HOBr (NaOBr) 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Chloramine 

A No data found 

in literature 

Relevant Chemicals 

F sheepshead 

minnows 

(Cyprinodon 

variegatus) 

 NOEC 4.8 

mg/L (28d) 

Ward et al., 

1981 

C No data found 

in literature 

Tribromomethane 

A Selenastrum 

capricornutum

 NOEC:10 

mg/L /96h 

U.S. EPA 1978

F Oryzias latipes 3.2mg/L/21da

y 

IMO, 

MEPC 58/2 

C No data found 

in literature 

Dibromochloro 

methane 

A No data found 

in literature 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 19 

I:\MEPC\60\2-12.doc 

F No data found 

in literature 

C Daphnia magna NOEC=1.6 

(mg/L/21days) 

MEPC 58/2/7 

GESAMPBWWG 6/9, 

annex 7 

Monobromoacetic 

acid 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Dibromoacetic 

acid 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Tribromoacetic 

acid 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Bromochloro 

acetic acid 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Dibromochloro 

acetic acid 

A No data found 

in literature 

F No data found 

in literature 

C No data found 

in literature 

Dibromoaceto 

nitrile 

A No data found 

in literature 

F Morone 

saxatilis

 LC50:(93) 

mg/L (10d), 

NOEC:(50) 

mg/L (10d) 

Richardson 

et al. ,1981 

C No data found 

in literature 

Bromate 

A Isochrysis 

galbana

 NOEC:8 

mg/L (7d) 

Erickson and 

Freeman, 1978 

Other chemicals 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 20 

I:\MEPC\60\2-12.doc

F Oncorhynchus 

mykiss

 600mg/L 

18 month 

In/with 

FW: NO 

MORTALITY,

Temp:15°C 

pH :7.82-7.92 

ECB, IUCLID, 

2000 

C No data found 

in literature 

Sodium 

thiosulphite 

A No data found 

in literature 

F = Fish; C = Crustacean; A = Algae. 

3 ENDOCRINE DISRUPTION

No reports were found, showing that the Active Substances might have any endocrine effects on 

aquatic organisms. Likewise, no reports were found, indicating the relevant chemicals and other 

chemicals identified might have any endocrine effects on aquatic organisms. 

4 SEDIMENT TOXICITY 

Chemical Koc (L/kg) Reference 

Active Substances 

HOCl(NaOCl) 14.3 MEPC 58/2/7, 

GESAMP-BWWG 6/9, annex 6 

HOBr(NaOBr) 14.3 MEPC 58/2/7, 

GESAMP-BWWG 6/9, annex 6 

Chloramine 

Relevant Chemicals 

Tribromomethane 35.04 HSDB, 2009 

Dibromochloromethane 95-468 MEPC 59/2/11 

Monobromoacetic acid 39.8 HSDB, 2009 

Dibromoacetic acid 1.5 HSDB, 2009 

Tribromoacetic acid 5.3 HSDB, 2009 

Bromochloroacetic acid 1.9 HSDB, 2009 

Dibromochloroacetic acid 

Dibromoacetonitrile 13 HSDB, 2009 

Bromate 2.7×10-8 MEPC 58/2/7, 

GESAMP-BWWG 6/9, annex 5 

Other Substances 

Sodium thiosulphite 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 21 

I:\MEPC\60\2-12.doc 

5 BIOAVAILABILITY/BIOMAGNIFICATION/BIOCONCENTRATION 

Chemical Log Pow BCF (L/kg) Reference 

Active Substances 

HOCl(NaOCl) -3.42 -2.19 MEPC 58/2/7, 

GESAMP-BWWG 6/9, annex 6 

EPI SUIT (2007) 

HOBr(NaOBr) -1.03 1.24 MEPC 58/2/7, 

GESAMP-BWWG 6/9, annex 7 

Chloramine 

Relevant Chemicals 

Tribromomethane 2.4 14 HSDB, 2009 

Dibromochloromethane 2.24 0.74-1.47 MEPC 59/2/11 

Monobromoacetic acid 0.41 3.2 HSDB, 2009 

Dibromoacetic acid 0.70 0.17 HSDB, 2009 

Tribromoacetic acid 1.71 0.63 HSDB, 2009 

Bromochloroacetic acid 0.61 3.2 HSDB, 2009 

Dibromochloroacetic acid 1.62 HSDB, 2009 

Dibromoacetonitrile 0.47 3 HSDB, 2009 

Bromate -7.18 3.7×10-7 MEPC 58/2/7, 

GESAMP-BWWG 6/9, annex 5 

Other chemicals 

Sodium thiosulphate -4.53 3.162 MEPC 58/2 

6 FOOD WEB/POPULATION EFFECTS 

6.1 Based on the low Kocs and Log Pows, little biomagnification and persistence in aquatic 

and mammalian food webs is anticipated from the Active Substances, Relevant Chemicals and 

other chemicals. All of the Kocs for the Active Substances, Relevant Chemicals and other 

chemicals are <500 L/kg, which indicate that the chemicals would not readily be absorbed into 

sediments so that they would not be of concern to benthic populations and their food webs. 

6.2 All the chemicals have established Bio-Concentration Factors (BCFs). The BCFs show 

that little bioconcentration/bioaccumulation will occur in aquatic organisms. Little 

biomagnification occurs in aquatic food webs and bird/mammalian food webs since the 

chemicals are not readily bioconcentrated/bioaccumulated. 

* * * 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 22 

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APPENDIX 2 

MAMMALIAN TOXICITY DATA FOR ACTIVE SUBSTANCES, RELEVANT CHEMICAL 

AND OTHER CHEMICALS 

1 ACUTE MAMMALIAN TOXICITY 

Chemical Exposure 

Route 

Species Value Range Reference/Comments 

a. Oral LD50

(mg/L) 

b. Oral LD50

(mg/L) 

a. Mouse 

b. Rat 

a. 880 mg/kg bw 

b. >5000 mg/kg bw 

ECB, IUCLID, 2000 

Dermal LD50 rabbit >10000 mg/kg bw ECB, IUCLID, 2000 

HOCl(NaOCl) 

Inhalation 

LC50(mg/L/4h) 

Rat >10.5mg/L (1h) ECB, IUCLID, 2000 

HOBr(NaOBr) No data available; this 

compound is thought to 

be similar in toxicity to 

chlorinated analogue. 

Chloramine a.Oral LD50 

b.Oral LD50

a. Rabbits: 

under 3 wk 

of age; older 

than 3 wk 

b. Rat 

a.LD:40-50 mg/kg; 

60-70 mg/kg, 

respectively 

b. 935mg/kg 

a. HSDB, 2009 

b. Mallinkrodt Baker, 

2006 

a. Oral LD50 

b. Oral LD50 

a.Male 

mice/female 

mice 

b. Male rats/ 

female rats 

a. 1,400 mg/kg/ 

1,550 mg/kg 

b. 1388 mg/kg 

 1147 mg/kg 

a. Bowman et al., 1978 

b. Chu et al., 1980 

Tribromomethane 

Inhalation LC50 a. Dog 

b. Mouse 

a. 7 mg/L (4 h) 

b. 12.1mg/L (2h) 

RTECS, 2006 

Dibromochloro

methane 

a. Oral LD50 

b. Oral LD50 

a.Male 

mice/female 

mice 

b. Male rats/ 

female rats 

a. 800 mg/kg/ 

1,200 mg/kg 

b. 1186 mg/kg/ 

848 mg/kg 

IPCS, 2000 

Oral LD50 rat 50mg/kg RTECS, 2008 

Dermal LD50 rabbit 59.9mg/kg RTECS, 2008 

Monobromo 

acetic acid 

Inhalation LC50 rat lowest published 

lethal concentration: 114 

gm/m3

/30 minute 

RTECS, 2008 

Dibromoacetic 

acid 

Oral LD50 Rat 1737 mg/kg Linder et al., 1994 

Tribromoacetic 

acid 

 No data available; this 

compound is thought to 

be similar in toxicity to 

chlorinated analogue. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 23 

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Chemical Exposure 

Route 

Species Value Range Reference/Comments 

Bromochloroacetic acid  No data found 

in literature 

Dibromochloro 

acetic acid 

 

Oral LD50 Rat 245 mg/kg for male 

rats 

361 mg/kg 

female rats 

Dibromo- Hayes JR et al., 1986 

acetonitrile 

Inhalation LC50 Rat 10g/m3

/h IMO, MEPC 58/2 

Bromate a. Oral LD50 

b. Oral LD50

a. Rat 

b. Mouse 

a. 157mg/kg 

b. 289mg/kg 

RTECS, 2007 

Sodium 

thiosulphite 

a. Oral LD50 

b. Oral LD50

a. Rat (males 

and females 

combined) 

b. rat 

a. >5,050 mg/kg 

b. 2,500mg/kg to 

5,000mg/kg 

a. EPA Federal Register 

Sodium thiosulfite, 2001 

b. RTECS, 2006 

2 EFFECTS ON SKIN AND EYE, AND SENSITIZATION EFFECTS 

Chemical Skin Eye Sensitization Reference/Comments 

HOCl(NaOCl) Irritation to the 

skin 

Irritation to 

the eye 

225 patients tested 

with sodium 

hypochlorite in 

patch test, 3 showed 

positive tractions 

(1.3%) 

ECB, IUCLID, 2000 

HOBr(NaOBr) No data available; this 

compound is thought to 

be similar in toxicity to 

chlorinated analogue. 

Chloramine Did not 

produce 

hyperplasia of 

the skin 

Irritation to 

the eye 

Did not produce 

hyperplasia of the 

skin. 

WHO, 2000 

HSDB, 2009 

Tribromomethane Irritation to the 

skin. Repeated 

or prolonged 

contact may 

cause 

dermatitis. 

Irritation to 

the eye. 

Repeated or 

prolonged 

contact may 

cause 

dermatitis. 

Skin:Y (Redness.) 

Inhalation:Y(Re

ddening of the 

face.Salivation. 

Disturbance of 

movements. 

Convulsions. 

Cough. Dizziness. 

Headache. 

HSDB, 2009 

ICSC, 0108 

Dibromochloromethane Irritation to the 

skin 

Irritation to 

the eye 

 Aldrich Chemical MSDS 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 24 

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Chemical Skin Eye Sensitization Reference/Comments 

Monobromoacetic acid Cause severe 

burns 

Cause severe 

burns 

 HSDB, 2009 

Dibromoacetic 

acid 

Cause burns Cause burns Inhalation may 

result in spasm, 

inflammation and 

edema of the larynx 

and bronchi, 

chemical 

pneumonitis, and 

pulmonary edema. 

Sigma-Aldrich, 2006, 

MSDS 

Tribromoacetic 

acid 

Irritating to the 

skin 

Irritating to 

the eye 

Inhalation may 

result in spasm, 

inflammation and 

edema of the larynx 

and bronchi, 

chemical 

pneumonitis, and 

pulmonary edema 

Fisher Scientific MSDS 

HSDB, 2009 

Bromochloroacetic acid Extremely 

destructive to 

shin 

Extremely 

destructive to 

eye 

 Sigma-Aldrich, MSDS 

2006 

Dibromochloro 

acetic acid 

Extremely 

destructive to 

shin 

Extremely 

destructive to 

eye 

Inhalation may 

result in spasm, 

inflammation and 

edema of the 

larynxand bronchi, 

chemical 

pneumonitis, and 

pulmonary edema. 

is extremely 

destructive to tissue 

of the mucous 

membranes and 

upper respiratory 

tract. 

HSDB, 2009 

Dibromoacetonitrile May cause 

skin irritation 

Cause eye 

irritation 

 HSDB, 2009 

Bromate May cause 

skin irritation 

Cause 

moderate eye 

irritation. 

May cause 

transient 

corneal 

injury. 

May cause skin 

irritation. 

May cause 

respiratory tract 

irritation. 

The chemical database 

Sodium 

thiosulphite 

May cause 

skin irritation 

May cause 

eye irritation 

and possible 

burns 

May cause skin 

irritation. 

May cause 

respiratory tract 

irritation. 

The chemical database 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 25 

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3 REPEATED-DOSE TOXICITY 

Chemical Exposure 

Route 

Species Value Range Reference/ 

Comments 

HOCl(NaOCl) a. Oral, 13 

weeks 

b. Oral, 

90days 

a. F344 rats 

b. Mouse 

a. Significant suppression of body 

weight (as a result of decreased 

consumption of water and food) 

occurred at 0.2% and above. 

Slight damage to the liver as indicated 

by increased levels of serum enzymes 

(not specified) at 0.2% and 0.4% 

sodium hypochlorite in both sexes. No 

evidence of treatment-related 

pathology was observed in this study. 

b.NOAEL 50mg/L 

(10-12mg/kg/d) 

a. Hasegawa R, 

et al., 1986 

b. Daniel 

et al., 1991 

HOBr(NaOBr) No data 

available; this 

compound is 

thought to be 

similar in 

toxicity to 

chlorinated 

analogue. 

Chloramine a. Oral, 

90-day 

(drinkingwater) 

b. Oral, 90-

day 

(drinkingwater) 

a. SpragueDawley 

rats 

b. B6C3F1 

mice 

a. NOAEL: 100mg/L, equivalent to 

5.8 mg/kg bw/d. 

b. NOAEL: 50 mg/L, equivalent to 

8.6 mg/kg bw/d. 

WHO, 2000 

Tribromomethane a. Oral 

Gavage 

5 days/week 

for 13 

weeks 

b. Oral 

Gavage 

5 days/week 

for 13 

weeks 

a. F344/N 

rats/sex 

b. B6C3F1 

mice 

a. LOAEL: 50 mg/kg/day 

(converted to 35.7 mg/kg/d) 

NOEL: 25 mg/kg/day (converted to 

17.9 mg/kg/d) 

b. LOAEL: 50 

mg/kg/day(converted to 35.7 

mg/kg/d) 

NOEL: 25 mg/kg/d (converted to 

17.9 mg/kg/d) 

NTP 1989 

Dibromochloromethane a. Gavage, 

13 weeks 

b. Gavage, 

90 days 

a. Rats and 

mice 

b. Rats 

a. NOAEL:30 mg/kg/d 

b. Kidney damage at 50 and 100 

mg/kg/d 

IPCS, 2000 

Monobromoacetic acid Oral pig Damage to the liver, heart, kidney, 

lung and skeletal muscle was found 

in pigs which died and movement 

disorders occurred in those that 

survived. 

HSDB, 2009 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 26 

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Chemical Exposure 

Route 

Species Value Range Reference/ 

Comments 

Dibromoacetic 

acid 

a. Oral, 28d 

b. Oral, 3 

months 

a. Mouse 

b. Mouse 

a. NOAEL: 38 mg/kg/d 

b. No deaths but various effects seen at 

>500 mg/L 

WHO, 2004 

Tribromoacetic acid  No data found 

in literature 

Bromochloroacetic acid a. oral, 3 

months 

b. oral, 3 

months 

a. B6C3F

1 Mice 

b.

F344/N 

Rats 

a. Mean body weight gains of females 

exposed to 250 mg/L or greater were 

significantly decreased. Liver weights 

of 1000 mg/L males and all exposed 

groups of females were significantly 

increased. All males and females 

exposed to 500 or 1000 mg/L had 

periportal cytoplasmic vacuolization. 

In the spleen, there were increased 

incidences of hematopoietic cell 

proliferation in 62.5, 125 and 250 

mg/L males and 125 and 1000 mg/L 

females. 

b. Liver weights of 500 and 1000 

mg/L males and females and kidney 

weights of 1000 mg/L males were 

significantly increased. In the liver, 

there were significantly increased 

incidences of cytoplasmic 

vacuolization in 10000 mg/L males 

and females. 

HSDB, 2009 

Dibromochloroacetic acid  No data found 

in literature 

Dibromoacetonitrile Oral, 13 

weeks 

SpragueDawley 

rats 

NOAEL: 10 mg/kg/d, equivalent to 

1.11 and 1.21 mg/kg/d in the males 

and females, respectively 

Poon R et al., 

2003 

Bromate Oral, 13 

weeks 

Rats Liver toxicity at higher doses IPCS, 2000 

Sodium 

thiosulphate 

 No data found 

in literature 

4 CHRONIC TOXICITY 

Chemical Exposure 

Route 

Species Value Range Reference/ 

Comments 

HOCl(NaOCl) Oral 

2 years 

Rat and 

Mouse 

NOAEL: 14.4mg/kg/d NTP, 1992 

HOBr(NaOBr) No data available; 

this compound is 

thought to be 

similar in toxicity to 

chlorinated 

analogue. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 27 

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Chemical Exposure 

Route 

Species Value Range Reference/ 

Comments 

Chloramine Oral 

(drinking 

water) 

2-year 

F344/N rats 

and 

B6C3F1 

mice 

There was a decrease in mean 

body weight in high-dose rats. 

The high-dose group had 

decreases in organ weights and 

increases in organ-to-body 

weight ratios at 14- or 66-week 

evaluations. There was also a 

dose-related decrease in mean 

body weights of dosed male and 

female mice throughout the 

study. There were decreases in 

organ weights and increases in 

organ-to-body weight ratios 

observed in high-dose mice at 

15- or 66-week evaluations. 

EPA, 1994 

Tribromomethane a. gavage 

5 

days/week 

for 2 years 

b. gavage 

5 

days/week 

for 2 years 

a. F344/N 

rats 

b.

B6C3F1 

mice 

a. NOAEL: 17.9 mg/kg/d 

b. NOAEL: 17.9 mg/kg/d 

NTP 1989. 

Dibromochloromethane Gavage, 2 

years 

Mice and 

rats 

Kidney and liver effects noted at 

all doses 

IPCS, 2000 

Monobromoacetic acid  No data found 

in literature 

Dibromoacetic 

acid 

a. Oral, 2 

years 

b. Oral, 2 

years 

a. Mouse 

b. Rat 

a. Increased body weights at 

50 and 500 mg/L in males 

only 

b. Decrease body weights at 

500and 1000 mg/L 

NTP, 2007 

Tribromoacetic acid  No data found 

in literature 

Bromochloroacetic acid a. oral, 2 

years 

b. oral, 2 

years 

a. B6C3F

1 Mice 

b. F344/N 

Rats 

a. Survival of 1000 mg/L males 

was significantly less than that 

of the control group. Mean body 

weight of 1,000 mg/L males 

were 12% less than the control 

group after week 97, and those 

of 1,000 mg/L females were 8% 

less than the control group after 

week 21. 

b. Mean body weights of 500 

mg/L males were 8% less than 

the control group after week 81, 

and those of 1000 mg/L males 

were 10% less than the control 

group after week 69. Mean body 

weights of 1000 mg/L females 

were 10% less than the control 

group after week 85. 

HSDB, 2009 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 28 

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Chemical Exposure 

Route 

Species Value Range Reference/ 

Comments 

Dibromochloroacetic acid  No data found 

in literature 

Dibromoacetonitrile drinking 

water 

2-year 

Mice and 

Rat 

there was clear evidence of 

carcinogenic activity of 

dibromoacetonitrile in male rats 

based on increased incidences of 

squamous cell papillomas or 

carcinomas of the oral cavity; 

adenomas in the glandular 

stomach of male rats were also 

considered to be exposurerelated. There was some 

evidence of carcinogenic 

activity of dibromoacetonitrile 

in female rats based on an 

increased incidence of 

squamous cell papillomas of the 

oral cavity; increased incidences 

of basal cell or squamous cell 

neoplasms of the skin in female 

rats may have been related to 

dibromoacetonitrile exposure. 

There was clear evidence of 

carcinogenic activity of 

dibromoacetonitrile in male and 

female mice based on increased 

incidences of squamous cell 

papillomas or carcinomas of the 

forestomach. Increased 

incidences of neoplasms in the 

liver of male mice may have 

been related to 

dibromoacetonitrile exposure. 

Exposure to dibromoacetonitrile 

for 2 years caused increased 

incidences of epithelial 

hyperkeratosis in the esophagus 

of male and female rats, ectasia 

of the glandular stomach and 

squamous epithelial hyperplasia 

of the tongue in female rats, and 

squamous epithelial hyperplasia 

of the forestomach in male mice. 

NTP/NIEHS, 2008 

Bromate a. 

Drinking 

water, 100 

weeks 

b. 

Drinking 

water, 100 

weeks 

a. Male, 

B6C3F1 

mice 

b. Male 

F344 rats 

a. NOAEL: 800mg/L 

b. NOAEL: 20mg/L 

WHO, 2005 

Sodium 

thiosulphite 

 No data found 

in literature 
GESAMP-BWWG 11/6 

ANNEX 6 

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5 DEVELOPMENTAL AND REPRODUCTIVE TOXICITY 

Chemical Exposure 

Route 

Species Effects Reference/ 

Comments 

HOCl(NaOCl) Oral Rat NOAEL: 14.4 mg/kg/d Druckrey, 1968 

HOBr(NaOBr) No data available; 

this compound is 

thought to be 

similar in toxicity 

to chlorinated 

analogue. 

Chloramine Gavage, 

66-76 days 

male 

(12/dose) 

and female 

(24/dose) 

Long-Evans 

rats 

NOAEL:10 mg/kg/d Carlton 

et al. 1986 

Tribromomethane a. gavage, 

105 days 

b. Gavage, 

days 6-15 

a. mice 

b. rat 

a. No effect on fertility or offsping. 

b. An increased incidence of minor 

skeletal abnormalities, including 

appearance of a 14th rib, intraparietal 

deviations, and delayed ossification of 

sternebrae, was seen in developing 

fetuses at 100 and 200 mg/kg. 

a. WHO, 

EHC216 (2000) 

b. Ruddick, 

et al. 1983 

Dibromochloromethane exposed 

individuall

y in 5 ml 

of embryo 

rearing 

solution, 

15 days 

Medaka 

embryos at 

stage 10 

(N= 60 per 

concentratio

n) 

Embryos were evaluated daily for 

mortality and cardiovascular 

abnormalities. The heartbeat count was 

made for one full minute from day 3-10. 

The earliest lesion observed was the 

tubular heart on day 4 of exposure. Lack 

or incomplete chambers formation often 

began on day 5. Diathesis or pooling of 

blood in various tissues began to appear 

staring on day 5 of exposure, followed 

by slowing of blood flow and complete 

stasis usually on day 10. At this time 

pericardial edema began to develop and 

progressed to other organs and interfered 

with hatching which resulted in partial 

hatching. In addition, low incidence of 

the following lesions was observed: nondevelopment of heart, absence or 

reduced numbers of vitelline vessels, 

reduced numbers of blood cells, and 

ruptured blood vessels. 

Palit S et al. 

(2004) 

Monobromoacetic acid a. Oral 

intubation 

b. N.A. 

a. pregnant 

Long Evans 

rats 

b. rats 

a. These results suggest that bromoacetic 

acid is developmentally toxic at 100 

mg/kg/d. 

b. Did not affect parameters related to 

male reproductive function 

a. Randall JL 

et al. , 1991 

b. Environmental 

Health Criteria 

216 
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Chemical Exposure 

Route 

Species Effects Reference/ 

Comments 

Dibromoacetic 

acid 

Oral Rat NOAEL:125 mg/kg/d Cummings 

et al. ,1998 

Tribromoacetic acid gavage rat Tribromoacetic acid at up to 400 ppm 

marginally reduced water consumption 

and did not affect reproductive function 

or produce general toxicity. TBA is not a 

reproductive toxicant in males or 

females at doses up to 400 ppm. 

NTP, 1998 

Bromochloroacetic acid gavage SpragueDawley rats There were no clinical signs of general 

toxicity noted at any dose level. There 

were no treatment-related effects on 

body weights or feed consumption. 

Water consumption was decreased by 

21-34% at many of the intervals for the 

600 ppm rats. The overall calculated 

consumption of BCA for Groups 2-4 

was 7, 20, and 50 mg/kg/d, respectively. 

Clinical chemistry and hematology 

endpoints at necropsy were unaffected 

by BCA treatment except for a 16% 

increase in the albumin to globulin ratio 

in the 600 ppm A males; decreases of 15 

and 20% in the alanine aminotransferase 

parameter in the 200 and 600 ppm A 

males, respectively; and increases of 5 

and 9% in albumin in the 60 and 600 

ppm A males, respectively. The 

increases in albumin to globulin ratio 

and albumin represent a small but 

possible biologically significant 

indicator of dehydration, probably 

attributable to decreased fluid 

consumption. The decreases in alanine 

aminotransferase are of little 

toxicological significance. 

Results of this study indicate that BCA 

at doses of 600 ppm produced a 

consistent decrease in water 

consumption in both sexes and affected 

reproductive function in females at a 

dose of 600 ppm. From these data, 

BCA is taste-aversive and a general 

toxicant in both sexes at 600 ppm and 

also a female reproductive toxicant 

at 600 ppm. 

NTP, 1998 

Dibromochloroacetic acid drinking 

water 

rats The first range-finding study was 

conducted at concentrations of 0, 30, 

100, 300, and 500 ppm of DBCA in the 

drinking water for two weeks, with 

no significant test-article related 

effects observed at any dose level 

including 500 ppm. Following two 

HSDB, 2009 
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Chemical Exposure 

Route 

Species Effects Reference/ 

Comments 

weeks of a wash-out period, the second 

range-finding study was conducted 

at concentrations of 0, 750, 1000, 

and 1500 ppm of DBCA in the drinking 

water for two weeks. During the 

treatment period, all animals survived to 

the scheduled necropsy. Body weights 

were 10-14% less than controls in 

the 1500 ppm A and C females. Water 

consumption was decreased at several of 

the intervals for the 1000 and 1500 ppm 

dose groups. Water consumption 

was decreased by 12-49% at 1000 

and 1500 ppm in both males and females 

throughout the course of the study. 

Results of this study indicate that DBCA 

at doses at and above 1000 ppm 

produced consistent decreases in food 

and water consumption in both sexes, 

but did not result in any female 

reproductive toxicity or any visceral 

malformation or variations in any pups. 

In the male reproductive data, a decrease 

of 11% in the male sperm velocity 

samples and in the male ALH max were 

observed in the 1500 ppm A male; no 

changes in fertility were noted. 

Dibromoacetonitrile gavage Long-Evans 

rats 

Four of the 26 dams treated with 

dibromoacetonitrile died. There was a 

significant decrease in maternal weight 

gain during the period of treatment. 

Litter weight at the time of birth was 

lower than in the controls, and weight 

gain to lactation day 4 was significantly 

decreased. There was no significant 

effect on the percentages of pregnant 

females or resorptions and no effect on 

neonatal survival after birth. 

HSDB, 2009 

Bromate Oral rat NOAEL: 7.7 mg/kg/d 

NOEL: 22 mg/kg/d 

WHO, 2005 

Sodium 

thiosulphite 

a. Oral 

b. Oral 

a. Mouse 

b. Rat 

a. There was no indication of any effect 

on maternal or fetal survival, or in 

incidences of visceral or skeletal 

abnormalities. 

b. There was no indication of any effect 

on maternal or fetal survival, or in 

incidences of visceral or skeletal 

abnormalities. 

EPA Federal 

Register Sodium 

thiosulfate, 2001. 
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ANNEX 6 

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6 CARCINOGENICITY 

Chemical Carcinogen 

Classification 

Description Reference/ 

Comments 

HOCl(NaOCl) Not carcinogenic NTP, 1992 

HOBr(NaOBr) No data available; 

this compound is 

thought to be 

similar in toxicity 

to chlorinated 

analogue. 

Chloramine IARC Group 3-not classifiable as to 

its carcinogenicity to humans. 

Negative 

Inadequate evidence 

in humans and 

sufficient evidence in 

experimental animals. 

MOUSE, 

B6C3F1/male and 

female 

Oral, 0; 50; 100; 200 

ppm in buffered, 

charcoal-filtered, 

deionized water for 

104 wk 

(study duration: 2 yr) 

IARC,2004 

CCRIS,1993 

Tribromomethane IARC Group 3- not classifiable as to 

carcinogenicity to humans 

 WHO, EHC216 

(2000) 

Dibromochloromethane Group 3-not classifiable as to its 

carcinogenicity 

 IPCS, 2000 

Monobromoacetic acid  No data available; 

Dibromoacetic acid Carcinogenic (tumours/cancers 

observed) 

Mouse and Rat NTP, 2007 

Tribromoacetic acid No data available; 
GESAMP-BWWG 11/6 

ANNEX 6 

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Chemical Carcinogen 

Classification 

Description Reference/ 

Comments 

There was clear evidence of 

carcinogenic activity in male F344/N 

rats based on increased incidences of 

malignant mesotheliomas and 

adenomas of the large intestine. There 

was clear evidence of carcinogenic 

activity in female F344/N rats based 

on increased incidences of adenomas 

of the large intestine; increased 

incidences of multiple fibroadenomas 

of the mammary gland in female rats 

were also considered to be exposure 

related. Increased incidences of 

pancreatic islet adenomas in male rats 

and of hepatocellular adenomas in 

male and female rats may have been 

related to bromochloroacetic acid 

exposure. 

F344/N rats HSDB, 2009 

Bromochloroacetic acid 

There was clear evidence of 

carcinogenic activity in male and 

female B6C3F1 mice based on 

increased incidences of hepatocellular 

neoplasms and hepatoblastoma (males 

only). Exposure to bromochloroacetic 

acid for 2 years resulted in increased 

incidences of nonneoplastic lesions in 

the liver of male rats, liver and lung 

of female rats, and liver of male and 

female mice. 

B6C3F1 mice HSDB, 2009 

Dibromochloroacetic acid No data available; 

Dibromoacetonitrile Group 3-not classifiable as to its 

carcinogenicity to humans 

Inadequate evidence 

in humans and 

sufficient evidence in 

experimental animals. 

HSDB, 2009 

Bromate IARC Group 2B- possibly 

carcinogenic to humans. 

Inadequate evidence 

in humans and 

sufficient evidence in 

experimental animals 

IPSC, 2000 

Sodium 

thiosulphite No data available; 
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7 MUTAGENICITY/GENOTOXICITY 

Chemical Study Results Reference/Comments 

HOCl(NaOCl) Mice 

Not mutagenic 

Hayashi, 1988 

Meier et al., 1985 

HOBr(NaOBr) No data available; this 

compound is thought to 

be similar in toxicity to 

chlorinated analogue. 

Chloramine Mice 

No evidence of any significant effects in 

any of the tests. 

USEPA, 1994 

Salmonella typhimurium, in vitro, 

Positive 

Simmon et al. 1977; 

Simmon and Tardiff 1978 

Salmonella typhimurium, in vitro, 

Negative 

Rapson et al. 1980; 

Varma et al. 1988 

Kubo et al. 2002 

human lymphocytes, in vitro, Increase in 

sister chromatid exchange 

Morimoto and Koizumi 

1983 

rat erythroblastic leukemia K3D, in vitro, 

Increase in sister chromatid exchange 

Fujie et al. 1993 

Tribromomethane 

Chinese hamster ovary cells in vitro, No 

increase in sister chromatid exchange 

Galloway et al. 1985 

Dibromochloromethane Positive mutagenicity results in several in 

vitro and in vivo assays. 

IPCS, 2000 

Monobromoacetic acid Salmonella typhimurium strains TA98, 

TA100, and RSJ100 +/- S9, Positive 

Kargalioglu Y et al.,2002 

Dibromoacetic acid Salmonella typhimurium, Ames test, 

Positive at 10 mg/L

Giller et al., 1997 

Tribromoacetic acid Positive with metabolic activation in the 

Ames assay 

IPCS, 2000 

Salmonella typhimurium strain TA100, in 

vitro, Positive in tests conducted with and 

without exogenous metabolic activation 

enzymes (S9) 

Bromochloroacetic acid HSDB, 2009 

Salmonella typhimurium strain TA98 or 

Escherichia coli WP2 uvrA/pKM101, in 

vitro, no mutagenicity was detected with 

or without S9 

HSDB, 2009 

Dibromochloroacetic acid No data available; 

Dibromoacetonitrile Rat intestinal epithelial cells, may trigger 

various forms of imbalance to intestinal 

mucosa and its functions 

USEPA. 2000. 

Bromate Weakly mutagenic in Ames assay with 

metabolic activation, caused 

chromosomal aberrations in Chinese 

hamster cell lines at high concentrations 

IPSC, 2000 

Sodium thiosulphite sodium thiosulfite was found to cause 

no mutagenic effects. 

EPA Federal Register 

Sodium thiosulfite, 2001. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 35 

I:\MEPC\60\2-12.doc 

8 TOXICOKINETICS 

Chemical Study Results Reference/ 

Comments 

HOCl(NaOCl) Free chlorine is consumed upon contacting with living 

tissues, making measurement of biodegradation impossible 

and unnecessary. The chloride ion is actively transported by 

most fresh water and marine organisms, typically being 

concentrated in fresh water species and diluted in saltwater 

forms including some hyperosmotic and isotonic groups 

such as chondrichthys (sharks, rays etc). Free chlorine is 

very toxic to biodegrading micro-organisms and may 

interfere with the biodegradation of other materials at levels 

of greater than or equal to 0.01 mg/L. 

ECB, IUCLID, 2000 

HOBr(NaOBr) No data available; 

this compound is 

thought to be similar 

in toxicity to 

chlorinated analogue. 

Chloramine Information on the absorption of inorganic chloramines 

is extremely limited. In one study Abdel-Rahman et al. (1983) 

calculated an absorption rate constant for 36Cl at 0.278 mg/hour 

(after 8 hours) with an absorption half-life of 2.5 hours after 

male Sprague-Dawley rats were administered a single oral dose 

of 4.6 mg/kg/day. After 48 hours the radiolabel was eliminated 

from the plasma with a half-life of 38.8 hours and a rate 

constant of 0.018 mg/hour. Absorption rates with respect to 

various dosage media and different routes of exposure were not 

available. 

The distribution of radiolabeled chlorine in the subfractions 

of rat liver homogenates, in organs, tissues and fluids was 

similar (120 hours) after oral administration of either 36Cl 

(200 mg/L as Na36Cl) or NH2

36 Cl (370 mg/L NH2Cl). Plasma 

contained the highest concentrations of 36Cl radioactivity for 

NH36Cl followed by whole blood skin, testes, packed cells, 

bone marrow, kidney, lung, stomach, thyroid, thymus, 

duodenum, spleen, carcass, liver, ileum and fat. 

Abdel-Rahman 

et al. 1983; 

Suh and 

Abdel-Rahman,1983 

Tribromomethane The metabolism of bromoform, dibromochloromethane, and 

other trihalomethanes has been investigated by Anders and 

colleagues. The first step in the metabolism of trihalomethanes 

is oxidation by the cytochrome P-450 mixed function oxidized 

system of liver. This has been demonstrated in vitro using 

isolated rat liver microsomes, and in vivo, where the rate of 

metabolism is increased by cytochrome P-450 inducers 

(phenobarbital) and decreased by cytochrome P-450 inhibitors 

(SKF-525A). The product of this reaction is presumed to be 

trihalomethanol, which then decomposes by loss of hydrogen 

and halide ions to yield the dihalocarbonyl. Although this 

intermediate has not been isolated, its formation has been 

inferred by the detection of 2-oxothiazolidine-4-carboxylic acid 

(OZT) in an in vitro microsomal system metabolizing 

bromoform in the presence of cysteine. The dihalocarbonyl 

molecule (an analogue of phosgene) is highly reactive, and 

may undergo a number of reactions, including: (a) direct 

reaction with cellular nucleophiles to yield covalent adducts; 

(b) reaction with two moles of glutathione (GSH) to yield 

ATSDR, 2005 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 36 

I:\MEPC\60\2-12.doc

Chemical Study Results Reference/ 

Comments 

carbon monoxide and oxidized glutathione (GSSG); and (c) 

hydrolysis to yield CO2. The amount of trihalomethane 

metabolized by each of these pathways has not been studied in 

detail, but it appears that conversion to CO2 is the main route. 

However, this depends on the species, the trihalomethane being 

metabolized and metabolic conditions (cellular glutathione 

levels). Mink et al. (1986) found that mice oxidized 72% of an 

oral dose of dibromochloromethane and 40% of an oral dose of 

bromoform to CO2. In contrast, rats oxidized only 18% of 

dibromochloromethane and 4% of bromoform to CO2. The 

fraction of the dose converted to carbon monoxide has not been 

quantified, but dramatically increased levels of 

carboxyhemoglobin have been reported following oral 

exposure of rats to bromoform. Mink et al. (1986) reported 

that.about 10% of a dose of bromoform was present in blood in 

mice; the form of the label was not investigated, but it may 

have been carboxyhemoglobin. 

Dibromochloromethane Oral dosing in rats and mice showed that less than 2% of the 

dose was excreted in the urine in both species. Half-lives of 

DBCM in rats and mice were estimated to be 1.2 h and 2.5 h, 

respectively. 

IPCS, 2000 

Monobromoacetic 

acid 

 No data available; 

Dibromoacetic 

acid 

di-HAAs are nearly completely eliminated by metabolism 

and exhibit poor renal elimination. FPTC, 2006 

Tribromoacetic 

acid 

brominated tri-HAAs exhibit both moderate renal and 

metabolic elimination. FPTC, 2006 

Bromochloroacetic 

acid 

di-HAAs are nearly completely eliminated by metabolism 

and exhibit poor renal elimination. FPTC, 2006 

Dibromochloroacetic acid No data available 

Dibromoacetonitrile 

Urinary thiocyanate accounted for 2.25–12.8% of a single 

gavage dose of bromochloroacetonitrile, 

dibromoacetonitrile, dichloroacetonitrile or 

trichloroacetonitrile during the 24-h period following dosing 

of male rats. The cyanide carbon group is more readily 

excreted in the urine, whereas the halomethyl carbon group 

is excreted nearly equally in enhaled air and in urine; 

excretion in faeces is low. 

WHO, 2004 

Bromate Bromate may be converted into hypobromic acid by 

hypochloric acid in the stomach. Liver and kidney tissues 

may degrade bromate to bromide by a process involving 

glutathione, although only a small amount appears to be 

reduced in this way. Bromate is excreted mainly by urine as 

bromate and bromide and some may also be eliminated by 

faeces. Bromate concentrationsin urine peak at about 1 hour, 

and bromate is not detectable in plasma after 2 hours4. 

MEPC 58/2/7, 

GESAMP-BWWG 

6/9, annex 5 

Sodium 

thiosulphite 

Sodium thiosulfite is poorly absorbed from bowel and 

thiosulfite ion distributes itself in extracellular fluid. HSDB, 2009 

* * *
GESAMP-BWWG 11/6 

ANNEX 6 

Page 37 

I:\MEPC\60\2-12.doc 

APPENDIX 3 

ENVIRONMENTAL FATE DATA FOR ACTIVE SUBSTANCES, RELEVANT 

CHEMICAL AND OTHER CHEMICALS 

1 MODES OF DEGRADATION (biotic; abiotic) 

1.1 The degradation information of the Active Substances, Relevant Chemicals and other 

chemicals are presented in Tables 4-13, 4-14 and 4-15. The results show that the half-lives of the 

chemicals are ranging from hours to years. For example, the half-lives of HOCl are 0.8 hour (at 

pH 7) and 1.4 hour (at pH 8). Chloramine half-lives are ranging from 9 to 420 hours. . Half-life 

of tribromomethane in fresh water is 1.7 years and the half-life of monobromoacetic acid in water 

is 8.7 days, in soil: 17 days, in sediment: 78 days and in air: 22 days. 

Aerobic degradation for the Chemicals 

Chemical Aerobic Degradation Reference/Comments 

HOCl(NaOCl) No data found 

HOBr(NaOBr) No data found 

Chloramine No data found 

Tribromomethane 0% biodegradation in 4 weeks at 30 

mg/L and the Japanese MITI test 

HSDB, 2009 

Dibromochloromethane 25-39% loss in 28 days; HSDB, 2006 

Monobromoacetic acid Fresh water 

Mineralized in river water with 73% 

conversion to carbon dioxide 

in 8-10 days at 29oC. 

FPTC, 2006 

Dibromoacetic acid Probability of Biodegradability 

=1.000, due to probability of 

biodegradability is greater than 0.7, 

dibromoacetic acid may be capable to 

biodegradation. 

MEPC 58/2 

Tribromoacetic acid Probability of Rapid Biodegradation: 

Biowin 1(Linear model)-0.3565 

Biowin 2(Non-linear model)-0.0000 

Expert Survey Biodegradation 

Results: Biowin3 (Ultimate survey 

model) 

-2.7827 weeks Biowin4 (Primary 

survey model)-3.7579 days 

MEPC 58/2 

Bromochloroacetic acid activated sludge,65% loss in 21 days 

activated sludge,100% loss 

in 28 days 

ECB, IUCLID, 2000 

Dibromochloroacetic acid activated sludge,65% loss in 21 days 

activated sludge,100% loss 

in 28 days 

ECB, IUCLID, 2000 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 38 

I:\MEPC\60\2-12.doc

Chemical Aerobic Degradation Reference/Comments 

Dibromoacetonitrile No data found 

Bromate No data found 

Sodium thiosulphite No data found 

Anaerobic degradation for the Chemicals 

Chemical Anaerobic Degradation Reference/Comments 

HOCl(NaOCl) No data found 

HOBr(NaOBr) No data found 

Chloramine No data found 

Approximately 20% of the initial 

concentration of 57 ug/L underwent 

biodegradation after 6.25 hours; 

approximately 30% biodegraded after 

25 hours. 

Wookeun B et al.,1990 

Greater than 99% of the initial 

concentration of 18 ug/L was removed 

under methanogenic, denitrification 

and sulfate reducing conditions after 

2.5 days 

Bouwer EJ and Wright 

JP, 1988 

Tribromomethane 

Greater than 99% reduction, initially 

present at 132-177 ug/L was observed 

after 1.5 hours 

Cobb GD and Bouwer EJ, 

1991 

Dibromochloromethane 100% loss in 2 weeks; mixed 

methanogenic bacterial culture 

HSDB, 2006 

Monobromoacetic acid No data found 

Dibromoacetic acid No data found 

Tribromoacetic acid No data found 

Bromochloroacetic acid Bacteria, 100% loss in 2 days ECB, IUCLID, 2000 

Dibromochloroacetic acid Bacteria, 100% loss in 2 days ECB, IUCLID, 2000 

Dibromoacetonitrile No data found 

Bromate No data found 

Sodium thiosulphite No data found 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 39 

I:\MEPC\60\2-12.doc 

The Half-lives of the Chemicals 

Chemical Half-life Reference/Comments 

HOCl(NaOCl) Half-life:1.4 hour(at pH 8) Taylor, 1993 

HOBr(NaOBr) Biodegrades fast MEPC 59/2/16 

GESAMP-BWWG 8/6, annex 6 

Chloramine Chloramine half-lives ranging from 9 to 

420 hours 

HSDB, 2009 

Tribromomethane Half-life (fresh water):1.7 years HSDB, 2009 

Dibromochloromethane Half-life: 

Water: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 280 days 

PBT Profiler 

Monobromoacetic acid Half-life: 

Water: 8.7 days 

Soil: 17 days 

Sediment: 78 days 

Air: 22 days 

PBT Profiler 

Dibromoacetic acid 

Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 25 days 

PBT Profiler 

Tribromoacetic acid 

Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 31 days 

PBT Profiler 

Bromochloroacetic acid 

Half-life: 

Water: 15 days 

Soil: 30 days 

Sediment: 140 days 

Air: 24 days 

PBT Profiler 

Dibromochloroacetic 

acid No data found 

Dibromoacetonitrile 

Half-life: 

Water: 38 days 

Soil: 75 days 

Sediment: 340 days 

Air: 540 days 

PBT Profiler 

Bromate Seawater: 12 hours MEPC 57/2/10 

GESAMP-BWWG 5/9, annex 5 

Sodium thiosulphite Biodegrades fast MEPC 59/2/16 

GESAMP-BWWG 8/6, annex 6 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 40 

I:\MEPC\60\2-12.doc

2 BIOACCUMULATION, PARTITION COEFFICIENT, OCTANOL/WATER 

PARTITION COEFFICIENT 

2.1 The octanol/water partition coefficients (Pows) and bioaccumulation factors (BCFs) for 

the Active Substances,Relevant Chemicals and other chemicals are given above in 

section 4.1.5. The adsorption coefficients (Kocs) for the Active Substances,Relevant Chemicals 

and other chemicals are given in section 4.1.4. 

3 PERSISTENCE AND IDENTIFICATION OF THE MAIN METABOLITES IN THE 

RELEVANT MEDIA (BALLAST WATER, MARINE AND FRESH WATERS) 

3.1 Active Substances have low Log Pow (range from -3.42 to -1.03) and BCF values and, 

therefore, it is expected they are not considered to be bioaccumulation on aquatic organisms and 

to be main metabolites. For Relevant Chemicals and other chemicals, there is no food chain 

concentration potential. Due to low Log Pows and BCF values, it is unlikely that these will be 

accumulated through the aquatic organisms and metabolites. 

4 REACTION WITH ORGANIC MATTER 

4.1 HOCl (NaOCl) reacts with organic matter in water forming by-products such as 

halomethanes and halogenated acetic acids. 

4.2 For most of Relevant Chemicals, there is no accumulation through aquatic organisms and 

there is no available information on reaction with organic matter by Relevant Chemicals. 

5 POTENTIAL PHYSICAL EFFECTS ON WILDLIFE AND BENTHIC HABITATS 

5.1 No data were found, indicating that the Active Substances,Relevant Chemicals and 

other chemicals could cause potential physical effects to wildlife. 

6 POTENTIAL RESIDUES IN SEAFOOD 

6.1 Based on the low log Pows and BCFs of the Active Substances, Relevant Chemicals and 

other chemicals, there is little possibility for significant residues to accumulate in tissues which 

could impact the consumption of seafood 

7 ANY KNOWN INTERACTIVE EFFECTS 

7.1 No interactive effects of the Active Substances, Relevant Chemicals and other chemicals 

have been identified. 

* * * 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 41 

I:\MEPC\60\2-12.doc 

APPENDIX 4 

PHYSICAL PROPERTIES FOR ACTIVE SUBSTANCES, RELEVANT CHEMICAL 

AND OTHER CHEMICALS 

1 PHYSICAL AND CHEMICAL PROPERTIES FOR ACTIVE SUBSTANCES 

1.1 Hypochlorous acid/hypochlorite 

Property Value Reference/Comments/ 

Justification for missing data 

Melting point (°C) - 20 to -30°C ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

Boiling point (°C) 96 – 120 °C ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

Flammability (flash point for 

liquids; °C) 

Non flammable solution The chemical data base 

Density (20 °C; kg/m3) 1.23 g/cm3 at 25°C ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

Vapour pressure (20 °C; Pa) 17.4 - 20 hPa at 20°C ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

Vapour density (air = 1) N. A 

Water solubility (temp; effect of 

pH; mg/L) 

Miscible [29.3 g/100 g 

(0 deg C) in water] 

ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

pH in solution >11@20°C 

Approx. 11 

ECB, IUCLID, 2000 

Dissociation constant (pKa) N. A 

Oxidation-reduction potential N. A 

Corrosivity to material or 

equipment 

Contact with metals may 

evolve flammable hydrogen 

gas 

The chemical data base 

Reactivity to container material Contact with metals may 

evolve flammable hydrogen 

gas 

The chemical data base 

Auto-ignition temperature (°C) Non flammable solution The chemical data base 

Explosive properties Anhydrous sodium 

hypochlorite is very 

explosive. 

ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

Oxidizing properties Strong 

oxidizing agent 

usually stored 

and used insolution 

ECB, Risk Assessment Report 

for Sodium hypochlorite, 2007 

Surface tension N. A 

Viscosity N. A 

Thermal stability and identity 

of breakdown products 

N. A 

Other physical or chemical 

properties 

N. A 
GESAMP-BWWG 11/6 

ANNEX 6 

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I:\MEPC\60\2-12.doc

1.2 Hypobromous acid/hypobromite 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) -7.2 The Chemical Database 

Boiling point (°C) -58.7 The Chemical Database 

Flammability (flash point for 

liquids; °C) 

Non flammability ICSC: 0107 

Density (20 °C; kg/m3) 3.121g/cm3 The Chemical Database 

Vapour pressure (20 °C; Pa) 190mmHg (25°C) The Chemical Database 

Vapour density (air = 1) 5.5 The Chemical Database 

Water solubility (temp; effect 

of pH; mg/L) 

Insoluble The Chemical Database 

pH in solution N. A 

Dissociation constant (pKa) N. A 

Oxidation-reduction potential N. A 

Corrosivity to material or 

equipment 

Corrosiveness: Attacks all metals and 

organic tissues of plastics, only those 

which are fluorinated resist bromine 

attack. 

ECB, IUCLD, 2000 

Reactivity to container 

material 

Corrosiveness: Attacks all metals and 

organic tissues of plastics, only those 

which are fluorinated resist bromine 

attack. 

ECB, IUCLD, 2000 

Auto-ignition temperature 

(°C) 

Flash point: -18°C The Chemical Database 

Explosive properties Not explosive ECB, IUCLD, 2000 

Oxidizing properties A very powerful oxidizer ECB, IUCLD, 2000 

Surface tension 40.9g/s2(25°C) The Chemical Database 

Viscosity 0.314sq mm/s The Chemical Database 

Thermal stability and 

identity of breakdown 

products 

Producing hydrogen bromide The Chemical Database 

Other physical or chemical 

properties 

N.A. 

1.3 Chloramine 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) -66 °C HSDB, 2009 

Boiling point (°C) N. A 

Flammability (flash point for 

liquids; °C) 

N. A 

Density (20 °C; kg/m3) N. A 

Vapour pressure (20 °C; Pa) N. A 

Vapour density (air = 1) N. A 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 43 

I:\MEPC\60\2-12.doc 

Property Value Reference/Comments/ 

Justification for missing 

data 

Water solubility (temp; effect of 

pH; mg/L) 

Soluble in water, alcohol and 

ether 

HSDB, 2009 

pH in solution N. A 

Dissociation constant (pKa) N. A 

Oxidation-reduction potential N. A 

Corrosivity to material or 

equipment 

N. A 

Reactivity to container 

material 

N. A 

Auto-ignition temperature (°C) N. A 

Explosive properties N. A 

Oxidizing properties N. A 

Surface tension N. A 

Viscosity N. A 

Thermal stability and 

identity of breakdown 

products 

It may decompose violently 

above -66 °C , 

When heated to decomposition 

it emits very toxic fumes of 

/nitrogenoxides, ammonia, and 

hydrogen chloride/. 

HSDB, 2009 

Other physical or chemical 

properties 

Sensitive to light, temperature 

and pH change. Reacts with 

oxidizing materials. 

The chemical database 

2 PHYSICAL AND CHEMICAL PROPERTIES FOR THE RELEVANT CHEMICALS 

2.1 Tribromomethane 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) 9.2 The chemical database 

Boiling point (°C) 149.5 The chemical database 

Flammability (flash point 

for liquids; °C) 

83 The chemical database 

Density (20 °C; kg/m3) 2.8912 g/cm3 (20 C) The chemical database 

Vapour pressure (20 °C; 

Pa) 

700 ICSC 0108 

Vapour density (air = 1) 8.7 The chemical database 

Water solubility (temp; 

effect of pH; mg/L) 

0.1 g/100 g water at 20 °C HSDB, 2009 

pH in solution N.A. 

Dissociation constant (pKa) N.A. 

Oxidation-reduction 

potential 

N.A. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 44 

I:\MEPC\60\2-12.doc

Property Value Reference/Comments/ 

Justification for missing 

data 

Corrosivity to material or 

equipment 

Keep away from metals. Liquid 

bromoform will attack some forms 

of plastics, rubber, and coatings 

The chemical database 

HSDB, 2009 

Reactivity to container 

material 

Do not store in metal containers. The chemical database 

Autoignition temperature 

(°C) 

N.A. 

Explosive properties N.A. 

Oxidizing properties Strong oxidizing agents, The chemical database 

Surface tension 41.53 dynes/cm at 20 °C HSDB, 2009 

Viscosity 1.73 cp (35 C) The chemical database 

Thermal stability and 

identity of 

breakdown products 

Stable at room temperature in 

closed containers under normal 

storage and handling conditions. 

Carbon monoxide, irritating and 

toxic fumes and gases, carbon 

dioxide, hydrogen bromide. 

The chemical database 

Other physical or chemical 

properties 

Colorless liquid, with characteristic 

odour. Turns yellow exposure on 

light and air. 

ICSC 0108 

2.2 Dibromochloromethane 

Property Value Reference/Comments/ 

Justification for missing data

Melting point (°C) -20 °C HSDB, 2006 

Boiling point (°C) 121.3-121.8°C HSDB, 2006 

Flammability (flash point for liquids; 

°C) 

20 °C The chemical database 

Density (20 °C; kg/m3) 2.38 HSDB, 2006 

Vapour pressure (20 °C; Pa) 5.54 mm Hg at 25 deg C 

(est) 

HSDB, 2006 

Vapour density (air = 1) 7.1 The chemical database 

Water solubility (temp; effect of pH; 

mg/L) 

2.07×103mg/L at 20°C HSDB, 2006 

pH in solution N.A. 

Dissociation constant (pKa) N.A. 

Oxidation-reduction potential N.A. 

Corrosivity to material or 

equipment 

N.A. 

Reactivity to container material N.A. 

Auto-ignition temperature (°C) N.A. 

Explosive properties N.A. 

Oxidizing properties N.A. 

Surface tension N.A. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 45 

I:\MEPC\60\2-12.doc 

Property Value Reference/Comments/ 

Justification for missing data

Viscosity N.A. 

Thermal stability and identity of 

breakdown products 

N.A. 

Other physical or chemical 

properties 

Enthalpy of formation at 

25°C: -5.0 kcal/mole 

(gas); 

Gibbs free energy of 

formation at 25°C: -4. 

50 kcal/mole (gas); 

entropy at 25°C: 78.31 

cal/mole (gas) 

HSDB, 2006 

2.3 Monobromoacetic acid 

Property Value Reference/Comments/Justification 

for missing data 

Melting point (°C) 49 HSDB, 2009 

Boiling point (°C) 208 HSDB, 2009 

Flammability (flash point for liquids; 

°C) 

113 Sigma-Aldrich, MSDS, 2006 

Density (20 °C; kg/m3) 1.9335 g/cm3 The Chemical Database,2009 

Vapour pressure (20 °C; Pa) 0.09 mmHg 

(25 °C) 

The Chemical Database,2009 

Vapour density (air = 1) N.A. 

Water solubility (temp; effect of pH; 

mg/L) 

Miscible The Chemical Database,2009 

pH in solution N.A. 

Dissociation constant (pKa) 2.72 The Chemical Database,2009 

Oxidation-reduction potential N.A. 

Corrosivity to material or 

equipment 

N.A. 

Reactivity to container material N.A. 

Auto-ignition temperature (°C) N.A. 

Explosive properties N.A. 

Oxidizing properties N.A. 

Surface tension 40.3 g/s2

(55°C) 

The Chemical Database,2009 

Viscosity 3.65 cp 

(50 °C) 

The Chemical Database,2009 

Thermal stability and identity of 

breakdown products 

Stable under normal 

temperatures and 

pressures. 

The Chemical Database,2009 

Other physical or chemical 

properties 

When heated to 

decomposition it 

emits toxic fumes 

HSDB, 2009 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 46 

I:\MEPC\60\2-12.doc

2.4 Dibromoacetic acid 

Property Value Reference/Comments/Justification 

for missing data 

Melting point (°C) 48°C HSDB, 2009 

Boiling point (°C) 232-234°C HSDB, 2009 

Flammability (flash point for liquids; 

°C) 

94°C The Chemical Database 

Density (20 °C; kg/m3) N.A. 

Vapour pressure (25 °C; Pa) 2.3×10-2 mm 

Hg 

HSDB, 2009 

Vapour density (air = 1) N.A. 

Water solubility (temp; effect of pH; 

mg/L) 

Very soluble The Chemical Database 

pH in solution N.A 

Dissociation constant (pKa) 1.47(pKa) The Chemical Database 

Oxidation-reduction potential N.A 

Corrosivity to material or equipment N.A 

Reactivity to container material N.A 

Auto-ignition temperature (°C) N.A 

Explosive properties N.A 

Oxidizing properties N.A 

Surface tension N.A 

Viscosity N.A 

Thermal stability and identity of 

breakdown products 

N.A 

Other physical or chemical properties N.A 

2.5 Tribromoacetic acid 

Property Value Reference/Comments/Justification 

for missing data 

Melting point (°C) 135°C The Chemical Database 

Boiling point (°C) 245°C The Chemical Database 

Flammability (flash point for liquids; °C) N.A. 

Density (20 °C; kg/m3) N.A. 

Vapour pressure (20 °C; Pa) 0.00028 mmHg 

at 25°C 

HSDB, 2009 

Vapour density (air = 1) N.A 

Water solubility (temp; effect of pH; 

mg/L) 

20000 mg/L HSDB, 2009 

pH in solution N.A 

Dissociation constant (pKa) 0.72 at 25°C HSDB, 2009 

Oxidation-reduction potential N.A. 

Corrosivity to material or equipment N.A. 

Reactivity to container material N.A. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 47 

I:\MEPC\60\2-12.doc 

Property Value Reference/Comments/Justification for 

missing data 

Auto-ignition temperature (°C) N.A. 

Explosive properties N.A. 

Oxidizing properties N.A. 

Surface tension N.A. 

Viscosity N.A. 

Thermal stability and identity of 

breakdown products 

N.A. 

Other physical or chemical properties N.A. 

2.6 Bromochloroacetic acid 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) 38 The chemical database 

Boiling point (°C) 201 The chemical database 

Flammability (flash point for liquids; °C) 110 Sigma-Aldrich, MSDS 

2006 

Density (20 °C; kg/m3) 1.9848 g/cm3 (31 °C) HSDB, 2009 

Vapour pressure (20 °C; Pa) 1.4×10-1mmHg at 25 °C HSDB, 2009 

Vapour density (air = 1) N.A. 

Water solubility (temp; effect of pH; 

mg/L) 

2.5×10+5 mg/L at 25 deg 

C 

HSDB, 2009 

pH in solution N.A. 

Dissociation constant (pKa) 1.40 HSDB, 2009 

Oxidation-reduction potential N.A. 

Corrosivity to material or equipment N.A. 

Reactivity to container material N.A. 

Auto-ignition temperature (°C) N.A. 

Explosive properties N.A. 

Oxidizing properties N.A. 

Surface tension N.A. 

Viscosity N.A. 

Thermal stability and identity of 

breakdown products 

N.A. 

Other physical or chemical properties Henry’s Law 

constant=2.2×10-8 atm-cu 

m/mole at 25 deg C 

HSDB, 2009 
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I:\MEPC\60\2-12.doc

2.7 Dibromochloroacetic acid 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) N. A 

Boiling point (°C) N. A 

Flammability (flash point for liquids; °C) N. A 

Density (20 °C; kg/m3) N. A 

Vapour pressure (20 °C; Pa) 5.2×10-3 mm Hg at 

25 deg C (est) 

HSDB, 2009 

Vapour density (air = 1) 

Water solubility (temp; effect of pH; 

mg/L) 

In water, 2.4×103 mg/L 

at 25°C 

HSDB, 2009 

pH in solution N.A. 

Dissociation constant (pKa) 0.03 HSDB, 2009 

Oxidation-reduction potential N. A 

Corrosivity to material or equipment N. A 

Reactivity to container material N. A 

Auto-ignition temperature (°C) N. A 

Explosive properties N. A 

Oxidizing properties N. A 

Surface tension N. A 

Viscosity N. A 

Thermal stability and identity of 

breakdown products 

N. A 

Other physical or chemical properties Henry's Law constant = 

2.6×10-9 atm-cu m/mole 

at 25 °C 

HSDB, 2009 

2.8 Dibromoacetonitrile 

Property Value Reference/Comments/Justification 

for missing data 

Melting point (°C) 6.98°C MEPC 58/2 

Boiling point (°C) 67°C The chemical database 

Flammability (flash point for liquids; 

°C) 

Non 

flammability 

(37°C) 

The chemical database 

Density (20 °C; kg/m3) 2.369 g/cm3

(20°C) 

The chemical database 

Vapour pressure (20 °C; Pa) 2mmHg The chemical database 

Vapour density (air = 1) 6.86 The chemical database 

Water solubility (temp; effect of pH; 

mg/L) 

Slightly soluble The chemical database 

pH in solution N.A. 

Dissociation constant (pKa) N.A. 

Oxidation-reduction potential N.A. 
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Property Value Reference/Comments/Justification for 

missing data 

Corrosivity to material or equipment N.A. 

Reactivity to container material N.A. 

Auto-ignition temperature (°C) N.A. 

Explosive properties N.A. 

Oxidizing properties N.A. 

Surface tension N.A. 

Viscosity N.A. 

Thermal stability and identity of 

breakdown products 

N.A. 

Other physical or chemical properties N.A. 

2.9 Bromate 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) 350 The chemical database 

Boiling point (°C) Decomposition point: 

370°C 

The chemical database 

Flammability (flash point for liquids; °C) N.A. 

Density (20 °C; kg/m3) 3.218 g/cm3 The chemical database 

Vapour pressure (20 °C; Pa) N.A. 

Vapour density (air = 1) 5.8 

Water solubility (temp; effect of pH; mg/L) 75 g/L 

pH in solution N. A 

Dissociation constant (pKa) N. A 

Oxidation-reduction potential N. A 

Corrosivity to material or equipment N. A 

Reactivity to container material N. A 

Auto-ignition temperature (°C) N. A 

Explosive properties N. A 

Oxidizing properties Oxidizer The chemical database 

Surface tension N. A 

Viscosity N. A 

Thermal stability and identity of 

breakdown products 

N. A 

Other physical or chemical properties N.A. 
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3 PHYSICAL AND CHEMICAL PROPERTIES FOR THE OTHER CHEMICALS 

3.1 Sodium thiosulphate 

Property Value Reference/Comments/ 

Justification for missing 

data 

Melting point (°C) 48 The chemical database 

Boiling point (°C) 100 The chemical database 

Flammability (flash point for liquids; 

°C) 

Non flammable ECB, IUCLID, 2000 

Density (20 °C; kg/m3) 1740 kg/m3 ECB, IUCLID, 2000 

Vapour pressure (20 °C; Pa) N. A 

Vapour density (air = 1) N. A 

Water solubility (temp; effect of pH; 

mg/L) 

701g/l at 20 °C 

pH:Ca. 6.5-9 at 100g/l and 

25°C 

ECB, IUCLID, 2000 

pH in solution N. A 

Dissociation constant (pKa) N. A 

Oxidation-reduction potential N. A 

Corrosivity to material or equipment N. A 

Reactivity to container material N. A 

Auto-ignition temperature (°C) N. A 

Explosive properties Not explosive ECB, IUCLID, 2000 

Oxidizing properties No oxidizing properties ECB, IUCLID, 2000 

Surface tension N. A 

Viscosity N. A 

Thermal stability and identity of 

breakdown products 

Stable under normal 

temperatures and pressures. 

Decomposition: Oxides of 

sulfur, hydrogen sulfide, 

sodium oxide. 

ECB, IUCLID, 2000 

Other physical or chemical properties N.A. 

4 PHYSICAL AND CHEMICAL PROPERTIES OF THE TREATED AND UNTREATED 

SEAWATER 

Property Untreated seawater Treated seawater 

Melting point (°C) N.A. N.A. 

Boiling point (°C) N.A. N.A. 

Flammability (flash point for liquids; 

°C) 

N.A. N.A. 

Density (20 °C; kg/m3) 1.0235 1.0235. 

Vapour pressure (20 °C; Pa) N.A. N.A. 

Vapour density (air = 1) N.A. N.A. 

Water solubility (temp; effect of pH; 

mg/L) 

N.A. N.A. 
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Property Untreated seawater Treated seawater 

pH in solution 8.23 8.09 

Dissociation constant (pKa) N.A. N.A. 

Oxidation-reduction potential 283 287 

Corrosivity to material or equipment / / 

Reactivity to container material N.A. N.A. 

Auto-ignition temperature (°C) N.A. N.A. 

Explosive properties N.A. N.A. 

Oxidizing properties N.A. N.A. 

Surface tension N.A. N.A. 

Viscosity N.A. N.A. 

Thermal stability and identity of 

breakdown products 

N.A. N.A. 

Salinity 30.13 29.74 

TOC, % particulate matter 1.90 3.21 

DOC, % particulate matter 1.75 2.89 

Other physical or chemical properties N.A. N.A. 

* * * 
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APPENDIX 5 

WATER PROPERTIES AMONG TEST WATERS USED FOR ECOTOXICITY 

TESTING AND CHEMICAL ANALYSIS 

Chemicals Control 0h after 

treatment 

Without 

neutralization 

24h after 

treatment 

Without 

neutralization 

48h after 

treatment 

With 

neutralization 

120h after treatment 

With 

neutralization 

Sampling date April 14 April 14 April 15 April 16 April 19 

Temperature 10.0 10.0 10.5 11.0 12.0 

Salinity 30.13 30.09 29.81 29.74 30.19 

TSS 

mg/l 

2.6 6.6 8.2 4.4 1.2 

DO 

mg/l 

9.92 10.73 10.51 8.97 8.79 

pH 8.23 8.22 8.22 8.09 8.04 

Turbidity 1.4 1.4 1.5 1.5 1.4 

DOC 

mg/l 

1.75 1.55 1.66 2.89 1.66 

POC 

mg/l 

0.15 0.12 0.09 0.32 0.26 

Eh 

mV 

283 272 281 287 292 

Relative 

density 

1.0235 1.0235 1.0235 1.0235 1.0235 

Chemical analysis of untreated and treated water 

Chemicals Control 0h after 

treatment 

Without 

neutralization 

24h after 

treatment 

Without 

neutralization 

48h after 

treatment 

With 

neutralization 

120h after 

treatment 

With 

neutralization 

Quantification 

limit 

Hypochlorous acid 

/hypochlorite 

ND 980 115 ND ND 40 

Hypobromous acid 

/hypobromite 

ND 7310 2005 ND ND 6 

Chloramines/ 

Bromamines 

ND 410 280 ND ND 40 

Trichoromethane 0.08 0.06 0.05 0.05 0.03 0.02 

Bromodichloromethane 0.05 0.05 0.04 0.05 0.04 0.02 

Dibromochloromethane 0.06 0.07 0.11 0.10 ND 0.03 

Tribromomethane ND 1.96 5.08 4.32 2.40 0.02 

Dibromoacetic 

acid 

0.19 74.87 200.34 157.98 129.78 0.03 

Bromochloroacetic acid 0.19 0.23 0.60 0.58 0.61 0.03 

Dibromoacetic 

acid 

0.52 12.09 20.30 19.98 17.74 0.03 

Dibromochloroacetic acid ND 5.12 6.60 5.40 5.23 0.03 

Tribromoacetic 

acid 

ND 45.62 55.25 41.63 40.99 0.03 

Dibromoacetonitrile ND 5.05 11.89 11.09 7.72 0.01 

Bromate ND 34.3 20.1 ND ND 0.4 

Sodium thiosulfite ND ND ND 862 529 20 

*** 
GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 7 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES

DESMI Ocean Guard Ballast Water Management System 

Submitted by Denmark for Basic Approval 

0 SUMMARY

0.1 Having considered all of the information provided by the applicant, the Group, agreed 

that the DESMI Ocean Guard Ballast Water Management System (BWMS) be recommended for 

Basic Approval subject to all the comments and recommendations of this report being taken into 

account. 

0.2 The Group agreed that the DESMI Ocean Guard Ballast Water Management System 

should not cause any unacceptable risk to the marine environment. 

0.3 Recognizing that, based on the information provided by the applicant, ballast water 

treated with the DESMI Ocean Guard Ballast Water Management System should not cause any 

unacceptable risk to the marine environment. Neither should it cause any unacceptable risk to 

human health or the structure of the ship. 

0.4 The Group recognized that the applicant has identified the relevant human exposure 

scenarios regarding occupational and general public by using an OEL to address inhalation risk 

in the workplace and TDI to address the risk resulting from combined exposures (swimming and 

eating fish from the area). The Group agreed that the risk was not unacceptable to the crew and 

general public. 

1 INTRODUCTION

1.1 Data used to evaluate this system were extracted from MEPC 60/2/4 and were 

supplemented by additional information provided to the Group. 

2 DESCRIPTION OF THE SYSTEM

2.1 The Group noted that the DESMI Ocean Guard BWMS proposed treatment at both 

uptake and discharge of ballast water. The main components of the system are: 

 .1 an automatic backflushing filtration unit (either a 20 μm gravity fed-free flow 

filter or a 40 μm pressurized unit); 

 .2 an ozone-generating component; 

 .3 a venturi injector system for introducing the generated ozone with the ballast 

water; 

 .4 an ozone reactor which includes a de-aeration function; and 

 .5 a UVC radiation treatment phase. 
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2.2 It was noted that the filtration stage is to be by-passed when the treatment is applied 

during discharge of ballast water. 

2.3 It was noted that generated ozone is injected into the water flow where it reacts with the 

ballast water in the ozone reactor that uses a pre-determined holding time to ensure efficient 

treatment. Any excess gaseous ozone is exhausted from the ozone reactor and destroyed and any 

remaining dissolved ozone is decomposed during the following UV treatment. 

2.4 Furthermore, it was noted that the applicant claimed that the system did not produce any 

persistent oxidants in the treated ballast water. 

2.5 The Group recalled that it had evaluated similar systems, which employed high pressure (HP) 

or medium pressure (MP) UV light, but that this system used low pressure (LP) UV generation to 

create UV-C light which has a narrower wavelength range (primarily 254 nm) than other systems. 
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2.6 A simplified flow diagram of the complete system, supplied by the applicant is shown 

below: 
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2.7 The Group noted that the applicant was proposing two versions of this system: 

 .1 an open pressureless filter systems, for situations where space is not a limiting 

factor, such as on new-build ships. These will use filters of 20μm and the water 

will flow by gravity through the filter to a combined filter housing/buffer tank; or 

 .2 a standard pressurized filter (40μm) primarily for retrofits where space might be at 

a premium. 

2.8 The Group noted that filtration is only intended during uptake of ballast water but that 

during ballasting and de-ballasting ozone is injected into the water which is then allowed a period 

of approximately 30 seconds to react prior to entering the UV treatment section. 

2.9 The Group noted that the ozone dose was 0.8 mg/L as O3 in ambient air. This followed 

by a UV dose in the range of 150 mJ/cm2 – 250 mJ/cm2. The applicant indicated that this UV 

dose will both disinfect the ballast water and degrade the TRO concentration of the treated water 

to below 0.04 mg/L as Cl2. In this context, the Group recommended that the applicant provide 

data to confirm the TRO concentration following the total treatment on uptake and during 

discharge. 

2.10 With the additional information provided by the applicant, the Group noted that 

maximum dose concentration of ozone is 0.4 mg/L (as O3) and the dose can be controlled 

according to water conditions. The Group strongly recommended that the applicant should 

clarify, in detail, the application of the ozone dose and its control in its application for 

Final Approval. 

3 CHEMICALS ASSOCIATED WITH THE SYSTEM

3.1 The Group noted that the primary disinfective moiety in this system is the photon which 

is the particle form of the wave/particle duality concept of light. The UVC spectrum 

(100-280 nm) employed by this system has germicidal properties in a process referred to as 

photolysis which disrupts chemical bonds particularly in the DNA of micro-organisms. The dual 

chromatic lamps used in this system emit light at 185 nm and 254 nm. 

3.2 The Group noted that the applicant had identified the following Active Substances (AS) 

associated with this system: 

 .1 ozone, which is generated in situ but has a short half-life (<30 min) and will not 

enter the environment in the treated ballast water; and 

 .2 hydroxyl radicals, have a half-life of milliseconds only and so will not enter the 

environment in the treated ballast water. 
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3.3 Recognizing that the Active Substances react with organic components contained in the 

ballast water, the applicant provided analysis results for the most likely chemical by-products 

anticipated in the treated ballast water with the results shown below: 

Parameter 

Fresh water 

before 

treatment 

Fresh water 

after treatment 

Marine water 

before treatment 

Marine water 

after treatment 

Sum parameters and nitrite (mg/L) 

Nitrite (NO2), mg/L 0.28 0.33 <0.005 <0.005

AOX, mg/L 0.05 0.04 0.17 <0.01

EOX, mg/L < 0.001 < 0.001 < 0.001 < 0.001

TRO mg Cl2/L < 0.04 < 0.04 0.35 < 0.04

VOC, mg/L 0.09 0.1 0.04 0.03

NVOC, mg/L 15 15 3.3 3.3

Suspended matter, mg/L 5.2 3.1 4.8 3.3

Trihalomethanes (THM) 

Trichloromethane CHCl3 (chloroform) < 0.05 < 0.06 < 0.07 < 0.08

Tribromomethane CHBr3 (bromoform) < 0.02 < 0.02 < 0.02 < 0.02

Dibromochloromethane CHClBr2 < 0.02 < 0.02 < 0.02 < 0.02

Dichlorobromomethane CHBrCl2 < 0.02 < 0.02 < 0.02 < 0.02

Highly volatile halogenated 

hydrocarbons (LHKW) 

1,2-dibromoethane < 0.02 < 0.02 < 0.02 < 0.02

1,2,3-trichloropropane < 0.02 < 0.02 < 0.02 < 0.02

2-chlorotoluene < 0.02 < 0.02 < 0.02 < 0.02

4-chlorotoluene < 0.02 < 0.02 < 0.02 < 0.02

1,2-dibromo-3-chloropropane < 0.02 < 0.02 < 0.02 < 0.02

1,2,3-tribromobenzene < 0.05 < 0.05 < 0.05 < 0.05

1,1,1-Trichloroethane < 0.02 < 0.02 < 0.02 < 0.02

Carbon tetrachloride < 0.02 < 0.02 < 0.02 < 0.02

Tetrachlorethene < 0.02 < 0.02 < 0.02 < 0.02

Haloacetic Acids (HAA) (μg/L) 

Monochloroacetic acid (MCAA) < 1.0 < 1.0 < 1.0 < 1.0

Dichloroacetic acid (DCAA) < 1.0 < 1.0 < 1.0 < 1.0

Trichloroacetic acid (TCAA) < 1.0 < 1.0 < 1.0 < 1.0

Monobromoacetic acid (MBAA) < 1.0 < 1.0 < 1.0 < 1.0

Dibromoacetic acid (DBAA) < 1.0 < 1.0 < 1.0 < 1.0

Tribromoacetic acid (TBAA) < 1.0 < 1.0 < 1.0 < 1.0

Bromochloroacetic acid (BCAA) < 1.0 < 1.0 < 1.0 < 1.0

Dibromochloroacetic acid (DBCAA) < 1.0 < 1.0 < 1.0 < 1.0

Dichlorobromoacetic acid (DCBAA) < 1.0 < 1.0 < 1.0 < 1.0

Bromophenols (μg/L) 

2,4-dibromophenol <0.01 <0.01 <0.01 <0.01

2,6-dibromophenol <0.02 <0.02 <0.02 <0.02

2,4,6-tribromophenol <0.04 <0.04 <0.04 <0.04

Acetonitrils (μg/L) 

Dibromoacetonitrile < 1.0 < 1.0 < 1.0 < 1.0

Bromochloroacetonitrile < 1.0 < 1.0 < 1.0 < 1.0

3.4 Properties of the above products used in environmental fate modelling are shown in 

appendix 1. 

3.5 The Group noted that, during this sampling, the TRO sensor after UV sterilizer had not 

yet been installed. The Group considered that the chemical analysis, above, was only the 

measured data for discharged concentration of TRO. The Group recommended that chemical 
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analysis, including TRO discharge concentration, should be repeated with adequate QA/QC in 

accordance with Guidelines in (G9). 

3.6 Furthermore, the Group recommended that, in order to confirm the efficacy of the TRO 

removal, by UV irradiation, the TRO concentration should be measured both upstream and 

downstream of the UV sterilizer for evaluation during consideration for Final Approval. 

4 QUESTIONS PUT TO THE APPLICANT DURING EVALUATION WITH 

ANSWERS AND THE GROUP’S REACTION 

Question 1: 

The dossier indicates that the residence time in the ozone reactor is between 30 – 120 

seconds. For a 1500 m3

 per hour system this would appear to require the ozone reactor to 

have a minimum sizing between 12.5 m3 and 50 m3

. Please could you indicate the actual 

size of the ozone reactor which is planned for full-scale ship use? 

Response 1: 

 .1 You are right about the calculated ozone reactor volumes for 1500 m3/h ballast 

water flow. 

 .2 The planned reactor volume is based on 30 seconds residence time corresponding 

to 12.5 m3 for 1500 m3/h flow. 

 .3 This is also the residence time used in our scaled set-up from which the reported 

data originates. 

 .4 The reason for writing 30-120 seconds is that we have discussed the possibility to 

use, as an alternative option, a ballast water tank as the ozone reaction chamber. 

 .5 If it turns out to be technically safe (especially considering the corrosion and 

safety issues) it might be interesting. Since ballast water tanks have different sizes 

we will have different residence times. 

Reaction: The Group agreed with the response, however, if the alternative option is 

pursued, then this system would have to be assessed under a new application. 

Question 2: 

Please could you provide the actual dosing rate of ozone used to generate the data in your 

application? 

Response 2: 

 .1 The dosing rates calculated for the tests was approximately 0.4 mg O3/l. Rates are 

calculated using measured ozone concentrations in the gas going in and out of the 

ozone reactor. It is difficult to measure the initial ozone concentrations in the 

water due to the very fast ozone reactions. Ozone dosing is therefore determined 

using indirect measures (the gas concentrations). 
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 .2 The ozone concentration in the water leaving the ozone reactor 

(before UV-radiation) will very much depend on the ozone “consumption” by the 

treated water. If the treated water is very clean (no oxidizable substances), it is 

possible to reach high ozone concentrations in the ozone reactor outlet. The 

dissolved ozone sensor (see figure 2, System Flow Diagram) will be used to 

control ozone gas production so that the ozone reactor outlet concentration at any 

time will be less than 0.25 mgO3/l. This maximum value guarantees that the 

UV-system will be able to destruct residual ozone at any time. 

Reaction: The Group was satisfied with the response. 

Question 3: 

What is the measure TRO value just after treatment by ozone/UV i.e.at the place on your 

flow diagram where the TRO sensor is indicated. 

Response 3: 

 .1 The measured TRO values after ozone/UV treatment was <0.04 mg/L (as Cl2) for 

both fresh and marine water. Please see table 3, row 6 in the application. The term 

“Oxidizing substances” is equivalent to total residual oxidants (TRO). We should 

have used “TRO” as this is commonly used to express the collection of residual 

oxidizing species such as chlorine, bromine etc. 

 .2 Samples were taken immediately after UV-treatment. Therefore, at the same place 

as the TRO, sensor will be installed in the final system. 

Reaction: The Group was satisfied with the response. 

Question 4: 

What is the difference between the dissolved ozone sensor, the DO sensor and the TRO 

sensor? Could you kindly provide the measurement principle of “dissolved ozone sensor”? 

Response 4: 

 .1 Dissolved ozone sensor – It is designed to be very sensitive to ozone in 

comparison to other substances; this is primarily due to the membrane and the 

electrolyte. 

.2 DO sensor – A dissolved oxygen sensor follows the same principle as the ozone 

sensor, but it measures the oxygen concentration in the water. 

.3 TRO sensor – The total residual oxidant sensor measures all substances that have 

an oxidation potential. This means both the ozone and the by-products of an 

ozone reaction like, for instance, bromate. 
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 .4 A method for measuring dissolved ozone is an electrochemical ozone sensor with 

a porous membrane that allows ozone to diffuse into a cell containing liquid 

electrolyte and electrodes. When the dissolved gas comes into contact with the 

electrolyte, a change in electrochemical potential between the electrodes is 

produced. This change is proportional to the dissolved ozone concentration. 

Reaction: The Group noted the response. The Group recommended that, for 

Final Approval, the detailed methods and any applicable standards be 

provided together with data sheets for these sensors. 

Question 5: 

During the two tests for chemical analysis and ecotoxicity testing, the TRO sensor, after the 

UV sterilizer, had not been installed yet. As a result, the chemical analysis at the test 

laboratory only the measured data for the discharged concentration of TRO. For 

confirmation, do you accept the statement above? If not, could you provide other real time 

TRO measurement data? 

Response 5: 

 .1 Yes.

Reaction: The Group was satisfied with the response. 

Question 6: 

Re clarification of the date of TRO measurement – In paragraph 4.1 of the application, it is 

stated that sampling for these chemical analysis was done on 2 July 2009 and carried to test 

laboratory (Teknologik Insitut, Arhus) on same day. However, the report from the test 

laboratory in confidential version, stated that the chemical analysis was performed 

from 6 to 23 July. 

It appears that the TRO concentration was measured at least 4 days after the sampling 

timing. As the application states that the fate of TRO in natural seawater and fresh water 

is very short, TRO could easily react with organic compounds and so be reduced 

significantly in 4 days. Could you please clarify and confirm the timing between sampling 

and TRO measurement at test lab? 

Response 6: 

 .1 All samples were either analysed or conserved for later analysis on the day of 

sampling. Teknologisk Institut, Arhus, stated a wrong date in their report. 

Reaction: The Group noted this response. 
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ANNEX 7 

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5 WHOLE EFFLUENT TESTING (WET)

5.1 The Group noted that the applicant had carried out the following tests on both treated 

fresh water and treated seawater: 

 .1 growth inhibition test with the fresh water microalga Pseudokirchneriella 

subcapitata;

 .2 growth inhibition test with the marine microalga Skeletonema costatum;

 .3 acute toxicity test with fresh water crustacean Daphnia magna;

 .4 acute toxicity test with the marine crustacean Acartia tonsa; and 

 .5 acute toxicity test with zebra fish (Danio rerio) – fresh water. 

5.2 The results of such tests are shown below: 

Test organism Sample NOEC LOEC L(E)C10 L(E)C50 

Fresh water samples 

Pseudokirchneriella subcapitata Treated fresh water 80% 80% 80% 80% 

Daphnia magna Treated fresh water 100% 100% 

Zebra fish (Danio rerio) Treated fresh water 100% 100% 

Marine water samples 

Skeletonema costatum Treated marine 

water 80% 80% 80% 80% 

Acartia tonsa Treated marine 

water 100% 100% 

6 RISKS TO THE SAFETY OF THE SHIP, ITS CREW AND THE GENERAL PUBLIC 

6.1 Risks associated with exposure of the crew to potential chemical by-products 

6.1.1 The Group concurred with the applicant’s view that crew exposure to Active Substances 

and their degradation products could happen in some situations and agreed with the HES chosen 

by the applicant to address occupational exposure: (a) sampling from the system; and (b) on the 

loading of the ballast tanks with water. 

6.1.2 The Group noted that the applicant considered the HES (b) as the worst case scenario for 

crew exposure assessment as chemicals that are partitioned out of the water into the air space 

above the treated ballast water can be exhausted on board and be inhaled by the crew. 

6.1.3 The Group noted that the applicant had used the predicted concentrations in the treated 

ballast water of the substances and potential chemical by-products to calculate the concentrations 

in air at equilibrium in the head space of the ballast tank and then compared these results with the 

OEL values found for the various substances for various countries. Whenever the substance was 

not detected in the treated ballast water, the concentration was assumed equal to the detection 

limit. 
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ANNEX 7 

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6.1.4 The Group agreed that no unacceptable risk was expected for crew exposure to this 

system as the calculated values (with the exception of dibromoethane) were below the OELs. 

6.2 Risks to the safety of the ship

6.2.1 The Group noted that the applicant had indicated that ballast water treated with this 

system did not contain any detectable chemicals likely to cause corrosion. 

6.2.2 As a result, the Group agreed that the risk to the ship from corrosion resulting from the 

use of this system would be minimal. 

6.2.3 The Group was also satisfied that the risks of fire, explosion or flooding would be no 

greater than with any other installation deemed acceptable by the national authorities. 

6.3 Risks to the general public from potential exposure during recreational activities 

6.3.1 The Group noted that the applicant in order to assess general public exposure to the 

treated ballast water considered the HES (a) oral intake due to bioaccumulation of the substances 

in seafood and HES b) oral, inhalative and dermal exposure during bathing in areas close to the 

ballast water outlet. The estimated calculated values for the daily uptake via eating fish and 

swimming in the harbour were found to be below the Tolerable Daily Intake (TDI) values for 

each substance (except for 1,2-dibromoethane for a child who swims twice a day and inhaling air 

from the area). 

6.3.2 Taking the above results into consideration and the overall information, the Group agreed 

with the applicant that there is no unacceptable risk to the general public when exposed via the 

environment to this system i.e. due to eating the fish from the harbour area and due to swimming 

in the harbour.

7 ENVIRONMENTAL RISK ASSESSMENT 

7.1 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T) 

7.1 Whilst recognizing that none of the potential chemical by-products had been detected in 

the treated ballast water, the Group also recognized that neither did these chemicals meet the 

PBT criteria as shown in the table below: 

Substance Persistent (P) 

Y/N 

Bioaccumulative (B) 

Y/N 

Toxic (T) 

Y/N 

Hydrogen peroxide N (1/2-life 15 h) N BCF <100) N 

Ozone N (1/2-life 28 h) N (BCF <100) N 

Nitrite N (1/2-life 0.5 h) N (BCF <100) N 

Sodium hypochlorite N (1/2-life 0.5 h) N (BCF <100) N 

Sodium hypobromite N (1/2-life 0.5 h) N (BCF <100) N 

Trichloromethane N (1/2-life 19 h) N (BCF <100) N 

Dichlorobromomethane N (1/2-life 19 h) N (BCF <100) N 
GESAMP-BWWG 11/6 

ANNEX 7 

Page 11 

I:\MEPC\60\2-12.doc 

Substance Persistent (P) 

Y/N 

Bioaccumulative (B) 

Y/N 

Toxic (T) 

Y/N 

Dibromochloromethane N (1/2-life 19 h) N (BCF <100) N 

Tribromomethane N (1/2-life 19 h) N (BCF <100) N 

Monochloroacetic acid N (1/2-life 15 h) N (BCF <100) N 

Dichloroacetic acid N (1/2-life 15 h) N (BCF <100) N 

Trichloroacetic acid Y (1/2-life 147 h) N (BCF <100) N 

Monobromoacetic acid N (1/2-life 15 h) N (BCF <100) N 

Dibromoacetic acid N (1/2-life 29 h) N (BCF <100) N 

Bromochloroacetic acid N (1/2-life 29 h) N (BCF <100) N 

Dichlorobromoacetic acid Y (1/2-life 147 h) N (BCF <100) N 

Dibromochloroacetic Y (1/2-life 147 h) N (BCF <100) N 

Tribromoacetic acid N (1/2-life 29 h) N (BCF <100) N 

Dibromoacetonitrile Y (1/2-life 147 h) N (BCF <100) N 

Bromochloroacetonitrile Y (1/2-life 147 h) N (BCF <100) N 

2,4-dibromophenol Y (1/2-life 147 h) N (BCF <100) N 

2,6-dibromophenol Y (1/2-life 147 h) N (BCF <100) N 

2,4,6-tribromophenol N (1/2-life 15 h) N (BCF <100) N 

1,2-dibromo-3-chloropropane Y (1/2-life 29 h) N (BCF <100) N 

1,2,3-trichloropropane Y (1/2-life 146 h) N (BCF <100) N 

2-chlorotoluene Y (1/2-life 147 h) N (BCF <100) N 

4-chlorotoluene Y (1/2-life 147 h) N (BCF <100) N 

7.3 Calculation of Predicted Environmental Concentration (PEC) 

7.3.1 The Group noted that the applicant had used the MAMPEC model to estimate the PECs 

for those potential by-products of the system using: 

 .1 the detection limits for each chemical as the maximum amount likely to be found 

in treated ballast water; and 

 .2 the OECD-EU commercial harbour with a fresh water (FW) and a seawater (SW) 

scenario. 

7.3.2 The results obtained, by the applicant, from running this model are shown below: 

CAS No. Substance PEC-SW 

(μg/L)

PEC-FW 

(μg/L)

7632-00-0 Nitrite (NO2) 0.038 0.001 

7722-84-1 Hydrogen peroxide (H2O2) 0.042 0.027 

10028-15-6 Ozone 0.025 0.025 

7681-52-9 HOCl/OCl- 0.004 0.004 

13824-96-9 HOBr/OBr- 0.004 0.004 

79-11-8 Monochloroacetic acid (MCAA) 0.006 0.006 
GESAMP-BWWG 11/6 

ANNEX 7 

Page 12 

I:\MEPC\60\2-12.doc

CAS No. Substance 

PEC-SW 

(μg/L) 

PEC-FW 

(μg/L) 

76-03-9 Trichloroacetic acid (TCAA) 0.007 0.007 

79-08-3 Monobromoacetic acid (MBAA) 0.006 0.006 

5278-95-5 Dibromochloroacetic acid (DBCAA) 0.007 0.007 

71133-14-7 Dichlorobromoacetic acid (DCBAA) 0.007 0.007 

3252-43-5 Dibromoacetonitrile 0.007 0.007 

83463-62-2 Bromochloroacetonitrile 0.007 0.007 

7.3.3 The Group was not able to recalculate these calculations as the necessary input data were 

not provided. 

7.4 Calculation of PEC/PNEC ratios

7.4.1 The Group noted the PNEC values for various potential chemical by-products, as shown 

in appendix 4, and agreed with the decision process used to derive them. 

7.4.2 The Group noted the applicant’s assessment of the PEC/PNEC ratios, as shown below. 

Substance 

Conc. in treated 

SW (μg/L) 

PEC-SW 

(μg/L) 

PNEC-SW 

(μg/L) PEC/PNEC 

Hydrogen peroxide (H2O2) 40 0.04 1.2 0.03 

Ozone 10 0.025 0.007 3.6 

HOCl/OCl- 40 0.004 0.04 0.11 

HOBr/OBr- 40 0.004 0.04 0.11 

Monochloroacetic acid 1 0.006 0.058 0.11 

Trichloroacetic acid 1 0.007 0.02 0.36 

Monobromoacetic acid 1 0.006 0.02 0.31 

Dibromochloroacetic acid 1 0.007 0.03 0.24 

Dichlorobromoacetic acid 1 0.007 0.03 0.24 

Dibromoacetonitrile 1 0.007 0.055 0.13 

Bromochloroacetonitrile 1 0.007 0.04 0.17 

7.4.3 The Group was not able to recalculate these calculations as the necessary input data were 

not provided. The PEC/PNEC ratio of 3.6 for ozone could, therefore, not be substantiated but it 

was noted that this was a worst case situation because of the detection limit for ozone being used 

to calculate the PEC. 

7.5 Estimation of Risks to the Environment

7.5.1 The Group agreed that, from the results of the preliminary Whole Effluent Testing (WET) 

presented, no unacceptable risk would be expected but, in the application for Final Approval, this 

would need confirmation. 

8 CONCLUSIONS AND RECOMMENDATIONS

8.1 The Group agreed that the DESMI Ocean Guard Ballast Water Management System 

should not cause any unacceptable risk to the marine environment. 
GESAMP-BWWG 11/6 

ANNEX 7 

Page 13 

I:\MEPC\60\2-12.doc 

8.2 The Group noted that the applicant used the MAMPEC model to calculate Predicted 

Environmental Concentrations (PEC). The Group also noted the applicant’s assessment of the 

PEC/PNEC ratios. However, the data provided did not allow recalculation of the concentrations 

in detail and recommended that clear input data are provided for such model calculation 

for Final Approval. 

8.3 The Group recognized that the methodology used by the applicant to develop HES 

associated with DESMI Ocean Guard Ballast Water Management System adequately addressed 

the potential risks of human exposure deriving from this system. The applicant has identified the 

relevant human exposure scenarios regarding occupational and general public by using an OEL 

to address the inhalation risk in the workplace and TDI to address the risk resulting from 

combined exposures (swimming and eating fish from the area). The Group agreed that the risk 

was not unacceptable to the crew and general public. 

8.4 Therefore, the Group concluded that the DESMI Ocean Guard Ballast Water 

Management System should be recommended for Basic Approval subject to all the comments 

and recommendations of this report are taken into account. 

* * * 
GESAMP-BWWG 11/6 

ANNEX 7 Page 14 I:\MEPC\60\2-12.doc 

APPENDIX 1 

PROPERTIES OF POTENTIAL BY PRODUCTS FROM THE DESMI SY

CAS No. Substance Mw g/mole MP oC BP oC log KOW log KOC Sw mg/L Psat Pa H Pa m3/mol7722-84-1 Hydrogen peroxide 34 -0.43 152 -1.57 1.2 1,000,000 263 1.7·10-2 10028-15-6 Ozone 48 -193 -112 -0.87 1.4 85,201 2.5·10-3 7.9·103 (F) 1.8·104 (M7632-00-0 Nitrite* 68 - - -3.7 1.4 82,000 - 0 7681-52-9 Sodium hypochlorite 74 310 708 -3.42 1.16 1,000,000 1.4·10-11 1.0·10-15 13824-96-9 Sodium hypobromite 119 319 728 -3.33 1.16 1,000,000 1.9·10-15 2.3·10-19 67-66-3 Trichloromethane 119 -64 61 1.97 1.55 8,000 2.1·104 3.1·102 75-27-4 Dichlorobromomethane 164 -56 118 2 1.55 1,287 7.7·103 9.7·102 124-48-1 Dibromochloromethane 208 -34 143 2.16 1.55 567 2.1·103 7.6·102 75-25-2 Tribromomethane 253 -12 167 2.4 1.55 204 7.1·102 54 79-11-8 Monochloroacetic acid 95 63 189 0.22 0.08 3,1700,00 8.7 2.6·10-4 79-43-6 Dichloroacetic acid 129 24 201 0.92 0.28 37,760 8.9·10-1 3.0·10-3 76-03-9 Trichloroacetic acid 163 56 197 1.33 0.44 1,300,000 2.5·101 3.2·10-3 79-08-3 Monobromoacetic acid 139 29 193 0.41 0.08 93,790 1.7·101 2.6·10-2 631-64-1 Dibromoacetic acid 218 54 243 0.7 0.28 22,140 3.1 3.0·10-2 5589-96-8 Bromochloroacetic acid 173 36 223 0.61 0.28 44,270 1.8·101 7.2·10-2 71133-14-7 Dichlorobromoacetic acid 208 48 235 1.53 0.44 4,869 4.8 2.0·10-1 5278-95-5 Dibromochloroacetic 252 68 264 1.62 0.44 2,353 6.9·10-1 7.4·10-2 75-96-7 Tribromoacetic acid 297 87 290 1.71 0.44 1,102 3.7·10-2 1.0·10-2 3252-43-5 Dibromoacetonitrile 199 7 204 0.47 1.11 9,600 4.0·101 8.3·10-1 83463-62-1 Bromochloroacetonitrile 154 -15 181 0.38 1.11 18,720 1.2·102 0.0 615-58-7 2,4-dibromophenol 252 71 270 3.22 2.86 156 2.1 3.5 608-33-3 2,6-dibromophenol 252 71 270 3.36 2.87 119 5.7·10-1 1.2 118-79-6 2,4,6-tribromophenol 331 94 244 4.13 3.07 50 4.2·10-2 2.8·10-1 106-93-4 1,2-dibromoethane 188 9-10 131 1.96 1.64 4,040 2.1·104 9.6·102 96-12-8 1,2-dibromo-3-chloropropane 236 -7 197 2.96 2.12 83 5.9·101 1.7·102 96-18-4 1,2,3-trichloropropane 147 -47 162 2.27 2.12 897 3.6·102 3.0·101 95-49-8 2-chlorotoluene 127 -27 159 3.42 2.65 114 3.6·102 3.9·102 106-43-4 4-chlorotoluene 127 -27 162 3.33 2.64 136 3.0·102 2.8·102 608-21-9 1,2,3-tribromobenzene 315 65 264 4.66 2.87 1 4.4·10-1 1.3·102 

* * *
I:\MEPC\60\2-12.doc 

APPENDIX 2 

PREDICTED CONCENTRATIONS IN AIR COMPARED WITH THE OEL-VA

FOR THE VARIOUS SUBSTANCES FOR VARIOUS COUNTRIE

Substance Ci (M)

μg/L 

Ci (F) 

μg/L 

Cair (M) 

mg/m3

Cair (F)

mg/m3 AT 

BE 

CZ 

CH 

DE 

DK 

EE 

ES 

EU 

FI 

FR 

GB 

GR 

HU 

IE 

IS 

LT 

LU 

LV 

NL 

Hydrogen peroxide 40 40 3.E-04 3.E-04 1.4 1.4 0.71 0.71 1.4 1.4 1.5 1.4 Ozone 10 10 8.E+01 3.E+01 0.2 0.2 0.1 0.2 0.2 0.12 Nitrite 5 330 Sodium hypochlorite 40 40 2.E-17 2.E-17 Sodium hypobromite 40 40 4.E-21 4.E-21 Trichloromethane 0.05 0.05 7.E-03 7.E-03 10 10 10 2.5 10 10 10 10 10 10 9.9 50 10 9.8 10 10 10 10 5 Dichlorobromomethane 0.02 0.02 8.E-03 8.E-03 Dibromochloromethane 0.02 0.02 6.E-03 6.E-03 Tribromomethane 0.02 0.02 5.E-04 5.E-04 5 5.3 5 5 5.3 5.2 5 5 5 5 5 Monochloroacetic acid 1 1 1.E-07 1.E-07 4 4 4 1.2 1 4 1 Dichloroacetic acid 1 1 1.E-06 1.E-06 2.7 4 4 Trichloroacetic acid 1 1 1.E-06 1.E-06 5 6.8 1 6.8 5 5 1 5 Monobromoacetic acid 1 1 1.E-05 1.E-05 Dibromoacetic acid 1 1 1.E-05 1.E-05 Bromochloroacetic acid 1 1 3.E-05 3.E-05 Dichlorobromoacetic acid 1 1 9.E-05 9.E-05 Dibromochloroacetic 1 1 3.E-05 3.E-05 Tribromoacetic acid 1 1 4.E-06 4.E-06 Dibromoacetonitrile 1 1 4.E-04 4.E-04 Bromochloroacetonitrile 1 1 0.E+00 2,4-dibromophenol 0.01 0.01 1.E-05 1.E-05 2,6-dibromophenol 0.02 0.02 1.E-05 1.E-05 2,4,6-tribromophenol 0.04 0.04 5.E-06 5.E-06 1,2-dibromoethane 0.02 0.02 8.E-03 8.E-03 0.8 1 1 3.9 0.78 3.9 4 4 1 0.002 1,2-dibromo-3-chloropropane 0.02 0.02 1.E-03 1.E-03 0.01 0.01 1,2,3-trichloropropane 0.02 0.02 3.E-04 3.E-04 300 61 0.6 300 18 300 300 60 2 2 0.108 2-Chlorotoluene 0.02 0.02 3.E-03 3.E-03 250 263 285 250 264 250 250 250 285 10 4-Chlorotoluene 0.02 0.02 2.E-03 2.E-03 10 1,2,3-tribromobenzene 0.05 0.05 3.E-03 3.E-03 

(M)= Marine Water (F)=Fresh Water 

* * *
GESAMP-BWWG 11/6 

ANNEX 7 Page 16 I:\MEPC\60\2-12.doc

APPENDIX 3 

CALCULATED TOTAL DAILY UPTAKE, TDI AND RISK QUOTIEN

Marine 

Exposure 

(μg/kg bw/day) RQ (-) Exposur

(μg/kg bw/

Substance 

TDI 

(μg/kg bw 

/day) 

Man Female Child Man Female Child Man Female 

Hydrogen peroxide 

- 

3.6E-04 4.0E-04 1.0E-03 - - - 2.3E-04 2.6E-04 

Ozone 

- 

3.7E+01 3.5E+01 1.8E+02 - - - 1.6E+01 1.5E+01 

Nitrite 46 3.2E-04 3.6E-04 8.7E-04 6.9E-06 7.7E-06 1.9E-05 5.8E-06 6.5E-06 Sodium hypochlorite 324 3.7E-05 4.2E-05 1.0E-04 1.2E-07 1.3E-07 3.1E-07 3.7E-05 4.2E-05 Sodium hypobromite 517 3.7E-05 4.2E-05 1.0E-04 7.2E-08 8.0E-08 2.0E-07 3.7E-05 4.2E-05 Trichloromethane Cl3CH 10 3.6E-05 3.4E-05 1.7E-04 3.6E-06 3.4E-06 1.7E-05 3.6E-05 3.4E-05 Dichlorobromomethane CHBrCl2 2.1 4.4E-05 4.2E-05 2.1E-04 2.1E-05 2.0E-05 9.9E-05 4.4E-05 4.2E-05 Dibromochloromethane CHClBr2 30 3.5E-05 3.3E-05 1.6E-04 1.2E-06 1.1E-06 5.5E-06 3.5E-05 3.3E-05 Tribromomethane Br3CH 25 2.5E-06 2.4E-06 1.2E-05 1.0E-07 9.7E-08 4.7E-07 2.5E-06 2.4E-06 Monochloroacetic acid (MCAA) 3.5 5.1E-05 5.7E-05 1.4E-04 1.5E-05 1.6E-05 4.0E-05 5.1E-05 5.7E-05 Dichloroacetic acid (DCAA) 40 5.1E-05 5.7E-05 1.4E-04 1.3E-06 1.4E-06 3.5E-06 5.1E-05 5.7E-05 Trichloroacetic acid (TCAA) 40 4.6E-05 5.1E-05 1.3E-04 1.2E-06 1.3E-06 3.3E-06 4.6E-05 5.1E-05 Monobromoacetic acid (MBAA) - 5.4E-05 6.0E-05 1.5E-04 - - - 5.4E-05 6.0E-05 Dibromoacetic acid (DBAA) 20 5.5E-05 6.0E-05 1.6E-04 2.7E-06 3.0E-06 7.8E-06 5.5E-05 6.0E-05 Bromochloroacetic acid (BCAA) - 6.0E-05 6.5E-05 1.8E-04 - - - 6.0E-05 6.5E-05 Dichlorobromoacetic acid (DCBAA) - 8.8E-05 9.4E-05 3.0E-04 - - - 8.8E-05 9.4E-05 Dibromochloroacetic acid (DBCAA) - 6.9E-05 7.6E-05 2.1E-04 - - - 6.9E-05 7.6E-05 Tribromoacetic acid (TBAA) - 6.0E-05 6.7E-05 1.7E-04 - - - 6.0E-05 6.7E-05 Dibromoacetonitrile 23 1.7E-04 1.7E-04 7.1E-04 7.6E-06 7.6E-06 3.1E-05 1.7E-04 1.7E-04 
I:\MEPC\60\2-12.doc 

Marine 

Exposure 

(μg/kg bw/day) RQ (-) Exposur

(μg/kg bw/

Substance 

TDI 

(μg/kg bw 

/day) 

Man Female Child Man Female Child Man Female 

Bromochloroacetonitrile 0.06 5.7E-05 6.4E-05 1.6E-04 1.0E-03 1.1E-03 2.7E-03 5.7E-05 6.4E-05 2,4-dibromophenol - 8.1E-06 8.3E-06 3.1E-05 - - - 8.1E-06 8.3E-06 2,6-dibromophenol - 1.1E-05 1.2E-05 3.4E-05 - - - 1.1E-05 1.2E-05 2,4,6-tribromophenol - 2.3E-04 2.7E-04 5.5E-04 - - - 2.3E-04 2.7E-04 1,2-Dibromoethane 0.01 2.7E-03 2.5E-03 1.3E-02 2.4E-01 2.2E-01 1.1E+00 2.7E-03 2.5E-03 1,2-dibromo-3-chloropropane 0.03 4.7E-04 4.4E-04 2.2E-03 1.6E-02 1.6E-02 7.7E-02 4.7E-04 4.4E-04 1,2,3-trichloropropane - 8.7E-05 8.3E-05 4.0E-04 - - - 8.7E-05 8.3E-05 2-chlorotoluene - 1.1E-03 1.1E-03 5.2E-03 - - - 1.1E-03 1.1E-03 4-chlorotoluene - 7.9E-04 7.5E-04 3.7E-03 - - - 7.9E-04 7.5E-04 1,2,3-tribromobenzene - 1.4E-03 1.4E-03 5.3E-03 - - - 1.4E-03 1.4E-03 Trichloroacetic acid (TCAA) - 4.6E-05 5.1E-05 1.3E-04 - - - 2.3E-04 2.6E-04 

* * * 
GESAMP-BWWG 11/6 

ANNEX 7 Page 18 I:\MEPC\60\2-12.doc

APPENDIX 4 

DATA USED FOR THE CALCULATION OF PNECS 

CAS No. 

Substance name 

Shortterm 

conc. 

(F) 

μg/L 

Shortterm 

conc. 

(M) 

μg/L 

Longterm 

conc. 

μg/L 

No data - Shortterm (F) 

No data - Shortterm (M) 

No data 

- Long 

term 

Assesssessment 

factor 

(fresh 

water) 

Assesssessment 

factor 

(marine 

water) 

PN

(fr

wa

μg

 

10028-15-6 Ozone 70 80 2 1 0 1000 10000 0.106-43-4 4-chlorotoluene 2000 10000 320 3 3 10 100 3 1,2-di- 106-93-4 bromoethane 15000 6200 7480 3 1 1 1000 10000 1 2,4,6-tri- 118-79-6 bromophenol 220 100 3 0 2 1000 10000 0. Dibromochloromethane 124-48-1 CHClBr2 6100 63 3 3 10 100 13824-96-9 

Sodium hypobromite 4 4 

3 3 100 100 

0.
I:\MEPC\60\2-12.doc CAS No. Substance name Shortterm 

conc. (F) μg/L 

Shortterm conc. (M) μg/L 

Longterm conc. μg/L 

No data - Shortterm (F) 

No data - Shortterm (M) 

No data - Long term 

Assesssessment factor (fresh water) 

Assesssessment factor (marine water) 

PNE(frewatμg/L 

   Dibromoace- 3252-43-5 tonitrile 550 3 0 1000 10000 0.

Dibromo- chloroacetic 

5278-95-5 acid (DBCAA) 0 0 

Bromo- 

chloroacet ic 

5589-96-8 acid (BC AA) 0 0  

1,2,3-tribro- 

608-21-9 mobenzene  2,6-dibromo- 608-33-3 phenol 3150 3 1000 10000 3.

***

GESAMP-BWWG 11/6 

I:\MEPC\60\2-12.doc 

ANNEX 8 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Blue Ocean Guardian (BOG) Ballast Water Management System 

Submitted by the Republic of Korea for Basic Approval 

0 SUMMARY

0.1 The Group recommended that the Blue Ocean Guardian (BOG) Ballast Water 

Management System (BWMS) be granted Basic Approval and that the comments and 

recommendations in this report are taken into account in the dossier for Final Approval. 

0.2 Based on the various concentrations of chemical by-products found in the treated ballast 

water, the Group agreed that these should not present any significant effect on the marine 

environment. This view was supported by the small-scale Whole Effluent Test (WET) results 

presented. 

0.3 Due to the fact that none of the potential chemical by-products were found in the treated 

ballast water at levels greater than those in the control (untreated) water, the Group agreed that 

there would be no unacceptable risks to the crew and general public from chemicals produced by 

this system. 

0.4 The Group agreed that the system should not cause any corrosion, which would be a risk 

to the safety of the ship as it neither uses any corrosive or aggressive additives nor produces such 

by-products. However the Group recommended that, for Final Approval, corrosion testing be 

conducted in accordance with the guidance provided in section 5.1 of the “Report of the eighth 

meeting of the GESAMP-BWWG”, contained in MEPC 59/2/16. 

0.5 The Group recognized that risk to operating personnel was inherent in the operation of the 

plasma module and the MPUV module by way of possible electric shock, exposure to UV-light 

and UV-radiation, heat and handling of the UV lamps. However, it was also recognized that 

appropriate risk mitigation measures and procedures were proposed to mitigate all such risk to an 

acceptable level, and that such risk control measures and procedures were to be fully described in 

the safety system for the ship’s crew to be incorporated to the operating manual and instructions. 

0.6 Due to the fact that none of the potential chemical by-products were found in the treated 

ballast water at levels greater than those in the control (untreated) water, the Group agreed that 

there would be no unacceptable risks to the environment from chemicals produced by this 

system. 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 2 

I:\MEPC\60\2-12.doc

1 INTRODUCTION

1.1 Data used to evaluate this system were extracted from MEPC 60/2/5 and were 

supplemented by additional information provided to the Group. 

2 DESCRIPTION OF THE SYSTEM 

2.1 The Group noted that the BOG BWMS comprised the following modules which are used 

to treat the incoming ballast water: 

 .1 filtration module (50 μm); 

 .2 plasma treatment reactor; 

 .3 medium pressure ultraviolet (MPUV) light treatment; and 

 .4 control module. 

2.2 It was also noted that only the MPUV phase is employed as a “stand-alone” treatment 

during deballasting. 

2.3 Whilst the Group recalled that it had evaluated systems employing filtration and UV 

treatment, this was the first system using plasma treatment which it had considered for the 

disinfection of ballast water. 

2.4 It was noted that the treatment of ballast water with plasma involves the generation of a 

high voltage current between two electrodes in the reactor which creates an ionization field 

producing a high energy plasma arc. 

2.5 It was noted that this arc causes an extremely rapid rise in pressure, temperature, density 

flow and expansion of the ballast water. At this precise moment, high energy plasma produces 

and intensive pressure shockwave which causes physical damage to the cellular matrix either by 

the sudden recoil of cell tissue or by micro-eddies created on the internal cell structure. 

2.6 In addition, the plasma discharge generates the following, which helps to render harmless 

aquatic organisms: 

 .1 hydroxyl radicals; 

 .2 ozone; 

 .3 atomic oxygen; 

 .4 nitric oxide; 

 .5 superoxide radicals; 

 .6 UV-radiation; and 

 .7 electrical fields. 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 3 

I:\MEPC\60\2-12.doc 

2.7 A schematic representation of the system, as supplied by the applicant, is shown below 

and it was noted that the filter module was by-passed and the plasma module was not used during 

de-ballasting: 

2.8 A simplified schematic representation of the system, produced by the Group, is shown 

below: 

Filter Ballast tank UV 

Plasma 

technology
GESAMP-BWWG 11/6 

ANNEX 8 

Page 4 

I:\MEPC\60\2-12.doc

3 CHEMICALS ASSOCIATED WITH THE SYSTEM

3.1 The Group noted that the system produced the following Active Substances in the treated 

ballast water but that such substances were either short lived or not detectable. 

Concentration at Compound CAS number MDL 32 psu 20 psu 

Superoxide radical(O2

-

) NN NN NN NN 

Single oxygen radical (Oh) NN NN NN NN 

Hydroxyl radical (OHh) 3352-57-6 NN NN NN 

Electron (e

-

) NN NN NN NN 

Ozone (O3) 10028-15-6 0.02 mg/L ND ND 

 NN = Not Necessary ND = Not Detectable 

3.2 As a result, the Group agreed that these Active Substances did not pose a risk to the 

environment, to the ship or to personnel. 

3.3 In addition, it was noted that the system produces the following gases: 

Analysed at Gas MDL 32 psu 20 psu 

Hydrogen (%) 0.05 0.09 0.06 

Ozone (μL/L) 0.2 50.0 18.0 

Chlorine (μL/L) 0.2 70.0 120 

3.4 Furthermore, it was noted that the applicant had analysed the untreated and treated ballast 

water (32 psu) for the following chemicals which were assumed to be potential by-products 

(Relevant Chemicals) of the system: 

Sampling time 0 day 1 day 5 day 

Sampling point/tank Test 

water Control Treated Control Treated Control 

Before 

deballast

After 

deballast 

Compounds MDL 

Active substance 

(mg/L) 

TRO 0.20 ND ND ND ND ND ND ND ND 

FRO 0.05 ND ND ND ND ND ND ND ND 

Ozone(O3) 0.02 ND ND ND ND ND ND ND ND 

ClO2 0.02 ND ND ND ND ND ND ND ND 

Sulfide(S2) 0.20 ND ND ND ND ND ND ND ND 

Bromate(BrO3

-

) (μg/L) 0.13 ND ND ND ND ND ND ND ND 

Bromide(Br-) 0.01 53.1 52.7 50.6 52.3 50.7 49.6 49.8 50.5 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 5 

I:\MEPC\60\2-12.doc 

Sampling time 0 day 1 day 5 day 

Sampling point/tank Test 

water Control Treated Control Treated Control 

Before 

deballast

After 

deballast 

Chlorinated organic compounds (μg/L)

1,1,1-Trichloroethane 0.01 ND ND ND ND ND ND ND ND 

1,1,2-Trichloroethane 0.01 ND ND ND ND ND ND ND ND 

1,1-Dichloroethane 0.01 ND ND 0.34 ND 0.17 ND 0.11 ND 

1,1,2,2-

Tetrachloroethane 0.01 0.19 0.18 ND ND ND ND ND ND 

 

1,1,1,2-

Tetrachloroethane 0.01 ND ND ND ND ND ND ND ND 

1,2,3-Trichlorobenzene 0.01 1.47 1.44 0.45 0.33 0.25 0.19 ND ND 

1,2,3-Trichloropropane 0.01 0.25 0.26 ND ND ND ND ND ND 

1,2,4-Trichlorobenzene 0.01 1.06 1.01 0.38 0.29 0.23 ND ND ND 

1,2-Dibromo-3-

chloropropane 0.01 ND ND ND ND ND ND ND ND 

1,1-Dichloroethene 0.02 ND ND 0.34 ND 0.29 ND ND 0.03 

1,2-Dichloropropane 0.02 0.03 0.03 ND ND ND ND ND ND 

2-Chlorotoluene 0.01 0.24 0.21 ND 0.08 ND ND ND ND 

4-Chlorotoluene 0.01 0.27 ND ND ND ND ND ND ND 

Bromobenzene 0.01 0.25 0.23 ND ND ND ND ND ND 

Bromochloromethane 0.01 ND ND ND ND ND ND ND ND 

Chlorobenzene 0.01 0.14 0.11 ND ND ND ND ND ND 

cis-1,2-dichloroethene 0.01 ND ND ND ND ND ND ND ND 

Dibromochloromethane 0.01 ND ND ND ND ND ND ND ND 

Dibromomethane 0.01 ND ND ND ND ND ND ND ND 

Dichlorobromomethane 0.01 ND ND ND ND ND ND ND ND 

Methylene chloride 0.02 3.12 3.13 3.22 2.56 2.03 ND ND ND 

Tetrachloroethene 0.01 ND ND ND ND ND ND ND ND 

Carbon tetrachloride 0.01 ND ND 0.01 ND ND ND ND ND 

trans-1,2-dichloroethene 0.01 ND ND ND ND ND ND ND ND 

Chloroform 0.01 0.27 0.26 0.15 0.20 ND 0.18 ND ND 

Bromoform 0.02 ND ND ND ND ND ND ND ND 

1,2,4-Tribromobenzene 0.02 7.94 7.60 4.16 2.99 2.23 1.63 1.23 1.05 

1,3,5-Tribromobenzene 0.02 3.59 3.08 1.75 1.21 0.92 0.69 ND ND 

Toluene 0.01 6.78 6.77 6.07 5.88 5.14 3.42 3.12 1.93 

Naphthalene 0.01 3.19 3.36 0.78 0.53 0.39 0.29 0.25 0.21 

THMs 0.27 0.26 0.15 0.20 ND 0.18 ND ND 

Halo-acetonitriles (μg/L)

Dibromoacetonitrile 0.004 0.05 0.05 0.04 ND ND ND ND ND 

Bromochloroacetonitrile 0.003 ND ND ND ND ND ND ND ND 

Chloropicrin 0.003 ND ND ND ND ND ND ND ND 

Chloral hydrate 0.002 0.02 0.02 ND 0.02 ND ND ND ND 

Trichloroacetonitrile 0.001 ND ND ND ND ND ND ND ND 

Dichloroacetonitrile 0.001 0.04 0.04 0.02 0.01 0.02 ND 0.01 ND 

Sum of HANs 0.11 0.10 0.07 0.03 0.02 ND 0.01 ND 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 6 

I:\MEPC\60\2-12.doc

Sampling time 0 day 1 day 5 day 

Sampling point/tank Test 

water Control Treated Control Treated Control 

Before 

deballast

After 

deballast 

Halo-acetic acids (μg/L)

2-mono-chloroacetic 

acid 0.059 ND ND ND ND ND ND ND ND 

2,2-dichloroacetic acid 0.166 ND ND ND ND ND ND ND ND 

Dalapon acid 0.103 ND ND ND ND ND ND ND ND 

2,2,2-trichloroacetic 

acid 0.02 ND ND ND ND ND ND ND ND 

2,2-bromochloroacetic 

acid 0.035 ND ND ND ND ND ND ND ND 

2,2,2-

bromodichloroacetic 

acid 

0.014 ND ND ND ND ND ND ND ND 

2,2,2-tribromoacetic 

acid 0.094 ND ND ND ND ND ND ND ND 

2-monobromoacetic 

acid 0.049 ND ND ND ND ND ND ND ND 

2,2-dibromoacetic acid 0.022 ND ND ND ND ND ND ND ND 

Sum of HAAs ND ND ND ND ND ND ND ND 

Chlorinated Phenols (μg/L)

2-Chlorophenol 0.4 ND ND ND ND ND ND ND ND 

3-Chlorophenol 0.2 ND ND ND ND ND ND ND ND 

4-Chlorophenol 0.2 ND ND ND ND ND ND ND ND 

2,3-Dichlorophenol 0.2 ND ND ND ND ND ND ND ND 

2,4-Dichlorophenol 0.5 ND ND ND ND ND ND ND ND 

2,5-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,6-Dichlorophenol 0.4 ND ND ND ND ND ND ND ND 

3,4-Dichlorophenol 0.2 ND ND ND ND ND ND ND ND 

3,5-Dichlorophenol 0.4 ND ND ND ND ND ND ND ND 

2,3,4-Trichlorophenol 

+ 3,4,5-Trichlorophenol 0.4 ND ND ND ND ND ND ND ND 

2,3,5-Trichlorophenol 

+ 2,4,5-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,3,6-Trichlorophenol 0.2 ND ND ND ND ND ND ND ND 

2,4,6-Trichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,4,5-

Tetrachlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,4,6-

Tetrachlorophenol 0.2 ND ND ND ND ND ND ND ND 

2,3,5,6-

Tetrachlorophenol 0.3 ND ND ND ND ND ND ND ND 

Pentachlorophenol 0.5 ND ND ND ND ND ND ND ND 

Bromophenols (μg/L)

2,4-Dibromophenol 0.3 ND ND ND ND ND ND ND ND 

2,6-Dibromophenol 0.6 ND ND ND ND ND ND ND ND 

2,4,6-Tribromophenol 0.8 ND ND ND ND ND ND ND ND 

Others (mg/L) 

AOX 0.01 0.35 0.36 0.39 0.31 0.31 0.28 0.29 0.31 

DOC 4.65 4.67 4.67 2.09 2.28 2.57 2.40 2.34 

POC 0.01 1.35 1.38 1.13 1.31 1.53 0.39 0.39 0.13 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 7 

I:\MEPC\60\2-12.doc 

3.4.1 The Group noted the high concentrations of 1,2,4-tribromobenzene, 

1,3,5-tribromobenzene, toluene and naphthalene in the test water. The reasons for the high 

concentration of these contaminants were unclear to the Group. 

3.5 The following analyses of untreated and treated ballast water (20 psu) were also noted: 

Sampling time 0 day 1 day 5 day 

Sampling point/tank Test 

water Control Treated Control Treated Control 

Before 

deballast 

After 

deballast 

Compounds MDL 

Active substance (mg/L) 

TRO 0.20 ND ND ND ND ND ND ND ND 

FRO 0.05 ND ND ND ND ND ND ND ND 

Ozone(O3) 0.02 ND ND ND ND ND ND ND ND 

ClO2 0.02 ND ND ND ND ND ND ND ND 

Sulfide(S2) 0.20 ND ND ND ND ND ND ND ND 

Bromate(BrO3

-

) (μg/L) 0.13 ND ND ND ND ND ND ND ND 

Bromide(Br-) 0.01 36.6 35.0 35.6 34.9 34.4 34.1 34.6 34.7 

Chlorinated organic compounds (μg/L)

1,1,1-Trichloroethane 0.01 ND ND ND ND ND ND ND ND 

1,1,2-Trichloroethane 0.01 ND ND ND ND ND ND ND ND 

1,1-Dichloroethane 0.01 ND ND ND ND ND ND ND ND 

1,1,2,2-

Tetrachloroethane 0.01 ND ND ND ND ND ND ND ND 

1,1,1,2-

Tetrachloroethane 0.01 ND ND ND ND ND ND ND ND 

1,2,3-Trichlorobenzene 0.01 ND ND ND ND ND ND ND ND 

1,2,3-Trichloropropane 0.01 0.03 0.03 0.02 0.02 0.02 ND 0.01 0.01 

1,2,4-Trichlorobenzene 0.01 ND ND ND ND ND ND ND ND 

1,2-Dibromo-3-

chloropropane 0.01 ND ND ND ND ND ND ND ND 

1,1-Dichloroethene 0.02 ND ND ND ND ND ND ND ND 

1,2-Dichloropropane 0.02 ND ND ND ND ND ND ND ND 

2-Chlorotoluene 0.01 ND ND ND ND ND ND ND ND 

4-Chlorotoluene 0.01 ND ND ND ND ND ND ND ND 

Bromobenzene 0.01 ND ND ND ND ND ND ND ND 

Bromochloromethane 0.01 ND ND ND ND ND ND ND ND 

Chlorobenzene 0.01 ND ND ND ND ND ND ND ND 

cis-1,2-dichloroethene 0.01 ND ND ND ND ND ND ND ND 

Dibromochloromethane 0.01 0.41 0.40 0.27 0.37 0.25 0.29 0.21 ND 

Dibromomethane 0.01 ND ND ND ND ND ND ND ND 

Dichlorobromomethane 0.01 1.91 1.85 1.44 1.88 1.29 1.44 1.04 0.90 

Methylene chloride 0.02 0.57 0.55 0.54 0.13 0.10 ND ND ND 

Tetrachloroethene 0.01 ND ND ND ND ND ND ND ND 

Carbon tetrachloride 0.01 ND ND 0.01 ND ND ND ND ND 

trans-1,2-dichloroethene 0.01 ND ND ND ND ND ND ND ND 

Chloroform 0.01 11.7 11.5 8.32 10.5 6.32 5.34 5.62 4.03 

Bromoform 0.02 0.92 0.88 ND ND ND ND ND ND 

1,2,4-Tribromobenzene 0.02 0.85 0.83 1.08 0.54 0.64 0.39 ND ND 

1,3,5-Tribromobenzene 0.02 ND ND ND ND ND ND ND ND 

Toluene 0.01 2.03 2.12 1.48 1.85 0.54 0.62 1.92 ND 

Naphthalene 0.01 0.23 0.23 0.19 0.19 0.17 0.17 0.22 0.12 

THMs 15.0 14.6 10.0 12.7 7.86 7.07 6.87 4.93 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 8 

I:\MEPC\60\2-12.doc

Sampling time 0 day 1 day 5 day 

Sampling point/tank Test 

water Control Treated Control Treated Control 

Before 

deballast 

After 

deballast 

Halo-acetonitriles (μg/L)

Dibromoacetonitrile 0.004 0.10 0.10 ND ND ND ND ND ND 

Bromochloroacetonitrile 0.003 0.08 0.03 ND ND ND ND ND ND 

Chloropicrin 0.003 0.03 0.04 ND 0.10 ND ND ND ND 

Chloral hydrate 0.002 0.56 0.55 0.41 0.11 0.39 0.04 0.19 0.37 

Trichloroacetonitrile 0.001 ND ND ND ND ND ND ND ND 

Dichloroacetonitrile 0.001 0.71 0.68 0.66 0.09 0.54 0.06 0.14 0.48 

Sum of HANs 1.48 1.44 1.13 0.20 1.03 0.11 0.33 0.85 

Halo-acetic acids (μg/L)

2-monochloroacetic 

acid 0.059 ND ND ND ND ND ND ND ND 

2,2-dichloroacetic acid 0.166 ND ND ND ND ND ND ND ND 

Dalapon acid 0.103 ND ND ND ND ND ND ND ND 

2,2,2-trichloroacetic 

acid 0.02 ND ND ND ND ND ND ND ND 

2,2-bromochloroacetic 

acid 0.035 ND ND ND ND ND ND ND ND 

2,2,2-

bromodichloroacetic 

acid 

0.014 ND ND ND ND ND ND ND ND 

2,2,2-tribromoacetic 

acid 0.094 ND ND ND ND ND ND ND ND 

2-monobromoacetic 

acid 0.049 ND ND ND ND ND ND ND ND 

2,2-dibromoacetic acid 0.022 ND ND ND ND ND ND ND ND 

Sum of HAAs ND ND ND ND ND ND ND ND 

Chlorinated Phenols (μg/L)

2-Chlorophenol 0.4 ND ND ND ND ND ND ND 

3-Chlorophenol 0.2 ND ND ND ND ND ND ND 

4-Chlorophenol 0.2 ND ND ND ND ND ND ND 

2,3-Dichlorophenol 0.2 ND ND ND ND ND ND ND 

2,4-Dichlorophenol 0.5 ND ND ND ND ND ND ND 

2,5-Dichlorophenol 0.3 ND ND ND ND ND ND ND 

2,6-Dichlorophenol 0.4 ND ND ND ND ND ND ND 

3,4-Dichlorophenol 0.2 ND ND ND ND ND ND ND 

3,5-Dichlorophenol 0.4 ND ND ND ND ND ND ND 

2,3,4-Trichlorophenol 

+ 3,4,5-Trichlorophenol 0.4 ND ND ND ND ND ND ND 

2,3,5-Trichlorophenol 

+ 2,4,5-Trichlorophenol 0.6 ND ND ND ND ND ND ND 

2,3,6-Trichlorophenol 0.2 ND ND ND ND ND ND ND 

2,4,6-Trichlorophenol 0.3 ND ND ND ND ND ND ND 

2,3,4,5-

Tetrachlorophenol 0.3 ND ND ND ND ND ND ND 

2,3,4,6-

Tetrachlorophenol 0.2 ND ND ND ND ND ND ND 

2,3,5,6-

Tetrachlorophenol 0.3 ND ND ND ND ND ND ND 

Pentachlorophenol 0.5 ND ND ND ND ND ND ND 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 9 

I:\MEPC\60\2-12.doc 

Sampling time 0 day 1 day 5 day 

Sampling point/tank Test 

water Control Treated Control Treated Control 

Before 

deballast 

After 

deballast 

Bromophenols (μg/L)

2,4-Dibromophenol 0.3 ND ND ND ND ND ND ND 

2,6-Dibromophenol 0.6 ND ND ND ND ND ND ND 

2,4,6-Tribromophenol 0.8 ND ND ND ND ND ND ND 

Others (mg/L)

AOX 0.01 0.30 0.29 0.28 0.44 0.31 0.40 0.39 0.46 

DOC 0.01 7.31 7.08 8.57 3.17 2.29 4.19 3.34 3.12 

POC 0.01 13.3 13.1 10.3 10.3 2.18 0.98 0.12 0.22 

3.5.1 The Group noted the relatively high concentrations of 1,2,4-tribromobenzene, toluene and 

naphthalene in the test water, similar to the case in seawater with 32 psu. The reasons for the 

relatively high concentrations of these contaminants were unclear to the Group. 

4 QUESTIONS PUT TO THE APPLICANT, DURING EVALUATION, WITH 

ANSWERS AND REACTIONS OF THE GROUP 

4.1 The following text in this section reflects the questions put to the applicant, the answers 

received and the reactions of the Group: 

Question 1: 

The Group recognized that for the dose or irradiation of UV lamps, the application states in 

paragraph 2.3.1, that 300mJ/cm

2

 (300mW/cm

2

/sec) was set during the test for chemical 

analysis and toxicity testing. Please could you indicate whether you would accept that this 

value to be set as a maximum dose during the evaluation process, meaning that the values 

cannot be changed at the Final Approval stage? 

Response 1: 

 .1 The maximum dose of UV lamps for Basic Approval was set at 300 mJ/cm

2

, but 

the maximum dose during chemical analysis and toxicity testing was 242 mJ/cm

2

. 

However, it will be increased to (data deemed to be confidential and removed at 

the request of the submitting Administration) at the Final Approval stage. 

Reaction: The Group was satisfied with this response. 

Question 2: 

Also, could you kindly provide any information for the criteria of the plasma strength? The 

Group needs quantitative criteria for evaluating that the plasma component has no 

significant changes in the parameters which could affect chemical potential productions. 

However, the Group considered that electrical power consumption by the component is not 

adequate for the representation of this treatment. 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 10 

I:\MEPC\60\2-12.doc

Response 2: 

 .1 (Data deemed to be confidential and removed at the request of the submitting 

Administration.)

Reaction: The Group noted the reaction of the applicant. 

Question 3: 

In the table of paragraph 2.3.1, the application states that the salinity of seawater is 34 psu, 

however, in table 6 and others, it is mentioned as 32 PSU. Could you clarify what was the 

actual salinity (PSU) both for seawater and blackish water for chemical analysis and 

toxicity testing? 

Response 3: 

 .1 32 PSU is the correct number for the actual salinity of seawater in table 6, but 

brackish water remains as 20psu. Thus, all numbers that are stated as 34psu in 

table 2.3.1, must be changed to 32 PSU. However, we would like to let you know 

that we misspelled brackish water in our non-confidential paper. 

Reaction: The Group was satisfied with the reaction of the applicant. 

5 WHOLE EFFLUENT TESTING (WET) 

5.1 The Group noted the following results obtained from aquatic toxicity tests on ballast 

water treated with the BOG BWMS. The Group also noted that during these WET tests, the 

BWMS was operated with a flow rate of 125 m3/h ballast water which is less than the 200 m3/h 

recommended in Guidelines (G8). 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 11 

I:\MEPC\60\2-12.doc 

Acute aquatic toxicity of 32 PSU ballast water treated 

by the ‘BOG’ BWMS 

LC50 and/or EC50

Species End point Conc.(%) 

Reference/Comments/ 

justification for missing 

data 

Algae Skeletonema costatum 72 h EC50 > 100 Tested (OECD 201) 

Crustacean Tigriopus japonicas 48 h EC50 

48 h LC50 

> 100 

> 100 Tested (OECD 202) 

Fish Paralichthys 

olivaceus 96 h LC50 > 100 Tested (OECD 203) 

Acute aquatic toxicity of 20 PSU ballast water treated 

by the ‘BOG’ BWMS 

LC50 and/or EC 50

Species End point Conc.(%) 

Reference/Comments/ 

justification for missing 

data 

Algae Skeletonema costatum 72 h EC50 > 100 Tested (OECD 201) 

Crustacean Tigriopus japonicas 48 h EC50 

48 h LC50 

> 100 

> 100 Tested (OECD 202) 

Fish Paralichthys olivaceus 96 h LC50 > 100 Tested (OECD 203) 

5.2 The Group noted that the simulated discharged water had no unacceptable effects on the 

aquatic environment according to the results of these tests. 

6 HUMAN HEALTH ASSESSMENT

6.1 The Group recognized that none of the potential chemical by-products were found in the 

treated ballast water at levels greater than those in the control (untreated) water and so agreed 

that there was no need to carry out any risk assessment for the environment or for human health. 

6.2 The Group, consequently, agreed that the risks to the crew and general public from 

chemicals produced by this system would be within acceptable limits. 

6.3 The Group noted that in the non-confidential part of the dossier, the applicant stated that 

mammalian toxicity testing had not been performed. The Group emphasized that no animal 

testing in mammals is encouraged to generate new toxicity data. 

7 RISKS TO THE SAFETY OF THE SHIP, ITS CREW AND THE GENERAL 

PUBLIC 

7.1 Due to the fact that none of the potential chemical by-products were found in the treated 

ballast water at levels greater than those in the control (untreated) water, the Group agreed that 

there would be no unacceptable risks to the crew and general public from chemicals produced by 

this system. 
GESAMP-BWWG 11/6 

ANNEX 8 

Page 12 

I:\MEPC\60\2-12.doc

7.2 The Group recognized that risks to operating personnel was inherent in the operation of 

the plasma module and the MPUV module by way of possible electric shock, exposure to 

UV-light and UV-radiation, heat and handling of the UV lamps. However, it was also 

recognized that appropriate risk mitigation measures and procedures were proposed to mitigate 

all such risk to an acceptable level, and that such risk control measures and procedures were to be 

fully described in the safety system for the ship’s crew to be incorporated to the operating manual 

and instructions. 

7.3 The Group noted that the dossier states that this BWMS neither uses any corrosive or 

aggressive additives nor produces such by-products. As a result, the Group agreed that the 

system should not cause any corrosion which would be a risk to the safety of the ship. It was 

also noted that the applicant intends to carry out a comprehensive corrosion testing program to 

verify this assumption. The Group recommended that the corrosion testing be conducted in 

accordance with the guidance provided in section 5.1 of the “Report of the eighth meeting of the 

GESAMP-BWWG”, contained in MEPC 59/2/16. 

8 ENVIRONMENTAL RISK ASSESSMENT

8.1 For the reasons cited in paragraphs 5.1 and 6.1, the Group agreed that there would be no 

unacceptable risk to the environment from chemicals produced by this BWMS. 

8.2 The Group also agreed that the results of Whole Effluent Testing (WET) supported this 

view. 

8.3 From the fact above, the Group was of the opinion that there were no needs to perform 

calculation of PEC/PNEC ratios and analysis particulary for this BWMS. 

9 CONCLUSIONS AND RECOMMENDATIONS

9.1 The Group agreed that the amounts of generated hydrogen, ozone and chlorine gases 

would not constitute any significant additional risk to the ship or crew. 

9.2 Based on the various concentrations of chemical by-products found in the treated ballast water, 

the Group agreed that these should not present any significant effect on the marine environment. This 

view was supported by the small-scale Whole Effluent Test (WET) results presented. 

9.3 In addition, the Group agreed that there would be no unacceptable risks from the 

extremely low levels of potential chemical by-products found in the treated ballast water. 

9.4 The Group noted that there was some possibility of this BWMS producing an Active 

Substance and/or Relevant Chemicals, according to the references presented. In this regard, 

the Group recommended that, for Final Approval, it is confirmed that Active Substance and/or 

Relevant Chemical concentrations, following treatment, remain at insignificant levels as 

anticipated. Alternatively, the Group suggested that WET chronic aquatic toxicity tests be carried 

out, in accordance with Procedure (G9), to confirm that the treated ballast water does not have 

any harmful effects. 

9.5 The Group recommended that this BWMS be granted Basic Approval and that the 

comments and recommendations in this report are taken into account in the dossier 

for Final Approval. 

_________________