I:\MEPC\60\2-16.doc 

E

MARINE ENVIRONMENT PROTECTION 

COMMITTEE 

60th session 

Agenda item 2 

MEPC 60/2/16

 8 February 2010

 Original: ENGLISH

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER 

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

Note by the Secretariat 

SUMMARY

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

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

includes the evaluation of proposals submitted for approval 

by Germany, Norway 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 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 12/6 (attached) 

Introduction

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

held at IMO Headquarters from 7 to 11 December 2009 and its report is attached to this 

document as GESAMP-BWWG 12/6. 

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 7 of the 

attached report. 

Action requested of the Committee

3 The Committee is invited to: 

.1 agree that Basic Approval be granted to Hyundai Heavy Industries Co., Ltd. 

(HHI) Ballast Water Management System (HiBallast) submitted by the Republic 

of Korea in document MEPC 60/2/6 (see annex 4); 
MEPC 60/2/16 - 2 - 

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.2 agree that Basic Approval be granted to Kwang San Co., Ltd. (KS) Ballast Water 

Management System “En-Ballast” submitted by the Republic of Korea in 

document MEPC 60/2/7 (see annex 5); 

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

System submitted by Norway in document MEPC 60/2/8 (see annex 6); 

 .4 agree that Basic Approval be granted to Severn Trent DeNora BalPure® Ballast 

Water Management System submitted by Germany in document MEPC 60/2/9 

(see annex 7); 

 .5 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 paragraph 4.1.2); 

 

 .6 request Member States to submit their application dossiers in electronic form on a 

voluntary basis, with the view to facilitating the Group’s review process 

(see paragraph 5.1); and 

 .7 approve the report in general. 

***
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GESAMP-BALLAST WATER WORKING 

GROUP 

Agenda item 6 

GESAMP-BWWG 12/6

 11 December 2009

 Original: ENGLISH

REPORT OF THE TWELFTH 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 ...................................................... 9 

6 CONSIDERATION AND ADOPTION OF THE REPORT .................. 9 
GESAMP-BWWG 12/6 - 2 - 

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ANNEXES 

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

Annex 2 Agenda for the twelfth 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 – Hyundai Heavy Industries Co., Ltd. (HHI) Ballast 

Water Management System (HiBallast) 

– Submitted by the Republic of Korea for Basic Approval 

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

use of Active Substances – Kwang San Co., Ltd. (KS) Ballast Water Management 

System “En-Ballast” 

– Submitted by the Republic of Korea for Basic Approval 

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

use of Active Substances – OceanGuard Ballast Water Management System 

– Submitted by Norway for Basic Approval 

Annex 7 Review of proposals for approval of Ballast Water Management Systems that make 

use of Active Substances – Severn Trent DeNora BalPure® Ballast Water 

Management System 

– Submitted by Germany for Basic Approval 
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I:\MEPC\60\2-16.doc 

1 INTRODUCTION 

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

was held at IMO Headquarters, London, from 7 to 11 December 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 of this report. 

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

conveyed the appreciation of the Director of Marine Environment Division, IMO, for the effort 

made by the members of the GESAMP-BWWG to have this additional meeting before MEPC 60 

in the attempt to evaluate all the remaining four submissions, which had been submitted before 

the deadline established for MEPC 60 (i.e. 28 August 2009). 

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

Mr. John Crayford and Dr. Andrew Craven, for their 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. Stephan Gollasch, arrangements had been made for him to be excused when the proposal for 

approval of the Severn Trent DeNora BalPure® Ballast Water Management System (Germany) 

was reviewed, due to his involvement in the development of this technology. Dr. Gollasch took 

no part in this evaluation and his contract was consequently reduced to ten 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 the Republic of Korea (two proposals, MEPC 60/2/6 

and MEPC 60/2/7), Norway (MEPC 60/2/8) and Germany (MEPC 60/2/9). All four 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 IMO consultants signed the Statements of Acceptance related to confidentiality. 

2.4 The original copies of the Statements of Acceptance, duly signed and dated by all 

concerned, were filed with the Technical Secretary of the Group and were kept together with the 

submissions. 

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

available to the IMO consultant during the working hours. For the duration of the meeting, the 

members of the Group consulted these dossiers, which were made available to them in the 

meeting room and kept back in the Organization’s secure designated room after working hours. 
GESAMP-BWWG 12/6 - 4 - 

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

other members of the Group all the documents, drafts and any other associated records and 

reports, which were handed over 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 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 Bearing in mind that MEPC 61 was tentatively scheduled from 11 to 15 October 2010 

and considering the activities presented 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. 
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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 were submitted by the Republic 

of Korea (two proposals), Norway and Germany. 

4.1.2 The Group also noted that, during this meeting, it had become necessary to obtain 

additional information or clarification from the three applicants, as the dossiers were either 

incomplete or, more commonly, the information provided was unclear, so slowing down the 

evaluation process. On the other hand, the Group agreed that Germany’s dossier was sufficient to 

complete the Basic Approval evaluation and no further clarification was required from the 

applicant. As a result, the Group reiterated its request to MEPC to urge each Administration to 

check that all technical descriptions and specifications of the BWMS and, in particular, those 

related to the operating conditions are included in 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 also in each application. 

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 Hyundai Heavy Industries Co., Ltd. (HHI) 

Ballast Water Management System (HiBallast) 

Republic of Korea 

5 Kwang San Co., Ltd. (KS) Ballast Water 

Management System “En-Ballast” 

Republic of Korea 

6 OceanGuard Ballast Water Management System Norway 

7 Severn Trent DeNora BalPure® Ballast Water 

Management System 

Germany 

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

the information related to these submissions, the Group recommended that: 

.1 Basic Approval be granted to Hyundai Heavy Industries Co., Ltd. (HHI) Ballast 

Water Management System (HiBallast) (Republic of Korea); 

.2 Basic Approval be granted to Kwang San Co., Ltd. (KS) Ballast Water 

Management System “En-Ballast” (Republic of Korea); 

 .3 Basic Approval be granted to OceanGuard Ballast Water Management System 

(Norway); and 

 .4 Basic Approval be granted to Severn Trent DeNora BalPure® Ballast Water 

Management System (Germany). 
GESAMP-BWWG 12/6 - 6 - 

I:\MEPC\60\2-16.doc 

4.3 Specific comments related to Hyundai Heavy Industries Co., Ltd. (HHI) Ballast 

Water Management System (HiBallast) 

4.3.1 The Group noted that the HiBallast system comprised an optional filtration stage followed 

by chemical treatment with oxidants produced by electrolysis. The electrolysis unit is in a 

sidestream of the main ballast. The resulting solution of oxidants, produced by electrolysis, is 

injected back into the incoming ballast water at an appropriate rate to disinfect it. Any excess 

oxidants are neutralized during discharge of the ballast water. 

4.3.2 The Group noted that the system was described as having several different options of 

configuration and recommended that any application for Final Approval should include all the 

required information for the specific configuration proposed. 

4.3.3 It was noted that no corrosion test results or human risk assessment had been presented in 

the application and that this should be rectified in the application for Final Approval. 

4.3.4 Furthermore, loading quantities, rather than leaching rates, should be used to estimate the 

Predicted Environmental Concentrations (PECs) when running the MAMPEC model. 

4.3.5 In addition, the Group emphasized the recommendation that the applicant should provide 

the chronic ecotoxicity data for the WET test as this was not reported in the application for Basic 

Approval. 

4.4 Specific comments related to Kwang San Co., Ltd. (KS) Ballast Water Management 

System “En-Ballast” 

4.4.1 The Group noted that the En-Ballast system comprised a filtration stage followed by 

electrolysis, which generates oxidants, primarily sodium hypochlorite, in a sidestream off the 

main ballast water piping. The oxidants are then passed through a gas-freeing tank and then 

injected back into the ballast water in a controlled manner to disinfect it. Any excess oxidants 

would be neutralized with sodium thiosulphate during discharge of the ballast water. 

4.4.2 The Group also noted that no corrosion test results or human risk assessment to the crew 

had been presented in the application and that this should be rectified in the application for Final 

Approval. 

4.4.3 Furthermore, it was noted that the input data to MAMPEC were incorrect which led to 

erroneous estimates of the Predicted Environmental Concentrations (PECs) and that this error 

should be rectified in the application for Final Approval. 

4.4.4 In addition, the Group emphasized the recommendation that the applicant should provide 

the chronic ecotoxicity data for the WET test as this was not reported in the application for Basic 

Approval. 

4.5 Specific comments related to OceanGuard Ballast Water Management System 

4.5.1 The Group noted that the OceanGuard Ballast Water Management System is a system 

consisting of filtration, ultrasonic treatment and treatment with Active Substance sodium 

hypochlorite formed by in situ electrolysis of seawater, which has been submitted for Basic 

Approval by Norway. 
 - 7 - GESAMP-BWWG 12/6 

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4.5.2 Having reviewed all the data and information submitted by Norway with the application 

for Basic Approval and the information supplied by the applicant in response to questions posed 

by the Group during the GESAMP-BWWG meeting, the Group recommended to MEPC that 

Basic Approval be granted to the BWMS. 

4.5.3 The Group made the following recommendations or requests for information, if this 

system is to be reviewed for Final Approval in the future: 

 .1 the Group recommended that the applicant ensures that the environmentally safe 

MADC is not exceeded over the entire range of relevant chemical properties and 

all possible holding times; 

.2 the Group recommended that suitable monitoring and shut-down facility be 

incorporated to ensure that an MADC of 0.20 mg/L TRO as Cl2 cannot be 

exceeded at any time; 

 .3 the Group recommended that if the applicant finds that there would be a 

possibility of lower degradation rates of TRO in the ballast water tank, with 

respect to parameters other than salinity, for instance, DOC concentration and 

chlorine demands, then additional mitigation measures, such as neutralization, 

should be installed to ensure an environmentally safe MADC under all possible 

conditions; 

 .4 the Group recommended that the applicant should carefully select multi-timing 

sampling during the tank holding time, according to the applicant’s TRO dose, not 

only 2, 3 and 5-day holding time with 2 mg/L TRO but also 0, 1 and 2-day 

holding time with 1.5 mg/L TRO should be considered as sampling timings. The 

worst case scenario (concentrations of Relevant Chemicals) observed among these 

multi-timings should be used for PEC calculations; 

.5 the Group recommended that the applicant should 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, in conducting corrosion tests; 

 .6 the Group recommended that the applicant should confirm by further testing, that 

there will be no unacceptable risks (to ship safety, human health or the 

environment) due to the chemical composition of treated ballast water; 

.7 the Group recommended that both acute and chronic ecotoxicity testings of treated 

ballast water for at least three species should be performed in accordance with the 

full requirements of Procedure (G9); 

 .8 the Group recommended that the levels of hydrogen, methane and carbon 

monoxide gases in the air space of treated ballast water tanks should continue to 

be monitored throughout the remainder of land-based and shipboard testing to 

validate the assumption that the risks associated with these gases remain 

acceptable; and 
GESAMP-BWWG 12/6 - 8 - 

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.9 the Group recommended that an appropriate risk evaluation for human exposure 

to chemicals is performed and that measures and procedures to mitigate such risks 

are identified and clearly addressed, including consideration of operation units 

associated with personnel working inside the ballast tank and personnel working 

close to the system, with detailed explanation of all proposed risk mitigation 

measures. 

4.6 Specific comments related to Severn Trent DeNora BalPure® Ballast Water 

Management System 

4.6.1 The Group noted that the Severn Trent DeNora BalPure® Ballast Water Management 

System is a system consisting of filtration and treatment by disinfection on uptake with Active 

Substance sodium hypochlorite formed by on-demand in situ electrolysis of seawater, followed 

by residual oxidant neutralization with sodium bisulfite on discharge, submitted by Germany for 

Basic Approval. 

4.6.2 Having reviewed all the data and information submitted by Germany with the application 

for Basic Approval, the Group recommended to MEPC that Basic Approval be granted to 

the BWMS. 

4.6.3 The Group made the following recommendations and requests for information, if this 

system is to be reviewed for Final Approval in the future: 

 .1 the Group recommended that a comprehensive evaluation of the corrosion impacts 

on ships’ structures be conducted using the maximum anticipated treatment 

concentration, 20 mg/L (TRO as Cl2) and that a realistic TRO decay profile may 

be considered if the total corrosion loss over the ship’s life is to be projected. The 

Group noted, however, that such an analysis, while useful, is not necessary for the 

Group’s consideration. The Group recommended that corrosion testing be 

conducted, and 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; 

 .2 the Group recommended to take into consideration the human exposure during 

sampling of ballast water at discharge (inhalation, dermal contact), as well as 

during the periodic sediment cleaning (inhalation, dermal contact). These 

scenarios should also be considered in the conceptual exposure model (CEM); 

.3 the Group recommended that the data sets on the analysis of Active Substance, 

Relevant Chemicals and Other Chemicals in treated ballast water should be further 

investigated during land-based and shipboard testing; 

 .4 the Group recommended that confirmation by further testing should be performed, 

that there will be no unacceptable risks (to ship safety, human health or the 

environment) due to the chemical composition of ballast water treated by this 

BWMS; 

 .5 the Group recommended that all missing information concerning the 

environmental exposure assessment using an appropriate model be provided; 
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I:\MEPC\60\2-16.doc 

 .6 the Group recommended a verification that the residual oxidant neutralization with 

sodium bisulfite on discharge is effective at all times (MADC < 0.2 mg/L TRO 

as Cl2); and 

 .7 the Group recommended that both acute and chronic ecotoxicity testings of treated 

ballast water be performed in accordance with the full requirements 

of Procedure (G9) at the maximum proposed treatment dose. 

5 ANY OTHER BUSINESS 

5.1 The Group discussed the possibility of shifting from paper dossier to electronic dossier in 

the near future. Lack of additional copies of the dossier affected the Group’s evaluation 

efficiency as the members of the Group had to wait for their turn to get hold of the dossier. The 

efficiency would be improved if the dossier could be made available on CD, which could then be 

copied onto the members’ computers during the meeting for their simultaneous inspection. And, 

at the end of the meeting, the same procedure concerning confidentiality should be followed both 

for the paper dossier and electronic dossier. It was therefore proposed to recommend to MEPC 

the submission of electronic dossiers on a voluntary basis. 

6 CONSIDERATION AND ADOPTION OF THE REPORT 

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

on Friday, 11 December 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 12/6 

I:\MEPC\60\2-16.doc 

ANNEX 1 

LIST OF MEMBERS WHO ATTENDED THE TWELFTH 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 (OPRF) 

Kaiyo Senpaku Bldg. 

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 12/6 

ANNEX 1 

Page 2 

I:\MEPC\60\2-16.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-mail: 

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 

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 CONSULTANTS 

 

Mr. John Crayford 

2 Dunmow Hill, Fleet 

Hampshire GU51 3AN 

United Kingdom 

E-mail: 

Tel: 

j.crayford@ntlworld.com

+44 (0)1252 672245 

Dr. Andrew Craven 

23 Wenlock Drive, Escrick 

York YO19 6JB 

United Kingdom 

E-mail: 

Tel: 

Fax: 

andrew.craven7@btinternet.com 

+44 (0) 7849 070 668 (Mobile) 

+44 (0) 1904 728 428 (H) 

 
GESAMP-BWWG 12/6 

ANNEX 1 

Page 3 

I:\MEPC\60\2-16.doc 

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 12/6 

I:\MEPC\60\2-16.doc 

ANNEX 2 

AGENDA FOR 

THE TWELFTH 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 ballast water management systems that make use of 

Active Substances 

.1 Republic of Korea – Hyundai Heavy Industries Co., Ltd. (HHI) 

Ballast Water Management System (HiBallast) 

for Basic Approval 

.2 Republic of Korea – Kwang San Co., Ltd. (KS) Ballast Water Management 

System “En-Ballast” 

for Basic Approval 

.3 Norway – OceanGuard Ballast Water Management System 

for Basic Approval 

.4 Germany – Severn Trent DeNora BalPure® Ballast Water 

Management System 

for Basic Approval

5 Any other business 

6 Consideration and adoption of the report

*** 

GESAMP-BWWG 12/6 

I:\MEPC\60\2-16.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 12/6 

I:\MEPC\60\2-16.doc 

ANNEX 4 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Hyundai Heavy Industries Co. Ltd. (HHI) Ballast Water Management System (HiBallast) 

Submitted by the Republic of Korea for Basic Approval 

0 SUMMARY

0.1 Having considered all of the data provided by the applicant, the Group recommended that 

Basic Approval be granted to the HiBallast Ballast Water Management System. 

0.2 The Group noted that the HiBallast system comprised an optional filtration stage followed 

by chemical treatment with oxidants produced by electrolysis. The electrolysis unit is in a 

sidestream of the ballast main and the resultant solution of oxidants are injected back into the 

incoming ballast water at an appropriate rate to disinfect it. Any excess oxidants are neutralized 

during discharge of the ballast water. 

0.3 The Group noted that the applicant had described different options in its application 

for Basic Approval and recommended that any application for Final Approval include all results 

related to the configuration proposed. 

0.4 Whilst recognizing the various options associated with the system, the Group noted that 

the analytical and ecotoxicity test results were obtained from unfiltered, treated and neutralized 

ballast water. In addition, it was assumed that thiosulphate had been used as a neutralizer and 

this application was assessed on this basis. 

0.5 The Group noted that, although no corrosion test results were presented, the applicant had 

indicated that these would be available for consideration as part of its application for 

Final Approval. 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. 

0.6 The Group noted that the hazard identification index (HAZID study) was conducted in 

order to identify potential hazardous events and to provide guidance on how such hazards to ship 

and crew might be managed during the design and operation of the system. The Group 

considered that this was a useful approach. 

0.7 The Group agreed that the main potential risk to the crew will be due to exposure to high 

concentrations of disinfectant through leakage and when mixing sodium thiosulphate for the 

neutralizing process. Whilst recognizing that the measures (corrective actions) to be put in place 

in order to minimize the chances of the crew coming into contact with the Active Substances or 

the treated ballast water, the applicant had not carried out a human risk assessment concerning 

the crew and the general public. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 2 

I:\MEPC\60\2-16.doc 

0.8 Whilst an environmental risk assessment had been carried out, the Group noted that the 

applicant had calculated the PECs using the MAMPEC model into which leaching rates had been 

put rather than loading rates. The Group recommended that the quantity of chemicals released 

into the environment be calculated using the maximum ballast water discharge concentrations 

multiplied by the total daily volume of ballast water released to the port. 

0.9 The environmental risk assessment indicated that the system should not cause any 

unacceptable risk to the marine environment. 

0.10 Notwithstanding those observations made in this report, the Group would like to draw 

attention to the following specific points to be addressed in the application for Final Approval: 

 .1 the results of corrosion testing, as recommended, should be included in the 

application; 

 .2 monitors and failsafe systems should be put in place to ensure that the levels of 

hydrogen do not reach dangerous concentrations; 

 .3 all relevant information and the quantification of the risks associated with the 

exposure of the crew to high concentrations of disinfectant through leakage and 

mixing of sodium thiosulphate should be provided by the applicant according to 

the principles of Human Exposure Assessment (MEPC 56/2/2, annex 9); 

 .4 in addition the Group considered that the risks to the General Public (swimming 

and eating fish from the coastal area) as a result of effluent discharge of treated 

ballast water should be assessed by the applicant and resultant information 

provided; 

 .5 the required chronic toxicity test results, in accordance with Procedure (G9), 

should be provided as it was missing in the application for Basic Approval; and 

 .6 the TRO sensors’ sensitivity, reliability and its use in the neutralizer control 

should be confirmed as being appropriate to maintain the MADC of TRO. 

0.11 Notwithstanding the above, the Group recommended that all of the recommendations, 

raised in this report be taken into consideration prior to making an application 

for Final Approval. 

1 INTRODUCTION

1.1 Data used to evaluate this system were extracted from MEPC 60/2/6 and were 

supplemented by additional information provided to the Group. 

2 DESCRIPTION OF THE SYSTEM

2.1 The Group noted that the HiBallast system comprised the following components: 

 .1 an optional 50 μm filtration unit; 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 3 

I:\MEPC\60\2-16.doc 

 .2 an electrolysis unit to generate Active Substances; 

 .3 a neutralization unit to remove residual TRO; 

 .4 a system control unit; and 

 .5 a sampling unit. 

2.2 The Group noted that the system diverts part of the incoming ballast water to the 

electrolyser which produces a concentration of >1000 mg/L of oxidants. This solution is then 

injected back into the incoming ballast water to act as a disinfectant and it was noted that, in 

order to meet the D-2 standards, about 5 mg/L of oxidants are needed when the ballast water is 

filtered first and about 15 mg/L when it is not. 

2.3 Furthermore, it was noted that 1.3 to 1.7 times the stoichiometric equivalent of 

thiosulphate was needed for neutralization to be effective and, in addition, it was noted that the 

applicant had indicated that the detection limit was <0.22 mg/L TRO, measured as chlorine, at 

the time of ballast water discharge. The Group was not satisfied with the high detection limit of 

TRO and agreed that the maximum allowable discharge concentration of TRO should 

be <0.20 mg/L, as Cl2, when applying for Final Approval and this value also needs to be verified 

by the analytical method used. 

2.4 A schematic representation of the system is shown below: 

2.5 It was noted that, during electrolysis, chlorine and hydrogen are generated as by-products 

of the process and that these gases are to be either vented to the atmosphere or discharged using a 

water eductor, dependant upon the installation, location and customer requirements for the ship 

to which the ballast water treatment system is to be fitted. 

2.6 It was noted that the applicant did not specify the actual neutralizing agent to be used but 

indicated that it could be either sodium thiosulphate or sodium bisulphite. The Group carried out 

its evaluation, based on the data supplied by the applicant, which had been generated from tests 

in which sodium thiosulphate had been used as the neutralizing agent. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 4 

I:\MEPC\60\2-16.doc 

2.7 The Group recommended that the applicant provide monitoring and control of the TRO 

upon discharge to ensure that the MADC is not exceeded. The Group could not form an opinion 

on the reliability or accuracy of control scheme used for neutralization from the information 

provided. 

3 CHEMICALS ASSOCIATED WITH THE SYSTEM

3.1 The Group noted the results of chemical analysis of ballast water treated with the 

HiBallast system, including neutralization on day 5, as shown in the table below: 

Active Substances and by-products of “HiBallast” 

Component Chemical Name CAS 

Number Unit 

MDL 

(Minimum 

Detection 

Level) 

Conc. 

at 33/20 

(PSU) 

AS, RC, 

BP or 

Other6

Initial TRO (measured as chlorine)1 N.A. mg/L 0.22* 10.8**/15.5**

8.86/12.6 AS 

Discharged TRO (measured as chlorine)1 N.A. mg/L 0.22* ND/ND AS 

FRO (measured as chlorine)2 N.A. mg/L 0.05 ND/ND AS 

Chlorine 7782-50-5 AS 

Bromine 7726-95-6 AS 

Sodium hypochlorite 7681-52-9 AS 

Sodium hypobromite 13824-96-9 AS 

Hypochlorous acid 7790-92-3 

Hypobromous acid N.A. 

CRO (measured as chlorine)3 N.A. AS 

Chloramines4 N.A. AS 

Bromamines5

 N.A. AS 

Sodium bromate 7789-38-0 μg/L 0.10 26.6/32.1 RC 

Halogenated Aliphatic and Aromatic 

Compounds including THMs N.A. RC 

1,1,1-Trichloroethane 71-55-6 μg/L 0.01 ND/ND RC 

1,1,2-Trichloroethane 79-00-5 μg/L 0.01 ND/ND RC 

1,1-Dichloroethane 75-34-3 μg/L 0.01 ND/ND RC 

1,1,2,2-Tetrachloroethane 79-34-5 μg/L 0.01 ND/ND RC 

1,1,1,2-Tetrachloroethane 630-20-6 μg/L 0.01 ND/ND RC 

1,2,3-Trichlorobenzene 87-61-6 μg/L 0.01 ND/ND RC 

1,2,3-Trichloropropane 96-18-4 μg/L 0.01 ND/ND RC 

1,2,4-Tribromobenzene 615-54-3 μg/L 0.01 ND/ND RC 

1,2,4-Trichlorobenzene 120-82-1 μg/L 0.01 ND/ND RC 

1,2-Dibromo-3-chloropropane 96-12-8 μg/L 0.01 ND/ND RC 

1,2-Dichloropropane 107-06-2 μg/L 0.01 ND/ND RC 

1,3,5-Tribromobenzene 626-39-1 μg/L 0.01 ND/ND RC 

2-Chlorotoluene 95-49-8 μg/L 0.01 ND/ND RC 

4-Chlorotoluene 106-43-4 μg/L 0.01 ND/ND RC 

Bromobenzene 108-86-1 μg/L 0.01 ND/ND RC 

Bromochloromethane 74-97-5 μg/L 0.01 ND/0.25 RC 

Chlorobenzene 108-90-7 μg/L 0.01 ND/ND RC 

cis-1,2-dichloroethene 156-59-2 μg/L 0.01 ND/ND RC 

Dibromochloromethane 124-48-1 μg/L 0.01 0.75/6.96 RC 

Dibromomethane 74-95-3 μg/L 0.01 3.37/0.73 RC 

Dichlorobromomethane 75-27-4 μg/L 0.01 0.15/0.51 RC 

Dichloromethane 75-09-2 μg/L 0.01 0.16/1.57 RC 

Tetrachloroethene 127-18-4 μg/L 0.02 ND/ND RC 

Tetrachloromethane 56-23-5 μg/L 0.01 ND/ND RC 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 5 

I:\MEPC\60\2-16.doc 

Component Chemical Name CAS 

Number Unit 

MDL 

(Minimum 

Detection 

Level) 

Conc. 

at 33/20 

(PSU) 

AS, RC, 

BP or 

Other6

trans-1,2-dichloroethene 156-60-5 μg/L 0.02 0.01/ND RC 

Trichloromethane 67-66-3 μg/L 0.02 0.20/0.10 RC 

Tribromomethane 75-25-2 μg/L 0.01 0.25/111 RC 

Halogenated Aceto-nitriles N.A. 

Trichloroacetonitrile 545-06-2 μg/L 0.01 0.02/ND RC 

Dichloroacetonitrile 3018-12-0 μg/L 0.02 0.04/0.14 RC 

Bromochloroacetonitrile 83463-62-1 μg/L 0.01 ND/ND RC 

Dibromoacetonitrile 3252-43-5 μg/L 0.01 0.01/0.32 RC 

Chloral hydrate 302-17-0 μg/L 0.02 0.02/0.01 RC 

Chloropicrin 76-06-2 μg/L 0.01 0.45/1.54 RC 

Halogenated Acetic Acids N.A. 

2-monochloroacetic acid 79-11-8 μg/L 0.04 ND/ND RC 

2,2-dichloroacetic acid 79-43-6 μg/L 0.01 ND/ND RC 

2,2,2-trichloroacetic acid 76-03-09 μg/L 0.01 ND/ND RC 

2-monobromoacetic acid 79-08-3 μg/L 0.01 5.66/6.35 RC 

2,2-dibromoacetic acid 631-64-1 μg/L 0.01 55.1/32.0 RC 

2,2,2-tribromoacetic acid 75-96-7 μg/L 0.01 14.9/13.8 RC 

2,2-bromochloroacetic acid 5589-96-8 μg/L 0.01 ND/ND RC 

2,2,2-bromodichloroacetic acid 71133-14-7 μg/L 0.01 ND/ND RC 

Dalapon acid N.A. μg/L 0.05 ND/ND RC 

Halogenated Phenols N.A. 

Chlorinated Phenols N.A. RC 

2-Chlorophenol 95-57-8 μg/L 0.4 ND/ND RC 

3-Chlorophenol 108-43-0 μg/L 0.5 ND/ND RC 

4-Chlorophenol 106-48-9 μg/L 0.5 ND/ND RC 

2,3-Dichlorophenol 576-24-9 μg/L 0.4 ND/ND RC 

2,4-Dichlorophenol 120-83-2 μg/L 0.8 ND/ND RC 

2,5-Dichlorophenol 583-78-8 μg/L 0.9 ND/ND RC 

2,6-Dichlorophenol 87-65-0 μg/L 0.8 ND/ND RC 

3,4-Dichlorophenol 95-77-2 μg/L 0.9 ND/ND RC 

3,5-Dichlorophenol 591-35-5 μg/L 0.6 ND/ND RC 

2,3,4-Trichlorophenol 15950-66-0 μg/L 1.0 ND/ND RC 

2,3,5-Trichlorophenol 933-78-8 μg/L 0.8 ND/ND RC 

2,3,6-Trichlorophenol 933-75-5 μg/L 0.4 ND/ND RC 

2,4,5-Trichlorophenol 95-95-4 μg/L 0.8 ND/ND RC 

2,4,6-Trichlorophenol 88-06-2 μg/L 0.4 ND/ND RC 

3,4,5-Trichlorophenol 609-19-8 μg/L 1.0 ND/ND RC 

2,3,4,5-Tetrachlorophenol 4901-51-3 μg/L 0.3 ND/ND RC 

2,3,4,6-Tetrachlorophenol 58-90-2 μg/L 0.3 ND/ND RC 

2,3,5,6-Tetrachlorophenol 935-95-5 μg/L 0.4 ND/ND RC 

Pentachlorophenol 87-86-5 μg/L 0.4 ND/ND RC 

Brominated Phenols N.A. ND/ND RC 

2,4-Dibromophenol 615-58-7 μg/L 0.5 ND/ND RC 

2,6-Dibromophenol 608-33-3 μg/L 0.4 ND/ND RC 

2,4,6-Tribromophenol 118-79-6 μg/L 0.5 ND/ND RC 

Neutralizing Agent N.A. OC 

 Sodium thiosulphate 7772-98-7 OC 

Gas 

Hydrogen Gas (% vol) 1333-74-0 % 0.1 87.9/93.5 BP 

Ozone Gas 10028-15-6 μL/L 0.2 Negligible BP 

Oxygen Gas 7782-44-7 % 0.1 NA BP 

Chlorine Gas 7782-50-5 μL/L 0.5 Negligible BP 
GESAMP-BWWG 12/6 

ANNEX 4 

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I:\MEPC\60\2-16.doc 

Note: 1: Total Residual Oxidants, which was measured by the method using DPD 

(N,N- diethyl-p-phenylenediamine) 

2: Free Residual Oxidants, which was measured by the method using the 

ortho-tolidine 

3: Combined Residual Oxidants, which was measured by the method using DPD 

(N,N- diethyl-p-phenylenediamine) 

4: A mixture of mono- and di- chloramines, and nitrogen trichloride 

5: A mixture of mono- and di- bromamine, and nitrogen tribromide 

6: AS (Active Substances), RC (Relevant Chemicals), BP (By-Products) 

ND: Not detected; NA: Not analysed. 

*: The Group considered this MDL to be too high 

**: Estimated concentration of disinfectant as injected TRO 

3.2 The Group noted that FRO was measured by the method using the ortho-tolidine, which 

had been replaced by other methods using DPD because of its carcinogenic properties. From the 

viewpoint of GHS, the Group invited the applicant and the test facility not to use the method 

using the ortho-tolidine anymore even if it is still in common on domestic standards.

3.3 The Group noted the complete data set of ecotoxicity, toxicity and physical properties 

shown in Book IV, Appendix IV of the confidential data provided by the applicant and 

summarized in appendix 1 of this document. 

4 QUESTIONS PUT TO THE APPLICANT, THE RESPONSES AND THE 

GROUP’S REACTION 

4.1 The following questions were put to the applicant prior to the meeting: 

Question 1 I would be most grateful if you could ask the appropriate person in Hyundai if 

they could provide me with an electronic copy (in Word for Windows format) of 

their submission to IMO which was the first document in the confidential dossier 

headed MEPC 60/0/0. 

 This document contains some important data which was omitted from the 

scaled-down version submitted to MEPC as MEPC 60/2/6. 

Answer 1 HHI will provide electronic copy of confidential dossier. Please find the file 

attached. 

Reaction 1 The Group was satisfied with this response. 
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ANNEX 4 

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I:\MEPC\60\2-16.doc 

Question 2 Further to my last email, could you also ask Hyundai why, in table 7.1, some of 

the R&S phrases associated with a given chemical appear to be either repeated or 

make other phrases redundant. 

 e.g., 1,1,2-Trichloroethane R20/21/22-40-66-39 

 R23/24/25-23/24/25-11 

 S9-36/37-46-45-16 

 In the above R23/24/25 overrules (replaces) R20/21/22 and is also repeated in the 

same line. 

Answer 2 I sincerely apologize to make confusion as you pointed out. There were some 

typographical errors in the DSCL (EEE) Hazard classification and have been 

corrected as follows: 

 R20/21/22-40-66-39 

 R39/23/24/25-23/24/25-11 

 S9-36/37-46-45-16 

 In the meantime, we received some advice from specialist in REACH that all 

related R&S phrases should be thoroughly described regardless of lower or higher 

rank. However, because the meaning of R23/24/25 is more severe than 

R20/21/22, as you mentioned, the classification R20/21/22 was deleted and other 

classification codes were checked again in the same manner. 

 For 1,1,2-Trichloroethane, you will find its corrected phrases in the enclosed file 

as follows: 

 R40-66-39/23/24/25-23/24/25-11, S9-36/37-46-45-16 

Reaction 2 The Group noted this response. 

Question 3 I am a little confused by some of the information related to the use of the 

MAMPEC model which I hope the applicant will be able to help me with. 

 There is a reference to “Leaching rates” for various chemicals in table 8.12. 

As I understand it, the leaching rates are only used to estimate the amount of 

chemical going into the water from antifouling paints and has no relevance for this 

particular exercise. 

 Would it be possible to have (In WFW) format, a copy of the two MAMPEC 

screens used to input the harbour and emission details along with an input screen 

for the chemical tribromomethane? 

 The input screen for the emissions input is particularly important to show the 

relationship between the ballast water concentration of chemical, the total ballast 

water output/day, and the resultant PEC. 
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ANNEX 4 

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I:\MEPC\60\2-16.doc 

If you could also add the total output of BW/day as used in these runs it would be 

appreciated. 

Answer 3 For the meaning of “leaching rates”, I absolutely agree with you. However, in our 

calculation using MAMPEC, the leaching rate was used to simulate rate of 

discharge. Of course, it is possible to input emission rate directly. However, we 

used pre-calculated leaching rates to obtain proper emission rates. Therefore, the 

result is exactly same. 

 With regarding to your request, window word format figures were attached, as 

follows: 

Figure 1 :. Screenshot of emission input menu for Tribromomethane on Day 1 
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ANNEX 4 

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Figure 2 : Screenshot of emission input menu for Tribromomethane on Day 5 

 The total discharge rate of ballast water used in MAMPEC simulation was estimated on 

the following basis. You can also find the calculation basis in page 83 and Table 8.3 of 

confidential dossier. 

 .1 in a certain ship, the discharge quantity of ballast water is proportional to 

loading quantity of ship; 

 .2 in a certain port, the sum of loading quantity of all ships is proportional to 

export tonnage; 

 .3 the ballast water capacity is proportional to the dead weight tonnage of the 

ship and it was assumed that the ballast water capacity is about 35% of 

DWT of the ship; 

 .4 in the case of Rotterdam, it was found that the export tonnage is 

about 108,295,000 ton/year. Therefore, with this assumption, the total 

ballast water quantity could be estimated as 103,844 m3

/day. The data 

source of outgoing loads of Rotterdam port is published data of Rotterdam 

Port Authority. 

Reaction 3 The Group was satisfied with this response. 
GESAMP-BWWG 12/6 

ANNEX 4 

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I:\MEPC\60\2-16.doc 

Question 4 I am guessing that the applicant used the detection limit for each chemical as the 

concentration in ballast water to input values into MAMPEC, 

e.g., 1,2,3-trichloropropane was not detected in the ballast water but the MDL 

was 0.01 μg/L. Is this correct? 

 What is the assumed daily TOTAL discharge of ballast water which will be 

multiplied by the above number to get the total daily output of that chemical? 

Answer 4 HHI used the MDL values, for chemicals which were not detected in small-scale 

tests, as an input value for MAMPEC simulation. In addition, as you mentioned 

above, the discharge rate can be calculated by the multiplication of the total ballast 

water discharge rate and the chemical concentration. 

Reaction 4 The Group was satisfied with this response and considered that compounds found 

in concentrations below the detection limits do not need to be subject to the 

MAMPEC Calculations.

Question 5 To be absolutely sure that I understand correctly, please could either confirm the 

following or provide the correct details used to run MAMPEC. 

 Discharge volume of water from the port = 103844 m^3/d. 

 Concentration of e.g., bromoform on day 1 (table 8.7) = 8.8 mg/m^3 

 Therefore the daily load of bromoform used to calculate the PEC of 2.05 mg/m^3 

= 8.8 x 103844/1000 = 91.027 g/d 

 Or, to put it another way, Can the day 1 values in table 8.7 be put next to the 

corresponding chemicals in table 8.13 to show the concentration in ballast water 

which provided a calculated PEC. 

Answer 5 We apologize for our mistake in the MAMPEC simulation. 

 After receiving your e-mail, we checked the results of MAMPEC modelling again 

and we found our mistake. As we had mentioned in the previous e-mail, we used 

the leaching rate to simulate emission rate in our calculation using MAMPEC. 

However, in the conversion of leaching rate, we made an error on the calculation 

of chemical concentration as shown in the following table. 
GESAMP-BWWG 12/6 

ANNEX 4 

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Example of Bromoform 

Description 

Bromoform 

concentration 

(μg/L) 

Discharge 

volume 

based on 91 

ships 

(m3

/day) 

Surface 

Area of a 

ship (m2

) 

Leaching rate 

based on 

single ship 

(μg/cm2/d) 

No. of 

ship Result (g/day) PEC (μg/L) 

Old 8.8 103,844 15,640 5.842885 91 83158.2752 2.05 

New* 8.8 103,844 - - - 913.8272* 0.0225 

Correction 8.8 103,844 15,640 0.064208** 91 913.8272 0.0225 

* Revised emission rate from MAMPEC simulation, which 

** Newly estimated leaching rate

 PEC values are overestimated 91 times as a result of double multiplication of ship 

numbers, 91. Consequently, we recalculated all the chemical concentration 

correctly and changed the results of MAMPEC simulation as follows: 

 .1 confidential and non-confidential document for IMO Basic Approval, 

Table 8.12/8.13/8.14/8.18; and 

 .2 appendix VII, Environmental risk assessment report, Table 5.6/5.7/5.8/7.1. 

Figure 1 : Input form of old calculation to estimated emission rate of Bromoform on Day 1 
GESAMP-BWWG 12/6 

ANNEX 4 

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Figure 2 : Input form of revised calculation to estimated emission rate of Bromoform on Day 1 

Reaction 5 The Group was satisfied with this response. 

Question 6 In your application, reference is made to hydrogen and chlorine gases being 

created and removed by either venting to atmosphere or discharged using a water 

eductor. 

 Please could you indicate the levels of gases being produced and are there any 

monitors to detect the levels of gases being produced. If the levels reach a 

dangerous concentration, are there any safeguards in place? 

Answer 6 In our application, hydrogen gas generated from the electrolyzer could be vented 

by either via a conventional venting system or the newly proposed (data deemed 

to be confidential and removed at the request of the submitting Administration) 

venting system. It is needless to say that safety is the minimum requirement the 

system which shall be met, in both cases. 

 Some safety functions were prepared and the validity of safety functions will be 

verified during land-based type approval test to ensure safety level of HiBallast 

system. Please refer to the attachment to find the details of the safety functions 

and level of gases. 
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.1 Level of gases being produced 

 As mentioned in our application, the level hydrogen gas, which was produced in 

electrolysis, is about 90%. For more detailed data, please refer to Table 4.1 in document 

of proposal. 

Unfortunately, there is no evidence to show that the level is either safe or not, because 

there are no available data about safe composition of hydrogen gas mixture with various 

gases such as oxygen, nitrogen, chlorine and water vapour. According to the literature, a 

mixture of hydrogen and air and a mixture of hydrogen and pure oxygen, have explosion 

ranges between 3.5 and 95.8% v/v of hydrogen as shown in Table 1. [1] 

Therefore, the levels of hydrogen above 95.8% and under 3.5% are safe regardless of 

other gas compositions, temperature, and ignition source. 

In the case of using an eductor venting system, the gas compositions of the gas separator 

should be in the range above upper explosion level (hereafter referred as “UEL”). 

Besides, in the case of using a blower or fan venting system, the gas produced will be 

vented with air dilution to maintain a gas composition under the lower explosion level. 

Of course, the conventional gas venting system is good and HHI will adopt this system 

selectively. However, as mentioned in proposal, the merit of the eductor venting system 

is short piping to minimize risk of hydrogen leakage. 

As we understood, the concern is whether the produced gas mixture is safe or not. In our 

view, the gas produced from electrolysis is a mixture of nitrogen, oxygen, chlorine, water, 

and hydrogen. HHI believe that hydrogen is predominant and the content is above the 

UEL. To provide background data, HHI will measure the composition of hydrogen 

during land-based type approval tests and submit the precise levels of hydrogen and other 

gas compositions to determine whether the gas produced by the HiBallast system is safe 

Table 1 : Flammable concentration range in various gases. [1] 

.2 Monitors to detect the level of gases being produced 

 In our original design concept, the head-space of the gas separator will be maintained 

above atmospheric pressure and so there is no air inflow into gas separator. So, if the gas 

composition in the head space gas is verified as being in the safe range under normal 

operating conditions, there is no possibility of explosion in the head-space. Therefore, 

monitoring of gas content in the head-space is not considered necessary and the pressure 

in the head-space will be monitored instead. 
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ANNEX 4 

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I:\MEPC\60\2-16.doc 

 However, the hydrogen concentration will be monitored both at the outside of separator 

and the inside of the cofferdam. 

 In addition, if the gas content in gas separator changes due to modifications in operating 

conditions, monitoring of gas content inside head-space of gas separator can be 

considered and adopted as a part of the modified design. 

.3 Safeguards 

 As a safety function, the system and electrolysis unit will be shutdown when hydrogen 

gas is detected outside of the gas separator or inside of the cofferdam. Our design 

philosophy incorporates this safety function which is critical in ensuring that the system 

remains in a safe condition. Additionally, to minimize risk of explosion, the separator 

will be maintained with minimum volume of head-space during operation and shutdown. 

 For more detail information, please refer to appendix VI, system description part. 

 Reference: [1] Bjerketvedt, Dag et al, “Gas Explosion Handbook”, Journal of 

Hazardous Materials 52 (1997) pp 1-50

Reaction 6 The Group noted this response. 

4.2 The following questions were put to the applicant during the meeting: 

Question 1 Are there any results for chronic toxicity testing? 

 If your answer is negative, could you clarify the reasons for this omission? 

 In this context, we would like to emphasize that it is stated, in the confidential 

version, in paragraph 8.2.4: 

 “The chronic toxicity test and the risk characterization for the seawater treated 

from “HiBallast” are required to estimate the potential risk for aquatic 

ecosystem.” 

Response 1 We did not perform the chronic toxicity test. 

 Completion of chronic toxicity tests takes about 28 days for zooplankton, although 

the test duration varies with experimental taxa (e.g., algae, invertebrates and fish). 

The basis of the chronic toxicity test duration with aquatic organisms is given in 

annexes 1, 2 and 3 and is referenced to the OECD guidelines 201, 211 and 212. 

 We already recognized the importance of chronic toxicity tests for the aquatic 

ecosystem. However, we will carry out the chronic toxicity test in the land-based 

test through intensive preparation.

Reaction 1 The Group was satisfied with this response. 
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Question 2 At the QAPP for “HHI BWMS” and test report of chemical analysis, there is no 

description of the analytical method for FRO. Could you provide details of the 

analytical method used for FRO and provide the distinguishing definition between 

TRO and FRO in your report? 

Response 2 The test method used for FRO measurement is “Standard methods for Drinking 

Water” which is published by Ministry of Environment, Korea. Unfortunately, 

this standard method is described Korean in Annex 6. 

Reaction 2 The Group was satisfied with this response. 

Question 3 In the Table 2.4 of your confidential version report, it is noted that the 

measurement of TRO was performed the by US EPA’s titration method. Is there a 

difference between TRO values manually measured and those measured by the 

TRO sensor? 

Response 3 In case of “ATI Q45H-79-1/USA” TRO sensor, we could not found the difference 

between TRO values of EPA method and those of TRO sensor. We will also use 

this TRO sensor during land-based test. EPA test method is attached in Annex 7. 

Reaction 3 The Group noted this response. 

Question 4 At test Nos. 1-1 and 1-2, how much equivalent of sodium thiosulphate was added 

against each TRO for the two salinity test waters? Which TRO values were used 

to estimate the demands of the neutralizer (sodium thiosulphate) i.e. were the TRO 

values measured manually or by the TRO sensor? 

Response 4 As we mentioned in the dossier, sodium thiosulfate was added at about 1.3 and 1.7 

times of equivalent for ballast water. Of course, these figures reflect the results of 

lab-scale test. The TRO was measured manually using US EPA’s titration 

method. 

 However, we are considering appropriate fine tuning on addition of the 

neutralization agent during the land-based test of ‘Hiballast’ for the Final 

Approval. Also, we will collect all data from different operational conditions 

during land-based tests and sea trials. 

Reaction 4 The Group noted this response. 

Question 5 It is noted that it took almost one month before the chemical analysis was 

completed i.e. sampling for ballasting was started on 25th Feb 2009 and the 

chemical analyses were finished on 20th Mar 2009. What was the actual date for 

the measurement for the TRO and other volatile compounds for samples 

S33T1D0, S33T3D5 and S33T3D5N? 

Response 5 Please refer to the appendix , Page 29, “Figure 4 Flow chart of sample custody”, 

and, administration procedures for testing which are briefly described in the 

following flow chart. 
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ANNEX 4 

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 According to the test laboratory (Korea Testing & Research Institute, KTR), all 

samples taken from lab-scale test were measured on that day. 

Receipt

Sampling

Sample transfer

(Site → KTR)

Testing

Input of data

Identification of test report

Issue of test report

“D” day

“D-n” day

“D+0” day

“D+0” or

“D+20” day

10 days

Receipt

Sampling

Sample transfer

(Site → KTR)

Testing

Input of data

Identification of test report

Issue of test report

“D” day

“D-n” day

“D+0” day

“D+0” or

“D+20” day

10 days

Reaction 5 The Group was satisfied with this response. 

Question 6 The Group noted that the starting date for the all acute toxicity testing was one 

day after the sampling date reported in the aquatic toxicity test report. The Group 

understands that the TRO had been already neutralized before sampling so that 

degradation of TRO during this one day is irrelevant. However, the Group 

consideres that there is still a possibility that volatile organic compounds, such as 

THMs, could be reduced during this period. This potential error may significantly 

underestimate the total toxicity. 

 How were the samples kept during this period; was chemical analysis undertaken 

before and after this period and, if so, can you provide the results. 

Response 6 At that time, the temperature of samples was too cold (data deemed to be 

confidential and removed at the request of the submitting Administration) to 

perform the test. Therefore, the temperature of samples was increased gradually 

during a day based on EPA 821-R-02-013 (see, Annex 4), and the test was 

initiated on the next day. 

 Custody of test substance was based on Short-term Methods for Estimating the 

Chronic Toxicity of Effluents and Receiving Waters of Freshwater Organisms, 4th 

Edition, EPA 821-R-02-013 (see, annex 4). Therefore, the test substance was kept 

in a constant temperature room at 4. 
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Measured water quality (pH, DO, Temperature, etc.) for acute toxicity test with 

aquatic organisms (algae, invertebrate and fish) was given in the final report, and 

the results indicated in annex 5 are shown again in here. 

Reaction 6 The Group was satisfied with this response. 

Question 7 It is noted that the neutralization will be done according to the concentration of 

TRO during the discharge of the treated water. How was this measured? How do 

you ensure that the TRO levels never exceed 0.2 mg/l TRO? 

Response 7 TRO measurement of lab-scale test was performed under batch type. The 

concentration of TRO was measured by US EPA’s titration method. 

 The ‘HiBallast’ system includes the neutralization unit to remove the TRO. As 

shown in the chemical analysis result of the lab-scale test, the TRO is completely 

removed after the addition of neutralizing agent in the de-ballasting process. In 

addition, because the ‘HiBallast’ system has a control system to correct and 

monitor (data deemed to be confidential and removed at the request of the 

submitting Administration) we do anticipate that the TRO levels to be discharged 

never exceed 0.2 mg/l TRO. 

Reaction 7 The Group was satisfied with this response. 

Question 8 It is noted that the operating temperature range of the system is 

between 15 and 33o

C? What is the reason for this limitation and how will the 

system perform under higher or lower water temperatures? 

Response 8 The operating temperature range is between 15 and 33°C which is a normal 

condition with a conservative viewpoint. We believe that the ‘HiBallast’ system 

has a capability of acting in the range of 10 and 40°C. However, this worst case 

brings increase of power consumption. 

Reaction 8 The Group noted the limitation associated with this system. 

Question 9 ‘From appendix 2, summary of chemical analysis at Feb 25th 2009: 

 .1 Are there any analytical data for other chemicals in both salinities of 

treated water at ‘5 days before neutralization’; 

 .2 It is noted that the generation and degradation of the bromate ion is 

completely different in the testing of marine and brackish water. Is there a 

scientific explanation for this? 

Response 9 .1 As neutralization is a compulsory process in the ‘HiBallast’ system during 

the de-ballasting, we paid no attention to analysis of the chemicals in both 

salinities of treated water at ‘5 days before neutralization’. 
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.2 We think that there is no scientific causal relationship in bromate 

concentrations between tested seawater and brackish water. We will 

verify this phenomenon during land-based test in detail. 

Reaction 9 The Group noted this response. 

5 WHOLE EFFLUENT TESTING (WET)

5.1 Acute ecotoxicity tests 

5.1.1 The Group noted that the applicant had carried out acute eco-toxicity tests on treated 

ballast water with the results shown in the tables below: 

Acute aquatic toxicity of 33 PSU ballast water treated by “HiBallast” 

LC50 and/or EC50 Species End point Conc.(%) Reference/Comments 

Algae Skeletonema costatum 72 h EC50 69.30 OECD 201 

Crustacean Tigriopus japonicus 48 h EC50 

48 h LC50 

>100 

>100 OECD 202 

Fish Paralichthys olivaceus 96 h LC50 >100 OECD 203 

Acute aquatic toxicity of 20 PSU ballast water treated by “HiBallast” 

LC50 and/or EC 50 Species End point Conc.(%) Reference/Comments 

Algae Skeletonema costatum 72 h EC50 63.01 OECD 201 

Crustacean Tigriopus japonicus 48 h EC50 

LC50 48 h

>100

>100 OECD 202 

Fish Paralichthys olivaceus 96 h LC50 >100 OECD 203 

5.1.2 The Group noted that simulated ballast water was used in the laboratory-scale tests. The 

ballast water samples were prepared with five days holding time and then neutralized with 

thiosulphate. The doses used were 1.3 and 1.7 times the stoichiometric equivalent for TRO 

concentrations which were measured manually. The Group also noted that, before starting the 

exposure, a one day preparation period was needed to harmonize the temperature of the ballast 

water with that of the control water before the organisms could be tested. 

5.1.3 From these results, the Group noted that, whilst the “HiBallast” system had an acute toxic 

effect on the growth of the diatom, Skeletonema costatum, other organisms were not affected by 

the same treated water. 

5.1.4 The Group was generally satisfied with QA/QC for these tests. However, it was noted 

that the acute toxicity was higher than that expected from the reported concentration of TRO and 

other by-products after neutralization. The Group invited the applicant to check this apparent 

anomaly which could have been caused by a high POC in the original G8 test water. If the 

applicant ascertains that the high POC was the cause of this anomaly, then a modification of the 

testing procedure, such as pre-filtering process before exposure would be acceptable. 
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5.2 Chronic ecotoxicity tests 

5.2.1 The Group noted that the chronic toxicity tests were not performed in this application for 

Basic Approval. It was also noted that the applicant had recognized the need for chronic toxicity 

testing and further risk characterization according to the results of acute toxicity tests above. 

5.2.2 The Group emphasized that Procedure (G9) clearly requires both acute and chronic 

ecotoxicity testing for Basic Approval. The Group recalled that it had, previously, made a case 

for waiving the chronic toxicity testing for some BWMS applications for Final Approval 

providing the chemical analysis demonstrated that the concentrations of chemical by-products are 

similar to those provided in the application for Basic Approval. 

5.2.3 However, in this case, the Group recommended that, for Final Approval, in addition to the 

required acute toxicity test results, chronic toxicity test results, carried out in accordance with 

Procedure (G9), should also be provided as these were missing in the application for Basic 

Approval, because the analogy with earlier systems are not valid in this case. 

6 HUMAN HEALTH ASSESSMENT

6.1 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 severely corrosive to skin at concentrations >5%; 

 .2 Trihalomethanes and in particular bromoform are: 

 .1 toxic by inhalation, if swallowed and in contact with skin; 

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

 .3 may cause cancer. 

 .3 Other halogenated aliphatic and aromatic compounds

 .1 toxic by inhalation, if swallowed and in contact with skin; 

 .2 may cause cancer; and 

 .3 may be reprotoxic. 

 .4 halogenated acetonitriles

 .1 harmful by inhalation, if swallowed and in contact with skin; and 

 .2 irritating to skin, eyes and the respiratory system 

 .5 halogenated acetic acids 

 .1 corrosive or irritant depending on concentration; 

 .2 toxic by all routes of exposure; and 

 .3 may be carcinogenic. 
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 .6 halogenated phenols 

 .1 harmful if swallowed; and 

 .2 irritating to skin and eyes. 

 .7 sodium thiosulphate 

 .1 irritating to skin eyes and respiratory system. 

7 RISKS TO THE SAFETY OF THE SHIP, THE CREW AND THE GENERAL 

PUBLIC

7.1 Corrosion 

7.1.1 The Group noted that the applicant had not carried out any corrosivity testing at this stage 

but had indicated that long-term corrosivity testing would be carried out during land-based tests 

in accordance with IMO Performance Standard for Protective Coating (PSPC) guideline. 

7.1.2 The Group recommended that the applicant follow the recommendations for corrosion 

testing as referred to in paragraph 5.1 of the eighth session of the Ballast Water Working Group 

report (MEPC 59/2/16). 

7.2 Explosion and/or fire

7.2.1 The Group noted that both chlorine gas and hydrogen gas are produced as a by-product of 

hydrolysis. These gases are to be vented to atmosphere or discharged using a water eductor. 

7.2.2 The Group noted that a gas separator is included in the system following electrolysis and 

that the gases collected are either to be diluted with forced air and vented to the open deck or 

discharged overboard using a water eductor. In the case of gases being vented to the open deck, 

forced air dilution is to be arranged to ensure that the hydrogen content of the vented air/gas 

mixture remains below 1% by volume, and that the outflow is monitored so that automatic shut 

down will occur if the hydrogen content increases towards the lower explosive limit. In the case 

of discharge of the produced gases by water eductor, the gases are to be discharged directly 

overboard with the water stream powering the eductor. A hydrogen monitor is also to be 

installed in the space that will initiate shut down if hydrogen leakage from the enclosed system 

occurs. 

7.2.3 The Group noted that the applicant intends to utilise the main ballast water overboard 

connection for the discharge of hydrogen gas when a water eductor system is used for this 

purpose. The Group considered that, if the overboard connection is above the ships waterline, 

there is a potential for hydrogen gas to accumulate in the immediate vicinity of the overboard 

connection to such an extent that it might be within the explosive range. As a result, the Group 

recommended that this arrangement is only used when the overboard discharge remains below 

the waterline at all times. 

7.2.4 The Group agreed that the safety precautions to be put in place with this system would be 

adequate to reduce the risks of explosion and/or fire due to the production of hydrogen to an 

acceptable level provided the above concern is taken into account. 
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7.3 Human Exposure to chemicals 

7.3.1 The Group noted that the applicant had identified the various hazards, attributed to the 

chemicals associated with this system, by using the Hazard Identification index (HAZID study) 

and had described various measures to either reduce the likelihood of exposure or to be taken in 

the event of exposure. 

7.3.2 Such measures included: 

 .1 the use of non-corrosive materials, where appropriate, to reduce the risk of 

leakage caused by damage to materials of construction; 

 .2 taping of all joints where leakage may occur; 

 .3 proper training of crew; 

 .4 provision of appropriate safety equipment; and 

 .5 advice on actions to be taken in the event of exposure. 

7.3.3 The Group agreed that such measures when put in place should be adequate to reduce the 

risks to the crew associated with such chemicals. 

7.3.4 In addition, the applicant identified the need to develop “hazardous exposure scenarios” 

(App. V, Book IV, confidential dossier) related to some operational units which were considered 

relevant for crew exposure assessment. These included the potential failure of the electrolyzer 

enclosure leading to a leakage of the disinfection solution (<2000 mg/L) from the electrolyzer, 

the disinfectant supply or the inlet pipe. 

7.3.5 The Group agreed that the main potential risks to the crew would be from: 

 .1 exposure to high concentration disinfectant through leakage; and 

 .2 exposure to the neutralizing agent when mixing sodium thiosulphate powder. 

7.3.6 The Group considered that all relevant information and the quantification of the risks 

associated to these specific scenarios should be provided, by the applicant, for Final Approval 

according to principles of Human Exposure Assessment (MEPC 56/2/2, annex 9). 

7.3.7 The Group considered that the risks to the General Public (swimming and eating fish 

from the coastal area) as a result of effluent discharge of treated ballast water had, also, to be 

addressed by the applicant and information to be provided at the Final Approval stage. 

7.3.8 The Group noted the importance placed on the selection of appropriate materials and 

construction joint details for the parts of this system that may be exposed to the high 

concentrations of oxides formed during electrolysis which remain until diluted by injection into 

the ballast water main piping. It is recommended that such material and construction details are 

included in the operating manual so as to ensure correct repair in the event of failure being 

experienced in this part of the system. 
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7.3.9 The Group noted that the applicant was using sodium thiosulphate as the TRO neutralizer 

for the purposes of applying for Basic Approval. It is recommended that detailed procedures 

appropriate to the use of this chemical should be clearly identified and included in the operating 

manual for handling, system top-up and emergency actions in the event of spillage together with 

identification of the appropriate materials for the construction of the storage tanks and filling and 

supply piping. 

7.3.10 The Group agreed that such mitigation measures should be adequate to reduce the risks 

associated with such chemicals to an acceptable level and all such measures should be clearly 

identified and included in the ballast water treatment system operating manual. 

8 ENVIRONMENTAL RISK ASSESSMENT

8.1 Calculation of Predicted Environmental Concentrations (PEC) 

8.1.1 The Group noted that the applicant had employed the MAMPEC model to estimate 

the PECs of the various chemical by-products generated by this system. 

8.1.2 The applicant had used the default commercial harbour using statistical data for the Port 

of Rotterdam to predict total daily discharge of ballast water and chemicals with which it is 

associated. 

8.1.3 The Group noted the results of this exercise as shown in the table below: 

Chemical BW Conc 

(μg/L) 

Max PEC 

(μg/L) 

1,2,3-Trichloropropane 0.01 2.20E-03 

Dibromochloromethane 0.75/6.96 3.98E-01 

Dibromomethane 3.37/0.73 3.00E-01 

Dichlorobromomethane 0.15/0.51 5.39E-02 

Dichloromethane 0.16/1.57 1.03E-01 

trans-1,2-dichloroethene 0.01 1.29E-03 

Trichloromethane 0.2/0.1 3.14E-02 

Tribromomethane 0.25/1.1 2.05E+00 

Trichloroacetonitrile 0.02 5.73E-03 

Dichloroacetonitrile 0.04/0.14 1.96E-02 

Dibromoacetonitrile 0.01/0.32 5.72E-03 

Chloral hydrate 0.02/0.01 1.16E-02 

2-monochloroacetic acid 0.04 2.33E-02 

2,2-dichloroacetic acid 0.01 5.82E-03 

2,2,2-trichloroacetic acid 0.01 5.81E-03 

2-monobromoacetic acid 5.66/6.35 1.36E+00 

2,2-dibromoacetic acid 55.1/32 7.27E+00 

2,2,2-tribromoacetic acid 14.9/13.8 5.82E-03 

2,2-bromochloroacetic acid 0.01 5.82E-03 

Bromate ion (Sodium bromate) 26.6/32.1 1.50E+01 

8.1.4 The Group agreed with the calculation results achieved by the applicant using the 

model MAMPEC. 
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8.2 Calculation of PEC/PNEC ratios

8.2.1 The Group noted the calculated PEC/PNEC ratios as shown in the table below: 

Chemical compounds Available data Assessment 

Factor 

End 

point 

(mg/L) 

PNEC 

(μg/L) 

PEC 

(μg/L) PEC/PNEC

1,2,3-Trichloropropane Daphnia magna 

(Crustacea/acute/LC50/48hrs) 1000 20 20 0.0022 0.0001 

Dibromochloromethane Selenastrum capricornutum 

(Algae/acute/EC50/72hrs) 1000 9.6 9.6 0.398 0.04 

Dibromomethane NA - NA - 0.3 - 

Dichlorobromomethane Selenastrum capricornutum 

(Algae/acute /EC50/72hrs) 1000 12 12 0.054 0.005 

Dichloromethane Oryzias latipes 

(Fish/chronic/NOEC) 1000 75 75 0.103 0.001 

trans-1,2-

dichloroethene 

Daphnia magna 

(Crustacea/acute/LC50/24hrs) 1000 110 110 0.00129 0.00001 

Trichlorimethane Ceriodaphnia dubia 

(Crustacea /chronic/NOEC) 1000 3.4 3.4 0.0314 0.00009 

Tribromomethane Brevoortia tyrannus 

(Fish/acute/LC50/96hrs) 1000 9 9 2.05 0.22 

Trichloroacetonitrile Daphnia magna 

(Crustacea/acute/EC50/48hrs) 1000 0.044 0.044 0.00573 

Dichloroacetonitrile NA - NA - 0.0196 - 

Dibromoacetonitrile Pimephales promelas 

(Fish/acute/LC50/96hrs) 1000 0.55 0.55 0.00573 0.01 

Chloral hydrate Daphnia magna 

(Crustacea/acute/EC50/48hrs) 1000 500 500 0.0116 0.00002 

2-monochloroacetic 

acid 

Brachydanio rerio 

(Fish/ chronic/NOEC) 1000 25 25 0.0233 0.0009 

2,2-dichloroacetic acid Nitocra spinipes 

(Crustacea/acute/LC50/96hrs) 1000 21 21 0.00582 0.0003 

2,2,2-trichloroacetic 

acid 

Salmo gairdneri 

(Oncorhynchus mykiss) 

(Fish/acute/LC50/96hrs) 

1000 1050 1050 0.00581 0.000006 

2-monobromoacetic 

acid 

Daphnia magna 

(Crustacea/Chronic/NOEC) 1000 16 16 1.36 0.09 

2,2-dibromoacetic acid Pimephales promelas 

(Fish/acute/LC50/96hrs) 1000 69 69 7.27 0.1 

2,2,2-tribromoacetic 

acid NA - NA - 0.00582 - 

2,2-bromochloroacetic 

acid NA - NA - 0.00582 - 

Sodium bromate Bass prolarvae 

(Fish/acute/LC50/96hrs) 1000 30.8 30.8 15 0.5 
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8.3 Assessment of Persistence (P), Bioaccumulation (B) and Toxicity (T)

8.3.1 The Group noted the assessment of PBT criteria associated with the various chemical 

by-products associated with this system as shown in the table below: 

Chemical 

P*1)

(Yes/No) 

 (Half-life, days) 

B*2)

(Yes/No) 

(BCF: l/kg wet-wt) 

T*3)

(Yes/No) 

(NOEC) 

1,2,3-Trichloropropane No 

38 days in water 

No 

BCF: 5.3-13.0 NA 

Dibromochloromethane No 

38 days in water 

No 

BCF: 12.78 NA 

Dibromomethane No 

15 days in water 

No 

BCF: 3.23 NA 

Dichlorobromomethane No 

38 days in water 

No 

BCF: 10.01 NA 

Dichloromethane No 

38 days in water 

No 

BCF: 2.0-5.4 

No 

Fish:75mg/l 

trans-1,2-dichloroethene No 

38 days in water 

No 

BCF: 12.92 NA 

Trichloromethane No 

38 days in water 

No 

BCF: 1.4-4.7 

No 

Crustracean:15mg/l 

Tribromomethane No 

38 days in water 

No 

BCF: 7.1-21.2 NA 

Trichloroacetonitrile Yes 

60 days in water 

No 

BCF: 12.66 NA 

Dichloroacetonitrile No 

38 days in water 

No 

BCF: 3.0 NA 

Dibromoacetonitrile No 

38 days in water 

No 

BCF: 1.09 NA 

Chloral hydrate No 

38 days in water 

No 

BCF: 1.63 NA 

Chloropicrin Yes 

60 days in water 

No 

BCF: 11.95 NA 

2-monochloroacetic acid No 

15 days in water 

No 

BCF: 1.04 

No 

Fish:12.5mg/l 

2,2-dichloroacetic acid No 

15 days in water 

No 

BCF: 1.68 NA 

2,2,2-trichloroacetic acid No 

38 days in water 

No 

BCF: 0.4-1.0 

No 

Algal: 0.01 

2-monobromoacetic acid No 

8.7 days in water 

No 

BCF: 1.1 NA 

2,2-dibromoacetic acid No 

15 days in water 

No 

BCF: 1.29 NA 

2,2,2-tribromoacetic acid No 

15 days in water 

No 

BCF: 5.19 NA 

2,2-bromochloroacetic acid No 

15 days in water 

No 

BCF: 1.24 NA 

*1) Cited from http://www.pbtprofiler.net *2) Refer to Table 5.4 

*3) Refer to Table 5.2 NA: No Available Data 
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8.4 Interpretation of the results

8.4.1 The Group agreed that: 

 .1 the PEC/PNEC ratios for all of the potential chemical by-products 

indicated that there would be no unacceptable risk to the marine 

environment; 

 .2 none of the by-products met the PBT criteria which would have prevented 

the system for being used to treat ballast water; and 

 .3 whilst it was recognized that WET showed that treated ballast water 

showed some ecotoxicological effects, it was recognized that these would 

be diluted to an acceptable level. 

8.4.2 Based on the above observations, the Group agreed that the chemical by-products of this 

system should not pose any unacceptable risk to the marine environment in the quantities 

produced, if neutralization is carried out adequately in every ballast water discharge. 

9 CONCLUSIONS AND RECOMMENDATIONS 

9.1 Having considered all of the information provided by the applicant, the Group agreed 

that: 

 .1 although no corrosion testing results had been provided, the concentration of 

various chemicals in the treated ballast water should not cause undue concern with 

regard to further full-scale tests being carried out onboard; 

 .2 all relevant information and the quantification of the risks associated with 

exposure to the crew of high concentrations of disinfectants through leakage and 

to sodium thiosulphate when mixing, should be provided by the applicant for 

Final Approval according to principles of Human Exposure Assessment 

(MEPC 56/2/2, annex 9); 

 .3 the risks to the General Public (swimming and eating fish from the coastal area), 

as a result of exposure to the discharged treated ballast water, should be addressed 

by the applicant and information be provided in the application for Final 

Approval; 

 .4 the environmental risk assessment indicated that the system should not cause any 

unacceptable risk to the marine environment; 

 .5 with regard to the intention to discharge the back-flush effluent from the 

automatic ballast water filter (if fitted) through the ballast water system overboard 

connection, it was recommended that, where this arrangement is to be used, the 

possibility of contamination of the ballast water discharge line with untreated 

organisms and pathogens contained in the filter effluent should be fully 

considered and appropriate safeguards included in this part of the system to 

prevent such an situation occurring; 
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 .6 to recommend that consideration be given to incorporating a shut down feature in 

the treatment control system in the event of a neutralizing system failure, during 

discharge, to prevent the possibility of excess levels of TRO being discharged to 

the receiving water environment; 

 .7 the required chronic toxicity test results, in accordance with Procedure (G9), 

should be provided as it was missing in the application for Basic Approval; 

 .8 the TRO sensor sensitivity, reliability and its use in the neutralizer control should 

be confirmed as being appropriate to maintain the MADC of TRO; and 

 .9 the evaluation of a BWMS, by the Group, is dependent upon the specific results of 

the analytical testing performed. Such results are affected by the system 

configuration. The Group noted that the applicant had described different options 

in its application for Basic Approval, as described in section 2 of this annex 

including filter/no filter, different dose rates, different neutralizing chemicals, and 

recommended that any application for Final Approval include all results related to 

the configuration proposed. 

9.2 Notwithstanding the above comments, the Group agreed that the HiBallast BWMS should 

be recommended for Basic Approval. 

* * * 
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APPENDIX 

SUMMARY OF KEY DATA FOR CHEMICALS ASSOCIATED 

WITH THE HIBALLAST SYSTEM 

1 AQUATIC TOXICITY 

1.1 Acute aquatic toxicity 

Substances 

F 

C 

A*

Species End point L(E)C50

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

Active Substances

Sodium hypochlorite F Oncorhynchus kisutch LC50/96hrs/ 

Marine 0.026-0.038 - IUCLID dataset, 2000 

 C Daphnia magna EC50/96hrs 2.1 - IUCLID 

dataset, 2000 

 A Thalassiosira guilardii EC50/24hrs 0.075 - IUCLID 

dataset, 2000 

Monochloramine F Oncorhynchus clarki LC50/96hrs 0.074-0.094 - PAN 

Pesticide DB 

 C Ceriodaphnia dubia LC50/24hrs 0.016-0.02 - PAN 

Pesticide DB 

 A NA NA - - - 

Relevant Chemicals

Sodium bromate F Bass prolarvae LC50/96hrs 30.8 - HSDB,2009 

 C Crassostrea 

gigas(mollusc) EC50/24hrs/SW 170 - ECOTOX DB

 A Skeletonema costatum -/7days/SW 0.125- >16 - ECOTOX DB

1,1,2-trichloroethane F Pleuronectes platessa LC50/96hrs/ 

Marine 55 - IUCLID dataset, 2000 

 C Eliminius modestus LC50/48hrs 7.5 - IUCLID 

dataset, 2000 

 A Phaeodactylum 

tricornutum EC50/96hrs 60 - IUCLID dataset, 2000 

1,1,2,2-

Tetrachloroethane F Lepomis macrochirus LC50/96hrs/SW 13 - ECOTOX 

DB 

 C Americamysis bahia LC50/96hrs/SW 9.02 - ECOTOX DB

 A Skeletonema costatum EC50/96hrs/FW 6.44 - ECOTOX DB

1,2,3-

Trichlorobenzene F Oryzias latipes LC50/96hrs 

NOEC/14days 3.2 0.32 NITE web 

site 

 C Daphnia magna EC50/48hrs 

NOEC/21days 0.46 0.17 NITE web 

site 

 A Selenastrum 

capricornutum 

EC50/72hrs/ 

NOEC/72hrs 1.6 0.23 NITE web 

site 

1,2,3-

trichloropropane F Lepomis macrochirus LC50/96hrs/FW 

NOEC/96hrs 75 10 IUCLID 

dataset, 2000 

 C Daphnia magna LC50/48hrs 

NOEC/48hrs 20 5.6 IUCLID 

dataset, 2000 

 A Phaeodactylum 

tricornutum EC50/7days 34 - IUCLID 

dataset, 2000 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 28 

I:\MEPC\60\2-16.doc 

Substances 

F 

C 

A*

Species End point L(E)C50

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

1,2,4-

Trichlorobenzene F Jordanella floridae LC50/96hrs/FW 1.217 - IUCLID 

dataset, 2000 

 C Daphnia magna EC50/48hrs 

NOEC/0.1days 1.4 0.79 NITE web 

site 

 A Selenastrum 

capricornutum EC50/72hrs 5.7 - NITE web 

site 

2-Chlorotoluene F Salmo gairdneri LC50/96hrs/FW 2.3 - IUCLID 

dataset, 2000 

 C Daphnia magna EC50/48hrs 

NOEC/21days 0.7 0.31 NITE web 

site 

 A Selenastrum 

capricornutum 

EC50/72hrs 

NOEC/72hrs 7.8 2.6 NITE web 

site 

4-Chlorotoluene F Oryzias latipes LC50/96hrs 6.1 - NITE web 

site 

 C Daphnia magna EC50/48hrs 

NOEC/21days 2.0 0.32 NITE web 

site 

 A Selenastrum 

capricornutum EC50/72hrs 6.1 - NITE web 

site 

Bromobenzene F Pimephales promelas LC50/96hrs/FW 5.6 - ECOTOX DB

 C Daphnia magna EC50/24hrs 1.6 - ECOTOX DB

 A NA NA - - - 

Bromochloromethane F Cyprinus carpio LC50/3-

5day/FW 61-95 - ECOTOX DB

 C NA NA - - - 

 A NA NA - - - 

Chlorobenzene F Lepomis macrochirus LC50/96hrs/FW 4.5 - IUCLID 

dataset, 2000 

 C Daphnia magna EC50/48hrs 

NOEC/48hrs 19.9 6.25 IUCLID 

dataset, 2000 

 A Selenastrum 

capricornutum LC50/96hrs 12.5 - IUCLID 

dataset, 2000 

Cis-1,2-

dichloroethene F Oryzias latipes LC50/67/96hrs/ 67 - NITE web 

site 

 C Daphnia magna EC50/40/48hrs/ 40 - NITE web 

site 

 A Daphnia magna EC50/21days 

NOEC/21days 17 4.5 NITE web 

site 

Dibromochloromethane F Oryzias latipes LC50/96hrs 

NOEC/21days 79 3.2 NITE website

 C Daphnia magna EC50/48hrs 27 - NITE web 

site 

 A Selenastrum 

capricornutum 

EC50/72hrs 

NOEC/72hrs 9.6 4.5 NITE website

Dibromomethane F NA NA - - - 

 C NA NA - - - 

 A NA NA - - - 

Dichlorobromometane F Oryzias latipes LC50/96hrs 

NOEC/21days 28 0.78 NITE web 

site 

 C Daphnia magna EC50/48hrs 

NOEC/21days 29 0.79 NITE web site 

 A Selenastrum 

capricornutum EC50/72hrs 12 NITE web 

site 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 29 

I:\MEPC\60\2-16.doc 

Substances 

F 

C 

A*

Species End point L(E)C50

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

Dichloromethane F Pimephales promelas LC50/96 

hr/Fresh 177 IUCLID, 

2000 

 C Palaemonetes pugio LC50/48hrs 108.5 IUCLID, 

2000 

 A Skeletonema costatum EC50/-hrs >660 IUCLID, 

2000 

Tetrachloroethene F Oncorhynchus mykiss LC50/96hr/FW 4.99 IUCLID, 

2000 

 C Daphnia magna EC50/48hrs 7.49 IUCLID, 

2000 

 A Selenastrum 

capricornutum 

EC50/72hrs 

NOEC/72hrs 27 9.1 NITE web site 

Tetrachloromethane F Oryzias latipes LC50/96hrs 7.6 NITE web 

site 

 C Daphnia magna EC50/48hrs 

NOEC/21days 8.1 0.49 NITE web site 

 A Selenastrum 

capricornutum 

EC50/72hrs 

NOEC/72hrs 0.46 0.12 NITE web 

site 

trans-1,2-

dichloroethene 

(dichloroethene) 

F NA NA - - - 

 C Daphnia magna LC50/24hrs/FW <110 ECOTOX DB

 A NA NA - - - 

Trichloromethane 

(Chloroform) F Oncorhynchus mykiss LC50/96hrs 18 IUCLID, 2000 

 C Daphnia magna EC50/48hrs 29 IUCLID, 

2000 

 A Chlamydomonas 

reinhardii EC50/72hrs 13.3 IUCLID, 2000 

Tribromomethane F Brevoortia tyrannus LC50/96hrs 9-15 ECOTOX DB

 C Penaeus aztecus LC50/96hrs 20-33 ECOTOX DB

 A Skeletonema costatum LC50/96hrs 12.3 ECOTOX DB

Trichloroacetonitrile F Oryzias latipes LC50/96hrs 0.072 NITE web 

site 

 C Daphnia magna EC50/48hrs 0.044 NITE web 

site 

 A NA NA - - - 

Dichloroacetonitrile F NA NA - - - 

 C NA NA - - - 

 A NA NA - - - 

Bromochloroacetonitrile F NA NA - - - 

 C NA NA - - - 

 A NA NA - - - 

Dibromoacetonitrile F Pimephales promelas LC50/96hrs 0.55 ECOTOX 

DB 

 C NA NA - - - 

 A NA NA - - - 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 30 

I:\MEPC\60\2-16.doc 

Substances 

F 

C 

A*

Species End point L(E)C50

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

Chloral hydrate F Leuciscus idus melanotus LC50/48hrs/FW 1720 ECOTOX 

DB 

 C Daphnia magna EC50/48hrs/FW 500 ECOTOX 

DB 

 A Scenedesmus quadricauda LOEC/-/FW 2.8 ECOTOX 

DB 

Chloropicrin F Oncorhynchus mykiss LC50/96hrs/FW 0.014-0.019 ECOTOX 

DB 

 C Daphnia pulex EC50/ 

48hrs/FW 0.047-0.086 ECOTOX 

DB 

 A NA NA - - - 

2-monochloroacetic 

acid F Oryzias latipes LC50/96hrs 72 NITE web 

site 

 C Brachionus calciflorus LC50/48hrs 

NOEC/- 68.9 40 EURA RPT. 

 A Selenastrum 

capricornutum 

EC50/72hrs 

NOEC/72hrs 0.16 0.033 NITE web 

site 

2,2-dichloroacetic 

acid F NA NA - - - 

 C Nitocra spinipes LC50/96hrs 21-25 ECOTOX DB

 A NA NA - - - 

2,2,2-trichloroacetic 

acid F Salmo gairdneri LC50/96hrs 1050 IUCLID, 

2000 

 C Daphnia magna EC50/48hrs 2000 IUCLID, 

2000 

 A Chlorococcales EC10/24hr 1000 IUCLID, 

2000 

2-monobromoacetic 

acid F NA NA - - - 

 C Daphnia magna EC50/24hrs 65 ECOTOX DB

 A Scenedesmus subspicatus EC50/72hrs 0.2-1.4 ECOTOX DB

2,2-dibromoacetic 

acid F Pimephales promelas LC50/96hrs 69 ECOTOX DB

 C NA NA - - - 

 A NA NA - - - 

2,2,2-tribromoacetic 

acid F NA NA - - - 

 C NA NA - - - 

 A NA NA - - - 

2,2-

bromochloroacetic 

acid 

F NA NA - - - 

 C NA NA - - - 

 A NA NA - - - 

2,2,2-

bromodichloroacetic 

acid 

F NA NA - - - 

 C NA NA - - - 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 31 

I:\MEPC\60\2-16.doc 

Substances 

F 

C 

A*

Species End point L(E)C50

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

 A NA NA - - - 

Sodium thiosulfate F Notropis atherinoides LC50/5days/FW 2 IUCLID, 

2000 

 C NA NA - - - 

 A Ankistrodesmus falcatus LC50/1hr 64 IUCLID, 

2000 

* Note: F is Fish; C is Crustacean; and A is Algae. 

1.2 Chronic aquatic toxicity 

Substances 

F

C

A

Species End point L(E)C50 

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

Active Substances

Sodium hypochlorite F Oncorhynchus gorbuscha NOEC/23days - 0.042 PAN 

Pesticide DB 

 C Dreissena polymorpha LC50/295hrs 1.0 - IUCLID 

dataset, 2000 

 A NA NA - - - 

Relevant Chemicals

1,1,2-trichloroethane F Pleuronectes platessa LC50/56day 

NOEC/56days 5.5 3 IUCLID 

dataset, 2000 

 C Daphnia magna EC50/21days 

NOEC/21days 32 18 IUCLID 

dataset, 2000 

 A NA NA - - - 

1,1,2,2-

Tetrachloroethane F Jordanella floridae LOEC/10day - 7.23 ECOTOX DB

 C Daphnia magna LC50/28day 14 - HSDB,2005 

 A NA NA - - - 

1,2,4-

Trichlorobenzene F Pimephales promelas NOEC/32day/ 

FW - 0.5 IUCLID 

dataset, 2000 

 C Daphnia magna EC50/28day 0.36-0.6 - IUCLID 

dataset, 2000 

 A Green Algae EC50/96hr 

NOEC/96hr 24 5.6 PAN Pesticide DB 

2-Chlorotoluene F Pimephales promelas NOEC/30 day NA 2.9 Ichem,2001 

 C Daphnia magna NOEC/21day - 0.14 Ichem 

dataset,2001 

 A Scenedesmus subspicatus LC50/72h >60 - Ichem 

dataset, 2001 

Chlorobenzene F Oryzias latipes NOEC - 0.25 NITE 

web site 

 C Daphnia magna EC50/14days 2.5 - IUCLID 

dataset, 2000 

 A NA NA - - - 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 32 

I:\MEPC\60\2-16.doc 

Substances 

F

C

A

Species End point L(E)C50 

(mg/L) 

NOEC 

(mg/L) 

Reference

/ 

comments

Dichloromethane F Oryzias latipes LC50/21day 

NOEC 106 75 IUCLID dataset, 2000 

 C NA NA - - - 

 A NA NA - - - 

Tetrachloroethene F Oryzias latipes NOEC - 1.0 NITE 

web site 

 C Daphnia magna EC/28day 0.51 - IUCLID 

data -set,2000

 A NA NA - - - 

Trichloromethane 

(Chloroform) F Oncorhynchus mykiss LC50/648hrs/ FW 2.03 - IUCLID dataset, 2000 

 C Daphnia magna EC50/16day 

NOEC/16day 60 15 IUCLID dataset, 2000 

 A NA NA - - - 

Trichloroacetonitrile F Cyprinodon variegatus LC50/<20 days 7.1 - HSDB2009 

 C NA NA - - - 

 A NA NA - - - 

2-monochloroacetic 

acid F Brachydanio rerio NOEC/28days - 12.5 EURA RPT. 

 C Daphnia magna NOEC/21day 32 - EURA RPT. 

 A NA NA - - - 

2,2,2-trichloroacetic 

acid F Pimephales promelas LC50/96hrs 2000 - OECD-SIDS 

 C NA NA - - - 

 A Chlorella pyrenoidosa NOEC/14days - 0.01 OECD-SIDS 

Sodium thiosulfate F Oncorhynchus mykiss LC50/18month/

FW 600 - IUCLID dataset, 2000 

 C NA NA - - - 

 A NA NA - - - 

1.3 Endocrine disruption 

1.3.1 No reports on the endocrine disruption potential of Active Substances and Relevant 

Chemicals were found in the literature. Commonly, it was known that the chemicals such as 

Dichloro-diphenyl-trichloroethane (DDT), Polychlorinated biphenyls (PCB’s), Bisphenol A, 

Polybrominated diphenylethers (PBDEs), and a variety of Phthalates, etc. are classified as 

endocrine disruptors. However, no potential endocrine disrupting chemicals had been detected in 

the treated water. 

1.4 Sediment toxicity 

1.4.1 No report on the sediment toxicity, related to algae, crustacea and fish, for Active 

Substances and Relevant Chemicals were found in the literature. The sorption behaviour of 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 33 

I:\MEPC\60\2-16.doc 

substances in the sediment (soils or sludge) can be described through parameters of the 

adsorption coefficient (Koc), which is defined as the ratio between the concentration of the 

substance in the soil/sludge and the concentration of the substance in the aqueous phase at 

adsorption equilibrium. Therefore, the Koc value is a useful indicator of the binding capacity of a 

chemical on organic matter of the sediment and allows comparisons to be made between different 

chemicals. 

1.4.2 Most of Koc values for Active Substances and Relevant Chemicals are less than 500 l/kg. 

Therefore, these compounds are unlikely to have the sediment toxicity. The Koc 

of 1,2,3-Trichlorobenzene and 1,2,4-Trichlorobenzene are estimated as 1,383 l/kg 

and 1,356 l/kg, respectively. Because the octanol/water partition coefficients (Kow) are 

also more than 3, these chemicals may have effect on the sediment toxicity. Koc values 

for the Active Substances and Relevant Chemicals are summarized in the table. 

The Relevant Chemicals, 1,2,4-Trichlorobenzene and 1,2,3-Trichlorobenzene have Koc values 

larger than 500 l/kg, but these compounds were not detected in discharged water on day 5 in 

small-scale test. 

1.5 Bioavailability/biomagnification/bioconcentration 

1.5.1 The bioaccumulative potential of an organic chemical substance builds up in tissues of 

living organisms as a result of direct exposure to polluted water, air or soil, or through 

consumption of contaminated food. The log Kow value can be used as a screening tool to indicate 

a bioaccumulation potential, but only direct measurement of the BAF or BCF gives a reliable 

indication of a substance’s ability to bioaccumulate. 

1.5.2 Most of log Kow values for Active Substances and Relevant Chemicals are less than three 

except some chemicals. However, the BCF of these chemicals are less than the EU criteria to 

determine the PBT screening. Therefore, it is expected that the potential for the bioavailability, 

biomagnification and bioconcentration is unlikely to have an effect on the aquatic organisms. 

1.6 Food web/population effects 

1.6.1 Based on the Koc and BCF, it is anticipated that the potential for bioaccumulation in the 

food chain could be negligible because these factors do not exceed the BCF criteria. 

2 DATA ON MAMMALIAN TOXICITY 

2.1 General

2.1.1 The Group noted that mammalian toxicity data for the Active Substances and Relevant 

Chemicals had been obtained from literature sources such as Toxicology Data Network (ToxNet), 

the International Uniform Chemical Information Database (IUCLID), the EU Risk Assessment 

Report, and WHO guidelines for drinking water qualities, etc. The detailed mammalian toxicity 

data for the Active Substances and Relevant Chemicals are given in appendix 4 of Book IV of the 

confidential data supplied by the applicant. 

2.1.2 The Group noted the data related to mammalian toxicity for each chemical by-product, in 

appendix IV of book IV of the confidential dossier and summarised in the tables below: 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 34 

I:\MEPC\60\2-16.doc 

2.2 Acute mammalian toxicity 

Chemical Exposure 

route Species Value Reference 

Sodium hypochlorite 

1) Oral LD50 

2) Dermal LD0 

3) Inhalation LC50

1) Rat 

2) Rabbit 

3) Rat 

1) >5000 mg/kg 

2) >10000 mg/kg 

3) >10.5 mg/l 

IUCLID, 2000 

Monochloramine Oral Mice (male) NOAEL = 30 mg/kg/d WHO, 2004 

Sodium bromate 1) Oral LD50

2) Oral LD50

1) Rats, mice, 

hamsters 

2) Human 

1) 280 - 495 mg/kg 

2) Probable oral Lethal 

Dose 5-50mg/kg 

HSDB, 2009 

1,1,2-Trichloroethane 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC50 

1) Rats, mouse 

and 

dog 

2) Rabbit and 

Guinea pig 

3) Rat, mouse 

1) 100-1140 mg/kg 

2) 963-5377 mg/kg 

3) 2.3-9.02 (mg/l/6hrs) 

IUCLID, 2000 

1,1,2,2-Tetrachloroethane 

1) Oral LD50

2) Dermal LD50

3) Inhalation LD50

1) Rats 

2) Rabbits 

3) Rats 

1) 250 mg/kg 

2) 6360 mg/kg 

3) 8.6 (mg/l/4hrs) 

HSDB,2005 

1,2,3-Trichlorobenzene Oral LD50 Rats and mice 756 -766 mg/l HSDB,2004 

1,2,3-Trichloropropane 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC100

1) Rats 

2) Rabbits 

3) Rats 

1) 125-505 mg/kg 

2) 250-2457 mg/kg 

3) 697-2000 (mg/l/4hrs) 

IUCLID, 2000 

1,2,4-Trichlorobenzene 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC0

1) Rats 

2) Mice 

3) Rats 

1) 550-1107 mg/kg 

2) 300-305 mg/kg 

3) 418 (mg/l/4hrs) 

IUCLID, 2000 

2-Chlorotoluene 

1) Oral LD50

2) Dermal LD50

3) Inhalation LD50

1) Rats 

2) Rats 

3) Rats and mice 

1) 1659-5700 mg/kg 

2) > 1083 mg/kg 

3) > 20 (mg/l/1hr) 

IUCLID, 2000 

4-Chlorotoluene 

1) Oral LD50 

2) Dermal LD50 

3) Inhalation LD50

1) Rats 

2) Rabbits 

3) Rats 

1) 1920-3600 mg/kg 

2) > 2000 mg/kg 

3) 26.9 (mg/l/1hr) 

IUCLID , 2000 

Bromobenzene Oral LD50 Rats 2383-3629 mg/kg HSDB,2003 

Bromochloromethane 1) Oral LD50 

2) Inhalation LC50

1) Rats and mice 

2) Mice 

1) 4300-5000 mg/kg 

2) 3000 (mg/l/7hrs) HSDB,2005 

Chlorobenzene 

1) Oral LD50 

2) Dermal LD100 

3) Inhalation LC50

1) Rats 

2) Rats 

3) Rats and mice 

1) 1110-11100 mg/kg 

2) 2200 mg/kg 

3) 1886-2965 (mg/l/6hrs) 

IUCLID, 2000 

cis-1,2-dichloroethene Oral Rats NOAEL 97mg/kg/d ATSDR, 1996 

Dibromochloromethane 1) Oral LD50 

2) Oral LD50

1) Rats 

2) Mice 

1) 370-760 mg/kg 

2) 667-1524 mg/kg HSDB,2006 

Dibromomethane Inhalation LC50 Rats 40 (g/m3/2hrs) HSDB,2002 

Dichlorobromomethane 1) Oral LD50 

2) Oral LD50

1) Rats 

2) Mice 

1) 969-1388 mg/kg 

2) 1820 mg/kg HSDB,2009 

Dichloromethane 1) Oral LD50 

2) Inhalation LC50

1) Rats 

2) Mice 

1) 1410-2524 mg/kg 

2) 16200 (mg/l/8hrs) IUCLID, 2000 

Tetrachloroethene 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC50

1) Rats 

2) Rabbits 

3) Mice 

1) 250-8850 mg/kg 

2) 3245 mg/kg 

3) 20.2 (mg/l/6hrs) 

IUCLID, 2000 

Tetrachloromethane 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC50

1) Rats 

2) Guinea pig 

3) Mice 

1) 2350-6770 mg/kg 

2) 2100-8500 mg/kg 

3) 59.9 (mg/l/8hrs) 

IUCLID, 2000 

trans-1,2-dichloroethene 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC50

1) Rats and mice 

2) Rabbits 

3) Mice 

1) 2100-10000 mg/kg 

2) LOAEL 170mg/kg 

3) 21723 (mg/l/6hrs) 

ATSDR, 1996 

Trichloromethane 

1) Oral LD50

2) Dermal LD50

3) Inhalation LD50

1) Rats 

2) Rabbits 

3) Mice 

1) 908-2000 mg/kg 

2) 3980 mg/l 

3) 6.15 mg/l 

IUCLID, 2000 

Tribromomethane 1) Oral LD50

2) Oral LD50

1) Rats 

2) mice 

1) 933-1388 

2) 707-1550 ATSDR, 2005 

Trichloroacetonitrile N.A. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 35 

I:\MEPC\60\2-16.doc 

Chemical Exposure 

route Species Value Reference 

Dichloroacetonitrile 1) Oral LD50

2) Oral LD50

1) Mice 

2) Rats 

1) 270-279 mg/kg 

2) 330-339 mg/kg HSDB, 2009 

Bromochloroacetonitrile N.A. 

Dibromoacetonitrile 1) Oral LD50

2) Oral LD50

1) Mice 

2) Rats 

289-303 mg/kg 

245-361 mg/kg HSDB,2009 

Chloral hydrate 1) Oral LD50

2) Dermal LD50

1) Rats 

2) Rats 

1) 200-500 mg/kg 

2) 3030 mg/l HSDB,2009 

Chloropicrin 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC50

1) Rats 

2) Rats 

3) Rats 

1) 37.5-250 mg/kg 

2) 100 mg/kg 

3) 14.4 (mg/l/4hrs) 

HSDB,2009 

2-monochloroacetic acid 

1) Oral LD50

2) Dermal LD50

3) Inhalation LC50 

1) Rats 

2) Rabbits 

3) Rats 

1) 55 mg/kg 

2) 250 mg/kg 

3) 180 (mg/l/4hrs) 

EURA RPT. 

2,2-dichloroacetic acid 1) Oral LD50 

2) Dermal LD50

1) Rats and mice 

2) Rats 

1) 2,820- 5,520 mg/kg 

2) 795 mg/kg WHO, 2005 

2,2,2-trichloroacetic acid 1) Oral LD50 

2) Dermal LD50

1) Rats and mice 

2) Rats 

1) 3,320- 4,970 mg/kg 

3) >2,000 mg/kg WHO, 2004 

2-monobromoacetic acid Oral LD50 Rats 177 mg/kg WHO, 2004 

2,2-dibromoacetic acid Oral LD50 Rats 1737 mg/kg WHO, 2004 

2,2,2-tribromoacetic acid N.A. 

2,2-bromochloroacetic acid N.A. 

2,2,2-bromodichloroacetic 

acid N.A. 

Sodium thiosulphate Oral LD50 Rats >5,050 mg/kg PMEP 

2.3 Effects on skin and eye

Skin and eye effects 

Chemical Skin Eye Reference 

Sodium hypochlorite 

1) Rabbit: Irritation test, Severely 

irritant at 6.25% 

2) Guinea pig: FHSA method 

5.0-5.25% sol. FAC, Slightly irritant 

3) Human: Patch test 0.1-2% sol., 

Positive 

4) Rabbit: FHSA/Draize 

method, 4.74% sol. FAC, 

Severely irritant 

1,2,4) EU RA 

Report, 2007 

3) IUCLID, 

2000 

Monochloramine N.A. N.A. 

Sodium bromate Human: irritating Human: irritating HSDB, 2009 

1,1,2-Trichloroethane Rabbit: Draize test, Highly irritating Rabbit: Draize test, slightly 

irritating IUCLID, 2000 

1,1,2,2-Tetrachloroethane Dog: irritating Guinea pig: Irritating 

Exposed at 576ppm HSDB, 2005 

1,2,3-Trichlorobenzene Rat: irritation Human: irritation at 3-5ppm HSDB, 2004 

1,2,3-Trichloropropane Rabbit: Intact and abraded skin 

irritation test, Slightly irritating Rabbit: Moderately irritating IUCLID, 2000 

1,2,4-Trichlorobenzene Rabbit: Slightly irritating Rabbit: Slightly irritating IUCLID, 2000 

2-Chlorotoluene Rabbit: OECD404, Slightly irritating Rabbit: OECD405, No 

irritating IUCLID, 2000 

4-Chlorotoluene Rabbit: slightly irritating Rabbit: slightly irritating IUCLID, 2000 

Bromobenzene Human: Irritant HSDB, 2003 

Bromochloromethane N.A. 

Chlorobenzene Rabbit: OECD guide line 404, 

Moderately irritating 

Rabbit: OECD guideline 405, 

Not irritating IUCLID, 2000 

cis-1,2-dichloroethene Human: Irritation HSDB, 2003 

Dibromochloromethane Rats and mice: Gavage for up to 

2 years, No histological alterations 

Rats and mice: Gavage for up 

to 2 years, No histological 

alternations 

ATSDR, 2005 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 36 

I:\MEPC\60\2-16.doc 

Chemical Skin Eye Reference 

Dibromomethane N.A. 

Dichlorobromomethane N.A. 

Dichloromethane Rabbit: Draize test, Highly Irritating Rabbit: Irritating IUCLID, 2000 

Tetrachloroethene Rabbit: Highly irritating Rabbit: Slightly irritating IUCLID, 2000 

Tetrachloromethane Rabbit: Draize test, Irritating Rabbit: Draize test, Slightly 

irritating IUCLID, 2000 

trans-1,2-dichloroethene N.A. 

Trichloromethane Rabbit: Draize test, Highly irritating Rabbit: Draize test, Highly 

irritating IUCLID, 2000 

Tribromomethane Human: Irritant (Redness) Human: Irritant (Redness, 

Pain) MSDS 

Trichloroacetonitrile N.A. N.A. 

Dichloroacetonitrile N.A. N.A. 

Bromochloroacetonitrile N.A. N.A. 

Dibromoacetonitrile N.A. N.A. 

Chloral hydrate N.A. N.A. 

Chloropicrin N.A. N.A. 

2-monochloroacetic acid Human: Extremely hazardous Human: Extremely hazardous MSDS 

2,2-dichloroacetic acid Human: Extremely hazardous Human: Extremely hazardous MSDS 

2,2,2-trichloroacetic acid Human: Very hazardous Human: Hazardous MSDS 

2-monobromoacetic acid N.A. N.A. 

2,2-dibromoacetic acid Human: Causes burns Human: Causes burns MSDS 

2,2,2-tribromoacetic acid N.A. N.A. 

2,2-bromochloroacetic acid Human: Causes burns Human: Destructive to tissue 

of mucous membrane. MSDS 

2,2,2-bromodichloroacetic 

acid N.A 

Sodium thiosulfate Human: Slightly hazardous Human: Hazardous MSDS 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 37 

I:\MEPC\60\2-16.doc 

2.4 Repeated dose toxicity

Chemical Exposure route Species Value Reference 

Sodium hypochlorite 

1) Oral: 90days, dose up to 25mg 

Cl/kg/d 

2) Oral: 13weeks, dose up to 118 mg 

NaClO/kg/d 

1) Rats 

2) Rats 

1) NOAEL 17-25mg/kg/d 

2) Decrease in body 

weight gain was 

observed in both sexes. 

No histological changes 

attributable to the 

treatment. 

OECD SIDS, 

2004 

Mono-chloramine Oral: 90days, dose up to 200 mg/l Mice NOAEL 8.6-9.2 mg/kg/d WHO, 2004 

Sodium bromate Oral: 2 weeks, dose 0, 10.8, 54, 

108, 270 or 540 mg/kg/d Mice NOAEL 108 mg/kg/d WHO, 2005 

1,1,2-Trichloroethane Inhalation: 6 months (5days/week, 

7hrs/day) 15ppm(83mg/m3

) Rats 

No histopathological 

changes observed during 

necropsy 

IUCLID, 2000 

1,1,2,2-Tetrachloroethane N.A. 

1,2,3-Trichlorobenzene Oral: 90days dose up to 1,000ppm 

in corn oil Rats 

High dose groups of 

treated males had a general 

trend towards lower wt. 

gain 

HSDB,2004 

1,2,3-Trichloropropane Oral: 90days dose to 1.5, 7.4, 14.7, 

59 mg/kg /d Rats LOAEL 1.5mg/kg/d IUCLID, 2000 

1,2,4-Trichlorobenzene Inhalation: 15days (6hrs/day), dose 

to 0.15mg/l Rats NOAEL 0.15mg/l IUCLID, 2000 

2-Chlorotoluene Oral: 90 days (daily), dose to 30, 

100, 300 mg/kg/d Dogs 

NOEL: 300mg/kg/d for 

female, 100mg/kg/d for 

male 

IUCLID, 2000 

4-Chlorotoluene Oral gavage: 14days, daily, dose to 

200, 600, 1800 mg/kg/d Rats NOAEL 600 mg/kg IUCLID, 2000 

Bromobenzene N.A. 

Bromochloromethane N.A. 

Chlorobenzene Inhalation: 24weeks (5days/week, 

7hrs/day) dose to 75 or 250ppm Rats Small effect on the food utilization IUCLID, 2000 

cis-1,2-dichloroethene Oral gavage: 90days, dose to 32, 

97, 290, 870 mg/kg/d Rats NOAEL 32 mg/kg/d ATSDR, 1996 

Dibromochloromethane Oral: 14days dose to 0,37,74,147 

mg/kg/d Mice NOAEL 37 mg/kg/d. ATSDR, 2005 

Dibromomethane Inhalation: 90 days (6hrs/day), dose 

to 25, 75, 150ppm Rat, dog No gross or histological 

changes HSDB, 2002 

Dichlorobromomethane 

Oral: 25-30 days, dose to 0, 8, 41, 

68 mg/kg/d for male and 0, 14, 72, 

116 mg/kg/d for female 

Rats NOAEL 68 mg/kg/d (M) 

NOAEL 116 mg/kg/d (F) ATSDR, 2005 

Dichloromethane N.A. 

Tetrachloroethene 

Inhalation: 2 weeks (5d/week, 

6hr/day) dose to 100, 200, 425, 875, 

1750ppm 

Rats 

2/5 males and 3/5 females 

died at 1750ppm. Body 

weights reduced (72%) in 

males at 1750ppm 

IUCLID, 2000 

Tetrachloromethane Inhalation: 90days, dose to 0, 

25ppm Rats 

Fatty change in all livers, 

and some cirrhosis of the 

liver observed 

IUCLID, 2000 

trans-1,2-dichloroethene N.A. 

Trichloromethane N.A. 

Tribromomethane 

(bromoform) 

1) Oral: 90 days, dose to 0, 0.65, 

6.1, 57 or 218 mg/kg/d (male) 

and 0, 0.64, 6.9, 55 or 283 

mg/kg/d (female) 

2) Oral: 13 weeks (5days/week), 

dose to 0, 25, 50, 100 or 200 

mg/kg/d (rats) and 0, 25, 50, 100, 

200 or 400 mg/kg/d (mice) 

1) Rats 

2) Rats 

and 

mice 

1) NOAEL 57 (male), 55 

(female) 

2) NOAEL 25 (rats), 100 

(mice) 

ATSDR, 2005 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 38 

I:\MEPC\60\2-16.doc 

Chemical Exposure route Species Value Reference 

Trichloroacetonitrile N.A. 

Dichloroacetonitrile N.A. 

Bromochloroacetonitrile N.A. 

Dibromoacetonitrile N.A. 

Chloral hydrate N.A. 

Chloropicrin N.A. 

2-monochloroacetic acid 

1) Oral: 13 weeks (5d/w) dose to 0, 

25, 50, 100, 150 or 200 mg/kg/d 

2) Oral: 13 weeks (5d/w) dose to 0, 

30, 60, 90, 120 or 150 mg/kg/d 

1) Mice 

2) Rats 

1) NOAEL 100 

2) NOAEL 30 EURA RPT. 

2,2-dichloroacetic acid 

1) Oral: 3 months dose sodium 

dichloroacetate to 0, 125, 500 or 

2000 mg/kg/d 

2) Oral: 13 weeks, dose(by 

capsule) to 0, 50, 75 or 100 

mg/kg/d 

3) Oral: 90days, dose(by capsule) 

to 0, 12.5, 39.5 or 72 mg/kg/d 

1) Rats 

2) Beagle 

dogs 

3) Beagle 

dogs 

1) LOAEL 125 

2) LOAEL 50 

3) LOAEL 12.5 

WHO, 2005 

2,2,2-trichloroacetic acid Oral: 90 days, dose to 0, 4.1, 36.5 

or 355 mg/kg/d 

1) Rats 

(male) NOAEL 36.5 WHO, 2004 

2-monobromoacetic acid N.A. 

2,2-dibromoacetic acid 

1) Oral: 13 weeks, dose 0, 125, 

250, 500, 1000 or 2000 mg/L 

2) Oral: 6 months, dose 0, 20, 72 

or 161 mg/kg/d 

1) Rats 

and 

mice 

2) Rats 

1) NOAEL 500 (mice), 

1000 (rats) 

2) NOEL 20 

WHO, 2004 

2,2,2-tribromoacetic acid N.A. 

2,2-bromochloroacetic 

acid N.A. 

2,2,2-

bromodichloroacetic acid N.A. 

Sodium thiosulfate N.A. 

2.5 Chronic mammalian toxicity 

Chemical Exposure route Species Value Reference

Sodium Hypochlorite Oral: 12 months, dose up to 

100 mg/l Rats 

Decrease of blood 

glutathione with 10, 100 

mg/l, increase of osmotic 

fragility after 6 months. In 

animals exposed for 3 

months, the 3H-thymidine 

incorporation into nuclei 

of rat kidney and testes in 

the 100mg/l group was 

increased. 

IUCLID, 

2000 

Mono-chloramine 

1) Oral: 2years, dose up to 

200mg/l 

2) Oral: 2years, dose up to 

200mg/l 

1) Rats 

2) Mice 

1) NOAEL 

5.2-5.7mg/kg/d 

2) NOAEL 

9.8-10.6mg/kg/d 

WHO, 2004 

Sodium bromate 

1) Dermal: 51weeks (2/week) 

dose 0.2 ml of KBrO3 

solution in acetone 

(40mg/ml) 

2) Oral: 100 weeks, dose 0, 

1.1, 

6.1, 12.9 or 28.7 mg/kg/d 

3) Oral: 100 weeks, 0, 6.9, 

32.5 

or 59.6 mg/kg/d 

1) Mice 

2) Rats 

3) Mice 

1) No skin tumors 

2) NOAEL 1.1 

3) NOAEL 59.6 

WHO, 2005 

1,1,2-Trichloroethane NA 

1,1,2,2-Tetrachloroethane Oral: 78 weeks (5days/week), 

dose up to 284 mg/kg/d Mice NOAEL 284 mg/kg/d ATSDR, 

2005 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 39 

I:\MEPC\60\2-16.doc 

Chemical Exposure route Species Value Reference

1,2,3-Trichlorobenzene N.A. 

1,2,3-Trichloropropane N.A. 

1,2,4-Trichlorobenzene N.A. 

2-Chlorotoluene N.A. 

4-Chlorotoluene N.A. 

Bromobenzene N.A. 

Bromochloromethane N.A. 

Chlorobenzene N.A. 

cis-1,2-dichloroethene N.A. 

Dibromochloromethane Oral: 2 years (5days/week) 0, 

40, or 80 mg/kg gavage doses Rats LOAEL = 28 mg/kg/d ATSDR, 

2005 

Dibromomethane N.A. 

Dichlorobromomethane Oral: 52weeks, dose to 0, 22, 

39 mg/kg/d Rats NOAEL 22 mg/kg/d ATSDR, 2005 

Dichloromethane Inhalation: 2years (6hr/day, 

5days/week) Rats NOAEL 200ppm IUCLID, 

2000 

Tetrachloroethene Inhalation: 8-10 months, 

3hrs/day, dose to 14.5ppm Rats antibodies to typhoid antigens 

IUCLID, 

2000 

Tetrachloromethane Oral: 2years, dose to 80, 

200ppm Rats 

Mortality increased from 

age 14 months. No 

treatment-related effects 

on weight gain, food 

consumption 

IUCLID, 

2000 

trans-1,2-dichloroethene N.A. 

Trichloromethane N.A. 

Tribromomethane 

(bromoform) 

1) Oral (diet) 24 months, 0, 

22, 

90 or 364 mg/kg/d (male) 

and 0, 38, 152 or 619 

mg/kg/d(females) 

2) Oral: 103 weeks (5 days 

per week), dose to 0, 100 or 

200 mg/kg/d 

3) Oral: 103 weeks (5 days 

per week), dose to 0, 50 or 

100 mg/kg (male) and 0, 100 

or 200 mg/kg (female) 

1) Rats 

2) Rats 

3) Mice 

1) NOAEL 22 (male), 38 

(female) 

2) LOAEL 100 

3) NOAEL 100 (male) 

NOEL 100 (female) 

ATSDR, 

2005 

Trichloroacetonitrile N.A. 

Dichloroacetonitrile N.A. 

Bromochloroacetonitrile N.A. 

Dibromoacetonitrile N.A. 

Chloral hydrate N.A. 

Chloropicrin N.A. 

2-monochloroacetic acid 

1) Oral: 103weeks 

(5days/week), dose to 0,15, 

30 mg/kg/d 

2) Oral: 103weeks 

(5days/week), dose to 0, 

50, 

100 mg/kg/d 

1) Rats 

2) Mice 

1) LOAEL=15mg/kg 

2) LOAEL=50mg/kg EURA RPT. 

2,2-dichloroacetic acid 

1) Oral: 75 weeks, dose to 0, 

7.6 or 77 mg/kg/d 

2) Oral: 100 weeks, dose to 0, 

3.6, 40.2 or 139.1 mg/kg/d 

1) Mice 

(male) 

2) Rats 

(male) 

1) NOAEL 7.6 

2) NOEL 3.6 WHO, 2005 

2,2,2-trichloroacetic acid Oral: 51-82weeks, dose to 0, 

78, 262 or 784 mg/kg/d 

Mice 

(female) NOAEL 78 WHO, 2004 

2-monobromoacetic acid N.A. 

2,2-dibromoacetic acid N.A. 

2,2,2-tribromoacetic acid N.A. 

2,2-bromochloroacetic acid N.A. 

2,2,2-bromodichloroacetic acid N.A. 

Sodium thiosulphate N.A. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 40 

I:\MEPC\60\2-16.doc 

2.6 Developmental and reproductive toxicity 

Chemical Exposure route Species Value Reference

Sodium hypochlorite 

Oral: 2 1/2 months, daily in 

drinking water prior to and 

throughout gestation 

1, 10, 100 mg/l 

Rats 

Slight decrease of fetal weight 

and increase of skeletal variants 

in both high concentration 

groups, increase of total 

variations (skeletal and soft 

tissue) in the high concentration 

group. 

IUCLID, 

2000 

Mono-chloramine Oral: 66-76days, dose up to 

10mg/kg/d Rats NOAEL 10mg/kg/d WHO, 2004 

Sodium bromate Oral: 35 days, dose 2.2, 7.7 or 22 

mg/kg/d Rats NOAEL 7.7 

LOAEL 22 WHO, 2005 

1,1,2-Trichloroethane Gavage: Gestational days 8 to 12, 

350 mg/kg/day Mice 

Mortality(3/30) in treated 

mice(0/30 in control group) 

No effects noted on material 

weight gain 

IUCLID, 

2000 

1,1,2,2-Tetrachloroethane Inhalation: 9 moths (4hrs/day) dose 

to 2ppm 

Rats 

(male) 

No gross malformations were 

observed in the offspring HSDB, 2005 

1,2,3-Trichlorobenzene 

Gavage: 6days and 15day of 

gestation, dose to 150, 300, 600 

mg/kg 

Rats Dams did not exhibit any signs of 

toxicity HSDB, 2004 

1,2,3-Trichloropropane Inhalation: 16 weeks (6hrs/day, 

5day/week) dose to 5, 15ppm Rats NOAEL 5ppm IUCLID, 2000 

1,2,4-Trichlorobenzene 

Gavage: Day 9-10 of gestation and 

section on day 14 of gestation, dose 

to 36, 120, 360, 1200 mg/kg/d 

Rats NOAEL 36mg/kg/d IUCLID, 

2000 

2-Chlorotoluene 

1) Gavage: dose to 2700mg/kg 

2) Gavage: 95days, dose to 

0,5,20,80 mg/kg/d 

1) Rats 

2) Dogs 

1) Microscopically all the males 

showed a reduction in 

spermatogenesis 

2) No pathological alteration 

1) IUCLID, 

2000 

2) ICHEM,

2001 

4-Chlorotoluene Inhalation: 6-28 days of gestation, 

dose to 1.5, 4.0, 10 mg/l Rabbit Maternal effects higher than 

4mg/l 

IUCLID, 

2000 

Bromobenzene N.A. 

Bromochloro-methane 

Inhalation: 114days (7hrs/day, 

5days/week), dose up to 267 

mg/kg/d 

Guinea 

Pigs LOAEL 124.29 – 129.53 mg/kg/d EPA/600/8-91/016, 1990

Chlorobenzene 

Inhalation: Day 6-15 of gestation 

(6hrs/day) dose to 0, 75, 210, 590 

mg/l 

Rats NOAEL 210ppm(maternal) 

NOAEL 590ppm(teratogen) 

IUCLID, 

2000 

cis-1,2-dichloroethene N.A. 

Dibromochloro-methane 

1) Oral: 17, 170 or 685 mg/kg/d 

2) Oral: 6-15days of gestation, 

gavage dose to 0, 50, 100, 200 

mg/kg/d 

1) Mice 

2) Rats 

1) dose (685 mg/kg/d): a marked 

reduction in fertility, decreases 

in litter size 

2) Maternal weight gain was 

significantly decreased at 

highest dose level 

HSDB,2006 

Dibromomethane N.A. 

Dichlorobromo-methane 

1) Oral: GD 6-15, gavage (Corn 

oil) dose 0, 50, 100, 200 mg/kg/d

2) Oral: GD 6-15, gavage dose 0, 

25, 50, 75 mg/kg/d 

1) Rats 

2) Rats 

1) NOAEL 100 mg/kg/d 

2) LOAEL 25 mg/kg/d 

ATSDR, 

2005 

Dichloromethane Inhalation: 7hrs, dose to 1250ppm Rats NOAEL 1250ppm IUCLID, 

2000 

Tetrachloroethene 

Inhalation: GD 0-21 (3weeks, 

5d/week, 7hrs/day) , dose to 

500ppm 

Rats and 

rabbits No evidence of material toxicity IUCLID, 

2000 

Tetrachloromethane Inhalation: 10.5 months, dose to 50, 

100, 200, 400ppm Rats 

Liver cirrhosis observed at 

100-400ppm. Dose effect of 

conceived litters is not observed. 

IUCLID, 

2000 

trans-1,2-dichloroethene N.A. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 41 

I:\MEPC\60\2-16.doc 

Chemical Exposure route Species Value Reference

Trichloromethane N.A. 

Tribromomethane 

(bromoform) 

1) Oral: GD 6-15, gavage dose to 0, 

50, 100 or 200 mg/kg/d 

2) Oral: 105 days, gavage dose to 0, 

50, 100 or 200 mg/kg/d 

1) Rats 

2) Mice 

1) NOAEL 50 (developmental), 

200 (maternal) 

LOAEL 100 (developmental) 

2) NOAEL 100 (developmental / 

maternal) 

LOAEL 200 (developmental / 

maternal) 

ATSDR, 

2005 

Trichloroacetonitrile N.A. 

Dichloroacetonitrile N.A. 

Bromochloroaceto-nitrile N.A. 

Dibromoaceto-nitrile N.A. 

Chloral hydrate N.A. 

Chloropicrin Pup NOEL > 1.5ppm HSDB, 2009 

2-monochloroacetic acid Oral: gestation days 1 to 22 (GD 

1-22), dose to 0 or 193 mg/kg/d Rats NOAEL 193 (developmental) LOAEL 193 (maternal) WHO, 2004 

2,2-dichloroacetic acid 

1) Oral: GD 6-15, dose to 0, 14, 

140 or 400 mg/kg/d (first) and 0, 

900, 1400, 1900 or 2400 

mg/kg/d(second) 

2) Oral: 14 days, dose to 0, 18, 54, 

160, 480 or 1,440 mg/kg/d 

1) Rats 

2) Rats 

1) NOAEL 14 (maternal and 

developmental) 

2) NOAEL 18 

WHO, 2005 

2,2,2-trichloroacetic acid 

1) Oral: GD 6-15, dose to 0, 330, 

800, 1200 or 1800 mg/kg/d 

2) Oral: GD 1-22, dose 0 or 290 

mg/kg/d 

1) rats 

2) rats 

1) LOAEL 330 (maternal and 

developmental) 

2) LOAEL 290 (maternal, 

reproductive and 

developmental) 

WHO, 2004 

2-monobromoacetic acid N.A. 

2,2-dibromoacetic acid 

1) Oral: GD 1-8, dose 0, 62.5, 125 

or 250 mg/kg/d 

2) Oral: Beginning 14 days prior to 

cohabitation and continuing 

through gestation and lactation 

(63-70 days of treatment), dose 

0, 125, 250, 500 or 1,000ppm 

1) Rats 

(female) 

2) Rats 

1) NOAEL 125mg/kg 

2) NOAEL 66 mg/kg (male), 60 

mg/kg (female) 

WHO, 2004 

2,2,2-tribromoacetic acid N.A. 

2,2-bromochloroacetic 

acid 

Oral: during cohabitation and 

separated after mating. 

gestation day 6 to onset of birth 

(pregnant rats) dose 0, 60, 200 or 

600ppm 

Rats NOAEL 19 mg/kg 

LOAEL 50 mg/kg WHO, 2004 

2,2,2-bromodichloroacetic acid N.A. 

Sodium thiosulphate 

1) oral gestation days 6 to 15 

0, 5.5, 25.5, 118 or 550 mg/kg/d 

2) oral gestation days 6 to 15 

0, 4, 19, 86 or 400 mg/kg/d 

3) oral gestation days 6 to 15 

0, 4, 19, 86 or 400 mg/kg/d 

4) oral gestation days 6 to 18 

highest dose level of 580 

mg/kg/d 

1) mice 

2) rats 

3) hamsters 

4) rabbits 

1,2,3,4) No indication of any 

effect 

1,2,3,4) 

PMEP 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 42 

I:\MEPC\60\2-16.doc 

2.7 Carcinogenicity

Chemical Species Method Details Results Reference

Sodium hypochlorite Mouse Dermal Exposure: 300days 

>10% effective chlorine sol. No skin tumors, no leukemia. IUCLID, 2000 

Mono-chloramine Rats and 

Mice 

Oral: 2year bioassays, 

0, 50, 100 or 200 mg/l 

Increases in leukemia incidence 

in dosed female rats were small 

and not clearly dose-related. 

WHO, 2004 

Sodium bromate 

1) Rats 

2) Rats 

3) Mice 

1) Oral: 104weeks, dose 0, 0.7, 

1.3, 2.5, 5.6, 12 or 33 

mg/kg/d 

2) Oral: 104weeks, dose 0 or 

32.3 mg/kg/d 

3) Oral: 100weeks, dose 0, 6.9, 

32.5 or 59.6 mg/kg/d 

1) Significantly increased 

dysplastic foci in the kidney 

(≥ 1.3 mg/kg/d). 

2) Increased dysplastic foci and 

renal adenomas 

3) Increased renal adenomas and 

carcinomas (6.9 mg/kg/d). Not 

increased renal tumors (32.5 

or 59.6 mg/kg/d) 

WHO, 2005 

1,1,2-Trichloroethane Rats Gavage: 78weeks (5days/week), 

46-92mg/kg/d 

No effects were noted on weight 

gain and mortality. 

IUCLID, 

2000 

1,1,2,2-

Tetrachloroethane 

Rats and 

mice 

Inhalation: 11 months (3-4 

hrs/day), dose up to 14.6ppm 

Liver damage, involving 

increased metabolic activity at 

14.6ppm 

HSDB,2005 

1,2,3-Trichlorobenzene N.A. 

1,2,3-Trichloropropane Rats and 

mice 

Gavage: 104weeks (1 

injection/day, 5days/week) 

Dose to 3, 10, 30 mg/kg/d to rats 

, dose to 6, 20, 60 mg/kg/d to 

mice 

Significant lower survival. 

Lower mean body weight of high 

dose. 

IUCLID, 

2000 

1,2,4-Trichlorobenzene Mice 

Dermal: 2 years (twice a week), 

dose to 0.03ml of a 30%, 60% 

sol. 

Tumors developed in lung, 

kidney, stomach, urinary 

bladder, mammary gland and 

skin. 

IUCLID, 

2000 

2-Chlorotoluene N.A. 

4-Chlorotoluene Mice In vitro transformation of cells Negative IUCLID, 

2000 

Bromobenzene N.A. 

Bromochloro-methane Human EPA/600/8-87-045 B2, Probable human carcinogen EPA, IRIS 

Chlorobenzene 1) Rats 

2) Mice 

1) Gavage: 103weeks 

(5days/week) 2 year 

carcinogenesis 

2) Gavage: 103weeks 

(5days/week) dose to 30, 60 

mg/kg/d(male), 60, 120 

mg/kg/d(female) 

1) Negative 

2) Negative 

IUCLID, 

2000 

cis-1,2-dichloroethene Human Not classifiable as to human 

carcinogenicity EPA, IRIS 

Dibromochloromethane 1)Mice 

2)Human 

1) Positive carcinogenic 

evidence 

2) Not classifiable as to its 

carcinogenicity to humans 

1)HSDB, 

2006 

2)IARC, 

1991 

Dibromomethane N.A. 

Dichlorobromomethane Rat(M/F) Positive /kidney, Intestine 

tumors HSDB,2009 

Dichloromethane 1) Rats 

2) Mice No data 1) NOEL 5mg/kg 2) NOEL 185mg/kg 

IUCLID, 

2000 

Tetrachloroethene Mice Inhalation: 2 years, 100ppm Liver tumors IUCLID, 

2000 

Tetrachloromethane Rats 

Oral: 78 weeks (5times/week), 

gavage dose to 47, 94 mg/kg 

male and 80, 160 mg/kg female 

Neoplastic nodules of the liver 

occurred 

IUCLID, 

2000 

trans-1,2-

dichloroethene N.A. 

Trichloromethane N.A. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 43 

I:\MEPC\60\2-16.doc 

Chemical Species Method Details Results Reference

Tribromomethane 

(bromoform) 

1) Rats 

2) Mice 

1) Oral: 103 weeks (5 days per 

week), gavage dose in oil, 0, 

100 or 200 mg/kg/d. 

2) Oral: 103 weeks (5 days per 

week), gavage dose in oil, 0, 

50 or 100 mg/kg/d (male) and 

0, 100 or 200 mg/kg/d 

(female). 

1) Increased adenomatous 

polyps or adenocarcinomas. 

2) No statistically significant 

increases in the incidence of 

any neoplastic lesion in any 

dose group compared to 

controls. 

ATSDR, 

2005 

Trichloroacetonitrile N.A. 

Dichloroaceto-nitrile N.A. 

Bromochloroacetonitrile Mice 

An increase in the proportion of 

animals with lung tumors and 

number of tumors per mouse was 

observed 

HSDB,2009 

Dibromoaceto-nitrile N.A. 

Chloral hydrate Mice 

Carcinogenic (hepatocellular 

neoplasia) in the male mouse, 

but not in the rat 

HSDB, 2009

Chloropicrin Mice LOAEL 0.5ppm HSDB, 2009

2-monochloroacetic 

acid 

1) Rats 

and 

mice 

2) rats 

1) 2years, dose to 0, 15 or 30 

mg/kg/d for rats and 0, 50 or 

100 mg/kg/d for mice 

2) Oral: 2years, dose to 0, 3.5, 

26.1 or 59.9 mg/kg/d 

No evidence WHO, 2004 

2,2-dichloroacetic acid Mice 

(male) 

Oral: 61 weeks, dose to 0 or 

1000 mg/kg/d 

An increase in hepatocellular 

carcinomas was observed in 81% 

of treated animals 

WHO, 2005 

2,2,2-trichloroacetic 

acid 

1) Mice 

(female) 

2) Rats 

(male) 

1) Oral: 104 weeks, dose 0, 71 

or 583 mg/kg/d 

2) Oral: 2 years, dose 0, 3.6, 

32.5 or 364 mg/kg/d 

1) Liver tumor (adenomas + 

carcinomas) in the high-dose 

group, LOAEL 71 

2) NOAEL 32.5 

WHO, 2004 

2-monobromoacetic 

acid N.A. 

2,2-dibromoacetic acid Rats Oral: 2years, dose 0, 50, 500 or 

1,000 mg/L 

Some evidence of carcinogenic 

activity NTP (2007) 

2,2,2-tribromoacetic 

acid N.A. 

2,2-bromochloroacetic 

acid 

Rats and 

mice 

Oral: 2years, dose 20, 250, 500 

or 1,000 mg/L 

Clear evidence of carcinogenic 

activity NTP (2008) 

2,2,2-

bromodichloroacetic 

acid 

 N.A. 

Sodium thiosulphate N.A. 

2.8 Mutagenicity/genotoxicity 

Chemical Species Method Details Results Reference

Sodium 

hypochlorite 

1) Hamster 

cells 

2) Mice 

1) Route: treated for three hours 

with 0.5 μg/mL 

2) Oral: dose up to 8 mg/kg/day 

for 5 days 

1) Positive (+S9) 

2) Negative 

OECD SIDS, 

2004 

Monochloramine 

1) Bacillus 

subtilis 

2) Mouse 

1) Weakly mutagenic 

2) Negative WHO, 2004 

Sodium bromate 

1) Chinese 

hamster 

fibroblasts 

2) Mouse bone 

marrow cells 

1) Chromosomal aberration assay

2) Micronucleus test 

1) Increase in the frequency of 

exchange-type aberrations 

2) Increased micronuclei 

WHO, 2005 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 44 

I:\MEPC\60\2-16.doc 

Chemical Species Method Details Results Reference

1,1,2-

Trichloroethane N.A. 

1,1,2,2-Tetrachloroethane N.A. 

1,2,3-

Trichlorobenzene N.A. 

1,2,3-

Trichloropropane 

1) Bacterial 

Mammalian 

cell 

2) Mice 

1) Gene conversions 

2) Oral: dose up to 120 mg/kg/d 

1) Positive. 

2) The average estrous cycle 

length was significantly 

increased for all 1,2,3- 

trichloropropane-exposed 

females of the F1 generation, 

with the lowest dose being 30 

mg/kg/d 

ICHEM 

1,2,4-

Trichlorobenzene 

Salmonella 

typhimurium Ames test 1-5 ul/plate Negative IUCLID, 2000

2-Chlorotoluene 

Bacterial 

Mammalian 

cell 

In vitro No mutagenic activity ICHEM. 2001

4-Chlorotoluene Salmonella 

typhimurium 

Ames test 

7 doses of 0.02-1.17ul per plate Negative IUCLID, 2000

Bromobenzene 

Chinese 

hamster ovary 

cell 

In vitro chromosomal 

Dose: 50, 160, 500 ug/ml Negative CCRIS, 2006 

Bromochloromethane N.A. 

Chlorobenzene 

1) Mice 

2) Drosophila 

melanogaster 

1) Cytogenetic assay 

IP: single, dose up to 

1000mg/kg 

2) Inhalation: 4hrs, dose to 

900ppm 

1) Positive only one of two series 

with 1000 mg/kg 

2) Negative 

IUCLID, 2000

cis-1,2-

dichloroethene 

Humans or 

animals Non-positive results EPA, IRIS 

Dibromochloromethane Mice Positive mutagenicity data HSDB, 2006 

Dibromomethane N.A. 

Dichlorobromomethane N.A. 

Dichloromethane N.A. 

Tetrachloroethene N.A. 

Tetrachloromethane Rats Inhalation: 300-1000ppm No teratogenicity IUCLID, 2000

trans-1,2-

dichloroethene N.A. 

Trichloromethane N.A. 

Tribromomethane 

(bromoform) N.A. 

Trichloroacetonitril

e N.A. 

Dichloroacetonitrile 

1) S. 

typhimurium 

2) S. 

cerevisiae. 

1) Mutagenic 

2) Not mutagenic HSDB, 2009 

Bromochloroacetonitrile N.A. 

Dibromoacetonitrile Salmonella 

typhimurium Ames fluctuation test No mutagenic effect was found HSDB, 2009 

Chloral hydrate Salmonella 

typhimurium Mutagenic HSDB, 2009 

Chloropicrin 

1) mouse 

lymphoma 

2) Rabbits 

1) 0.038-16 nl/ml 

1) Did not induce a mutagenic 

2) NOAEL 0.4ppm (maternal) 

NOAEL 1.2ppm 

(developmental) 

HSDB, 2009 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 45 

I:\MEPC\60\2-16.doc 

2.9 Toxicokinetics

Chemical Results 

Sodium bromate 

Bromate is rapidly absorbed from the gastrointestinal tract, at least in part unchanged. It is 

distributed throughout the body appearing in plasma and urine unchanged and in other tissues 

as bromide. Bromate is reduced to bromide in several body tissues, probably by GSH or other 

sulfhydryl-containing compounds. Most bromate is excreted in the urine, either as bromate or 

bromide, but some may leave the body in the feces. Bromine has been detected in adipose 

tissue of mice following long-term treatment with bromate. 

Monochloramine 

In rats, the oral route is rapidly and readily absorbed from the gastrointestinal tract. 

In humans, most of the monochloramine from drinking-water would reach the stomach intact 

but would rapidly decay in stomach fluid. 

Bromochloromethane 

Bromochloromethane is rapidly absorbed by rats in biphasic manner following acute inhalation 

exposure, but quantitative data are not available regarding the extent of inhalation exposure or 

the rate or extent of oral exposure. There appears to be some distribution of bromide to the 

brain of dogs during subchronic inhalation exposure. 

Monochloroacetic acid 

monochloroacetic acid is rapidly absorbed and systemically distributed following direct skin 

contact covering at least 10% of the skin surface. 

Dichloroacetic acid 

Dichloroacetic acid is rapidly absorbed into the bloodstream from the gastrointestinal tract in 

rats and mice and via both the oral and dermal routes in humans. Dichloroacetic acid is 

dechlorinated to glyoxylate and then oxidized to oxalate, all of which are excreted in the urine. 

Transamination of glyoxylate forms glycine and can distribute the label from dichloroacetic 

acid to urinary glycine conjugates, such as hippuric acid. In rats, dogs, and humans given 

single doses of sodium dichloroacetate intravenously, average half-lives of the parent 

compound in plasma were 2.97, 20.8, and 0.43 h, respectively. 

Trichloroacetic acid 

Trichloroacetic acid is rapidly absorbed from the gastrointestinal tract in rats and by both the 

dermal and oral routes in humans. Trichloroacetic acid was metabolized by reductive 

dehalogenation to dichloroacetic acid. Further reductive dehalogenation of dichloroacetic acid 

to monochloroacetic acid and ultimately to thiodiglycolate has been proposed as a metabolic 

pathway. The mean elimination half-life of trichloroacetic acid in urine was 45.6 h in humans, 

compared with 11.0 h in rats, suggesting that elimination of trichloroacetic acid in rats is more 

rapid. 

Bromochloroacetic acid 

Bromochloroacetic acid was systemically absorbed following gavage dosing, with peak 

concentrations in blood occurring 1.5 h after dosing. The oral bioavailability was estimated to 

be 47%. 

Monobromoacetic acid 

No studies of the absorption, distribution, metabolism or excretion of monobromoacetic acid 

have been identified in the literature. 

Dibromoacetic acid 

Following gavage exposure in rats, the concentration of dibromoacetic acid in blood peaked 

within 1 h after dosing, suggesting rapid intestinal absorption. The oral bioavailability of 

dibromoacetic acid was estimated to be 30%. Dibromoacetic acid metabolites appear to be 

rapidly excreted, and dibromoacetic acid does not exhibit evidence of bioaccumulation. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 46 

I:\MEPC\60\2-16.doc 

3 DATA ON ENVIRONMENTAL FATE AND EFFECT UNDER AEROBIC AND 

ANAEROBIC CONDITIONS 

3.1 Modes of degradation (biotic; abiotic) 

3.1.1 The Group noted the information shown in the table below which was mainly from 

National Institute of Technology and Evaluation database. 

Biodegradation for Relevant Chemicals 

Chemical Biodegradation Results Reference 

Sodium bromate N.A. 

Sodium thiosulphate N.A. 

1,1,2-Trichloroethane 28days, MITI-I(OECD TG 301C) Non-biodegradability 

GC 5% NITE Database 

1,1,2,2-Tetrachloroethane 28days, MITI-I(OECD TG 301C) Non-biodegradability TOC 0%, 

GC 10% NITE Database 

1,2,3-Trichlorobenzene 2weeks, MITI-I(OECD TG 301C) Non-biodegradability BOD 0%, 

GC 0% NITE Database 

1,2,3-Trichloropropane 4weeks, MITI-I(OECD TG 301C) Non-biodegradability BOD 0%, 

GC 8% NITE Database 

1,2,4-Trichlorobenzene Activated sludge, Aerobic=56% after 5day IUCLID, 2000 

2-Chlorotoluene Activated sludge 10mg/l, Aerobic=0% after 28day IUCLID, 2000 

4-Chlorotoluene MITI-I(OECD TG 301C) Non-biodegradability NITE Database 

Bromobenzene MITI-II(OECD TG 302C) Non-biodegradability NITE Database 

Bromochloromethane MITI-I(OECD TG 301C) Non-biodegradability NITE database 

Chlorobenzene MITI-II(OECD TG 302C) Non-biodegradability NITE database 

cis-1,2-dichloroethene MITI-II(OECD TG 302C) Non-biodegradability NITE database 

Dibromochloromethane Aerobic, a static flask screening procedure and incubation 28 days, 

25-39% loss HSDB,2006 

Dibromomethane No significant biotic or abiotic degradative processes have been reported 

in natural waters or soil. HSDB,2002 

Dichlorobromomethane Aerobic, a static flask screening procedure and incubation 28days, 

51-59% loss HSDB,2009 

Dichloromethane MITI-I(OECD TG 301C) Non-biodegradable BOD 13% GC 1% NITE database 

Tetrachloroethene MITI-I(OECD TG 301C) Non-biodegradable BOD 11% GC 0% NITE database 

Tetrachloromethane 2weeks(MITI-I(OECD TG 301C) Non-biodegradability BOD 0% TOC 

0% NITE database 

trans-1,2-dichloroethene Closed Bottle Test(OECD TG 301D) Non-biodegradable BOD 0% NITE database 

Trichloromethane MITI-I(OECD TG 301C) Non-biodegradable BOD 0% GC 4.6% 

2weeks NITE database 

Tribromomethane MITI-I(OECD TG 301C) Non-biodegradable GC 0% 4weeks NITE database 

Trichloroacetonitrile 

It is a by-product of water chlorination and hydrolyzes quickly, therefore 

biodegradation is not expected to be an important fate in the 

environment. 

HSDB, 2009 

Trichloroacetonitrile 

It is a by-product of water chlorination and hydrolyzes quickly, therefore 

biodegradation is not expected to be an important fate in the 

environment. 

HSDB, 2009 

Bromochloroaceto-nitrile 

It is a by-product of water chlorination and hydrolyzes quickly, therefore 

biodegradation is not expected to be an important fate in the 

environment. 

HSDB, 2009 

Dibromoaceto-nitrile 

It is a by-product of water chlorination and hydrolyzes quickly, therefore 

biodegradation is not expected to be an important fate in the 

environment. 

HSDB, 2009 

Chloral hydrate Biodegradation data for chloral hydrate were not available HSDB, 2009 

Chloropicrin 

MITI-I(OECD TG 301C) Non-biodegradable GC 4% BOD 0% TOC 

0%, 4weeks 

Anaerobic, activated sludge inoculums at 20°C: Aerobic biodegradation 

rate: 1.5/day Half-life: 0.46day 

NITE database 

HSDB2009 

2-monochloroacetic acid MITI-I(OECD TG 301C) Ready biodegradable GC 100% BOD 65% 

TOC 99.8% 3weeks NITE Database 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 47 

I:\MEPC\60\2-16.doc 

Chemical Biodegradation Results Reference 

2,2-dichloroacetic acid MITI-I(OECD TG 301C) Ready biodegradable HPLC 100% BOD 97% 

TOC 94% 2weeks NITE Database 

2,2,2-trichloroacetic acid MITI-I(OECD TG 301C) 4weeks, Non-biodegradable BOD 7%, 

TOC 42% NITE Database 

2-monobromoacetic acid MITI-I(OECD TG 301C) 3weeks, Readily biodegradable BOD 65%, 

GC 100%, TOC 99.8% NITE Database 

3.1.2 The Group noted that the applicant had indicated that TRO, sodium hypochlorite and 

sodium hypobromite are rapidly degraded in nature and they are not considered to be 

bio-accumulated on aquatic organisms. 

3.2 Bioaccumulation, partition coefficient, octanol/water partition coefficient 

3.2.1 The bioaccumulation factors (BCFs) and octanol-water partition coefficient (Kows) for 

the Active Substances and Relevant Chemicals are listed in Table 5.4 of section 5.1.5. The 

adsorption coefficients (Kocs) for the Active Substances and Relevant Chemicals are given in 

section 5.1.4. 

3.3 Persistence and identification of the main metabolites in the relevant media 

Because of low Log Pow and no bioavailability, there was no report on persistence and 

identification of main metabolites in Active Substance. For Relevant Chemicals, the Level III 

Fugacity models of the EPI suit v.4.0 uses three environmental compartments (water, soil, and 

sediment) to determine the persistence of a chemical in the environment. It has estimated that any 

chemical is expected to be found predominantly in any compartment and its persistence estimate 

is based on its transformation in this medium (half-life). The persistence of the above by-products 

is given in sections 5.1, 8.1 and 8.2. 

3.4 Reaction with organic matter

When natural organic matter is treated with hypochlorite species (HOCl, OCl), high molecular 

weight chlorinated compounds form in the first step that is followed by the cleavage of benzene 

rings into trihalomethanes and haloacetic acids. For most of Relevant Chemicals, there is no 

accumulation through aquatic organisms. And there is no information which is available on 

reaction with organic matter by Relevant Chemicals. 

3.5 Potential physical effects on wildlife and benthic habitats 

No data were available for potential physical effects on wildlife and benthic habitats. Most of 

Active Substances and Relevant Chemicals have low Kow and BCF values. Therefore, effects on 

wildlife and benthic habitats by treated ballast water would be expectedly low. 

3.6 Potential residues in seafood 

For Active Substances and Relevant Chemicals, there is no potential concentration of food chain. 

Due to low Kow and BCF values, it is unlikely that these will be accumulated through the food 

chain. 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 48 

I:\MEPC\60\2-16.doc 

3.7 Any known interactive effects 

There is no study of interactive effects on Active Substances and Relevant Chemicals. 

3.8 Physical and chemical properties for the Active Substances and Relevant Chemicals 

(G9: 4.2.1.4) 

The physical and chemical properties for the Active Substances and Relevant Chemicals are 

briefly described in Table 5.14 and detailed in appendix 4 “Chemicals data-set”. 

Table 5.14 : Physical and chemical properties for the Active Substances 

and Relevant Chemicals 

Chemical MP BP FA DE VP VD WS DC CM AT 

Sodium hypochlorite 18 96 Non 1210 1740 • 293000 • Y Non 

Monochloramine • • • • • • • • • • 

Sodium bromate 381 1390 381 3339 5.6E-16 • 364000 • • • 

1,1,2-trichloroethane -35 113 Non 1.44 225 4.21 4400 • Y 460 

1,1,2,2-Tetrachloroethane -43.8 146.5 Non 1595 615.95 5.79 2900 • Y Non 

1,2,3-Trichlorobenzene 53.5 218.5 112.7 1453.3 28 6.26 18 • • • 

1,2,3-trichloropropane -14.7 156.85 180 1388.9 492 5.1 1750 • • 304 

1,2,4-Trichlorobenzene 17 213.5 105 1459 21.5 6.26 19 • • 571 

2-Chlorotoluene -35.59 158.97 49 1082.6 350 • 374 • • • 

4-Chlorotoluene 7.5 162.4 49 1069.7 374 4.37 106 • • 595 

Bromobenzene -30.6 156.2 51 1495.2 557.3 5.41 410 • • 565 

Bromochloromethane -87.9 68 Non 1934.4 18932 • 16700 • Y Non 

Chlorobenzene -45.2 131.7 29.2 1105.8 1200 3.88 502 • Y 638 

Cis-1,2-dichloroethene -80 60.1 2.2 1283.7 23998 3.54 6410 • • 460 

Dibromochloromethane -20 121.3 Non 2451 10133 • 2700 • • Non 

Dibromomethane -52.5 97 Non 2496.9 5866.2 6.05 11900 • Y Non 

Dichlorobromometane -57 90 Non 1980 666.1 • 3968 • • Non 

Dichloromethane -95 39.75 Non 1326 7653 2.93 13700 • • 605 

Tetrachloroethene -22.3 121.3 Non 1620 1900 5.7 160 • Y Non 

Tetrachloromethane -23 76.8 Non 1594 11940 5.32 793 • • • 

Dichloroethene -49.8 48.7 2.2 1257 44129 3.67 6300 • • 460 

Trichloromethane -63.4 61.17 Non 1476 20829 4.12 8000 • Y Non 

Tribromomethane 8.69 149.1 Non 2879 718.9 8.7 3100 • Y • 

Trichloroacetonitrile -42 85.7 195 1440 9879 • 715 • • • 

Dichloroacetonitrile • 112 • 1369 376 • 33500 • Y • 

Bromochloroacetonitrile • 138 • 1680 121.7 • 18700 • • • 

Dibromoacetonitrile • 68 • 2296 40.13 • 9600 • • • 

Chloral hydrate 57 96 • 1908 1999 5.1 793000 • • • 

Chloropicrin -64 112 Non 1645 3200 5.7 1620 • Y • 

2-monochloroacetic acid 63 189.3 126 1370 8.7 3.26 860000 2.85 Y 500 

2,2-dichloroacetic acid 9.7 194 • 1563 23.9 4.45 1.0E+6 1.26 • • 

2,2,2-trichloroacetic acid 57.5 195.5 Non 1613 8 • 54000 0.51 • • 

2-monobromoacetic acid 49 208 113 1934 15.9 • 1.8E+6 2.89 • • 

2,2-dibromoacetic acid 48 232 113 • 3.07 • 2.1E+6 1.48 • • 

2,2,2-tribromoacetic acid 129 245 • • 0.037 • 200000 0.72 • • 

2,2-bromochloroacetic acid • 215 110 1985 18.7 • 250000 1.40 • • 

2,2,2-bromodichloroacetic acid • • • • 4.8 • 4900 0.72 • • 

Sodium thiosulphate 48.3 100 Non 1667 • • 209000 • • • 
GESAMP-BWWG 12/6 

ANNEX 4 

Page 49 

I:\MEPC\60\2-16.doc 

Note: 

MP : Melting Point, °C BP : Boiling Point, °C

FA : Flammability(Flash point for liquids, °C) DE : Density, kg/m3

VP : Vapour Pressure, Pa VD : Vapour Density, Pa 

WS : Water solubility, mg/l DC : Dissociation Constant, pKa 

CM : Corrosivity to the Materials or equipment of normal ship Construction, Yes/No Details in appendix 4

AT : Autoignition Temperature Non : Non-Flammable 

• : No available data 

3.9 Analytical methods at environmentally relevant concentrations (G9: 4.2.1.5) 

Procedures for sampling, transferring and analysis methods are described in detail in appendix 2 

(QAPP by KTR). 

*** 

GESAMP-BWWG 12/6 

I:\MEPC\60\2-16.doc 

ANNEX 5 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Kwang San Co., Ltd. (KS) Ballast Water Management System “En-Ballast” 

Submitted by the Republic of Korea for Basic Approval 

0 SUMMARY 

0.1 Having considered all of the data provided by the applicant, the Group recommended 

that Basic Approval be granted to the En-Ballast Ballast Water Management System. 

0.2 The Group noted that the En-Ballast system comprised a filtration stage followed by 

electrolysis which generates oxidants, primarily sodium hypochlorite, in a sidestream off the 

main ballast water piping. The oxidants are then passed through a gas-freeing tank and then 

injected back into the ballast water in a controlled manner to disinfect it. Any excess oxidants 

would be neutralized with sodium thiosulphate during discharge of the ballast water. 

0.3 The Group noted that no corrosion tests had been carried out but would be available for 

consideration in the application for Final Approval. 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. 

0.4 Having noted that hydrogen gas is generated, during electrolysis, and is vented to 

atmosphere and that a suitable monitoring and control systems is to be put in place to ensure that 

the concentration does not reach the Lower Explosive Limit, the Group was satisfied that the 

risks associated with hydrogen could be mitigated to an acceptable level by such controls. 

0.5 The Group also noted that the applicant had stated that there would be no risk to human 

health from the chemicals associated with the system as the ship’s personnel would not come into 

contact with it. As a result, no human risk assessment had been carried out for the crew. The 

Group could not agree with this assumption as there will always be a risk of equipment 

break-down and leakage, especially as the TRO concentration produced by the electrolyser is 

considered to be high at 500-2000 mg/L. Furthermore, the risks associated with the loading and 

mixing of the neutralizer chemical, sodium thiosulphate, requires proper assessment with 

appropriate risk mitigation measures and procedures to be put in place and clearly detailed in the 

system operating manual. The Group recommended that these basic operational concerns be 

fully addressed in any application for Final Approval. 

0.6 The Group noted that the applicant had not provided 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) was not 

provided. Therefore, the risks to the crew could not be quantified because the potential exposure 

situations had not been identified by the applicant. 

0.7 The Group noted that the applicant had carried out a risk assessment for the general 

public based on the MOS approach. The calculated MOS values, provided, were found to be 

considerably higher than the MOSref (100) and therefore no unacceptable risk was anticipated. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 2 

I:\MEPC\60\2-16.doc 

0.8 The Group noted the environmental risk assessment carried out by the applicant. 

However, it was noted that the applicant had not performed the MAMPEC calculations correctly. 

The load of the system into the receiving harbour, as reported in the dossier, was not correct 

(a factor of 1000 too low) and the degradation of the substances was not converted to the correct 

unit (a half-life in days results in a rate in d-1 (k = ln(2)/DT50). 

0.9 Consequently, the PEC and PEC/PNEC results, as calculated by the applicant, were not 

accepted by the Group. However, a recalculation with the correct input values for MAMPEC 

still resulted in PECs and PEC/PNEC values that did not show any unacceptable risk to the 

environment. 

0.10 The Group noted that there would be no unacceptable risk associated with this system 

providing that the neutralization step is performed adequately during every ballast water 

discharge. However, the Group noted that the control scheme for maintaining the MADC of 

TRO using TRO sensors were still under development. In an application for Final Approval the 

neutralization control system should be fully documented to give confidence in its reliability. 

0.11 Notwithstanding those observations made in this report, the Group would like to draw 

attention to the following specific points to be addressed in the application for Final Approval: 

 .1 the results of corrosion testing, as proposed, should be included in the application 

for Final Approval, taking into consideration the Group’s recommendation for 

comprehensive testing; 

 .2 monitors and failsafe systems should be put in place, as indicated by the applicant 

in response 3 in section 4, to ensure that the levels of hydrogen and chlorine to not 

reach dangerous concentrations; 

 .3 a comprehensive risk assessment for the crew and the general public should be 

carried out to cover various exposure scenarios; 

 .4 the required chronic toxicity test results, in accordance with Procedure (G9), 

should be provided, as it was missing in the application for Basic Approval; and 

 .5 the TRO sensors’ sensitivity, reliability and its use in the neutralizer control 

should be confirmed as being appropriate to maintain the MADC of TRO. 

0.12 In addition to the specific points made above, the Group recommended that all of the 

concerns addressed in this report be taken into consideration prior to making an application for 

Final Approval. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 3 

I:\MEPC\60\2-16.doc 

1 INTRODUCTION 

1.1 Data used to evaluate this system were extracted from MEPC 60/2/7 and were 

supplemented by additional information provided to the Group. 

2 DESCRIPTION OF THE SYSTEM 

2.1 The Group noted that the En-Ballast system comprises: 

 .1 an automatic back-flush filtration (50μm) module; 

 .2 an electrolysis unit which generates, primarily, a high concentration of sodium 

hypochlorite (500-2000 mg/L of TRO) which is then injected into the ballast water; 

 .3 a neutralization module which neutralizes the treated ballast water, with sodium 

thiosulphate, prior to its discharge to the sea; and 

 .4 a control system which monitors the TRO being produced, controls the amount of 

electrolysis, to ensure dosage TRO levels of 7 mg/L and controls the amount of 

sodium thiosulphate being added to the ballast water during discharge to ensure 

that the TRO concentration is kept below 0.2 mg/L. 

2.2 A schematic representation of the system, as supplied by the applicant is shown below: 

2.3 The Group noted that 500-2000 mg/L of TRO, as chlorine, are generated by electrolysis 

in the form of a solution which is injected into the ballast water main. 

2.4 The TRO dosage concentration is controlled to a level of 7 mg/L in the ballast water to 

ensure adequate disinfection. 

2.5 In addition, the Group noted, with respect to the control scheme, that: 

 .1 a conductivity sensor, installed at the head of the electrolysis module, is used to 

set the electric current magnitude of the rectifier; 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 4 

I:\MEPC\60\2-16.doc 

 .2 an online TRO sensor, installed at the end of the electrolysis module, is used to 

control the electric current magnitude of the rectifier during ballasting to maintain 

the level dosage level 7 mg/L TRO; 

 .3 a flow-rate transmitter is used to control the electric current magnitude of the 

rectifier in proportion to the flow-rate; and 

 .4 pressure transmitters, installed at the inlet of the filtration module and at the outlet 

of the electrolysis module, are used to measure any pressure drop so that 

appropriate controls may be applied. 

2.6 However, the Group noted that the applicant had indicated that the intended TRO sensor 

was not suitable for use with seawater and that an alternative TRO sensor was to be used in this 

system. The Group recommended the sensor, eventually selected, be verified as appropriate for 

the application intended. 

2.7 It was also noted that the applicant indicated that the hydrogen and chlorine gases 

generated as part of the electrolysis process are to be safely vented to the open deck with a degas 

blower. 

3 CHEMICALS ASSOCIATED WITH THE SYSTEM 

3.1 The Group noted that the En-Ballast system produces: 

 .1 free chlorine in the form of hypochlorous acid (HOCl) in equilibrium with 

hypochlorite ion (OCl-

); 

 .2 hypobromous acid (HOBr in equilibrium with hypobromite ion (OBr-); 

 .3 chloroamines and bromines; and 

 .4 free hydroxyl radicals which are very short lived and so did not need to be 

considered further for risk assessment. 

3.2 It was also noted that the applicant regarded these as Active Substances and, when 

considered as a whole, could be grouped as Total Residual Oxidants (TRO) and Free Residual 

Oxidants (FRO). 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 5 

I:\MEPC\60\2-16.doc 

3.3 Concentrations of TRO and FRO, found by the applicant, are shown in the table below: 

Concentrations of Free Residual Oxidant (FRO) and Total Residual Oxidant (TRO) 

Salinity 35 PSU 23 PSU 

 FRO3 TRO3 FRO3 TRO3 Time 

MDL (mg/L) 0.05 0.2 0.05 0.2 

Test water 1 ND ND ND ND 

Control ND ND ND ND 

Electrolyzer 180.00 460.0 280.00 495.0 Day 0 

Treated 3.00 4.1 2.80 5.2 

Control ND ND ND ND Day 1 Treated 1.40 2.3 1.00 1.8 

Control ND ND ND ND 

Treated 0.80 1.4 0.15 0.25 Day 5 Treated after 

neutralization < 0.05 < 0.2 NA2 NA2 

1 Test waters including organisms (≥50 μm, ≥10-50 μm), starch, and glucose to correspond with 

Guidelines (G8). 

2 The water is not neutralized because the concentration of TRO is <0.25 mg/L. 

 3 FRO was measured by method using the ortho-tolidine and TRO was measured by the method using DPD 

(N,N-diethyl-p-phenylenediamine). 

3.4 The Group noted that FRO was measured by the method using the ortho-tolidine, which 

had been supplanted by other methods using DPD because of its carcinogenic properties. From 

the view point of GHS, the Group invited to the applicant and test facility not to use the method 

using the ortho-tolidine anymore even if it is still in common on domestic standards.

3.5 The Group noted that during this initial testing, neutralization was deemed unnecessary 

for a discharge concentration of 0.25 mg/L TRO. The Group recommended that an MADC for 

TRO of 0.20 mg/L or lower should be maintained at all times to gain acceptance for Final 

Approval. 

3.6 In addition to the Active Substances, the results from the analysis of Relevant Chemicals 

in ballast water are shown in appendix 1. 

3.7 From the results shown in the tables in appendix 1, the Group noted that thirty-two 

compounds were detected in test water, control water and treated water. Of these, those 

identified as being produced by the En-Ballast BWMS were the subject of further risk 

assessment. 

3.8 In addition to the Relevant Chemicals identified, the Group noted that the applicant had 

also identified the following “Other Chemicals”: 

 .1 Ozone; 

 .2 chlorine dioxide; and 

 .3 sulphide. 
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4 QUESTIONS PUT TO THE APPLICANT WITH RESPONSES AND THE 

GROUP’S REACTION 

4.1 Questions raised prior to the meeting 

4.1.1 The following questions were put to the applicant and their responses are shown together 

with the Group’s reactions. 

Question 1 In section 7.4 of their application (Human Exposure Scenario), there is a table 

showing the potential exposure to various chemicals which is used to calculate the 

MOS. 

 Please could you provide details of how the exposure was calculated and, 

if possible, could you provide a worked example for one of the chemicals 

e.g., tribromomethane. 

Response 1 We calculated MOS according to GESAMP-BWWG 3/9 (MEPC 56/2/2, annex 9, 

2007). 

 In case of tribromomethane, assuming that the exposure of a human population in 

drinking water is 0.232 mg/L, obtained from the treated water analysis result, 

for 60 kg person consuming on average 2 L of water/day. 

 

 And LOAEL of tribromomethane is 100 mg/kg/day in mice. Therefore we can 

calculate MOS on the followed equation. 

 

 Then, we obtain 12,931, MOS value of tribromomethane. 

Reaction 1 The Group noted this response. 

Question 2 In paragraph 7.2 of the submission (Risks to human health), it is stated that “ship’s 

personnel would not be expected to contact Active Substances and Relevant 

Chemicals under normal operation”. However, this does not take account of the 

following situations: 

 

 .1 Entering the ballast tank post discharge; 

 
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.2 Sampling operations and other unit operations which might bring 

personnel into contact with the treated ballast water; 

 

 .3 Accidental exposure due to equipment malfunction. 

 Please could you explain why these situations were not addressed in your 

application. 

Response 2 There are no gases in the treated water. Therefore, toxicities and risks to the ship’s 

crews and other interested persons from gas exposure would not be expected. 

 Table 1 shows the margin of safety (MOS) with maximum concentration in the 

“En-Ballast” BWMS. 

 These MOS value are substantially higher than the MOSref (100), except for 

chloropicrin, and we expect that crews and other interested persons will not have 

any harmful effects on accidental exposure. 

 Since we selected the highest concentrations obtained from the electrolyzer’s 

chemical analysis, MOS value of chloropicrin is lower than the MOSref. 

 While the MOS values for the electrolyzer’s products are lower than MOSref, the 

MOS value for the treated water is higher than MOSref. Therefore, we expect that 

chloropicrin can cause toxicity to human when exposed to water through 

immediate electrolysis. 

 Chloropicrin is a hazardous and colourless liquid with intensely irritating tear gas 

odour. This may cause severe eye irritation with corneal injury which may result 

in permanent impairment of vision, even blindness. It also causes painful 

irritation of the eyes at 1 ppm or less and a concentration of 15 ppm for longer 

than 1 minute is intolerable to humans. Chloropicrin may cause severe skin burns 

and is classified as corrosive according to DOT guidelines. Chloropicrin is also 

toxic to fish and other aquatic organisms. 

 In the event of accidental exposure, immediately evacuate the area of spill or leak. 

Use a NIOSH/MSHA approved self-contained breathing apparatus and other 

appropriate personal protective equipment for entry into affected area to correct 

problem. Move leaking or damaged containers outdoors or to an isolated location, 

observing strict safety precautions. Work upwind if possible. Allow spilled 

material to evaporate or absorb onto vermiculite, dry sand, earth or similar 

absorbent material which may be disposed of on site, or at an approved disposal 

facility. Do not permit entry into spill area or cleanup area by unprotected persons 

until concentration of chloropicrin is determined to be less than 0.1 ppm. 

 If sampling operations and other unit operations which might bring personnel into 

contact with the treated ballast water, personnel should wear protective clothing. 

Open the container only in a well-ventilated area wearing protective clothing and 

respiratory protection if necessary. 

 Avoid eye, skin and clothing contact. Do not breathe mist or vapour. 
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Reaction 2 The Group was satisfied with this response. 

Question 2.1 With regard to question 2, perhaps I made a mistake in referring to gases in the air 

above the ballast water. What I meant to refer to were those chemicals produced 

in the ballast water, as a result of treatment, which then partition out into the air 

above. These are the vapours which the crew could be exposed to in the event of 

having to enter the tank. 

Response 2.1 Hydrogen gas – As a side reaction of electro-chemical production of chlorine, 

hydrogen gas is produced on cathode of electrolytic cell. 

 Hydrogen gas is removed by air blowers of electrolysis module before the treated 

ballast water enters ballast tank and so there is little hydrogen gas in ballast tank. 

 Chlorine gas – As a side reaction of electrochemical production of chlorine, 

chlorine gas is produced on anode of electrolytic cell. However, chlorine gas 

produced during electrolysis is removed by air blowers before the treated ballast 

water enters ballast tank. 

 When the treated ballast water containing hypochlorous acid and hypochlorite is 

exposed to the atmosphere, liquid chlorine in the treated water vaporizes to 

chlorine gas. So chlorine gas may exist in ballast tank after de-ballasting 

operation. 

 Chlorine gas has an irritating odour and is harmful if inhaled, respiratory tract 

burns, skin burns and eye burns. The recommended exposure limits of chlorine 

gas are; TLV (threshold limit value) as TWA (time weighted average) is 0.5 ppm, 

as STEL(short term exposure limit) is 1 ppm. 

 It is recommended that the MSDS of chlorine gas is supplied to manage safe 

handling. 

 In the event of having to enter the ballast tank, the chlorine gas in ballast tank 

should be diluted and vented out by gas freeing fan. 

 Also crews should put on goggles, rubber shoes, glove, respirator. 

Reaction 2.1 The Group noted this response. 

Question 3 In your application, reference is made to hydrogen gas being produced and that 

this is diluted and vented to atmosphere to keep the concentration <1%. 

 Please could you tell me how the concentration of hydrogen is monitored to 

ensure that levels are kept safe. 

 Is there any sort of shut-down facility should the levels rise. 

Response 3 During electrochemical process, hydrogen is generated as a by-product on cathode 

of electrolytic cell. Hydrogen is highly explosive, it is should be removed as soon 

as possible when it is generated. The Electrolysis module has air blowers which 

blows the air into the NaOCl storage tank. 
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 Hydrogen accumulated in NaOCl storage tank is diluted by air blowing and 

vented overboard by internal pressure of NaOCl storage tank. 

 We can select the capacity of the air blowers because it is possible to calculate the 

volume of hydrogen gas generated during electrolysis process.

 A hydrogen concentration sensor will be equipped on ventilation pipe to monitor 

the concentration of the hydrogen gas. If the concentration of hydrogen gas is 

between 1~3%, En-Ballast system gives the alarm, and if the concentration of 

hydrogen gas is over 3%, then En-Ballast system is to shut down. 

 Blowers are not applied in lab scale En-Ballast for Basic Approval because 

lab-scale En-ballast is very small scale. However, we will apply air blowers for 

dilution of hydrogen in land-based “En-Ballast” for Final Approval. 

 If the parts of En-Ballast system such as electrolyzer, connection piping, NaOCl 

storage tank and pumps are damaged by mechanical defect, hydrogen can leak 

out, so hydrogen gas detector should be installed to detect leakage of hydrogen. 

 When hydrogen gas detector detects the leakage the hydrogen gas, En-Ballast 

system should be automatically shut down and would be isolated from main 

ballast line by emergency isolation valves. 

Reaction 3 The Group were satisfied with this response. 

Question 4 In tables 20 and 21 of your submission to IMO, there is a reference to “sulphide”. 

 I cannot see where this chemical comes from. Should it be a reference to sodium 

thiosulphate? If not, where does the sulfide come from? 

Response 4 Sulphide rarely exists in natural seawater. Also sulfide doesn’t come from 

Sodium thiosulphate as neutralizing agent. Meanwhile, a high portion of sulphide 

in the seawater may be responsible for metal corrosion. 

 Refer to the following: 

 “Many metal sulphides are so insoluble in water that they are probably not very 

toxic. But dissolved free sulphides (S-2, H2S and HS-

) are very aggressive species 

for the corrosion of many metals such as steel, stainless steel, and copper. 

Sulfides present in aqueous solution are responsible for stress corrosion cracking 

(SSC) of steel. Also, microbially-induced corrosion (MIC) or biogenic sulphide 

corrosion are also caused by sulfate reducing bacteria producing sulphide.” 

 We made efforts to analyze as many kinds of chemicals as possible. Sulfide was 

only one of the chemicals to be analyzed. As shown in tables 20 and 21, sulfide 

was not detected in the result of chemical substances analysis. 

Reaction 4 The Group were satisfied with this response. 
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4.2 Questions raised during the meeting

4.2.1 The following questions were put to the applicant during the meeting and their responses 

are shown together with the Group’s reactions. 

Question 1 In the QAPP for “EnBallast” and test report of chemical analysis, there is no 

description of the analytical method for FRO. Could you provide details of the 

analytical method used for FRO and provide the distinguishing definition between 

TRO and FRO in your report? 

Response 1 FRO analysis was performed according to “Drinking Water Quality Standard and 

Test ES 05310.1, Korea : 2008”. This method is the ortho-tolidine method but we 

could not find the documentation in English. We will send this to you 

immediately we find the document in English. 

FRO includes hypochlorous acid (HOCl), hypochlorite ion (OCl-), hypobromous 

acid (HOBr), hypobromous ion (OBr-), Chlorine(Cl-), Bromine(Br-) and so on. 

FRO react rapidly with ammonia and amino nitrogen compounds in seawater and 

this react produces chloramines and bromamines which are called ‘Combined 

Residual Oxidants’. 

FRO is a more powerful disinfection agent than ‘Combined Residual Oxidants’ 

TRO includes FRO and ‘Combined Residual Oxidants’. 

Reaction 1 The Group noted this response. 

Question 2 The Group noted that the starting date, as reported in the aquatic toxicity test 

report, for the all acute toxicity testing was one day after the sampling date. The 

Group understands that the TRO had been already neutralized before sampling so 

that degradation of TRO during this one day is irrelevant. However, the Group 

bconsidered that there is still a possibility that volatile organic compounds, such 

as THMs, could be reduced during this period and this may underestimate the total 

toxicity significantly. 

 How the samples were kept during this period; was chemical analysis undertaken 

before and after this period and, if so, can you provide the results. 

Response 2 Samples were carried by a refrigerator car and were kept at 20°C during 

transportation. These samples were transported to the laboratory within one hour 

and were kept at 4°C under dark condition in a 200 litre PE bottle. 

 (Refer to appendix 4, section 3, non-confidential version report 3.1.8, 3.2.8, 3.3.8) 

Reaction 2 The Group noted this response. 
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Question 3 Are there any results for chronic toxicity testing? 

 If your answer is negative, could you clarify the reasons for this omission? 

Response 3 We did not performe chronic toxicity testing in the laboratory-scale test because 

chronic toxicity testing requires a large amount of control and treated water and 

requires long period. However, we will have chronic toxicity test data from the 

full scale land-based test. 

Reaction 3 The Group were satisfied with this response 

Question 4 In the Table 7 of your non-confidential version report, it is noted that the 

measurement of TRO was performed the by US EPA’s titration method. Is there a 

difference between TRO values manually measured and those measured by the 

TRO sensor? 

Response 4 We failed to get effective values from the TRO sensor in the laboratory scale test. 

What we learned from the laboratory scale test is that a TRO sensor, using 

amperometric method, was not suitable for seawater. As a result, we have been 

testing another TRO sensor using DPD method, and were able to obtain consistent 

results from that sensor. 

Reaction 4 The Group was satisfied with this response 

Question 5 It is noted that it took almost two months before the chemical analysis was 

completed i.e. sampling for ballasting was started on 28th April 2009 and the 

chemical analyses were finished on 12th June 2009. What was the actual date for 

the measurement for the TRO and other volatile compounds against sample 

named S33S1D0, S33S2D5 and S33S5D5? 

Response 5 TRO measurements for 33PSU water were performed on 2009/5/13 (0 day), 

2009/5/14 (1 day) and 2009/5/18 (5 day). 

TRO measurements for 20PSU water were performed on 2009/5/20 (0 day), 

2009/5/21 (1 day) and 2009/5/25 (5 day). 

 The measurement of S33S1D0 was performed on 2009/5/13 (0 day), 

The measurement of S33S2D5and S33S5D5 was performed on 2009/5/18 (5 day). 

(Refer to appendix 3 ‘Analysis results of water collected from the En-Ballast 

BWM system”)

Reaction 5 The Group was satisfied with this response. 

Question 6 In the table 3, on page 9 of the “system description of the laboratory-scale 

“En-ballast” BWM system (appendix 1 of dossiers), the sensitivity of TRO sensor 

can be selected from three ranges; 0-0.2 mg/L, 0-2 mg/L and 0-20 mg/L. Do you 

have any plan for the setting of MADCs for TRO which could be set to less than 

0.22 mg/L under the control using 0-2 mg/L? 
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Response 6 As shown as Response 4, the TRO sensor which was used for laboratory-scale test 

was found to be unsuitable for seawater. We will use the TRO sensor which 

utilizes the DPD method of which the range of measurement is 0~10mg/L. The 

resolution is 0.01mg/L and the accuracy is 0.02mg/L. If we set the upper limit of 

the measured value of TRO to 0.18mg/L, even though in the worst case, the actual 

value of TRO will not overrun the limit for discharge of 0.2mg/L, we will reflect 

this idea in our land-based test for Final Approval. 

Reaction 6 The Group was satisfied with this response 

Question 7 Are there any analytical data for other chemicals in both salinities of treated water 

at “5 day before neutralization”; 

Response 7 As you know, we analyzed treated and control water as below; 

 0 day 1 day 5 day 

35 PSU Control Immediately after 

electrolysis (storage 

tank for electrolysis 

water) 

Treated Control 

Treated 

Control 

Treated 

(after neutralization) 

23 PSU Control Immediately after 

electrolysis (storage 

tank for electrolysis 

water) 

Treated Control 

Treated 

Control 

Treated 

(not neutralization) 

There are no more data in both salinities of treated water at “5 day before 

neutralization”. 

Reaction 7 The Group noted this response 

5 WHOLE EFFLUENT TESTING 

5.1 Acute ecotoxicity tests 

5.1.1 The Group noted the results from the acute ecotoxicity tests carried out on treated ballast 

water, Whole Effluent Tests (WET) as shown in the tables below: 

Acute aquatic toxicity of 35 PSU ballast water treated by the “En-Ballast” BWMS 

LC50 and/or EC 50 Species End point Conc.(%) Reference

Algae Skeletonema costatum 72 h EC50 90.19 Tested (OECD 201) 

Crustacean Tigriopus japonicus 48 h EC50 

48 h LC50 

>100 

>100 Tested (OECD 202) 

Fish Paralichthys olivaceus 96 h LC50 >100 Tested (OECD 203) 
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Acute aquatic toxicity of 23 PSU ballast water treated by the “En-Ballast” BWMS 

LC50 and/or EC 50 Species End point Conc.(%) Reference 

Algae Skeletonema costatum 72 h EC50 68.53 Tested (OECD 201) 

Crustacean Tigriopus japonicus 48 h EC50 

48 h LC50 

>100 

>100 Tested (OECD 202) 

Fish Paralichthys olivaceus 96 h LC50 >100 Tested (OECD 203) 

5.1.2 The Group noted that the simulated ballast water of the laboratory-scale test was used for 

these tests. The 33 PSU ballast water were prepared with five days holding time and neutralized 

with thiosulphate. In contrast, the 23 PSU ballast water samples were prepared with five days 

holding time without any neutralization, because the TROs were less than 0.25 mg/L. The Group 

also noted that, before starting the exposure, a one day preparation period was needed to adjust 

the temperature between the ballast water and control water for test organisms. 

5.1.3 From these results, the Group agreed that the “En-Ballast” system had an acute toxic 

effect on the growth of diatom, Skeletonema costatum only. Other organisms were not affected 

by the same treated seawater. 

5.1.4 The Group was satisfied with QA/QC for these tests in general. However, the Group 

considered that the acute toxicity against the diatom was higher than that predicted from the 

concentration of TRO and that from similar BWMS with neutralization. The Group invited the 

applicant to re-check the apparent anomaly of this toxicity which might have been caused by high 

POC in the original G8 test water. If the applicant finds the reason for this anomaly, a 

modification of the test procedure, such as pre-filtering before exposure, might be accepted. 

5.2 Chronic ecotoxicity tests 

5.2.1 The Group noted that the chronic ecotoxicity tests had not been performed in this 

application for Basic Approval. The Group also noted that the applicant had recognized the need 

for chronic toxicity testing and further risk characterization according to the results of acute 

toxicity tests above. It was agreed that the chronic ecotoxicity tests should also be provided as 

these were missing in the application for Basic Approval. 

5.2.2 The Group emphasized that Procedure (G9) clearly requires both acute and chronic 

ecotoxicity testing for Basic Approval. The Group recalled that it had, previously, made a case 

for waiving the chronic toxicity testing for some BWMS applications for Final Approval 

providing the chemical analysis demonstrated that the concentrations of chemical by-products are 

similar to those provided in the application for Basic Approval. 

5.2.3 However, in this case, the Group recommended that, for Final Approval, in addition to the 

required acute toxicity test results, chronic toxicity test results, carried out in accordance with 

Procedure (G9), should also be provided as these were missing in the application for Basic 

Approval, because the analogy with earlier systems are not valid in this case. 
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5.3 Biomagnification 

5.3.1 In addition, some data on bioavailability/biomagnification had been provided for the 

Active substances and Relevant Chemicals as shown in appendix 2. 

6 HUMAN HEALTH ASSESSMENT 

6.1 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 equilibrium with hypochlorous acid is: 

 .1 severely corrosive to skin at concentrations >5%; 

 .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 

 .1 acutely toxic if swallowed; 

 .2 acutely toxic if inhaled; 

 .3 acutely toxic in contact with skin; and 

 .2 corrosive to skin, 

 .4 halo-alkanes/alkenes

 .1 harmful if swallowed, inhaled or in contact with the skin; 

 .2 narcotic; and 

 .3 irritating, 

 .5 halo-aromatics 

 .1 harmful if swallowed, inhaled or in contact with the skin; 

 .2 skin irritant; and 

 .3 possible carcinogen, 

.6 halo-acetonitriles

 .1 harmful by inhalation, if swallowed and in contact with the skin; and 

 .2 irritating to skin, eyes and the respiratory system, 

 .7 halo-phenols 

 .1 harmful if swallowed; and 

 .2 irritant to skin and eyes; and 

 .8 Sodium thiosulphate

 .1 irritating to skin, eyes and the respiratory system. 
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7 RISKS TO THE SAFETY OF THE SHIP, ITS CREW AND THE GENERAL 

PUBLIC 

7.1 Risks to the safety of the ship – Corrosion

7.1.1 The Group noted that the applicant had indicated that corrosion tests will be carried out 

with on steel exposed to the treated water of HOCl for a period of six months following an aging 

period of two months. This test is to be carried out in parallel with the full-scale land-based 

testing. The Group noted that these tests alone are unlikely to be sufficient to make a 

comprehensive assessment of the corrosivity of this Active Substance. 

7.1.2 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.

7.1.3 The Group recognized that the selection of corrosion resistant materials and construction 

details for the electrolysis unit and piping containing the concentrated solution of TRO prior to 

injection into the main ballast piping will be crucial to the expectation of continued integrity of 

the system. The same considerations apply to the storage tank and supply piping for the 

neutralization system. The Group, consequently, recommended that these details be fully 

considered and clearly identified in the operating manual for this treatment system when any 

submission is presented for Final Approval. 

7.2 Risks to the safety of the ship – Fire and/or explosion 

7.2.1 The Group noted that free hydrogen gas is generated as a by-product of electrolysis and 

that the Lower Explosion Limit (LEL) of hydrogen is 4%. However, it was noted that the system 

dilutes any such gas produced to ensure that limits are kept below 1%. 

7.2.2 As a result, the Group agreed that the risks of fire and/or explosion due to the production 

of hydrogen were acceptable providing the risk mitigation measures identified in the submission 

are applied as indicated. 

7.3 Risks to the Crew from exposure to treated ballast water

7.3.1 The Group noted that the applicant had stated that, under normal operations, there would 

be no risk to human health associated with treated ballast water as the ship’s personnel would not 

come into contact with it. 

7.3.2 The Group could not agree with this assumption as there will always be a risk of 

equipment breakdown and leakage, especially as the TRO concentration produced by the 

electrolyser is considered high at 500 mg/L-2000 mg/L. Furthermore, the risks associated with 

the loading and mixing of the neutralizer chemical, sodium thiosulphate, requires full assessment 

with appropriate risk mitigation measures and procedures to be put in place and clearly detailed 

in the system operating manual. The Group recommended these basic operational concerns be 

fully addressed in any application for final approval. 

7.3.3 Notwithstanding the above observations, 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. Therefore, the Group considered that 

there was a level of uncertainty concerning the safety of this system as presented. 
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7.3.4 The Group recommended that such information should be fully supported and 

documented in any application for Final Approval. 

7.4 Risks to the general public from exposure to treated ballast water

7.4.1 The Group noted that the applicant had carried out a risk assessment, assuming that the 

exposure would be to undiluted treated ballast water and so the general public would be exposed 

to the maximum concentration of each chemical produced as a result of the treatment. 

7.4.2 The results of this risk assessment are shown in the table below: 

Compounds Value 1 

(mg/kg/day) 

Maximum 

concentration 

(mg/L) 

Exposure 

(mg/kg/day) MOS 

Chlorine dioxide LOAEL: 2 0.02 6.67E-04 3,000 

Bromate ion NOAEL: 7.7 0.00217 7.23E-05 106,452 

Dibromochloromethane NOAEL: 40 0.00879 2.93E-04 136,519 

Dibromomethane Not found 0.00041 1.37E-05 NA 

Dichlorobromomethane NOAEL: 13.4 0.00019 6.33E-06 2,115,789 

Tribromomethane LOAEL: 100 0.232 7.73E-03 12,931 

Dibromoacetonitrile NOAEL: 8.2 0.00103 3.43E-05 238,835 

Chloral hydrate NOAEL: 1.89 0.00002 6.67E-07 2,835,000 

Chloropicrin NOAEL: 0.002 0.00034 1.13E-05 176 

2-monochloroacetic acid NOAEL: 193 0.0429 1.43E-03 134,965 

2,2-dichloroacetic acid NOAEL: 3.9 0.00541 1.80E-04 21,627 

2,2-dibromoacetic acid NOAEL: 25 0.00179 5.97E-05 418,994 

2,2,2-tribromoacetic acid Not found 0.00129 4.30E-05 NA 

Dalapon acid Not found 0.0503 1.68E-03 NA 

7.4.3 The Group concurred with the applicant that the MOS values for exposure to bromoform, 

having been calculated using an unrealistic and conservative scenario, infer that there will be no 

unacceptable risk to the general public when swimming in the coastal area where treated ballast 

water has been discharged. 

7.4.4 However, the Group considered that the MOS for chloropicrin (176) is close to MOSref 

(100). As chloropicrin is considered to be highly toxic (harmful if swallowed, very toxic by 

inhalation, irritating to eyes, skin and respiratory system, may cause sensitization by skin 

contact), the Group recommended that the presence of chloropicrin be further assessed as part of 

the testing for Final Approval and the need for risk mitigation measures. 

7.4.5 The Group considered the risk assessment for the general population exposed to the 

chemical by-products of this system from eating fish. It was agreed that there was a low 

potential for these chemicals to be bioconcentrated and so there should be no unacceptable risk to 

the general population (see table under section 8.3.1). 
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7.4.6 Notwithstanding the above observations, and having considered all of the information 

provided by the applicant, the Group agreed that there should be no unacceptable risks to the 

general public from exposure to ballast water treated by this system. 

8 ENVIRONMENTAL RISK ASSESSMENT 

8.1 Calculation of Predicted Environmental Concentrations (PEC) 

8.1.1 The Group noted that the applicant had employed the MAMPEC model to estimate the 

PECs of those chemicals produced by the system. 

8.1.2 It was also noted that, to obtain such PEC estimates, the default commercial harbour 

using statistical data for the Port of Rotterdam had been used in the MAMPEC model, the results 

of which are shown below: 

Estimation of PECs for chemicals produced by the “En-Ballast” BWMS 

MAMPEC result 

Compounds (μg/L) 1 Load 

(g/day) 2 

Maximum 

concentration 

(μg/L) 3 

Half-life 

(day) Harbour 

Chlorine dioxide 0 0 15 0 

Bromate 0.8613207 2.17 15 2.00E-06 

Dibromochloromethane 3.4889443 8.79 38 4.96E-06 

Dibromomethane 0.1627380 0.41 15 3.81E-07 

Dichlorobromomethane 0.0754151 0.19 38 1.01E-07 

Tribromomethane 92.085904 232 38 1.24E-04 

Dibromoacetonitrile 0.4088296 1.03 38 5.51E-07 

Chloral hydrate 0.0079384 0.02 38 1.07E-08 

Chloropicrin 0.1349534 0.34 60 1.38E-07 

2-monochloroacetic acid 17.027953 42.9 15 4.05E-05 

2,2-dichloroacetic acid 2.1473480 5.41 15 5.07E-06 

2,2-dibromoacetic acid 0.7104903 1.79 15 1.68E-06 

2,2,2-tribromoacetic acid 0.5120293 1.29 15 1.21E-06 

Dalapon acid 19.965176 50.3 38 2.69E-05 

1 Active Substance and Relevant Chemicals. 

2 Load amount estimated from the OECD-EU commercial harbour (Rotterdam), 396,922 m3

 per day of discharge. 

3 The worst case applied. 

8.1.3 The Group disagreed with the calculations presented by the applicant because some 

incorrect data had been used when running MAMPEC. Firstly, the load of the substances 

presented in the table in 8.1.2 was a factor of 1000 too low compared to the results of the 

calculations with MAMPEC as presented in annex 6 of the confidential information and secondly 

the maximum worst case concentration was not always used. Thirdly, in the input values for all 

substances the half-life as presented in the table were inserted in MAMPEC under de heading of 

the degradation rate when the following value should have been used: k = ln(2)/DT50. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 18 

I:\MEPC\60\2-16.doc 

8.1.4 The Group recalculated the concentrations for bromoform in the harbour using the data 

provided with corrected load and half-life values. The result obtained was a maximum 

concentration of 5.27 μg/L. 

8.2 Calculation of PEC/PNEC ratios

8.2.1 The Group noted the results of calculating the PEC/PNEC ratios for those chemicals 

produced by the system, as shown in the table below: 

PEC/PNEC ratio from MAMPEC modelling result 

Compounds Toxicity 

(mg/L) 

Assessment 

factor 

PNEC 

(μg/L) PEC (μg/L) PEC/PNEC (μg/L) 

Chroline dioxide 2.6 100 26.00 0 0 

Bromate ion 0.125 1000 0.13 2.00E-06 1.60E-05 

Dibromochloromethane 34 1000 34.00 4.96E-06 1.46E-07 

Dibromomethane - - - 3.81E-07 - 

Dichlorobromomethane 1.424 1000 1.42 1.01E-07 7.09E-08 

Tribromomethane 10 100 100 1.24E-04 1.24E-06 

Dibromoacetonitrile 0.55 1000 0.55 5.51E-07 1.00E-06 

Chloral hydrate 2.8 1000 2.80 1.07E-08 3.82E-09 

Chloropicrin 0.0165 1000 0.02 1.38E-07 8.36E-06 

2-monochloroacetic acid 32 100 320.00 4.05E-05 1.27E-07 

2,2-dichloroacetic acid 1485 1000 1485.00 5.07E-06 3.41E-09 

2,2-dibromoacetic acid 69 1000 69.00 1.68E-06 2.43E-08 

2,2,2-tribromoacetic acid - - - 1.21E-06 - 

Dalapon acid 10 1000 10.00 2.69E-05 2.69E-06 

* No toxicity value (see Table 30). 

8.2.2 The Group did not agree with the PEC/PNEC-ratios as presented in the table of 8.2.1 

because the PECs are not correct. 

8.2.3 The Group performed a recalculation of the PEC/PNEC ratio for bromoform using the 

PEC of section 8.1.4. The ratio PEC/PNEC = 5.27/100 = 0.0527, which is still <1. Therefore, 

the Group agreed that the EnBallast system should not cause any unacceptable environmental 

risks. However, it was recommended that the applicant should redo the calculations with the 

correct input data in the application for Final Approval. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 19 

I:\MEPC\60\2-16.doc 

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

8.3.1 The Group noted the PBT characteristics of those chemicals produced by the system as 

shown in the table below: 

PBT evaluation based on water 

Compounds 

Persistent 

(y/n) 

(Va/Tb/Hc) 

Bioaccumulatived

(y/n) 

Toxic 

(y/n) 

Chlorine dioxide No 

3.0501/w/15 d in water 

No

Log Pow = -3.22 

No 

Acute LC50: 2.6 mg/L/24 hr 

(algae) 

Bromate No 

3.0226/weeks/15 d in water 

No

Log Pow = 0.63 

No 

NOEC: >0.125 mg/L/168 hr 

(algae) 

Dibromochloromethane 

No 

2.6386/weeks-months/38 d 

in water 

No 

Log Pow = 1.70 

No 

LC50: 34 mg/L/72-1200 hr (fish) 

Dibromomethane No 

2.8729/weeks/15 d in water 

No 

Log Pow = 1.52 Not found 

Dichlorobromomethane 

No 

2.5197/weeks-months/38 d 

in water 

No 

Log Pow = 1.61 

No 

LC50: 1.424 mg/L/9 months (fish) 

Tribromomethane 

No 

2.7275/weeks-months/38 d 

in water 

No 

Log Pow = 1.79 

No 

NOEC: 10 mg/L/96 hr (algae) 

Dibromoacetonitrile 

No 

2.7353/weeks-months/38 d 

in water 

No 

Log Pow = 0.47 

No 

Acute LC50: 0.55 mg/L/96 hr (fish) 

Chloral hydrate 

No 

2.4219/weeks-months/38 d 

in water 

No 

Log Pow = 0.98 

No 

Acute LOEC: 2.8 mg/L/NRe

(algae) 

Chloropicrin No 

2.1043/months/60 d in water 

No 

Log Pow = 1.32 

No 

Acute LC50: 0.0165 mg/L/96 hr 

(fish) 

2-monochloroacetic acid No 

3.1818/weeks/15 d in water 

No 

Log Pow = 0.34 

No 

NOEC: 32 mg/L/504 hr 

(crustacea) 

2,2-dichloroacetic acid No 

2.9325/weeks/15 d in water 

No 

Log Pow = 0.52 

No 

EC03: 1,485 mg/L/168 hr (algae) 

2,2-dibromoacetic acid No 

3.1403/weeks/15 d in water 

No 

Log Pow = 0.70 

No 

Acute LC50: 69 mg/L/96 hr (fish) 

2,2,2-tribromoacetic acid No 

2.7827/weeks/15 d in water 

No 

Log Pow = 1.71 Not found

Dalapon acid 

No 

2.6894/weeks-months/38 d 

in water 

No 

Log Pow = 1.68 

No 

Acute LC50: 10 mg/L/24 hr (fish) 

a Numerical value from model; 

b Words assigned, representing expected total degradation time; 

c Half-life; 

d U.S EPI suite 2008; 

e Time information not reported. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 20 

I:\MEPC\60\2-16.doc 

8.4 Interpretation of the results

8.4.1 The Group agreed that: 

 .1 the recalculated PEC/PNEC ratios based on corrected MAMPEC input for all of 

the potential chemical by-products do not result in unacceptable risk to the 

environment; based on the laboratory test with treated ballast water some effects 

may be expected on the local scale; 

 .2 none of the by-products met the PBT criteria which would have prevented the 

system from being used to treat ballast water; and 

 .3 whilst it was recognized that WET showed that treated ballast water showed some 

ecotoxicological effects, it was recognized that these would be diluted to an 

acceptable level. 

8.4.2 Based on the above observations, the Group agreed that the chemical by-products of this 

system should not pose any unacceptable risk to the marine environment in the quantities 

produced, if neutralization is carried out adequately in every ballast water discharge. 

9 CONCLUSIONS AND RECOMMENDATIONS

9.1 Having considered all of the information provided by the applicant, the Group agreed 

that: 

 .1 ballast water treated by this system should not cause any unacceptable risk to the 

marine environment: 

 .2 ballast water treated by this system should not cause any unacceptable risk to the 

safety of the ship; 

 .3 ballast water treated by this system should not cause any unacceptable risk to the 

crew or general public; 

 .4 the required chronic toxicity test results, in accordance with Procedure (G9), 

should be provided, as it was missing in the application for Basic Approval; 

 .5 the TRO sensors’ sensitivity, reliability and its use in the neutralizer control 

should be confirmed as being appropriate to maintain the MADC of TRO; and 

 .6 the neutralization control system should be fully documented to give confidence 

in its reliability. 

9.2 Furthermore, the Group was not satisfied with the high detection limit of TRO 

as 0.2 mg/L could infer 0.249 mg/L. As a result, it was recommended that that the maximum 

allowable discharge concentration of TRO should be 0.20 mg/L as Cl2, or lower when applying 

for Final Approval and this value also needs to be verified by the analytical method used. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 21 

I:\MEPC\60\2-16.doc 

9.3 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 so that it can be taken into account if the 

system has to be reviewed for Final Approval in the future. 

9.4 The Group recommended that the presence of chloropicrin be further assessed as part of 

the testing for Final Approval and the need for risk mitigation measures. 

* * * 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 22 

I:\MEPC\60\2-16.doc 

APPENDIX 1 

CONCENTRATION OF RELEVANT CHEMICALS 

IN TREATED BALLAST WATER 

1.1 Concentration of halogenated volatile organic compounds in 35 PSU seawater 

35 PSU Day 0 

 

 

Day 1 

 

Day 5 

 

MDL 

(μg/L) Test water 1 Control Electro -lyzer Treated Control Treated Control 

Treated 

(neutralized) 

Absorbable organic 

halogens (AOX) 0.01 0.46 0.52 1.14 0.46 0.85 0.77 0.68 0.84 

1,1,1-Trichloroethane 0.01 0.01 0.01 0.07 0.01 N.D N.D N.D N.D 

1,1,2-Trichloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1-Dichloroethane 0.01 0.42 N.D 0.38 0.25 N.D 0.13 N.D N.D 

1,1,2,2-

Tetrachloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1,1,2-

Tetrachloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2,3-Trichlorobenzene 0.01 0.29 0.25 0.22 0.18 N.D 0.02 N.D N.D 

1,2,3-Trichloropropane 0.01 N.D N.D 0.01 N.D N.D N.D N.D 0.01 

1,2,4-Tribromobenzene 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2,4-Trichlorobenzene 0.01 0.30 0.27 0.26 0.21 N.D N.D N.D N.D 

1,2-Dibromo-3-

chloropropane 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1-Dichloroethene 0.02 0.25 0.20 N.D N.D N.D N.D N.D N.D 

1,2-Dichloropropane 0.02 N.D N.D 0.01 N.D N.D N.D N.D N.D 

1,3,5-Tribromobenzene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

2-Chlorotoluene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

4-Chlorotoluene 0.01 N.D 0.05 0.13 0.04 N.D N.D N.D N.D 

Bromobenzene 0.01 N.D N.D 0.20 N.D N.D N.D N.D N.D 

Bromochloromethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

Chlorobenzene 0.01 0.26 0.27 0.33 0.24 0.20 0.21 0.16 0.15 

cis-1,2-dichloroethene 0.02 N.D N.D 0.20 N.D N.D N.D N.D N.D 

Dibromomethane 0.01 N.D N.D 1.04 0.70 N.D 0.62 N.D 0.41 

Dichloromethane 0.02 0.54 N.D 0.40 0.17 0.47 0.26 0.42 0.33 

Tetrachloroethene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

Tetrachloromethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

trans-1,2-

dichloroethene 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

Dibromochloromethane 0.01 N.D ND 19.2 1.65 0 4.75 0 8.79 

Dichlorobromomethane 0.01 N.D ND 6.02 5.14 0 0.29 0 0.19 

Trichloromethane 0.01 0.24 0.25 1.20 0 0.16 0 0 0.00 

Tribromomethane 0.01 N.D 0.47 90.9 41.1 0.44 120 0.37 232 

1 Test waters including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 23 

I:\MEPC\60\2-16.doc 

1.2 Concentration of halogenated volatile organic compounds in 23 PSU seawater 

23 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electrolyzer Treated Control Treated Control 

Treated 

(not 

neutralized) 2 

Absorbable organic 

halogens (AOX) 0.01 0.53 0.46 0.85 0.43 0.48 0.70 0.79 0.77 

1,1,1-Trichloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1,2-Trichloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1-Dichloroethane 0.01 0.91 0.85 N.D N.D N.D N.D N.D N.D 

1,1,2,2-Tetrachloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1,1,2-Tetrachloroethane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2,3-Trichlorobenzene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2,3-Trichloropropane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2,4-Tribromobenzene 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2,4-Trichlorobenzene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,2-Dibromo-3-

chloropropane 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

1,1-Dichloroethene 0.01 0.43 0.42 0.54 0.52 0.15 0.38 N.D 0.20 

1,2-Dichloropropane 0.01 1.13 1.29 0.06 0.01 0.03 N.D N.D N.D 

1,3,5-Tribromobenzene 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

2-Chlorotoluene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

4-Chlorotoluene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

Bromobenzene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

Bromochloromethane 0.01 N.D N.D 0.52 0.41 N.D 0.11 N.D 0.02 

Chlorobenzene 0.01 0.29 0.21 0.30 0.29 0.23 0.24 0.20 0.15 

cis-1,2-dichloroethene 0.01 N.D N.D N.D N.D N.D N.D N.D N.D 

Dibromomethane 0.01 N.D N.D 5.92 5.11 N.D 1.29 N.D 0.48 

Dichloromethane 0.01 1.60 0.58 8.63 4.83 0.44 0.99 N.D 0.66 

Tetrachloroethene 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

Tetrachloromethane 0.02 N.D N.D N.D N.D N.D N.D N.D N.D 

trans-1,2-dichloroethene 0.01 0.24 0.24 N.D N.D 0.09 N.D N.D N.D 

Dibromochloromethane 0.01 3.70 3.86 13.8 6.25 3.78 9.11 2.27 12.6 

Dichlorobromomethane 0.01 3.29 3.57 4.82 3.82 3.16 0.42 1.06 N.D 

Trichloromethane 0.01 4.44 3.61 5.44 4.83 3.37 4.08 1.78 4.17 

Tribromomethane 0.01 2.03 2.57 55.7 34.0 1.93 127 1.85 205 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

2

 The water is not neutralized because the concentration of TRO is < 0.25 mg/L, see chapter 3.3. 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 24 

I:\MEPC\60\2-16.doc 

2.1 Concentration of haloacetonitriles in 35 PSU seawater 

35 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electro -lyzer Treated Control Treated Control

Treated 

(neutralized) 

Trichloroacetonitrile 0.001 N.D N.D N.D N.D N.D N.D N.D N.D 

Dichloroacetonitrile 0.01 0.13 0.13 105 0.30 0.14 0.21 0.19 0.09 

Bromochloroacetonitrile 0.001 N.D N.D 2.69 N.D N.D N.D N.D N.D 

Dibromoacetonitrile 0.001 0.12 0.14 8.71 2.20 0.13 1.19 N.D 1.03 

Chloral hydrate 0.001 N.D N.D 8.63 0.12 N.D 0.09 N.D 0.02 

Chloropicrin 0.001 0.01 0.01 80.7 3.61 0.01 3.23 0.01 0.34 

1 Test waters including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

2.2 Concentration of haloacetonitriles in 23 PSU seawater 

23 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electro -lyzer Treated Control Treated Control

Treated 

(not 

neutralized) 2 

Trichloroacetonitrile 0.001 N.D N.D 2.59 N.D N.D N.D N.D N.D 

Dichloroacetonitrile 0.01 0.49 0.47 28.0 3.15 0.41 2.32 0.43 0.14 

Bromochloroacetonitrile 0.001 N.D N.D 5.85 N.D N.D N.D N.D N.D 

Dibromoacetonitrile 0.001 0.15 0.14 38.2 30.1 0.04 29.5 0.05 22.1 

Chloral hydrate 0.001 0.27 0.21 17.0 0.08 0.25 0.13 0.23 0.13 

Chloropicrin 0.001 0.09 0.28 95.7 3.62 0.25 4.81 0.23 2.83 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

2 The water is not neutralized because the concentration of TRO is < 0.25 mg/L, see chapter 3.3. 

3.1 Concentration of halo acetic acids in 35 PSU seawater 

35 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electro -lyzer Treated Control Treated Control

Treated 

(neutralized) 

2-monochloroacetic acid 0.21 4.46 4.83 169 27.4 4.77 48.7 3.41 42.9 

2,2-dichloroacetic acid 0.12 N.D N.D 6.09 6.78 N.D 6.13 N.D 5.41 

2,2,2-trichloroacetic acid 0.03 1.10 1.14 46.1 14.7 1.27 0.65 1.53 0.51 

2-monobromoacetic acid 0.09 N.D N.D 2.85 2.45 N.D N.D N.D N.D 

2,2-dibromoacetic acid 0.03 0.71 0.75 8.50 4.74 0.77 2.03 0.78 1.79 

2,2,2-tribromoacetic acid 0.47 N.D 1.13 31.4 13.3 N.D 1.32 N.D 1.29 

2,2-bromochloroacetic 

acid 0.07 28.0 27.1 41.7 22.2 26.3 23.5 26.1 20.6 

2,2,2-bromodichloroacetic 

acid 0.08 6.10 6.76 9.43 5.45 5.56 1.43 5.29 1.25 

Dalapon acid 0.15 10.5 10.2 613 292 11.4 113 12.8 50.3 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 25 

I:\MEPC\60\2-16.doc 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

3.2 Concentration of halo acetic acids in 23 PSU seawater 

23 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electro -lyzer Treated Control Treated Control

Treated 

(not 

neutralized) 2 

2-monochloroacetic acid 0.21 20.9 20.8 332 41.9 18.5 38.4 18.6 20.7 

2,2-dichloroacetic acid 0.12 N.D N.D 11.5 1.25 N.D N.D N.D N.D 

2,2,2-trichloroacetic acid 0.03 7.86 7.85 212 8.50 2.07 5.88 0.58 4.90 

2-monobromoacetic acid 0.09 2.85 2.95 11.7 10.5 2.72 3.04 N.D 1.60 

2,2-dibromoacetic acid 0.03 1.14 1.09 26.2 18.3 1.08 15.7 1.05 11.6 

2,2,2-tribromoacetic acid 0.47 11.1 10.9 15.9 12.2 N.D 11.0 11.0 5.41 

2,2-bromochloroacetic acid 0.07 22.5 20.5 161 40.1 27.2 42.9 32.1 47.3 

2,2,2-bromodichloroacetic acid 0.08 3.56 3.56 71.9 4.66 3.31 4.32 3.28 3.87 

Dalapon acid 0.15 16.9 15.1 515 108 8.68 24.8 8.54 10.3 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

2 The water is not neutralized because the concentration of TRO is < 0.25 mg/L, see see chapter 3.3. 

4.1 Concentration of chlorinated phenols in 35 PSU seawater 

35 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water Control Electro -lyzer Treated Control Treated Control

Treated 

(neutralized) 

2-Chlorophenol 0.5 ND ND ND ND ND ND ND ND 

3-Chlorophenol 0.5 ND ND ND ND ND ND ND ND 

4-Chlorophenol 0.4 ND ND ND ND ND ND ND ND 

2,3-Dichlorophenol 0.3 0.78 0.58 0.60 0.81 ND ND ND ND 

2,4-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,5-Dichlorophenol 0.3 3.45 3.62 2.28 2.25 3.54 2.36 2.22 1.94 

2,6-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

3,4-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

3,5-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,4-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,3,5-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,3,6-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,4,5-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,4,6-Trichlorophenol 0.4 ND ND ND ND ND ND ND ND 

3,4,5-Trichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,4,5-Tetrachlorophenol 0.4 ND ND ND ND ND ND ND ND 

2,3,4,6-Tetrachlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,5,6-Tetrachlorophenol 0.6 ND ND ND ND ND ND ND ND 

Pentachlorophenol 0.4 ND ND ND ND ND ND ND ND 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 26 

I:\MEPC\60\2-16.doc 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

4.2 Concentration of chlorinated phenols in 23 PSU seawater 

23 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electro -lyzer Treated Control Treated Control

Treated 

(not 

neutralized) 2 

2-Chlorophenol 0.5 ND ND ND ND ND ND ND ND 

3-Chlorophenol 0.5 ND ND ND ND ND ND ND ND 

4-Chloophenol 0.4 ND ND ND ND ND ND ND ND 

2,3-Dichlorophenol 0.3 1.89 1.26 0.80 0.50 0.76 0.61 ND ND 

2,4-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,5-Dichlorophenol 0.3 3.55 3.82 2.78 2.65 3.12 2.44 2.15 1.54 

2,6-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

3,4-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

3,5-Dichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,4-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,3,5-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,3,6-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,4,5-Trichlorophenol 0.6 ND ND ND ND ND ND ND ND 

2,4,6-Trichlorophenol 0.4 ND ND ND ND ND ND ND ND 

3,4,5-Trichlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,4,5-Tetrachlorophenol 0.4 ND ND ND ND ND ND ND ND 

2,3,4,6-Tetrachlorophenol 0.3 ND ND ND ND ND ND ND ND 

2,3,5,6-Tetrachlorophenol 0.6 ND ND ND ND ND ND ND ND 

Pentachlorophenol 0.4 ND ND ND ND ND ND ND ND 

1 Test waters including organism (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

2 The water is not neutralized because the concentration of TRO is < 0.25 mg/L, see see chapter 3.3.

5.1 Concentration of bromated phenols in 35 PSU seawater 

35 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water 1 Control Electro -lyzer Treated Control Treated Control

Treated 

(neutralized) 

2,4-Dibromophenol 0.4 ND ND ND ND ND ND ND ND 

2,6-Dibromophenol 0.8 0.95 0.82 0.65 ND ND ND ND ND 

2,4,6-Tribromophenol 0.5 ND ND ND ND ND ND ND ND 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 
GESAMP-BWWG 12/6 

ANNEX 5 

Page 27 

I:\MEPC\60\2-16.doc 

5.2 Concentration of bromated phenols in 23 PSU seawater 

23 PSU Day 0 Day 1 Day 5 

MDL 

(μg/L) 

Test 

water1 Control Electro -lyzer Treated Control Treated Control

Treated 

(not 

neutralized) 2 

2,4-Dibromophenol 0.4 ND ND ND ND ND ND ND ND 

2,6-Dibromophenol 0.5 0.98 1.05 ND ND ND ND ND ND 

2,4,6-Tribromophenol 0.5 ND ND ND ND ND ND ND ND 

1 Test water including organisms (≥ 50 μm, ≥ 10-50 μm), starch, and glucose to correspond with Guidelines (G8). 

2 The water is not neutralized because the concentration of TRO is < 0.25 mg/L, see see chapter 3.3. 

* * * 
GESAMP-BWWG 12/6 

ANNEX 5 

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APPENDIX 2 

BIOCONCENTRATION DATA FOR ACTIVE SUBSTANCES 

AND RELEVANT CHEMICALS 

BIOCONCENTRATION OF ACTIVE SUBSTANCES 

Active Substance Measured/Calculated 

(L/Kg wet-weight) 

Reference 

3.16 (Regression-based 

estimate) 

Chlorine dioxide (ClO2)

0.89 (Arnot-Gobas) 

US EPA (EPI suit. 2008) 

3.16 (regression -based 

estimate) 

Bromate (BrO3

-

) 

1.13 (Arnot-Gobas) 

US EPA (EPI suit. 2008) 

Bioconcentration of Relevant Chemicals 

Relevant Chemical Measured/Calculated 

(L/Kg wet-weight) 

Reference 

3.96 (Regression-based 

estimate) 

Dibromochloromethane 

3.23 (Arnot-Gobas) 

US EPA (EPI suit, 2008) 

Dibromomethane 4 L/kg wet-wt HSDB, 1990 

Dichlorobromomethane 3.00 HSDB, 2008 

3.20 PBT Profiler, 2006 

Tribromomethane 2-20 L/kg wet-wt Kenaga, 1980 

Dibromoacetonitrile 3 L/Kg wet-wt HSDB, 2008

3.2 L/Kg wet-wt PBT Profiler, 2006

Chloral hydrate 3.00 HSDB, 2008 

Chloropicrin 11.10 US EPA (EPI suit, 2008) 

8.00 HSDB, 2008 

2-monochloroacetic acid 3.16 US EPA (EPI suit, 2008) 

3.20 HSDB, 2008 

2,2-dichloroacetic acid 3.16 US EPA (EPI suit, 2008) 

3.20 HSDB, 2008 

2,2-dibromoacetic acid 3.16 US EPA (EPI suit, 2008) 

0.17 HSDB, 2008 

3.162 (regression-based 

estimate) 

2,2,2-tribromoacetic acid 

5.185 (Arnot-Gobas) 

US EPA (EPI suit. 2008) 

3.162 (regression-based 

estimate) 

Dalapon acid 

5.624 (Arnot-Gobas) 

US EPA (EPI suit. 2008) 

*** 
GESAMP-BWWG 12/6 

I:\MEPC\60\2-16.doc 

ANNEX 6 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

OceanGuard Ballast Water Management System 

Submitted by Norway for Basic Approval 

0 SUMMARY 

0.1 Having reviewed all the data and information submitted by Norway with the application 

for Basic Approval and the information received from the applicant during 

the GESAMP BWWG meeting, the Group recommended to MEPC that Basic Approval be 

granted to this BWMS. 

0.2 The Group noted that the OceanGuard Ballast Water Management System (BWMS) is the 

technology of Qingdao Headway Technology Co. Ltd. of China and uses a combination of 

filtration and in situ Electrolysis enhanced by Ultrasonic Treatment (referred to in the application 

as EUT) of seawater to produce the Active Substance sodium hypochlorite to treat the ballast 

water, without the addition or mixing of any other chemicals. 

0.3 The Group noted that the original dossier submitted by the applicant proposes to treat 

seawater (33 PSU) at 1 mg/L (as Cl2) initial maximum TRO dose and brackish water (22 PSU) 

at 2 mg/L (as Cl2) initial maximum TRO dose. Whilst the original dossier was based on the 

above control scheme, as a result of the Group’s questions during the GESAMP-BWWG 

meeting, the applicant provided a revised control scheme in which the treatment maximum TRO 

dosages for the BWMS would be 2 mg/L (as Cl2) for the treatments with more than 2 days’ 

holding time, and 1.5 mg/L (as Cl2) for the treatments with less than or equal to 2 days’ holding 

time, respectively. 

0.4 The Group recognized that the applicant has provided information on environmental risk 

assessment for aquatic organisms and has proposed a maximum allowable discharge 

concentration (MADC) for the Active Substance of 0.2 mg/L (TRO as Cl2) without any 

neutralization measures or monitoring at discharge. The Group considered that the applicant’s 

approach to ensuring MADC for the Active Substance is not sufficient and recommended that the 

applicant ensures that the environmentally safe MADC is not exceeded over the entire range of 

relevant chemical properties and all possible holding times. The Group considered that this 

could not be achievable when a 1.5 mg/L (TRO as Cl2) dosed ballast water was discharged in the 

period up to 2 days, without a neutralization step. 

0.5 The Group recommended that suitable monitoring and shut-down facility be incorporated 

to ensure that a MADC of 0.20 mg/L TRO as Cl2 cannot be exceeded at any time, full details of 

such an arrangement should be provided in any application for Final Approval. 

0.6 The Group noted that the applicant intends to conduct corrosion tests and to submit the 

resultant data in their application for Final Approval. 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, in conducting these corrosion tests. 
GESAMP-BWWG 12/6 

ANNEX 6 

Page 2 

I:\MEPC\60\2-16.doc 

0.7 The Group considered that the information provided by the applicant in the submitted 

dossier is sufficient to allow the Group to recommend Basic Approval but is not sufficient for full 

evaluation of the potential risks posed by the treated ballast water with the revised dose settings 

described in 0.3 above. However, in view of the similarity with other evaluated BWMS which 

use electrolysis, the Group believed that this BWMS would not give rise to risks substantially 

different from those other systems. The Group recommended that an application for 

Final Approval of this system should include confirmation by further testing, that there will be no 

unacceptable risks (to ship safety, human health or the environment) due to the chemical 

composition of ballast water treated by this BWMS. 

0.8 The Group noted the information submitted by the applicant on the assessment 

of Human Exposure Scenario related to the BWMS which included the analysis of the potential 

human health risks associated with occupational exposure scenarios (personnel working inside 

the ballast tank and personnel working close to the BWMS) and the exposure of the general 

public (sea bathers in the harbour areas including children, adults and elders). 

0.9 The Group noted that the applicant used the MAMPEC-model version 2 to calculate the 

Predicted Environmental Concentrations for different Relevant Chemicals. The Group accepted 

the MAMPEC calculations of the applicant which were based upon the OECD-EU commercial 

harbour and the ballast water discharge description of the Port of Rotterdam. 

0.10 The Group recommended that both acute and chronic ecotoxicity testing of treated ballast 

water with the revised TRO dose settings described in 0.3 above for at least three species should 

be performed in accordance with the full requirements of Procedure (G9), to be reviewed for 

Final Approval. 

0.11 In conclusion, having reviewed all the information submitted by Norway in the 

application for Basic Approval and the information supplied by the applicant in response to 

questions posed by the Group during this GESAMP-BWWG meeting, the Group agreed to 

recommend to the MEPC that Basic Approval be granted to the OceanGuard BWMS. The Group 

recommended that in any future submission for Final Approval of this BWMS, the 

recommendations given in this report are taken into account. 

1 INTRODUCTION

1.1 The data used to evaluate this system were extracted from that supplied by Norway in 

document MEPC 60/2/8 and in the confidential dossier, which was supplemented by additional 

information provided by the applicant after a request for further information by the Group during 

its meeting. 

2 COMPLETENESS OF DOSSIER AND APPLICANT RESPONSES TO DATA 

REQUESTS FROM THE GROUP

2.1 As the Group recognized that the chemical analysis and ecotoxicity testing reports 

provided by the applicant did not include QA/QC documentation, the Group was of the opinion 

that some of the test procedures and methods may not have been performed in accordance with 

the Guidelines (G8) and Procedure (G9). The QAPP report provided by the applicant was for the 

full-scale land-based testing in the future, not for the pilot testing already provided in the dossier 

for Basic Approval. 
GESAMP-BWWG 11/6 

ANNEX 6 

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2.2 During the GESAMP-BWWG meeting, the Group posed to the applicant a total of six 

questions on issues it felt needed further clarification in order to complete the evaluation for 

Basic Approval. The Group’s questions (in bold text), the applicant’s responses (in plain text) 

and the reactions of the Group (in italic text) are noted below, in numerical order of the 

individual questions. 

Question 1 

The production of carbon monoxide and methane – The applicant stated in paragraph 4.4 

of non-confidential version as follows: “Carbon monoxide, methane and hydrogen sulfide 

are the products from the incomplete oxidation of TRO and the organics in a high 

concentration of the organics in the water.” 

.1 As indicated in table 3.1, even after this treatment heterotrophic bacteria are 

still alive with high concentration both in seawater and brackish water. 

.2 So not the oxidation but biological fermentation against organic compounds 

in BW will occur during tank holding time. 

.3 This is why these gases are detected only at brackish water, which contains 

more organic compounds according to G8 requirement. 

.4 That means that their dose of TRO is not enough against heterotrophic 

bacteria. 

Response 1 

.1 The biological efficiency of OceanGuard BWMS is achieved by Hydroxyl 

radicals, not TRO. Carbon monoxide, methane are the products from the 

incomplete oxidation of TRO and the organics in a high concentration of the 

organics in the water, and no hydrogen sulfide are detected during the whole 

testings. 

.2 During tank holding time, it is oxidation that occurs, not biological fermentation 

against organic compounds. The reasons are as following: 

.1 If it is biological fermentation, there should be Carbon monoxide in 

control water. However, no Carbon monoxide is detected in control water. 

.2 If it is biological fermentation, there should be decrease in DO. However, 

no decrease is detected. Please refer to the following data of pilot testing 

report from NIVA (Ref. P21—P22, NIVA report). 

Group reaction – The Group noted the response. 

Question 1 (continued) 

So first of all, how they collected the gas for the analysis in Table 4.3? Was this sampling 

directly done from the simulated BW tank? How much is the distance from the water level? 

And at the sampling time, did they recognize a smell? 
GESAMP-BWWG 12/6 

ANNEX 6 

Page 4 

I:\MEPC\60\2-16.doc 

Response 1 (continued): 

.1 Testing method for the analysis in Table 4.3 (Ref. P19 , NIVA report). 

.2 Gas phase parameters 

Gas phase parameters were measured in the headspace in each tank (i.e. empty 

space between tank roof and water surface) for analysis of O2, H2, CH4, H2S and 

Cl2 gas. Gas was measured using handheld gas sensors (Dräger X-am 5000 and 

GasAlert MicroClip RW), sensors which have been developed and is used for 

portable monitoring of gases for personnel working in potentially hazardous areas. 

Gas was measured on day 0 and day 5. 

Yes, the sampling was directly from the simulated BW tank. At the sampling 

time, no smell was recognized. 

Group reaction – The Group noted the response. 

Question 1 (continued) 

Finally, could you provide the chemical parameters (DO, POC, DOC and) of control and 

treated water? If not in their reports, please ask additional information for that.

Response 1 (continued) 

.1 Kindly please refer to the following info regarding DO from NIVA pilot testing 

report. (Ref. P23—P24, NIVA report). Data of POC, DOC (Ref. P22—P23, 

NIVA report) 

Group reaction – The Group noted the response. 

Question 2 

The threshold between seawater and brackish water - The applicant proposes to treat 

seawater (ca. 33 PSU) at 1 mg/L (as Cl2) initial maximum TRO dose and brackish water 

(ca. 22 PSU) at 2 mg/L (as Cl2) initial maximum TRO dose. What is the changeover point 

or threshold of PSU for changing TRO from 2 mg/L to 1 mg/L? Are there any possibilities 

that other parameters, such as DOC will affect the G8 efficacy? 

Response 2: 

.1 From landbased testings in NIVA (please see the following two tables), the 

biological efficiency of OceanGuard BWMS is achieved by Hydroxyl radicals, 

not TRO. In the updated OceanGuard BWMS, there is no changeover point or 

threshold of PSU for changing TRO. 

.2 There are two modes of OceanGuard BWMS as following: 

.1 In MODE 1, i.e. where the estimated ballast water storage time is longer 

than 2 days, the maximum allowed TRO concentration is 2 mg/L. 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 5 

I:\MEPC\60\2-16.doc 

.2 In MODE 2, i.e. where the estimated ballast water storage time is shorter 

than 2 days, the maximum allowed TRO concentration is 1.5 mg/L. 

Group reaction – The Group noted this response but questioned the validity of the argument 

presented that the MADC of 0.2 mg/L TRO as Cl2 can be maintained at all times using the dosing 

rates specified. 

Question 3 

It is noted in the submitted dossier that the intention was to treat marine water with a 

dosage of 1 mg/L TRO and brackish water with a dosage of 2 mg/L TRO. We now note 

from your initial replies to earlier questions that the dosage has been changed to depend 

upon intended holding time in the ballast tank, i.e. > 2 days holding time, TRO dosage 

maximum = 2 mg/L, and < 2 days holding time, TRO dosage maximum = 1.5 mg/L. Please 

clearly indicate the maximum dosages applicable and under which conditions and PSU 

ranges these apply. 

Response 3: 

.1 Maximum TRO dosages applicable of OceanGuard BWMS is 2 mg/L 

(For < 2 days holding time, TRO dosage maximum = 1.5 mg/L). These settings 

apply to all conditions and PSU ranges. Please be noted that the 2 mg/L 

and 1.5 mg/L as mentioned refer to the online data. 

Group reaction – The Group noted this response but questioned the validity of the argument 

presented that the MADC of 0.2 mg/L TRO as Cl2 can be maintained at all times using the dosing 

rates specified. 

Question 4 

It is noted that the maximum discharge level of TRO is stated as 0.2 mg/L. The TRO level 

at discharge is dependent upon the concentrations of chlorine demanding organic 

compounds, especially in brackish waters, and the tank holding time. It is noted that there 

is conflicting information on the degradation rate of TRO that may be expected. The Group 

has concern that the information provided in the dossier does not give confidence that the 

discharge TRO level of maximum 0.2 mg/L can be ensured at all times. How is the 

maximum discharge TRO level to be assured to ensure environmental acceptability, 

without incorporating a TRO neutralization system? 

Response 4: 

.1 According to the landbased testings, TRO level is set within a fixed range. 

Biological efficiency of OceanGuard BWMS is achieved mainly by the hydroxyl 

radicals, not the TRO. A certain level of TRO is to make sure the sustaining 

biological efficiency for a period of holding time, to inhibit the growth of 

organisms. From testing data in landbased testings, it can be indicated that IMO 

D-2 Requirements can be achieved with the maximum initial TRO level 

of 1.5 mg/L or 2 mg/L. 
GESAMP-BWWG 12/6 

ANNEX 6 

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I:\MEPC\60\2-16.doc 

.2 Please refer to the following table showing the TRO decay. It can be indicated 

that TRO concentration in treated water on Day 1 or Day 2 can fully meet the 

IMO requirements of TRO <0.2 mg/L. On Day 5 before discharge, TRO level 

is <0.1 mg/L. Meanwhile, during deballasting, only ultrasound part is operated, 

which will not increase the TRO level. 

.3 In conclusion, discharge TRO level of OceanGuard BWMS can completely be 

assured to be lower than 0.2 mg/L, to make sure the environmental acceptability 

without incorporating a TRO neutralization system. 

Group reaction – The Group noted this response but questioned the validity of the argument 

presented that the MADC of 0.2 mg/L TRO as Cl2 can be maintained at all times using the dosing 

rates specified. 

Question 5 

Can you provide any literature or scientific reasoning for the production or presence of 

carbon monoxide from the incomplete oxidation of organics during electrolysis? The 

Group notes the assertion of this possibility by NIVA but no justification was provided. 

Response 5: 

.1 Please refer to Attachment 2 MSDS (P6, ref. 10. STABILITY AND REACTIVITY). 

Some chemicals are added into testing water (influent water), including starch, in order to 

make sure the compliance with G8 requirements. Production or presence of carbon 

monoxide in trace as detected is from reactions of TRO and starch. 

Group reaction – The Group noted this response. 

TRO Decay (Data from Landbased Testings in NIVA) 
GESAMP-BWWG 11/6 

ANNEX 6 

Page 7 

I:\MEPC\60\2-16.doc 

Question 6 

Can you provide any literature or scientific reasoning for the presence of methane? Were 

either carbon monoxide or methane measured or detected in the control tank water? Is the 

system expected to result in these products when in service? 

Response 6 

.1 Gas measurements have been carried out both in treated tank and control tank water, 

through pilot testing, landbased testing and shipboard testing. For all testing cycles 

carried out, no carbon monoxide or methane is detected in control tank. 

.2 Reasoning for the presence of methane is as following. TRO are substances with very 

strong oxidizing property, and can have redox reactions (oxidation and reduction 

reactions) with many different organics, with methane as one of the outcomes. 

.3 During pilot testings and landbased testings, carbon monoxide and methane is 

detected in very low concentration (Note: concentration of methane detected in 

landbased testings is very low, and for some cycles, even no methane is detected). 

During shipboard testing, only low concentration of carbon monoxide is detected, 

with no methane. When in service, there is the possibility of resulting in these 

products, however, the concentration is sure to be very low and insignificant. 

Group reaction – The Group noted this response. 

3 DESCRIPTION OF THE SYSTEM

3.1 Working Principles of the BWMS 

3.1.1 Overview 

3.1.1.1 The Group noted that the OceanGuard BWMS presented for Basic Approval utilizes 

automatic back-flushing mechanical filtration (50μm) followed by an electrolysis component that 

produces sodium hypochlorite in situ, as Active Substance, with ultrasonic treatment of the ballast 

water. The Group noted that ballast water goes through the filter and the ultrasonic treatment and 

electrolysis in the EUT unit during ballasting. During de-ballasting, only the ultrasonic treatment 

phase is used. Figure 1 schematically shows the BWMS being reviewed for Basic Approval. 

Figure 1 – Schematic process diagram of BWMS 
GESAMP-BWWG 12/6 

ANNEX 6 

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I:\MEPC\60\2-16.doc 

3.1.1.2 The Group recalled that sodium hypochlorite is determined as TRO (expressed 

as mg Cl2/L). The Group noted that according to the applicant, the biological efficacy of the 

BWMS is achieved mainly through Active Substance generated in the water as hydroxyl radicals, 

not TRO. The ultrasonic treatment acts as a supplementary part, to enhance the biological 

efficacy. However, the Group recommended that the applicant explains the role of the hydroxyl 

radicals at Final Approval as a substantial difference with other BWMSs using electrolysis. 

3.1.1.3 The Group recognized that the applicant stated in their original application dossier to 

treat seawater (33 PSU) at 1 mg/L (as Cl2) initial maximum TRO dose and brackish water 

(22 PSU) at 2 mg/L (as Cl2) initial maximum TRO dose. However, after communication with the 

applicant during the GESAMP-BWWG meeting, the applicant proposed that maximum TRO 

dosages applicable for OceanGuard BWMS would be 2 mg/L for the treatments with more 

than 2 days’ holding time, and 1.5 mg/L for the treatments with less than or equal to 2 days’ 

holding time, respectively. The applicant claimed that these settings for TRO dose could ensure 

the MADC of 0.2 mg/L (as Cl2) without any neutralization. The Group considered that the 

applicant’s approach to ensuring MADC for the Active Substance is not sufficient and 

recommended that the applicant ensures that the environmentally safe MADC is not exceeded 

over the entire range of relevant chemical properties and all possible holding times. The Group 

considered that this could not be achievable when a 1.5 mg/L (TRO as Cl2) dosed ballast water 

was discharged in the period up to 2 days, without a neutralization step. 

3.1.1.4 The Group noted that the small-scale testing of the ballast water treatment technology 

for Basic Approval has been carried out by NIVA at their test facilities near Oslo in Norway in 

January 2009. Also the Group noted that the small-scale tests have been carried out using 

medium salinity brackish water (between 3 and 32 PSU, ca. 22 PSU) and high salinity seawater 

(>32 PSU, ca. 33 PSU) according to Guidelines (G8). However, the Group recognized that 

certain of the conditions may not have been fully achieved according to the Guideline as the 

testing may not have been performed under adequate QAPP. 

3.1.1.5 As the BWMS does not require the storage of chemicals on board ship, the Group 

recognized that there will not be any associated storage safety problems. 

3.1.2 Description of test system used for Basic Approval 

3.1.2.1 The Group noted that according to the applicant, simulative sealed ballast tanks for 

treated and control ballast water were set up according to the IMO requirements. Tests with 

seawater (ca. 33 PSU) and brackish water (ca. 22 PSU) were carried out in different time periods, 

but with the same procedure and a flow rate of 2 m3

/h. Ballasting of treated water and control 

water was on the same day. Test water was pumped in, through the filter and the complete EUT 

unit treatment, into the 1 m3 treated ballast tank. On day 5, the pump was used to mix the water in 

the tank and treated water was discharged with ultrasonic treatment only (see Figure 1 above). 

3.2 Safety and Control 

3.2.1 The Group noted that the control unit for the entire system is in charge of various types of 

sensors, handling of alarm signals, as well as startup and shutdown of the system and it contains 

controlling procedures and displays the operating conditions of the BWMS. The applicant states 

that if the treatment system fails, it will make an audio and light alarm and automatically switch 

to a safe mode. Data of operating conditions of the system can be recorded, memorized, 

displayed and printed. Authorized operators can take control and make manual adjustments 

through this control unit. The Group additionally recommended that suitable monitoring and 
GESAMP-BWWG 11/6 

ANNEX 6 

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I:\MEPC\60\2-16.doc 

shutdown facility be incorporated to ensure that a MADC of 0.20 mg/L TRO as Cl2 cannot be 

exceeded at any time, full details of such an arrangement should be provided in any application 

for Final Approval. 

3.2.2 The Group noted that according to the applicant, parameters like salinity, flow rate, TRO 

and EUT power consumption can be measured by the sensors. The control unit can respond to 

the system conditions and initiate adjustments accurately in time to get an ideal treatment effect.

Salinity, flow rate and TRO are very important parameters in the process. The most suitable 

initial operational mode of the EUT unit can be set by the control unit through the internal 

memory procedures. With the TRO sensors, power supply parameters can be adjusted by the 

control unit, so that suitable initial TRO level can be set to ensure the biological treatment 

efficacy and also to limit the discharge toxicity. Data from TRO sensors are transmitted to the 

control unit. If the data indicate that TRO is higher than the required value set, parameters of 

EUT power supply will be adjusted to lower the initial TRO level, and vice versa. Therefore, the 

initial concentration of TRO will remain in a range of constant concentration. 

3.2.3 The Group noted that the applicant has provided some information on fire prevention and 

exposure to gases from the BWMS. In tests with 33 PSU seawater treated at 1 mg Cl2/L initial 

TRO dose and 22 PSU brackish water treated at 2 mg Cl2/L initial TRO dose, no hydrogen, 

chlorine, hydrogen sulfide, or surplus oxygen were detected. In the tests, on day 0, just after the 

treatment, 25 ppmV carbon monoxide and 2.5% LEL (lower explosive limit) methane were 

detected. However, on day 5, these gases were not detected. Although the Group agreed with 

the applicant’s conclusion that the levels of these gases encountered during testing to date would 

not cause significant concern, it is recommended that the levels of hydrogen, methane and carbon 

monoxide gases in the air space of treated water tanks continue to be monitored throughout the 

remainder of land based and shipboard testing to validate the assumption that the risks associated 

with these gases remain acceptable. 

3.2.4 The Group recognized that the probability of leaking or breakdown of the BWMS in 

normal working conditions should be small. According to the applicant, once any error occurs, 

the system will be stopped automatically and instantly, and there will be light and sound alarms 

at the same time and that when carrying out repairs, the operators should follow the existing 

safety protection measures on board. It was noted by the Group that the applicant considers that 

the risk of exposure to chemicals is small with this BWMS, but nevertheless the Group 

considered this possibility to remain an important and relevant consideration, and recommended 

that an appropriate risk evaluation for all eventualities is performed and that measures and 

procedures to mitigate such risks identified are clearly addressed in any submission 

for Final Approval. 
GESAMP-BWWG 12/6 

ANNEX 6 

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3.3 Chemical processes involved in the BWMS - Active Substance (AS), Relevant 

Chemicals (RC) and Other Chemicals (OC) 

3.3.1 The Group recalled the chemical reactions involved in the electrolysis of natural sea 

water. In the BWMS under consideration, according to the applicant, the Active Substance is 

applied at up to the maximum allowable initial dose of 2 mg/L (as TRO Cl2) into the ballast 

water. According to the applicant, in the tests for Basic Approval with the initial TRO dose 

of 2 mg/L (as TRO Cl2), after 1 day storage, the TRO level was generally below 0.2 mg/L, with 

some exceptions, however, the Group noted that according to the table supplied by the applicant 

in response to the Group’s Question 4, this was not the case. 

3.3.2 The Group believed that the observed TRO degradation rates may significantly vary with 

respect to parameters other than salinity, such as DOC concentration and chlorine demands. 

The Group concluded that this will need confirming during the tests performed 

for Final Approval using seawater and brackish water with lower content of DOC. If the 

applicant finds that there would be any possibility of lower degradation rates of TRO in the 

ballast tank, then additional mitigation measures, such as neutralization, should be installed to 

ensure an environmentally safe MADC under all possible conditions. 

3.3.3 In the case of Relevant Chemicals, the Group recognized that trihalomethanes (THM), 

haloacetic acids (HAA) and sodium bromate are included amongst many possible disinfection 

by-products. A selected list of Relevant Chemicals is presented by the applicant in Table 1 

below, which includes AOX, EOX, bromate ion, THM, phenols and other halogenated organics. 

As is shown in Table 1, tribromomethane is the main THM in the tested halogenated organics 

listed. In the test cycles selected by the applicant, i.e. seawater (33 PSU) treated 

with 1 mg Cl2/L initial TRO, and brackish water (22 PSU), treated with 2 mg Cl2/L initial TRO, 

the maximum levels detected are as follows: dibromochloromethane 5 μg/L, 

tribromomethane 150 μg/L, dibromoacetic acid 5.9 μg/L, 2,4,6-tribromophenol 0.1 μg/L and 

bromate ion 3.5 μg/L (refer to section 3.5, NIVA report). Therefore, these five Relevant 

Chemicals are identified by the applicant and listed separately in Table 2. 

3.3.4 However, the Group noted that the TRO dose for high salinity water (33 PSU) was 

initially set by the applicant as 1 mg/L which is only half of that in the applicant’s revised 

proposal. The Group considered that the results for high salinity water did not simulate the 

treatment proposed, and recommended that adequate testing should be performed during 

land-based testing for Final Approval. Also the Group recommended that the applicant should 

carefully select multi-timing sampling for chemical analysis and ecotoxicity testing during the 

tank holding time. Particularly for this BWMS according to the applicant’s TRO dose, not 

only 2, 3 and 5 days’ holding time with 2 mg/L TRO but also 0, 1 and 2 days’ holding time 

with 1.5 mg/L TRO should be considered as sampling timings. The worst case scenario 

(concentrations of Relevant Chemicals) observed among these multi-timings should be used for 

PEC calculations at Final Approval. 
GESAMP-BWWG 11/6 

ANNEX 6 

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Table 1 : Relevant Chemicals concentration in seawater (33 PSU) and brackish water 

(22 PSU) tests, as selected by the applicant for further development 

(samples are collected after 5-day storage) 

Component Unit Seawater (33 PSU) 

Day 5 

Brackish water 

(22 PSU) 

Day 5 

Trichloromethane μg/L <0.50 <0.50 

Bromodichloromethane μg/L <0.50 <0.50 

Dibromochloromethane μg/L 1.7 5 

Tribromomethane μg/L 44 150 

Monochloroacetic acid μg/L <0.50 <0.50 

Dichloroacetic acid μg/L <0.30 <0.30 

Trichloroacetic acid μg/L <0.20 <0.20 

Monobromoacetic acid μg/L <0.20 <0.20 

Dibromoacetic acid μg/L 0.66 5.9 

Bromochloroacetic acid μg/L <0.10 <0.10 

Bromodichloroacetic acid μg/L <0.10 <0.10 

Dibromochloroacetic acid μg/L <0.10 <0.10 

Tribromoacetic acid μg/L <0.10 <0.10 

2,4-Dibromophenol μg/L <0.10 <0.10 

2,6-Dibromophenol μg/L <0.10 <0.10 

2,4,6-Tribromophenol μg/L <0.10 0.1 

1,2-Dibromomethane μg/L <1.0 <1.0 

1,2,3-Trichloropropane μg/L <1.0 <1.0 

2-Chlorotoluene μg/L <0.50 <0.50 

4-Chlorotoluene μg/L <0.50 <0.50 

1,2-Dibromo-3- 

chloropropane 

μg/L <1.0 <1.0 

1,3,5-Tribromobenzene μg/L <1.0 <1.0 

AOX mg/L 0.02 0.1 

EOX mg/L <0.010 0.012 

Bromate ion μg/L 1.0 3.5 

Table 2 : Selected Relevant Chemicals in treated ballast water (the highest concentration in 

the tested waters of different quality, as selected by the applicant) 

Name Concentration (μg/L) 

Dibromochloromethane 5 

Tribromomethane 150 

Dibromoacetic acid 5.9 

Tribromophenol 0.1 

Bromate ion 3.5 
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3.3.5 The applicant indicated that the list for Relevant Chemicals may be incomplete at this 

point and that this area is to be further investigated during land-based and shipboard testing for 

Final Approval (see paragraph 3.3.4). 

3.3.6 In the case of Other Chemicals, the Group noted that the applicant has presented some 

information on concentrations of various gases produced by the BWMS. The information from 

the applicant in this area is shown in Table 3. 

Table 3 : Concentration of gases detected from the BWMS 

(Refer to section 3.2, NIVA report) 

Gas Unit Salinity (PSU) TRO (mg/L) Day 0 Day 5 

Hydrogen % LEL 33 1 0 0 

22 2 0 0 

Chlorine ppmV 33 1 0 0 

22 2 0 0 

Oxygen % v/v 33 1 20.9 20.9 

22 2 20.9 20.9 

Carbon 33 1 0 0 

monoxide 

ppmV 

22 2 25 0 

Hydrogen 33 1 0 0 

sulfide 

ppmV 

22 2 0 0 

Methane % LEL 33 1 0 0 

22 2 2.5 0 

4 HUMAN HEALTH ASSESSMENT 

4.1 Considerations for Risk Assessment 

4.1.1 The Group noted that the applicant had assessed the toxicological hazards and potential 

human exposure associated with chemicals of potential concern generated by the BWMS, which 

include the Active Substance sodium hypochlorite and Relevant Chemicals such as chloroform, 

bromoform, dibromoacetic acid, bromate, carbon monoxide and methane. The applicant used as 

the worst-case approach the concentrations of tribromomethane (bromoform) as detected in the 

treated ballast water and several exposure parameters to assess dermal exposure to crew and oral, 

dermal exposure to the general public as described in the confidential part of the dossier. 

4.1.2 The Group noted that the measured concentrations of the detected substances in the 

discharged treated ballast water were below the threshold values for drinking water (WHO, 2005) 

except in the case of tribromomethane (bromoform) where an exposure assessment and risk 

evaluation were performed. The Group concurred with the applicant that the MOS assessment of 

tribromomethane for crew (occupational exposure) and the general public should not pose any 

unacceptable risk to human health. 
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4.2 Assessment of exposure to Ship’s Crew 

4.2.1 The Group noted that the applicant assessed two occupational exposure scenarios, 

personnel working inside the ballast tank and personnel working close to the BWMS, considering 

dermal exposure as the exposure route of concern, and taking into consideration several 

assumptions as described in the confidential part of the dossier. 

4.2.2 Although the Group recognized that the applicant had performed a useful tiered exposure 

assessment, it also considered that the chosen occupational scenarios were not sufficiently 

described in order to capture the real exposure situations. Therefore the Group considered that 

the operation units associated with “personnel working inside the ballast tank and personnel 

working close to the BWMS” should be fully described for Final Approval. 

4.2.3 The Group concurred with the applicant that under normal conditions the ship’s crew 

(including BWMS operators) would not be exposed to sodium hypochlorite and by-products in 

the treated ballast water unless there is a failure of the system or when performing service on the 

system. The Group recognized that the risks associated with these scenarios can be mitigated by 

numerous system safety measures (leak detection, gas removal, equipment isolation, stray current 

protection, interlocks, etc) and by following the use of appropriate personal protective equipment 

when performing maintenance and/or repair on the system, and such mitigation measures should 

be detailed in the application for Final Approval. 

4.2.4 In addition, the Group noted that the emission concentration of carbon monoxide 

(25 ppmV) as measured in the treated ballast water was well below the permissible exposure 

level (PEL), for 8 hours, set by US OSHA (50 ppmV). However, other occupational exposure 

levels (OELs) are set at 25 ppmV with short exposures limited to 100 ppmV, therefore, the 

Group recommended that carbon monoxide should be further monitored during testing, as 

recommended in section 3, and additional risk mitigation measures (e.g., PPE/RPE) should be 

put in place as appropriate. 

4.3 Exposure of General Public through the environment and by the Food Chain 

4.3.1 The Group noted that the applicant considered the exposure to the general public taking 

into account as the worst case scenario, the sea bathers in the harbour areas (children, adults and 

elders) being exposed by the dermal route to bromoform. 

4.3.2 The Group considered that sea bathers in the harbour areas could potentially be exposed 

to discharged treated ballast water however concentrations in ballast water would be diluted in 

the sea water to which bathers could be exposed. In addition, as discussed above, the measured 

ballast water concentrations of various chemicals were generally lower than their respective 

reference values. Therefore, no adverse health effects would be expected from bathers exposed 

to diluted concentrations of these chemicals. 

4.3.3 The Group concurred with the applicant that the general public potentially exposed via 

consuming seafood from the harbour area where the treated ballast water may be discharged is 

unlikely to be exposed to chemicals generated by the system due to low bioaccumulative 

potential (log Kow less than 4) and consequently would not be expected to persist in the food 

chain. 
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4.4 Conclusion on Human Health assessment 

4.4.1 The Group considered that the semi-quantitative human exposure assessment submitted 

by the applicant is sufficient to recommend that Basic Approval is granted to the BWMS. 

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

5.1 Safety of the ship 

5.1.1 The Group noted that the proposed specific countermeasures to be employed in this 

system to deal with envisaged emergency and safety problems during the ballast water treatment 

have been summarized above. In particular a summary of the various safety measures developed 

by the applicant is given above in section 3. 

5.1.2 The Group noted that according to the applicant, all the units of this system, including the 

pipelines and ballast tanks are made of anti-corrosion materials or have anti-corrosion coatings. 

In this system, organisms are killed by a certain concentration of oxidants and there is the 

possibility of enhancing the corrosion to ballast tanks by the oxidants from this system. 

However, the degradation rate is very fast when the concentration of the oxidants is low, so the 

possibility of corrosion is predicted by the applicant to be very low. 

5.1.3 The Group recommended that comprehensive corrosion testing be conducted for Final 

Approval, taking into account the guidance in section 5.1 of the “Report of the eighth meeting of 

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

5.1.4 The applicant has considered the production of hydrogen gas during electrolysis and 

concluded that the levels produced should not pose any unacceptable risk to the ship. The Group 

also notes that no gas separator is included in the system to mitigate the risk of the production of 

hydrogen during electrolysis, but also recognizes that such gas production will be lower than 

experienced in other systems utilizing electrolysis due to the lower levels of oxidants being 

generated in this system. The Group also noted that limited quantities of methane and carbon 

monoxide were found to occur when the test water was treated by this system. Although the 

Group agrees with the applicant’s conclusion that the levels of these gases encountered during 

testing to date would not cause significant concern, it is recommended that the levels of 

hydrogen, methane and carbon monoxide gases in the air space of treated water tanks continue to 

be monitored throughout the remainder of land-based and shipboard testing to validate the 

assumption that the risks associated with these gases remain acceptable. 

5.2 Safety of the crew 

5.2.1 The Group considered that risk to safety of the ships’ crew (BWMS operators included) 

by exposure to chemicals and treated ballast water during normal operation of this treatment 

system can be accepted based on the measures developed by the applicant for installation onboard ship. A summary of the various safety measures developed by the applicant is given above 

in section 3. The Group considered that in this system, the risk to ships’ crew is judged to be 

appropriately managed based on the facts that the Active Substance is produced in situ as well as 

that system components are adopted that are expected to minimize the exposure risk of ships’ 

crew to chemicals and ballast water before and after treatment, through the exposure routes of 

concern assessed, as discussed above in section 4, however emergency scenario events remain to 

be fully addressed. 
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5.3 Safety of the general public 

5.3.1 The Group considered that the operation of this system should pose no unacceptable risk 

to the health of the general public according to the outcome of the human exposure routes of 

concern assessed, as discussed above in section 4. 

6 ENVIRONMENTAL RISK ASSESSMENT 

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

6.1.1 The Group noted that the applicant has made a listing of persistence (P), bioaccumulation 

(B) and toxicity (T) criteria for the Active Substance and Relevant Chemicals found in the treated 

ballast water and this is presented in the dossier for Basic Approval. Although sodium 

hypochlorite shows significant chronic toxicity and tribromomethane is fairly persistent in the 

environment, no Active Substance or Relevant Chemical fulfilled more than one of 

the PBT criteria, and none therefore are eligible for a PBT classification. 

6.1.2 Based on these results, the Group concluded that these chemicals should not be classified 

as PBT-substances. 

6.2 Acute ecotoxicity testing of treated ballast water 

6.2.1 The Group noted that acute aquatic ecotoxicity tests for the treated ballast water produced 

by the BWMS were carried out by the applicant on algae, invertebrates and fish with treated 

water sampled on day 5. The 1 mg/L (as Cl2) initial maximum TRO dose was chosen for full 

ecotoxicity testing of seawater (33 PSU). The test concentrations of 2 mg/L and 4 mg/L TRO 

were only tested with respect to marine algal growth inhibition. The 4 mg/L (as Cl2) initial 

maximum TRO dose was chosen for full ecotoxicity testing of brackish water (22 PSU), based on 

the rapid decay of TRO in brackish water and low concentrations of TRO measured on day 5. 

The test concentrations of 1 mg/L and 2 mg/L (TRO as Cl2) in brackish water were only tested 

with respect to algae toxicity. 

6.2.2 Seawater testing results 

6.2.2.1 The Group noted that results of ecotoxicity testing performed on treated seawater 

(33 PSU), sampled on day 5, are shown in Table 4. Results are presented as percentage (%) of 

treated ballast water. Dilution water is non-treated ballast water. 
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Table 4 : Ecotoxicity tests performed on treated seawater (33 PSU), sampled on day 5 

 

Test and initial TRO 

dose (as Cl2) 

Species Test Result 

Marine algae growth 

inhibition 

1 mg/L 

Skeletonema costatum EC10 = 92% 

EC50 = >100% 

Marine algae growth 

inhibition 

2 mg/L 

Skeletonema costatum EC50 = 33% 

EC10 = 30% 

Marine algae growth 

inhibition 

4 mg/L 

Skeletonema costatum EC50 = 18% 

EC10 = 11% 

Acute invertebrate 

1 mg/L 

Acartia tonsa LC50 = >100% 

NOEC = 56% 

Acute fish 

1 mg/L 

Scophthalmus maximus LC50 = >100% 

NOEC = ≥ 100% 

6.2.2.2 According to the results, there is residual ecotoxicity of seawater treated with the 1 mg/L 

initial TRO, however, after dilution, it is safe to discharge to the environment. The Group noted 

that there was ecotoxicity at 2 and 4 mg/L of TRO on Skeletonema costatum with 33% and 18% 

of EC50 at 5 days in the seawater ecotoxicity testing, respectively. 

6.2.2.3 The Group was of the opinion that the results with a TRO dose of 2 mg/L in seawater 

clearly indicated that unacceptable acute or short term risks could occur at discharge. The Group 

strongly recommended that further measurement and assessment would be needed for the setting 

of TRO dose and MADC, particularly for waters with lower DOC concentrations. The Group 

invited the applicant to reconsider the installation of a neutralization system in this BWMS. 

6.2.3 Brackish water testing results 

6.2.3.1 The Group noted that results of ecotoxicity testing performed on treated brackish water 

(22 PSU) sampled on day 5, are shown in Table 5. Results are presented as percentage (%) of 

treated ballast water. Dilution water is non-treated ballast water. 

Table 5 : Ecotoxicity test performed on treated brackish water 

(22 PSU) sampled on day 5 

Test and initial TRO dose (as 

Cl2) 

Species Test Result 

Marine algae growth inhibition 

1 mg/L 

Skeletonema costatum EC50 = >100% 

EC10 = ≥ 100% 

Marine algae growth inhibition 

2 mg/L 

Skeletonema costatum EC50 = >100% 

EC10 = ≥ 100% 

Marine algae growth inhibition 

4 mg/L 

Skeletonema costatum EC50 = >100% 

EC10 = 82% 

Acute invertebrate 

4 mg/L 

Acartia tonsa LC50 = >100% 

NOEC = ≥ 100% 

Acute fish 

4 mg/L 

Scophthalmus maximus LC50 = >100% 

NOEC = ≥ 100% 
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6.2.3.2 The Group noted that ecotoxicity testing of treated brackish water indicates that no 

ecotoxicity to these indicator test organisms will be caused by the brackish water treated by 

the 2 mg/L initial TRO dose, even without dilution. 

6.2.4 The results in the Tables 4 and 5 show that the ecotoxicity of treated seawater and 

brackish water is different. No ecotoxicity will be caused by the brackish water treated by 

the 2 mg/L initial TRO after 5 days holding time. 

6.3 Chronic ecotoxicity tests 

6.3.1 The Group noted that the chronic toxicity tests were not performed in this application for 

Basic Approval. It was also noted that the applicant had recognized the need for chronic toxicity 

testing and further risk characterization according to the results of acute toxicity tests above. 

6.3.2 The Group emphasized that Procedure (G9) clearly requires both acute and chronic 

ecotoxicity testing for Basic Approval. The Group recalled that it had, previously, made a case 

for waiving the chronic toxicity testing for some BWMS applications for Final Approval 

providing the chemical analysis demonstrated that the concentrations of chemical by-products are 

similar to those provided in the application for Basic Approval. 

6.3.3 However, in this case, the Group recommended that, for Final Approval, in addition to the 

required acute toxicity test results, chronic toxicity test results, carried out in accordance with 

Procedure (G9), should also be provided as these were missing in the application for Basic 

Approval, because the analogy with earlier systems are not valid in this case. 

6.4 Conclusion on WET-tests 

6.4.1 The Group concluded that the applicant has provided information on acute aquatic 

ecotoxicity testing of the treated ballast water that is sufficient to recommend Basic Approval. 

However, the Group was of the opinion that the information is not sufficient for full evaluation of 

the potential risks posed by the treated ballast water with the revised TRO dose settings. The 

Group recommended that both acute and chronic ecotoxicity testing of treated ballast water for at 

least 3 species with the revised TRO dose settings described in 3.1.1.3 should be performed in 

accordance with the full requirements of Procedure (G9), to be reviewed for Final Approval. 

Also the Group recommended that the applicant should carefully select multi-timing sampling 

during the tank holding time (see 3.3.4). 

6.5 Risk assessments of chemicals for aquatic organisms 

6.5.1 MAMPEC Modelling and Predicted Environmental Concentration (PEC) 

6.5.1.1 The Group noted that the applicant had employed the MAMPEC model in this 

application for Basic Approval to calculate PEC values of Active Substance and Relevant 

Chemicals in the harbour water after discharge of treated ballast water. The version 2.0 

of MAMPEC is applied by the applicant in this study. The applicant states that ballast water 

discharging capacity of OECD-EU commercial harbour has an exchange volume of 51,117,000 

m3 (refer to ESD). The daily volume of discharged treated ballast water is simulated 

as 300,000 m3

/d, according to the description of Port of Rotterdam in document MEPC 57/2/7. 

Concentration of sodium hypochlorite Active Substance in the discharged ballast water 
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is 0.05 mg/L. The results presented by the applicant show the calculated concentration of Active 

Substance in the Harbour and the Surroundings, as follows: 

Average concentration of the Harbour: 1.51x10-2 μg/L (= PEC); 

Maximum concentration of the Harbour: 3.27x10-2 μg/L; 

Average concentration of the Surroundings: 7.72x10-4 μg/L; 

Maximum concentration of the Surroundings: 4.00x10-3 μg/L. 

6.5.1.2 The Group noted that the MAMPEC model version 2.0 had been used to calculate the 

Predicted Environmental Concentrations (PEC) of the Active Substance and Relevant Chemicals 

associated with this system, using the OECD-EU commercial harbour and the ballast water 

discharge description of the Port of Rotterdam as the model harbour. The Group accepted 

the MAMPEC calculations of the applicant and was able to reproduce the values of the 

calculated concentrations of the Active Substance in the harbour and the surroundings as stated 

above. 

6.5.2 Aquatic Ecotoxicity and Predicted No-Effect Concentration (PNEC) 

6.5.2.1 The Group noted that the applicant has provided a comprehensive data-base of acute and 

chronic aquatic ecotoxicity data in the present dossier, for both the Active Substance and Relevant 

Chemicals. Key data for the Active Substance are summarized in Table 6. The Group noted that 

the applicant has calculated the PNEC value for the Active Substance using the lowest value of 

the data against different species. The assessment factor is selected according to the 

Methodology for information gathering and the conduct of work of the GESAMP-BWWG. 

According to the shortest period LC50 of species from two different trophic levels, and lowest 

chronic NOEC of species from several different trophic levels, the factor is decided by the 

applicant to be 50. 

Table 6 : Summary of Key Acute and Chronic Aquatic Ecotoxicity Data, for the Active 

Substance, and Calculation of PNEC Value (as presented by applicant) 

Species Effect Value 

(μg/L) Minimum Assessment factor PNEC 

Menidia beryllina (fish/sea) 96hLC50 128 

Mysid (crustacea/sea) 96hLC50 62 

Menidia peninsulae

(fish/sea) 

NOEC (28d) 40 

Dreissena polymorpha

(mollusc/fresh) 

NOEC (20d) 500 

Crassostrea virginica (sea) NOEC (13d) 7 

Natural algae (algae/fresh) NOEC (24d) 79 

 NOEC (7d) 3 3 (μg/L) 50 0.06 

μg/L 
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6.5.3 Risk to the aquatic environment – PEC/PNEC Ratio 

6.5.3.1 The Group noted that the calculation of the PEC/PNEC ratio by the applicant uses the 

values obtained above and gives the following result: 

PEC/PNEC = 0.0151 μg/L / 0.06 μg/L = 0.252 (ratio is <1). 

Therefore, this value of the PEC/PNEC ratio is less than 1 and therefore should indicate 

no unacceptable effects caused by the Active Substance TRO to the environment when 

discharging treated ballast water. 

6.5.4 Relevant Chemicals 

6.5.4.1 The Group recognized that the applicant, in addition to the above assessment of the 

Active Substance, had employed the MAMPEC model in this application for Basic Approval to 

calculate PEC values of selected Relevant Chemicals in the harbour water after discharge of 

treated ballast water. Comparison was then made with PNEC values obtained for the different 

Relevant Chemicals. 

6.5.4.2 The Group noted that the applicant refers to Table 2 where concentrations of 5 selected 

Relevant Chemicals in treated ballast water are presented (the highest concentration found in the 

tested waters of different quality). The applicant then notes that concentrations of 

dibromochloromethane, dibromoacetic acid, 2,4,6-tribromophenol and bromate ion, even in 

undiluted treated water, are lower than the PNEC value, so they should not have any effects on 

the aquatic environment when being discharged. Concentrations of tribromomethane in undiluted 

treated water exceed the relevant PNEC value, so treated water needs to be diluted in order to 

make sure it will not cause any effects to aquatics. By adopting the MAMPEC model scenario, 

the PEC/PNEC ratio of tribromomethane calculated by the applicant is lower than 1. Therefore, 

it is presumed by the applicant that the possibility of ecotoxicity from the treated ballast water to 

the environment caused by Relevant Chemicals is insignificant after dilution by port seawater. 

6.6 Conclusion from Environmental Risk Assessment 

6.6.1 The Group recognized that the applicant has provided information on environmental risk 

assessment for aquatic organisms and has proposed a maximum allowable discharge 

concentration (MADC) for the Active Substance of 0.2 mg/L (TRO as Cl2). The Group 

considered that the applicant’s approach to ensuring MADC for the Active Substance is not 

sufficient and recommended that the applicant ensures that the environmentally safe MADC is 

not exceeded over the entire range of relevant chemical properties and all possible holding times. 

6.6.2 The Group noted that the applicant has provided information on acute aquatic ecotoxicity 

testing of the treated ballast water that is sufficient to recommend Basic Approval. The Group 

recommended that both acute and chronic ecotoxicity testing of treated ballast water with the 

revised TRO dose settings described in 3.1.1.3 for at least 3 species should be performed in 

accordance with the full requirements of Procedure (G9), to be reviewed for Final Approval. 

6.6.3 The Group agreed with the MAMPEC modeling to calculate the Predicted Environmental 

Concentrations (PEC) of the Active Substance and Relevant Chemicals associated with this 

system and accepts the MAMPEC calculations of the applicant. 
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7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to safety of the ship 

7.1.1 The Group noted that specific countermeasures can be employed in this system to deal 

with envisaged emergency and safety problems during the ballast water treatment to reduce any 

inherent risk to an acceptable level. 

7.1.2 The Group recommended that comprehensive corrosion testing be conducted, taking into 

account the guidance in section 5.1 of the “Report of the eighth meeting of 

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

7.1.3 The Group considered that sufficient information had been provided by the applicant 

addressing risks to the safety of the ship to allow the Group to recommend Basic Approval for 

the OceanGuard BWMS to permit further development of this ballast water treatment system. 

7.2 Risks to the crew and general public 

7.2.1 The Group recommended that an application for Final Approval of this system should 

include a full description of the operation units associated with “personnel working inside the 

ballast tank and personnel working close to the BWMS” and the inhalation route of exposure 

should also be evaluated in terms of potential adverse health effects. 

7.2.2 The Group recommended that the level of carbon monoxide gas in the air space of treated 

ballast water tanks should continue to be monitored throughout the remainder of land based and 

shipboard testing to validate the assumption that the risks associated with this gas remain 

acceptable. 

7.3 Risks to the environment 

7.3.1 The Group was able to recommend Basic Approval for the BWMS, but the Group 

considered that the information provided by the applicant in the submitted dossier is not 

sufficient for a full evaluation of the risks posed by the treated ballast water with the applicant’s 

revised dose setting described above. The Group considered that the applicant’s approach to 

ensuring MADC for the Active Substance is not sufficient and recommended that the applicant 

ensures that the environmentally safe MADC is not exceeded over the entire range of relevant 

chemical properties and all possible holding times. 

7.4 Recommendation 

7.4.1 Having reviewed all the data and information submitted by Norway for Basic Approval 

and the information supplied by the applicant in response to questions posed by the Group during 

this GESAMP-BWWG meeting, the Group was able to recommend Basic Approval for the 

OceanGuard BWMS. 

7.4.2 The Group made the following recommendations or requests for information, if this 

system is to be reviewed for Final Approval in the future: 

 .1 The Group recommended that the applicant ensures that the environmentally safe 

MADC is not exceeded over the entire range of relevant chemical properties and 

all possible holding times; 
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.2 The Group recommended that suitable monitoring and shut-down facility be 

incorporated to ensure that a MADC of 0.20 mg/L TRO as Cl2 cannot be exceeded 

at any time; 

 .3 The Group recommended that if the applicant finds that there would be any 

possibility of lower degradation rates of TRO in the ballast water tank, with 

respect to parameters other than salinity, such as DOC concentration and chlorine 

demands, then additional mitigation measures, such as neutralization, should be 

installed to ensure an environmentally safe MADC under all possible conditions; 

 .4 The Group recommended that the applicant should carefully select multi-timing 

sampling during the tank holding time, according to the applicant’s TRO dose, not 

only 2, 3 and 5 day holding time with 2 mg/L TRO but also 0, 1 and 2 day holding 

time with 1.5 mg/L TRO should be considered as sampling timings. The worst 

case scenario (concentrations of Relevant Chemicals) observed among these 

multi-timings should be used for PEC calculations; 

.5 The Group recommended 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, in conducting corrosion tests; 

 .6 The Group recommended the applicant to confirm by further testing, that there 

will be no unacceptable risks (to ship safety, human health or the environment) 

due to the chemical composition of treated ballast water; 

.7 The Group recommended that both acute and chronic ecotoxicity testing of treated 

ballast water with the revised TRO dose settings for at least 3 species should be 

performed in accordance with the full requirements of Procedure (G9); 

 .8 The Group recommended that the levels of hydrogen, methane and carbon 

monoxide gases in the air space of treated ballast water tanks continue to be 

monitored throughout the remainder of land based and shipboard testing to 

validate the assumption that the risks associated with these gases remain 

acceptable; and 

.9 The Group recommended that an appropriate risk evaluation for human exposure 

to chemicals is performed and that measures and procedures to mitigate such risks 

are identified and clearly addressed, including consideration of operation units 

associated with personnel working inside the ballast tank and personnel working 

close to the system, with detailed explanation of all proposed risk mitigation 

measures. 

*** 

GESAMP-BWWG 12/6 

I:\MEPC\60\2-16.doc 

ANNEX 7 

REVIEW OF PROPOSALS FOR APPROVAL OF BALLAST WATER MANAGEMENT 

SYSTEMS THAT MAKE USE OF ACTIVE SUBSTANCES 

Severn Trent DeNora BalPure® Ballast Water Management System 

Submitted by Germany for Basic Approval 

0 SUMMARY 

0.1 Having reviewed all the data and information submitted by Germany with the application 

for Basic Approval, the Group recommended to MEPC that Basic Approval be granted to the 

Ballast Water Management System. 

0.2 The Group noted that the Severn Trent DeNora BalPure Ballast Water Management 

System (BWMS) uses a combination of filtration and on-demand in situ electrolysis of seawater 

to produce the Active Substance sodium hypochlorite to treat the ballast water by disinfection on 

uptake, followed by residual oxidant neutralization with sodium bisulfite on discharge. 

0.3 The Group noted that Active Substance sodium hypochlorite is not stored on board, but is 

generated by in situ electrolysis at a concentration of ~ 1000 mg/L before being injected into the 

ballasting system. As the sodium hypochlorite enters the ballast system it is diluted to a 

maximum concentration of 20 mg/L (as Cl2) initial TRO dose (normally ~ 10 mg Cl2/L TRO). 

The Group noted that the concentration of the Active Substance (TRO) is controlled using 

oxidation-reduction potential (ORP) technology. 

0.4 The Group noted that sodium bisulfite is added to ballast water discharge at a slight 

excess (<2 mg/L) to ensure complete neutralization of the TRO, and control of this addition is 

accomplished using oxidation-reduction potential (ORP) technology. The Group noted that 

according to the applicant, due to the neutralization step during ballast water discharge, the TRO 

in treated water discharge should be undetectable by the normal analytical method employed. 

The Group noted that the discharge and predicted environmental concentration (PEC) for TRO 

proposed by the applicant is 0 mg Cl2/L. 

0.5 The Group noted that treated ballast water discharge may contain sodium bisulfite, but 

recognized that in seawater bisulfite is reduced to bisulfate, and ultimately to sulfate ions. In the 

marine environment, sulfate ion is ubiquitous (seawater typically contains approximately 3 g/L of 

sulfate ion) and therefore the Group considered that the discharge or environmental 

concentrations of sodium bisulfite would not pose an unacceptable environmental risk. 

0.6 As the BWMS requires the storage of sodium bisulfite on board ship, the applicant had 

recognized that there were associated storage safety problems and has identified appropriate risk 

mitigation measures. The Group reviewed these potential risks and found the mitigation 

measures proposed to be acceptable. 
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0.7 The Group recognized that the applicant has provided information on system controls and 

safety considerations for installation of the BWMS on board ship, together with provisions for 

maintenance and emergency operations of the system. As such the Group considered that this 

information provided by the applicant is sufficient to allow the Group to recommend 

Basic Approval. 

0.8 The Group noted that the applicant indicated that corrosion is of significant concern. The 

applicant cited literature to indicate hypochlorite in levels commensurate with ballast water 

treatment will reduce the time for steel replacement in a ship by less than 5%. However, the 

Group did not agree with the provided analyses and cited several discrepancies with published 

and accepted corrosion rates. The Group considered that an analysis of the potential corrosion 

impacts of the Active Substance in the provided report alone is insufficient. The Group 

recommended that comprehensive corrosion testing be conducted, and invited the applicant to 

consider the guidance in section 5.1 of the “Report of the eighth meeting of 

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

0.9 The Group noted the provision by the applicant of some analytical results for 

the Active Substance, Relevant Chemicals and Other Chemicals in treated ballast water. As such 

the Group considered that this information provided by the applicant in the submitted dossier is 

sufficient to allow the Group to recommend Basic Approval. The Group recommended that an 

application for Final Approval of this system should include confirmation by further testing, that 

there will be no unacceptable risks (to ship safety, human health or the environment) due to the 

chemical composition of ballast water treated by this BWMS. 

0.10 The Group noted the information submitted by the applicant on human health assessment 

that includes occupational exposure (BWMS technicians, ship’s crew and dock workers) and the 

exposure of the general public (beachgoers and consumers of seafood). As such the Group 

considered that this information provided by the applicant in the submitted dossier is sufficient to 

allow the Group to recommend Basic Approval. 

0.11 Notwithstanding, the Group recommended to the applicant to take into consideration the 

exposure during sampling of ballast water at discharge (inhalation, dermal contact), as well as 

during periodic sediment cleaning (inhalation, dermal contact). These scenarios should also be 

considered by the applicant in the conceptual exposure model (CEM) for Final Approval. 

0.12 The Group noted that the applicant had not performed an environmental exposure 

assessment using an appropriate model for Basic Approval and the applicant indicated that such 

an analysis would be performed for Final Approval. The Group was of the opinion that this 

should be considered as an omission in the Basic Approval dossier, but because of the extensive 

chemical analysis of the treated ballast water and the results of the acute and chronic ecotoxicity 

testing, the Group considered this was acceptable in this particular case due to the other 

information provided. The Group recommended that all missing information be provided for 

Final Approval as indicated by the applicant. 

0.13 The Group noted that the applicant has provided information on environmental risk 

assessment for aquatic organisms and has proposed a maximum allowable discharge 

concentration (MADC) for the Active Substance of 0 mg/L (TRO as Cl2) to be achieved using 

residual oxidant neutralization with sodium bisulfite on discharge. The Group considered that 

this is acceptable subject to the applicant verifying that the neutralization is effective at all times 

(MADC < 0.2 mg/L TRO as Cl2). 
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0.14 The Group noted that there was algal toxicity existing with 66.1% of E(L)C50 with 

brackish water at 9.1 mg/L (TRO as Cl2) at 5 days after treatment and with neutralization. 

Consequently, the Group recommended that due to the algal toxicity, both acute and chronic 

ecotoxicity testing of treated ballast water be performed in accordance with the full requirements 

of Procedure (G9) at the maximum proposed treatment dose, for review at Final Approval. 

0.15 In conclusion, having reviewed all the information submitted by Germany in the 

application for Basic Approval, the Group agreed to recommend to the MEPC 

that Basic Approval be granted to this BWMS. The Group recommended that in any future 

submission for Final Approval of this BWMS, the recommendations given in this report are 

taken into account. 

1 INTRODUCTION

1.1 The data used to evaluate this system were extracted from that supplied by Germany in 

document MEPC 60/2/9 and in the confidential dossier. 

2 COMPLETENESS OF DOSSIER AND APPLICANT RESPONSES TO DATA 

REQUESTS FROM THE GROUP

2.1 Having reviewed all the data and information submitted by Germany for Basic Approval, 

the Group agreed that the information contained in the dossier was sufficient to complete the 

Basic Approval evaluation and no further clarification was required from the applicant. 

3 DESCRIPTION OF THE SYSTEM

3.1 Working Principles of the BWMS 

3.1.1 Overview 

3.1.1.1 The Group noted that in the BalPure BWMS, ballast water treatment is accomplished 

using a simple three-step process of filtration, injection of Active Substance sodium hypochlorite 

(NaOCl) solution, and residual oxidant neutralization. The first phase is filtration 

using a 40 micron stainless steel mesh filter. The second phase of the treatment process is 

electrochemical generation on-demand in situ of the biocide solution. This involves passing a 

small supply (1/100 of total ballast flow) of seawater, either from the incoming ballast water line 

or sea cooling water, through electrolytic cells, where it is subjected to medium amperage, low 

voltage direct current. The resulting disinfectant solution is injected directly into the incoming 

ballast water line. Any residual oxidant at discharge is neutralized using sodium bisulfite 

(NaHSO3). Figure 1 schematically shows the BWMS being reviewed for Basic Approval. 
GESAMP-BWWG 12/6 

ANNEX 7 

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Figure 1 – Schematic process diagram of BWMS 

3.1.1.2 The Group noted that the Active Substance sodium hypochlorite is determined as TRO 

(expressed as mg Cl2/L) in the dossier. The Group noted that the Active Substance is not stored 

on board, but is generated in situ at a concentration of ~ 1000 mg/L before being injected into the 

ballasting system. As the sodium hypochlorite enters the ballast system it is diluted to a 

maximum concentration of 20 mg/L (as Cl2) initial TRO dose (normally ~ 10 mg Cl2/L TRO). 

The Group noted that the concentration of the sodium hypochlorite solution is controlled using 

oxidation-reduction potential (ORP) technology. 

3.1.1.3 The Group noted that sodium bisulfite (38% aqueous solution) is added to ballast water 

discharge at a slight excess (<2 mg/L) to ensure complete oxidant neutralization of the TRO, and 

control of this addition is accomplished using oxidation-reduction potential (ORP) technology. 

The Group noted that according to the applicant, due to the neutralization step during ballast 

water discharge, the TRO in treated water discharge should be undetectable by the normal 

analytical method employed. 

3.1.1.4 The Group recognized that treated ballast water discharge may contain sodium bisulfite, 

but in seawater bisulfite is reduced to bisulfate, and ultimately to sulfate ions. In the marine 

environment, sulfate ion is ubiquitous and therefore, the Group considered that the discharge or 

environmental concentrations of sodium bisulfite should not pose unacceptable environmental 

risks. 

3.1.1.5 As the BWMS requires the storage of sodium bisulfite (38% aqueous solution) on board 

ship, the applicant had recognized that there were associated storage safety problems and has 

identified appropriate risk mitigation measures. The Group reviewed these potential risks and 

found the mitigation measures proposed to be acceptable. 

3.1.1.6 The Group noted that according to the applicant, the BalPure BWMS can be applied to 

ships with ballast water flow requirements from 100 to 10,000 cubic meters per hour. The 

system can be delivered as a complete system on one skid or divided into seven separate smaller 

skids based on specific unit operation (pumping, hypochlorite generation, hydrogen-hypochlorite 

separation, bisulfite storage, bisulfite metered addition, instrument and controls, and power 

rectification). 

3.2 Safety and Control 

3.2.1 The Group noted that the BalPure BWMS is designed to adjust the hypochlorite 

production rate by monitoring the operating voltage of the electrolytic cells and increasing the 

rectifier operating amperage to sustain the TRO concentration required to treat incoming ballast 
GESAMP-BWWG 12/6 

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water. These adjustments are small and used to control the hypochlorite production rate to 

a narrow range. According to the applicant, by monitoring the operating voltage of the 

electrolytic cells and adjusting the amperage applied, the Programmable Logic Controller (PLC) 

programming of the BalPure system guarantees effective operation over a wide temperature 

and/or PSU range. 

3.2.2 The Group noted that operational control of the BalPure system is accomplished by the 

main control panel or by the remote panel located in the cargo control room. Together, the 

control panel and the transformer/rectifier unit comprise the main PLC control and rectification 

components. The control panel provides a visual display of the status of the rectifier DC voltage 

and current, and can alert the operator of any system alarms via the operator interface terminal 

(OIT). The main control panel also has a local emergency stop push button. All major 

equipment such as booster pumps, bisulfite metering pumps, and hydrogen blowers can be 

controlled from the main control panel. Other system monitoring and control devices include a 

magnetic flow transmitter to monitor the flow of seawater at the electrolysis inlet, transformer 

temperature switches that monitor the internal temperature of the rectifier, and airflow switches 

that monitor the hydrogen gas dilution blowers. 

3.2.3 The Group noted that according to the applicant, during the automatic ballasting mode, 

the system will sense that adequate seawater flow is available using a flow meter in the main 

ballast line. Once the system is primed with sufficient water (an approximate 1 minute cycle), 

the transformer/rectifier will supply DC current to the electrolysis unit and initiate the 

electrochemical generation process. The hypochlorite production rate is primarily tied to the 

ballast flow rate and achieves the pre-set required oxidant concentration by modulating the 

rectifier output amperage to coincide with the ballast flow rate. The produced oxidants are then 

injected into the main ballast line. If necessary, the system may also be operated in manual 

mode. 

3.2.4 The Group noted that the BalPure BWMS remains in a stand-by mode until the flow 

meter in the main ballast line detects ballast water flow and activates the BalPure system. Using 

an inline booster pump, the BalPure system typically receives <1% of the total incoming ballast 

water flow as a side-stream off the main ballast intake line. An inlet flow transmitter, designed 

to protect the treatment system, will shut down the electrical current to the electrolysis unit 

should seawater flow through the electrolyser drop below 80% of the design flow rate. The 

filtered seawater passes through a heat sink where it absorbs excess heat generated by the siliconcontrolled rectifiers. The seawater then passes through a series of electrolytic cells, which are 

connected to the transformer/rectifier. The electrolysis units then generate the Active Substance 

along with hydrogen gas (H2) as a by-product. 

3.2.5 The Group noted that according to the applicant, the BalPure system has several safety 

mechanisms that are engineered into the system to ensure that hydrogen gas is effectively 

removed from the ship. These include a patented cyclone separator device that removes the 

hydrogen gas from the biocide solution and redundant non-sparking blowers to reduce the 

concentration of hydrogen gas to <1% within a vent line to the atmosphere outside the ship. 

Additionally, a hydrogen gas detector is located in the space(s) where hydrogen gas may enter 

should a BalPure system failure occur. The PLC monitors and controls all of these safety 

features and will result in an alarm condition should the system require maintenance. The Group 

recalled that the LEL (Lower Explosive Limit) for hydrogen gas is 4% and the operating 

limitations on the system therefore provide a safety factor which is considered by the Group to be 

acceptable. 
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ANNEX 7 

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3.2.6 The Group noted that in the de-ballast mode of operation, the last phase of the treatment 

process, residual oxidant present in the ballast tank is neutralized with sodium bisulfite just prior 

to discharge from the ship. Complete neutralization of residual oxidants is ensured using ORP 

technology and bisulfite metering pumps. Two ORP probes are used; one confirms the presence 

of residual oxidant exiting the ballast tanks, while the second probe monitors and controls the 

addition of sodium bisulfite to neutralize TRO during ballast water discharge. The first ORP 

probe is located upstream of the bisulfite injection point, and the second ORP probe is located 

downstream of the bisulfite injection point. As a fail-safe measure, the BalPure system is fitted 

with two redundant bisulfite metering pumps; one pump is the primary dosing pump and the 

second is an on-line ready spare. 

3.2.7 The Group recognized that the only chemical that will require on board storage and 

handling is the neutralizing agent, sodium bisulfite (38% aqueous solution). Moreover the Group 

recognized that this is non-flammable and does not present any on board fire risk. With the 

BalPure system, sodium bisulfite is stored in stainless steel tanks designed for installation in a 

marine setting. The Group considered that the only potential activities that may require 

“handling” of bisulfite is either system maintenance or chemical re-supply operations. Normal 

operation of the BalPure system involves automatic chemical dosing and does not require contact 

with any chemicals. Proper personal protective equipment (PPE) will be worn and only properly 

trained BalPure technicians or representatives will be allowed to perform sodium bisulfite 

re-supply. 

3.2.8 The Group noted that according to the applicant, in the event there is an accidental release 

of sodium bisulfite on board ship, the spill should be contained and neutralized with an alkali 

such as sodium carbonate, sodium bicarbonate, soda ash, lime or limestone granules. All spilled 

material and neutralization residues must be disposed of in accordance with applicable 

regulations. Decomposition of sodium bisulfite may liberate sulfur dioxide, which can be 

harmful when inhaled. Adequate ventilation and respiratory protection are required in any area 

of accidental release. The Group considered that in the event of a marine environment release, 

sodium bisulfite is water soluble and will not cause unacceptable environmental impacts as it will 

quickly be converted to sulfate. Overall, the Group concluded that the potential risks from 

sodium bisulfite (38% aqueous solution) storage have been adequately addressed and are 

minimal. 

3.3 Chemical processes involved in the BWMS – Active Substance (AS), Relevant 

Chemicals (RC) and Other Chemicals (OC) 

3.3.1 The Group recalled the chemical reactions involved in the electrolysis of natural 

seawater. The Group also recalled that Active Substance sodium hypochlorite is determined as 

TRO (expressed as mg Cl2/L), and the dosing concentration of TRO in this BWMS has been 

fully discussed above at section 3.1.1.2. In addition, the Group noted that the applicant has 

performed analyses for TRO levels in treated ballast water and the results are presented in the 

appendix, section 4 (Table A4). 

3.3.2 The Group recognized that during the electrolysis process, hydrogen gas is produced. For 

this reason, H2 is classified as a Relevant Chemical, however, the hydrogen gas produced is 

immediately separated from the solution and removed from the system via ventilation to the 

atmosphere – see above at section 3.2.5. The Group concluded that the risks associated with 

hydrogen gas are being adequately addressed. 
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3.3.3 The Group noted that the applicant has provided analyses of treated ballast water for 

Active Substance, Relevant Chemicals and Other Chemicals as part of this application for 

Basic Approval. In the case of Relevant Chemicals and Other Chemicals, the Group recognized 

that trihalomethanes (THM), haloacetic acids (HAA) and sodium bromate are disinfection 

by-products (DBP), and the applicant has performed analyses for these chemicals in treated 

ballast water – see appendix, section 6 (Tables A6, A7 and A8). 

3.3.4 The applicant identified the preliminary nature of the data sets provided on the analysis of 

Active Substance, Relevant Chemicals and Other Chemicals in treated ballast water in this 

submission and that this is to be further investigated during land-based and shipboard testing for 

Final Approval. 

4 HUMAN HEALTH ASSESSMENT 

4.1 Considerations for risk assessment 

4.1.1 The Group noted that the risk assessment methodology used by the applicant was based 

on the identification of complete exposure pathways concerning the different exposure scenarios 

which could represent a human health concern (US EPA, 1989). On every situation, the complete 

exposure pathway required four key elements: chemical sources; migration routes 

(i.e. environmental transport); potentially exposed human receptors; and routes of exposure to 

impacted media (e.g., ingestion of chemicals in water). Potential human receptor groups and 

exposure routes are described in the Conceptual Exposure Model (CEM) as presented by the 

applicant. Intake factors (Exposure Factors Handbook, US EPA, 1997) were used to determine 

the amount of chemicals of potential concern (COPC) that each receptor is potentially exposed to 

via each exposure route, and were used to evaluate both cancer risk and non-cancer hazard. 

SOURCES

Primary Secondary Tertiary

Vessel Surface

Seawater

Dock/Shoreline

• Pathway is or might be complete; sufficient data available for quantitative evaluation

X Pathway is or might be complete, but judged to be minor; not evaluated quantitatively

1

STDN Technician exposure considered worst-case scenario for anyone working onboard vessel.

2

Not evaluated quantiatively in risk assessment; semi-qualitatively evaluation provided.

Pathway is not complete; no evaluation required

General 

Public

Off Board

Dock 

Workers

•

X

Spills/Leaks from 

Storage Tanks, 

Pipelines or BWTS

Vapors/Indoor Air

Vapors/Outdoor Air

•

STDN 

Technician

X1

X

•

Release from

Ballast Tanks

Dermal Contact/

Incidental Ingestion X

Inhalation X

On Board

X

Dermal Contact/

Incidental Ingestion

Inhalation

X

Exposure Routes

•

X2

Ship's Crew

Figure 2 – Conceptual Human Exposure Model, BalPure System 
GESAMP-BWWG 12/6 

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4.1.2 The Group noted that the applicant assessed the toxicological hazards and potential 

human exposure associated with COPC generated by the BalPure system. The primary sources of 

COPC included the in situ production of sodium hypochlorite, the sodium bisulfite storage tanks 

and associated pipelines, and the treated ballast water itself. 

4.1.3 The Group noted that the applicant has identified the following chemicals associated with 

the BalPure system as possible COPC - sodium hypochlorite (TRO), THM, HAA, bromate and 

sodium bisulfite. Only exposure to COPC resulting from leaks of storage tanks, pipelines and 

ballast tanks discharges were evaluated quantitatively by the applicant in the risk assessment. 

4.1.4 The Group noted that the applicant considers that no exposure is anticipated during normal 

operating conditions due to the fact that chemicals used in the BalPure system are contained within a 

closed system (sodium hypochlorite is produced in situ and is injected directly into the ballast system; 

sodium bisulfite is injected into the ballast water as it is discharged from the ship). 

4.2 Assessment of exposure to ship’s crew and BWMS technicians 

4.2.1 The Group noted that according to the applicant under normal conditions the ship’s crew 

(including BWMS technicians) would not be exposed to sodium hypochlorite and by-products in 

the treated ballast water unless there is a failure of the system or when performing service on the 

system. The risks associated with these scenarios are mitigated by numerous system safety 

measures (leak detection, hydrogen gas removal, equipment isolation, stray current protection etc) 

and by following the use of appropriate personal protective equipment (PPE) when performing 

maintenance and/or repair on the system. Therefore, the Group recognized that under normal 

operating conditions, neither BWMS technicians nor the ship’s crew is expected to have contact 

with the system-related COPC. 

4.2.2 In addition to the above mentioned anticipated exposure situations the Group considered 

that the applicant should provide information regarding exposure during sampling of ballast 

water during discharge (inhalation, dermal contact), as well as during periodic sediment cleaning 

(inhalation, dermal). These scenarios should also be considered in the conceptual exposure model 

(CEM). 

4.2.3 Furthermore, the Group recommended that appropriate precautionary measures should be 

followed when any operator enters the ballast tanks for inspection or for sampling operational 

procedures and cleaning operations. 

4.3 Exposure of general public through the environment and food chain 

4.3.1 The Group noted the description made by the applicant regarding the exposure of the 

general public (beachgoers): 

- incidental ingestion of ballast water COPC discharged to seawater near the 

shoreline; 

- dermal contact with ballast water COPC discharged to seawater near the 

shoreline; and 

- inhalation of ballast water COPC vapours or mists in outdoor air near the 

shoreline. 
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4.3.2 According to the applicant the potentially complete and quantifiable exposure pathways 

for swimmers include: incidental ingestion of and dermal contact with hypochlorous acid, 

bromate, THM, HAA, sodium bisulfite, and recently discharged ballast water. It is 

conservatively assumed that maximum residual ballast water COPC concentrations are 

diluted 100-fold prior to contact with beachgoers. 

4.3.3 Chemicals detected in discharged treated ballast water may pose a threat to seafood 

consumers only if they tend to bioaccumulate (Log Kow >3 or a bioconcentration factor > 2000). 

The COPC identified in this risk assessment all have Log Kow values less than 3 and therefore are 

not expected to persist in the food web. 

4.3.4 The Group concurred with the view of the applicant that no adverse health effects would 

be expected from either bathers exposed to diluted concentrations of these chemicals or 

consumers of seafood. 

4.4 Conclusion on Human Health assessment 

4.4.1 The Group accepted that the applicant has assessed qualitatively and quantitatively the 

potential human exposures and health effects. Overall, the risk assessment determined that risks 

to all human receptor groups from the BalPure system under normal operating conditions do not 

pose any unacceptable risk. Hazards for the general public/beachgoers are well below levels of 

concern; actual risks to these receptors are expected to be even lower, as they are unlikely to be 

repeatedly exposed to treated ballast water as assumed in this risk evaluation. Since the risk 

assessment only evaluated direct exposure via ingestion and dermal contact with chemicals or 

ballast water, as these were considered the most relevant pathways, further semi-quantitative 

evaluation of the inhalation pathway was performed by the applicant for the volatile THM. This 

assessment demonstrated that conservative concentrations of airborne THM generated by a 

release of ballast water were well below occupational exposure limits taking into consideration a 

dilution factor of 10. 

4.4.2 The Group considered that the human exposure assessment submitted by the applicant 

makes possible to conclude that the operation of this BWMS poses no unacceptable risk to ships’ 

crew, technicians and to the general public. 

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

5.1 Safety of the ship 

5.1.1 The Group noted that specific countermeasures that can be employed in this system to 

deal with envisaged emergency and safety problems during the ballast water treatment have been 

summarized above. In particular a summary of the various safety measures developed by the 

applicant is given above in section 3.2. 

5.1.2 The Group noted that the applicant indicated that corrosion is of significant concern. 

Further, the applicant cited and reviewed a series of corrosion tests conducted by BMT Fleet 

Technology Limited (BMT) as well as their conclusion based on work by Paik et al. that 

hypochlorite in levels commensurate with ballast water treatment will reduce the time for steel 

replacement in a ship by less than 5%. However, in reviewing the cited report by BMT, the 

Group did not agree with interpretation of the work by Paik et al. In particular, the provided 

equation for corrosion loss, incorrectly defines the parameter tr as the thickness of steel at time T 

after construction. In fact, the Paik et al. model indicates that tr is the total material loss over 
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time T. The Group also notes other discrepancies in the BMT testing including the inappropriate 

substitution of salt water for natural seawater and the substantial difference in corrosion rates in 

untreated water from published and accepted values. With respect to the latter, BMT concluded 

that the natural corrosion rate of bare steel is between 0.1 and 1.4 mm/year for immersion in 

freshwater and 0.75 mm/year in seawater immersion. However, these are substantially higher 

than the generally accepted corrosion rate values, including those used by Paik et al. of 0.1 

and 0.2 mm/year for immersed, static corrosion in freshwater and seawater, respectively. The 

Group considered that an analysis of the potential corrosion impacts of the Active Substance on 

this report alone is insufficient. If the applicant intends to use the corrosion accumulation model 

provided by Paik et al. the Group recommended that the applicant considers the original 

reference material. 

5.1.3 The Group also noted that the applicant presented through the use of BMT’s literature 

review and impact assessment using the Paik et al. model for total corrosion loss over the life of 

the ship on the basis of intermittent exposure to the Active Substance. While the Group 

considered this a useful extension of the corrosion analyses, an estimation of total corrosion loss 

is unnecessary for the Group’s consideration. The Group recommended a comprehensive 

corrosion analysis which establishes the anticipated corrosion rates of the ship’s structures when 

exposed to the Active Substance. It is understood that the cumulative corrosion losses over the 

life of the ship will be dependent on ship operations and Active Substance decay rates, which are 

naturally difficult to predict for all conditions. If such an analysis is provided, however, the 

Group recommended that the applicant provides analyses for both typical and worst case 

conditions. 

5.1.4 The Group recommended that comprehensive corrosion testing be conducted, taking into 

account the guidance in section 5.1 of the “Report of the eighth meeting of the 

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

5.1.5 The Group considered that sufficient information had been provided by the applicant 

addressing risks to the safety of the ship to permit further development of this BWMS. 

5.2 Safety of the crew 

5.2.1 The Group considered that no unacceptable risk to safety of the ships’ crew (BWMS 

operators included) by exposure to chemicals and treated ballast water should be posed based on 

the measures developed by the applicant for installation on-board ship. A summary of the various 

safety measures developed by the applicant is given above in section 3.2. The Group considered 

that in this system, the risk to ships’ crew is judged to be appropriately managed based on the 

facts that the Active Substance is produced in situ as well as that system components are adopted 

that are expected to minimize the exposure risk of ships’ crew to chemicals and ballast water 

before and after treatment, through the exposure routes of concern assessed, as discussed above 

in section 4. 

5.3 Safety of the general public 

5.3.1 The Group considered that the system as presented would pose no unacceptable risk to 

the health of the general public according to the outcome of the human exposure routes of 

concern assessed, as discussed above in section 4. 
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6 ENVIRONMENTAL RISK ASSESSMENT 

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

6.1.1 The Group noted that the applicant has made a comprehensive listing of P, B and T 

criteria for the Active Substance and Relevant Chemicals found in the treated ballast water, with 

results being presented in the appendix, section 2 (Table A2). 

6.1.2 Based on these results, the Group concluded that none of these chemicals should be 

classified as PBT-substances. 

6.2 Ecotoxicity testing of treated ballast water 

6.2.1 The Group noted that the applicant has performed acute and chronic aquatic ecotoxicity 

testing of treated ballast water from the BalPure system, and full results are presented in the 

appendix, section 7 (Tables A9 – acute and A10 – chronic). The Group noted that the applicant 

performed the acute testing with fresh water at 6.7 mg/L (TRO as Cl2), with brackish water 

at 9.1 mg/L (TRO as Cl2), with seawater at 4.3 mg/L (TRO as Cl2), and chronic testing with 

seawater at 15.0 mg/L (TRO as Cl2), using the treated ballast water with neutralization. 

6.3 Acute aquatic ecotoxicity testing 

6.3.1 The Group noted that acute aquatic ecotoxicity tests were performed at differing 

hypochlorite concentrations. Tests were conducted using algae, invertebrates, and fish in fresh 

water, brackish water, and seawater – a total of 9 tests were performed. The samples were 

collected for toxicity testing on Day 0 (immediately after addition of hypochlorite), and on Day 2 

and Day 5 after treatment. Following the collection of Day 5 samples, residual TRO was 

neutralized with sodium bisulfite and a second Day 5 post-neutralization sample was collected 

for toxicity testing. The neutralized water was then held an additional 5 days (i.e. 10 days after 

hypochlorite treatment) and then tested for aquatic toxicity. 

6.3.2 The Group noted from the results presented that ecotoxicity was observed for all species in 

the samples collected immediately after hypochlorite treatment (Day 0) and some ecotoxicity was 

observed in the Day 2 and Day 5 pre-neutralization samples, with the exception of freshwater fish. 

With the exception of one data point (96-hour exposure EC50 of 66.1% for the marine algal diatom 

Skeletonema in brackish water), ecotoxicity was not observed in the Day 5 post-neutralization 

samples. From this single result, the Group recognized that less than a two-fold dilution of the 

treated ballast water would be required to reach a concentration less than the EC50 for 

Skeletonema. 

6.4 Chronic aquatic ecotoxicity testing 

6.4.1 The Group noted that chronic aquatic ecotoxicity tests were conducted using treated 

ballast water samples collected during the full-scale study. The chronic tests were performed on 

seawater samples only. Samples were collected from ballast water treated with hypochlorite 

at 15 mg Cl2/L TRO concentration and then held for 2 days. After 2 days the treated water was 

neutralized with an excess concentration of ~ 2 mg/L sodium bisulfite. Five concentrations of 

treated sample using a 0.5x dilution series were tested. Bioassays were conducted using 7-day 

tests with a mysid (Americamysis bahia) and a larval fish (Menidia beryllina), a 48-hour larval 

development test using a mussel (Mytilus galloprovincialis), and a 48-hour germination and germ 

tube length test using the giant kelp (Macrocystis pyrifera). 
GESAMP-BWWG 12/6 

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6.4.2 The Group noted that results for the chronic ecotoxicity tests indicated that no toxicity 

was observed with the treated water samples for any species tested at any concentration. The 

highest concentration with no observed effect (NOEC) was therefore 100 per cent sample. 

6.4.3 In summary, the Group concluded that whole effluent ecotoxicity testing (acute and 

chronic endpoints) of neutralized ballast water discharge indicates no apparent toxicity for all 

species and endpoints tested (E(L)C50 and/or NOEC values of ≥100% treated ballast water), 

except one single acute endpoint for the marine algal diatom Skeletonema in brackish water. The 

Group noted that there was algal toxicity existing with 66.1% of E(L)C50 with brackish water 

at 9.1 mg/L (TRO as Cl2) at 5 days after treatment and with neutralization. Consequently, the 

Group recommended that due to the algal toxicity, both acute and chronic ecotoxicity testing of 

treated ballast water be performed in accordance with the full requirements of Procedure (G9) at 

the maximum proposed treatment dose, for review at Final Approval. 

6.5 Risk assessments of chemicals for aquatic organisms 

6.5.1 Prediction of discharge and environmental concentrations for Active Substance 

TRO 

6.5.1.1 The Group noted that according to the applicant, due to the TRO neutralization during 

ballast water discharge, the TRO concentration in treated water discharged to the environment 

will be undetectable by the normal analytical method. The Group noted that the applicant has 

proposed a maximum allowable discharge concentration (MADC) for the Active Substance 

of 0 mg/L (TRO as Cl2) to be achieved using residual oxidant neutralization with sodium 

bisulfite on discharge. The Group considered that this is acceptable subject to the applicant 

verifying that the neutralization is effective at all times (MADC < 0.2 mg/L TRO as Cl2). 

6.5.1.2 The Group noted that according to the applicant, PEC values will be derived using 

appropriate emission scenario modeling based on analysis of treated ballast water samples drawn 

from the full-scale land-based testing and will be presented for Final Approval. 

6.5.2 Aquatic Ecotoxicity and Predicted No-Effect Concentration (PNEC) 

6.5.2.1 The Group noted that a literature search was conducted by the applicant to locate 

existing acute and chronic aquatic ecotoxicity data for the substances associated with thissystem. 

A complete base-set for fish, crustaceans and algae was not located for all substances and in 

some cases, the data do not meet validity criteria. However, the data have been provided by the 

applicant as supporting information and were used to derive PNEC values as calculated by the 

applicant, which are presented in the appendix, section 1 (Table A1). 

6.6 Conclusion from Environmental Risk Assessment 

6.6.1 The Group recognized that the applicant has proposed a maximum allowable discharge 

concentration (MADC) for the Active Substance of 0 mg/L (TRO as Cl2) to be achieved using an 

oxidant neutralization step at discharge with sodium bisulfite. The Group considered that this is 

acceptable subject to the applicant verifying that the neutralization is effective at all times 

(MADC < 0.2 mg/L TRO as Cl2). 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 13 

I:\MEPC\60\2-16.doc 

6.6.2 The Group noted that the applicant had not performed an environmental exposure 

assessment using an appropriate model for Basic Approval and the applicant indicated that such 

an analysis would be performed for Final Approval. The Group was of the opinion that this 

should be considered as an omission in the Basic Approval dossier, but because of the extensive 

chemical analysis of the treated ballast water and the results of the acute and chronic ecotoxicity 

testing, the Group considered this was acceptable in this particular case due to the other 

information provided. The Group recommended that all missing information be provided for 

Final Approval as indicated by the applicant. 

6.6.3 The Group agreed that the proposed BWMS should not pose any unacceptable risks for 

the environment. 

7 CONCLUSIONS AND RECOMMENDATIONS

7.1 Risks to safety of the ship 

7.1.1 The Group noted that specific risk mitigation measures are to be employed in this system 

to deal with envisaged emergency and safety problems during the ballast water treatment and 

have been described and discussed above. 

7.1.2 The Group considered that sufficient information had been provided by the applicant 

addressing risks to the safety of the ship to permit further development of this system. 

7.1.3 The Group recommended that corrosion testing be conducted, taking into account the 

guidance in section 5.1 of the “Report of the eighth meeting of the GESAMP-BWWG”, 

contained in MEPC 59/2/16. 

7.2 Risks to the crew and general public 

7.2.1 The Group considered that this BWMS should not pose any unacceptable risk to the 

health of the crew and the general public regarding the exposure to chemicals and treated ballast 

water, based on the information provided and on the incorporation of the risk mitigation 

measures proposed by the applicant. 

7.3 Risks to the environment 

7.3.1 The Group concluded that based on the applicant’s proposal for a MADC of the Active 

Substance and the Group’s evaluation of the information provided on acute and chronic aquatic 

ecotoxicity testing of treated ballast water, together with other information provided in the 

dossier, that the risks to the environment posed by use of this system should be acceptable, 

subject to the applicant verifying that the neutralization is effective at all times. 

7.4 Recommendation 

7.4.1 Having reviewed all the data and information submitted by Germany for Basic Approval, 

the Group was able to recommend to MEPC to give Basic Approval for the BalPure BWMS. 

7.4.2 The Group made the following recommendations and requests for information, if this 

system is to be reviewed for Final Approval in the future: 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 14 

I:\MEPC\60\2-16.doc 

 .1 The Group recommended that a comprehensive evaluation of the corrosion 

impacts on ships’ structures be conducted using the maximum anticipated 

treatment concentration, 20 mg/L (TRO as Cl2) and that a realistic TRO decay 

profile may be considered if the total corrosion loss over the ship’s life is to be 

projected. The Group noted however that such an analysis, while useful, is not 

necessary for the Group’s consideration. The Group recommended that corrosion 

testing be conducted, and 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; 

 .2 The Group recommended to take into consideration the human exposure during 

sampling of ballast water at discharge (inhalation, dermal contact), as well as 

during periodic sediment cleaning (inhalation, dermal). These scenarios should 

also be considered in the conceptual exposure model (CEM); 

.3 The Group recommended that the data sets on the analysis of Active Substance, 

Relevant Chemicals and Other Chemicals in treated ballast water should be further 

investigated during land-based and shipboard testing; 

 .4 The Group recommended that confirmation by further testing should be 

performed, that there will be no unacceptable risks (to ship safety, human health or 

the environment) due to the chemical composition of ballast water treated by this 

BWMS; 

 .5 The Group recommended that all missing information concerning the 

environmental exposure assessment using an appropriate model be provided; 

 .6 The Group recommended verification that the residual oxidant neutralization with 

sodium bisulfite on discharge is effective at all ballast discharges 

with MADC < 0.20 mg/L TRO as Cl2; and 

 .7 The Group recommended that both acute and chronic ecotoxicity testing of treated 

ballast water be performed in accordance with the full requirements of 

Procedure (G9) at the maximum proposed treatment dose. 

* * * 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 15 

I:\MEPC\60\2-16.doc 

APPENDIX 

Severn Trent DeNora BalPure Ballast Water Management System 

Submitted for Basic Approval by Germany

1 Effects on Aquatic Organisms – Information used to Derive PNEC Values 

 (As presented by applicant) 

Table A1 : PNEC Value Summary 

Substance Lowest Effect 

Concentration 

(mg/L) 

Assessment 

Factor 

PNEC Value 

(μg/L) 

Reference/Comments 

Active Substances

TRO (Fresh water) Insufficient 

Data Located -- 0.06 (as TRC) 

Based on EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

TRC in fresh water 

TRO (Saltwater) 0.062 1000 0.062 

HOCl 0.032 1000 0.032 

HOBr Data Not 

Located -- 0.032 Estimated based on HOCl toxicity data 

Relevant Chemicals

Bromate 13.6 1000 13.6 

THMs 

Chloroform 1.5 100 15 / 146 146 μg/L to be used as 

PNEC for Total THMs 

Bromoform 12.3 1000 12.3 / 146 146 μg/L to be used as 

PNEC for Total THMs 

Dibromochloromethane (DBCM) Data Not 

Located -- Not Derivable 

Use EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

Total THMs 

Dichlorobromomethane (DCBM) Data Not 

Located -- Not Derivable 

Use EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

Total THMs 

Total THMs -- -- 146 

Based on EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

Total THMs 

HAAs 

Bromochloroacetic 

acid 

Data Not 

Located -- 0.85 

Based on EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

HAAs 

Monochloroacetic 

acid 

Insufficient 

Data Located -- 0.85 Based on EU Sodium Hypochlorite RAR 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 16 

I:\MEPC\60\2-16.doc 

Substance Lowest Effect 

Concentration 

(mg/L) 

Assessment 

Factor 

PNEC Value 

(μg/L) 

Reference/Comments 

suggested PNEC for 

HAAs 

Dichloroacetic acid Insufficient 

Data Located -- 0.85 

Based on EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

HAAs 

Trichloroacetic acid 500 1000 500 

Monobromoacetic 

acid 

Insufficient 

Data Located -- 0.85 

Based on EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

HAAs 

Dibromoacetic acid Insufficient 

Data Located -- 0.85 

Based on EU Sodium 

Hypochlorite RAR 

suggested PNEC for 

HAAs 

Other Chemicals 

Sodium bisulfite Insufficient 

Data Located -- Not Derivable 

2 Screening for Persistence (P), Bioaccumulation (B) and Toxicity (T) 

(As presented by applicant) 

Table A2 : PBT Criteria Evaluation 

Substance 

Persistence (P) Half-life: 

>60 days in marine water (MW), or 

>40 days in fresh water (FW) , or 

>180 days in marine sediment (MS), 

or 

>120 days in freshwater sediment 

(FWS) 

 (YES or NO) 

Bioaccumul

ation (B) 

BCF >2,000 

or Log Kow 

≥3 

(YES or 

NO) 

Toxicity (T) 

Chronic 

NOEC 

<0.01mg/L 

(YES or NO) 

Active substances

Hypochlorous 

acid 

No 

FW: 15 days (EPI Suite, 2009c) 

No 

Log Kow = -

0.87 

No 

Lowest NOEC 

= 0.042 mg/L 

(Fish) 

Hypobromous 

acid 

No 

FW: 15 days (EPI Suite, 2009b)

No 

Log Kow = -

0.78 

No 

based on 

hypochlorous 

acid 

Relevant Chemicals

Bromate No 

FW: 15 days (EPI Suite, 2009a) 

No 

Log Kow = -

4.6 

No 

Lowest NOEC 

= 8 mg/L 

(Crustacean) 
GESAMP-BWWG 12/6 

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Substance 

Persistence (P) Half-life: 

>60 days in marine water (MW), or 

>40 days in fresh water (FW) , or 

>180 days in marine sediment (MS), 

or 

>120 days in freshwater sediment 

(FWS) 

 (YES or NO) 

Bioaccumul

ation (B) 

BCF >2,000 

or Log Kow 

≥3 

(YES or 

NO) 

Toxicity (T) 

Chronic 

NOEC 

<0.01mg/L 

(YES or NO) 

THMs

Chloroform 

No 

FW: 4.4 days; Not expected to adsorb 

to sediment. (HSDB/TOXNET 2009f)

No 

BCF = 

2.9-10.35 

No 

Lowest NOEC 

= 1.5 mg/L 

(Fish) 

Bromoform 

No 

FW: 7.1 days; Not expected to adsorb 

to sediment. (HSDB/TOXNET 2009l)

No 

BCF = 14 

No 

Lowest NOEC 

= 8.5 mg/L 

(Fish) 

Dichlorobromomethane 

No 

FW: 5 days; Not expected to adsorb to 

sediment. (HSDB/TOXNET 2009c)

No 

BCF = 7 

No 

LC50 = 

72 mg/L (Fish) 

Chlorodibromomethane 

No 

FW: 6 days; Not expected to adsorb to 

sediment. (HSDB/TOXNET 2009e)

No 

BCF = 9 

No 

LC50 = 

34 mg/L (Fish) 

HAAs

Bromochloroacetic 

acid 

No biodegradation data available. Not 

expected to adsorb to suspended 

solids or sediment. (HSDB/TOXNET 

2009b)

No 

Log Kow = 

0.61 

Data not 

located. 

Monochloroacetic 

acid 

No 

FW: 14 days (Ellis, et al. 2001); Not 

expected to adsorb to sediment. 

(HSDB/TOXNET 2009d)

No 

Log Kow = 

0.22 

No 

Lowest NOEC 

= 0.13 mg/L 

(Algae) 

Monobromoacetic 

acid 

No half-life data available; Not 

expected to adsorb to sediment. In 

aqueous biodegradation screening 

tests, reached 82% of its theoretical 

BOD when using pre-acclimatized 

inoculums (HSDB/TOXNET 2009a)

No 

Log Kow = 

0.41 

No 

NOEC = 

3.2 mg/L 

(Crustacean) 

Dichloroacetic 

acid 

No 

FW: 4 days (Ellis et al. 2001); Not 

expected to adsorb to sediment. 

(HSDB/TOXNET 2009h)

No 

Log Kow = 

0.92 

No 

EC03 = 

1485 mg/L 

(Algae) 

Dibromoacetic 

Acid 

No 

FW: 14 days (HSDB/TOXNET 

2009g)

No 

BCF = 0.17 

No 

Lowest LC50 = 

69 mg/L (Fish) 

Trichloroacetic 

acid 

No 

FW: 40 days (Ellis et al 2001); Not 

expected to adsorb to sediment. 

(HSDB/TOXNET 2009m)

No 

BCF = 

0.1-1.7 

No 

Lowest NOEC 

= 100 mg/L 

(Algae) 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 18 

I:\MEPC\60\2-16.doc 

Substance 

Persistence (P) Half-life: 

>60 days in marine water (MW), or 

>40 days in fresh water (FW) , or 

>180 days in marine sediment (MS), 

or 

>120 days in freshwater sediment 

(FWS) 

 (YES or NO) 

Bioaccumul

ation (B) 

BCF >2,000 

or Log Kow 

≥3 

(YES or 

NO) 

Toxicity (T) 

Chronic 

NOEC 

<0.01mg/L 

(YES or NO) 

Other Chemicals

Sodium bisulfite No 

FW: 15 days (HSDB/TOXNET 2009)

No 

BCF = 3.2 

No 

Lowest LC50 = 

100 mg/L 

(Fish) 

3 Properties of Treated Ballast Water 

(As presented by applicant) 

Table A3 : Physical and Chemical Properties of Treated Ballast Water 

Physical/Chemical Property Treated Ballast Water 

Density (20oC; kg/m3) Same as seawater 

Oxidation/Reduction potential <200 mV* 

Corrosivity to materials 

Similar to untreated ballast 

water 

Reactivity to container material 

Similar to untreated ballast 

water 

pH See Table 26 

Salinity See Table 26 

TOC See Table 26 

DOC See Table 26 

Other known’s None 

 * ORP as measured in ballast water after neutralization with sodium bisulfite. 

4 Total Residual Oxidants (TRO) in Treated Ballast Water 

(As presented by applicant)

Table A4 : Total Residual Oxidant (TRO) measured as Total Chlorine 

(The Day 0 value represents the applied concentration of the Active Substance) 

Day Treatment 

Tank 1*

TRO (mg/L) 

Treatment 

 Tank 2 

TRO (mg/L) 

Reference

Fresh Water

5-Dec (Day 0) 6.7 5.7 Sosik & Herwig, 2009 

7-Dec (Day 2) 2.3 1.5 Sosik & Herwig, 2009 

10-Dec (Day 5) 1 0.5 Sosik & Herwig, 2009 

15-Dec (Day 10) 0 0 Sosik & Herwig, 2009 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 19 

I:\MEPC\60\2-16.doc 

Day Treatment 

Tank 1*

TRO (mg/L) 

Treatment 

 Tank 2 

TRO (mg/L) 

Reference

Brackish Water 

9-Dec (Day 0) 9.1 10.5 Sosik & Herwig, 2009 

11-Dec (Day 2) 6.3 N/A Sosik & Herwig, 2009 

14-Dec (Day 5) 4.8 3.9 Sosik & Herwig, 2009 

19-Dec (Day 10) 0 0 Sosik & Herwig, 2009 

Saltwater 

9-Dec (Day 0) 4.3 4.5 Sosik & Herwig, 2009 

11-Dec (Day 2) 3.6 N/A Sosik & Herwig, 2009 

14-Dec (Day 5) 3.1 N/A Sosik & Herwig, 2009 

19-Dec (Day 10) 0 N/A Sosik & Herwig, 2009 

*

 Samples from Tank 1 were collected for DBP and toxicity evaluation. 

5 Water quality parameters in Treated Ballast Water 

(As presented by applicant)

Table A5 : Summary of Water Quality Parameters 

Parameter Fresh 

water 

Brackish 

Water 

Seawater Reference 

Initial POC (mg/L) 2.81 2.72 1.37 Sosik & Herwig, 2009 

Initial DOC (mg/L) 3.72 5.69 4.23 Sosik & Herwig, 2009 

Initial TSS (mg/L) 34.46 76.09 3.75 Sosik & Herwig, 2009 

Salinity range 

(PSU) 

0.62 – 0.64 21.54 – 21.75 30.48 – 

30.57 

Sosik & Herwig, 2009 

pH range 7.23 – 7.74 7.15 – 8.26 7.46 – 7.97 Sosik & Herwig, 2009 

Temperature range 

(°C) 

10.9 – 

13.16 

6.72 – 9.75 6.43 – 9.36 Sosik & Herwig, 2009 

6 Disinfection By-Products (DBP) in Treated Ballast Water 

(As presented by applicant)

The samples collected on Day 0 and Day 2 were analyzed prior to the neutralization step. The 

samples collected on Day 5 and Day 10 were analyzed after neutralization with sodium bisulfite. 

Table A6 : Levels of Trihalomethanes (THM) and Haloacetic acids (HAA) 

in Treated Fresh Water 

FRESHWATER 

Day 0 Day 2 Day 

5* 

Day 

10* Reference 

THM (EPA Method 

524.2) μg/L μg/L μg/L μg/L 

chloroform 21.6 42.2 52.9 43.1 Sosik & Herwig, 

2009 

dichlorobromomethane 33.2 70.8 90.2 73.6 Sosik & Herwig, 

2009 
GESAMP-BWWG 12/6 

ANNEX 7 

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FRESHWATER 

Day 0 Day 2 Day 

5* 

Day 

10* Reference 

chlorodibromomethane 71.8 127 157 123.7 Sosik & Herwig, 

2009 

bromoform 69.7 92.1 100 95 Sosik & Herwig, 

2009 

Total THM 196.3 332 400 335.4 Sosik & Herwig, 

2009 

HAA (EPA Method 

552.1) 

bromochloroacetic acid 23.4 49.7 38.3 44.2 Sosik & Herwig, 

2009 

monochloroacetic acid 3.9 2.5 2.7 2.8 Sosik & Herwig, 

2009 

dichloroacetic acid 18.4 38.8 33.7 39.5 Sosik & Herwig, 

2009 

trichloroacetic acid 33 42.2 47.7 56.3 Sosik & Herwig, 

2009 

monobromoacetic acid 2.4 3.3 3.3 2.1 Sosik & Herwig, 

2009 

dibromoacetic acid 36 51.1 47.4 54 Sosik & Herwig, 

2009 

Total HAA (6) 93.7 137.9 134.8 154.7 Sosik & Herwig, 

2009 

 “*” = Experimental tanks were neutralized with sodium bisulfite. 

Table A7 : Levels of Trihalomethanes (THM) and Haloacetic acids (HAA) 

in Treated Brackish Water 

BRACKISH WATER 

 Day 0 Day 2 Day 

5* 

Day 

10* Reference 

THM μg/L μg/L μg/L μg/L 

chloroform 0 0.5 0.6 0.5 Sosik & Herwig, 

2009 

dichlorobromomethane 2.4 6.4 6.3 4.6 Sosik & Herwig, 

2009 

chlorodibromomethane 13.4 42.8 45.7 34.1 Sosik & Herwig, 

2009 

bromoform 209 854 1046 782.8 Sosik & Herwig, 

2009 

Total THM 225 904 1099 822 Sosik & Herwig, 

2009 

HAA 

bromochloroacetic acid 11.2 7.8 9.4 7.1 Sosik & Herwig, 

2009 

monochloroacetic acid 7.4 12.1 15.3 0 Sosik & Herwig, 
GESAMP-BWWG 12/6 

ANNEX 7 

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BRACKISH WATER 

 Day 0 Day 2 Day 

5* 

Day 

10* Reference 

2009 

dichloroacetic acid 2.9 1.2 2.4 3.7 Sosik & Herwig, 

2009 

trichloroacetic acid 0 1.5 1.5 0.7 Sosik & Herwig, 

2009 

monobromoacetic acid 8.4 8.4 6.1 3.5 Sosik & Herwig, 

2009 

dibromoacetic acid 117.9 219 156.3 193 Sosik & Herwig, 

2009 

Total HAA (6) 136.6 242.2 181.6 200.9 Sosik & Herwig, 

2009 

Bromate 0 33 23 42 Sosik & Herwig, 

2009 

“0” = Level below detectable limits, <2 μg/L. 

“*” = Experimental tanks were neutralized with sodium bisulfite. 

Table A8 : Levels of Trihalomethanes (THM) and Haloacetic acids (HAA) 

in Treated Seawater 

SEAWATER 

 Day 0 Day 2 Day 

5* 

Day 

10* Reference 

THM μg/L μg/L μg/L μg/L 

chloroform 0 0 0 0 Sosik & Herwig, 

2009 

dichlorobromomethane 0 0 0 0 Sosik & Herwig, 

2009 

chlorodibromomethane 0.7 2.7 3.4 2.2 Sosik & Herwig, 

2009 

bromoform 32.6 106.9 117.9 90.1 Sosik & Herwig, 

2009 

Total THM 33.3 109.6 121.3 92.3 Sosik & Herwig, 

2009 

HAA 

Bromochloroacetic acid 0 0 0 0 Sosik & Herwig, 

2009 

monochloroacetic acid 5.3 12.8 9.9 0 Sosik & Herwig, 

2009 

dichloroacetic acid 0 0 0 0 Sosik & Herwig, 

2009 

trichloroacetic acid 0 0 0 0 Sosik & Herwig, 

2009 

monobromoacetic acid 0 1.4 2.2 0 Sosik & Herwig, 

2009 

dibromoacetic acid 12.5 19.6 24.7 19.3 Sosik & Herwig, 
GESAMP-BWWG 12/6 

ANNEX 7 

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SEAWATER 

 Day 0 Day 2 Day 

5* 

Day 

10* Reference 

2009 

Total HAA (6) 17.8 33.8 36.8 19.3 Sosik & Herwig, 

2009 

Bromate 0 13 23 14 Sosik & Herwig, 

2009 

“0” = Level below detectable limits, <2 μg/L. 

“*” = Experimental tanks were neutralized with sodium bisulfite. 

7 Ecotoxicity Testing of Treated Ballast Water 

(As presented by applicant)

Table A9 : Acute Aquatic Ecotoxicity - Treated Ballast Water 

Test 

Substance 

F 

C 

A 

Species 

Days after 

treatment, 

Pre/Post 

neutralization 

Test 

Type 

E(L)C5

0 % 

sample 

NOEC 

% 

sample 

References/ 

comments 

Freshwater (average conductivity 1002 μS/cm)

0 

72h 

growth 

(OECD 

201) 

7.76 <6.25 

Nautilus 

Environmental, 

2009 

2 

72h 

growth 

(OECD 

201) 

11.5 <6.25 

Nautilus 

Environmental, 

2009 

5-pre 

72h 

growth 

(OECD 

201) 

>100 25 

Nautilus 

Environmental, 

2009 

5-post* 

72h 

growth 

(OECD 

201) 

>100 100 

Nautilus 

Environmental, 

2009 

A Selenastrum 

capriconutum 

5+* 

72h 

growth 

(OECD 

201) 

>100 100 

Nautilus 

Environmental, 

2009 

6.7 

mg/L 

HOCl 

C Daphnia 

magna 

0 

48h 

survival 

(OECD 

202) 

3.13 <6.25 

Nautilus 

Environmental, 

2009 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 23 

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Test 

Substance 

F 

C 

A 

Species 

Days after 

treatment, 

Pre/Post 

neutralization 

Test 

Type 

E(L)C5

0 % 

sample 

NOEC 

% 

sample 

References/ 

comments 

2 

48h 

survival 

(OECD 

202) 

3.13 <6.25 

Nautilus 

Environmental, 

2009 

5-pre 

48h 

survival 

(OECD 

202) 

41.4 25 

Nautilus 

Environmental, 

2009 

5-post* 

48h 

survival 

(OECD 

202) 

>100 100 

Nautilus 

Environmental, 

2009 

5+* 

48h 

survival 

(OECD 

202) 

>100 100 

Nautilus 

Environmental, 

2009 

0 

96h 

survival 

(OECD 

203) 

4.03 <6.25 

Nautilus 

Environmental, 

2009 

2 

96h 

survival 

(OECD 

203) 

43.8 25 

Nautilus 

Environmental, 

2009 

5-pre 

96h 

survival 

(OECD 

203) 

>100 100 

Nautilus 

Environmental, 

2009 

5-post* 

96h 

survival 

(OECD 

203) 

>100 100 

Nautilus 

Environmental, 

2009 

F Pimephalus 

promelas 

5+* 

96h 

survival 

(OECD 

203) 

>100 100 

Nautilus 

Environmental, 

2009 

Brackish water (average salinity 22.14 PSU)

9.1 

mg/L 

HOCl A Skeletonema 

costatum 0 

96h 

survival 

(EPA 

OPPTS 

850.5400)

8.61 <6.25 

Nautilus 

Environmental, 

2009 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 24 

I:\MEPC\60\2-16.doc 

Test 

Substance 

F 

C 

A 

Species 

Days after 

treatment, 

Pre/Post 

neutralization 

Test 

Type 

E(L)C5

0 % 

sample 

NOEC 

% 

sample 

References/ 

comments 

2 

96h 

survival 

(EPA 

OPPTS 

850.5400)

15.9 12.5 

Nautilus 

Environmental, 

2009 

5-pre 

96h 

survival 

(EPA 

OPPTS 

850.5400)

16.4 12.5 

Nautilus 

Environmental, 

2009 

5-post* 

96h 

survival 

(EPA 

OPPTS 

850.5400)

66.1 50 

Nautilus 

Environmental, 

2009 

5+* 

96h 

survival 

(EPA 

OPPTS 

850.5400)

>100 100 

Nautilus 

Environmental, 

2009 

0 

96h 

survival 

(EPA 

OPPTS 

850.1035)

5.94 6.25 

Nautilus 

Environmental, 

2009 

2 

96h 

survival 

(EPA 

OPPTS 

850.1035)

17.7 12.5 

Nautilus 

Environmental, 

2009 

5-pre 

96h 

survival 

(EPA 

OPPTS 

850.1035)

17.5 12.5 

Nautilus 

Environmental, 

2009 

5-post* 

96h 

survival 

(EPA 

OPPTS 

850.1035)

>100 100 

Nautilus 

Environmental, 

2009 

5+* 96h >100 100 Nautilus 

 

C Americamysis 

bahia 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 25 

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Test 

Substance 

F 

C 

A 

Species 

Days after 

treatment, 

Pre/Post 

neutralization 

Test 

Type 

E(L)C5

0 % 

sample 

NOEC 

% 

sample 

References/ 

comments 

survival 

(EPA 

OPPTS 

850.1035)

 Environmental, 

2009 

0 

96h 

survival 

(EPA 

OPPTS 

850.1075)

11.7 6.25 

Nautilus 

Environmental, 

2009 

2 

96h 

survival 

(EPA 

OPPTS 

850.1075)

28.4 25 

Nautilus 

Environmental, 

2009 

5-pre 

96h 

survival 

(EPA 

OPPTS 

850.1075)

22.6 12.5 

Nautilus 

Environmental, 

2009 

5-post* 

96h 

survival 

(EPA 

OPPTS 

850.1075)

>100 100 

Nautilus 

Environmental, 

2009 

F Cyprinodon 

variegatus 

5+* 

96h 

survival 

(EPA 

OPPTS 

850.1075)

>100 100 

Nautilus 

Environmental, 

2009 

Saltwater (average salinity 31 PSU)

0 

96h 

survival 

(EPA 

OPPTS 

850.5400)

33.4 25 

Nautilus 

Environmental, 

2009 

2 

96h 

survival 

(EPA 

OPPTS 

850.5400)

34.5 25 

Nautilus 

Environmental, 

2009 

5-pre 96h 38 25 Nautilus 

 survival Environmental, 

 (EPA 2009 

 

4.3 

mg/L 

HOCl 

A Skeletonema 

costatum 

 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 26 

I:\MEPC\60\2-16.doc 

Test 

Substance 

F 

C 

A 

Species 

Days after 

treatment, 

Pre/Post 

neutralization 

Test 

Type 

E(L)C5

0 % 

sample 

NOEC 

% 

sample 

References/ 

comments 

OPPTS 

850.5400) 

5-post* 

96h 

survival 

(EPA 

OPPTS 

850.5400)

>100 100 

Nautilus 

Environmental, 

2009 

5+* 

96h 

survival 

(EPA 

OPPTS 

850.5400)

>100 100 

Nautilus 

Environmental, 

2009 

0 

96h 

survival 

(EPA 

OPPTS 

850.1075)

10.5 6.25 

Nautilus 

Environmental, 

2009 

2 

96h 

survival 

(EPA 

OPPTS 

850.1075)

16.7 12.5 

Nautilus 

Environmental, 

2009 

5-pre 

96h 

survival 

(EPA 

OPPTS 

850.1075)

16.8 12.5 

Nautilus 

Environmental, 

2009 

5-post* 

96h 

survival 

(EPA 

OPPTS 

850.1075)

>100 100 

Nautilus 

Environmental, 

2009 

C Americamysis 

bahia 

5+* 

96h 

survival 

(EPA 

OPPTS 

850.1075)

>100 100 

Nautilus 

Environmental, 

2009 

0 

96h 

survival 

(EPA 

OPPTS 

850.1075)

24.3 25 

Nautilus 

Environmental, 

2009 

2.5-pre 96h 28.3 12.5 Nautilus 

4.3 

mg/L 

HOCl F Cyprinodon 

variegatus 

 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 27 

I:\MEPC\60\2-16.doc 

Test 

Substance 

F 

C 

A 

Species 

Days after 

treatment, 

Pre/Post 

neutralization 

Test 

Type 

E(L)C5

0 % 

sample 

NOEC 

% 

sample 

References/ 

comments 

survival 

(EPA 

OPPTS 

850.1075)

 Environmental, 

2009 

5-pre 

96h 

survival 

(EPA 

OPPTS 

850.1075)

35 25 

Nautilus 

Environmental, 

2009 

5-post* 

96h 

survival 

(EPA 

OPPTS 

850.1075)

>100 100 

Nautilus 

Environmental, 

2009 

 

5+* 

96h 

survival 

(EPA 

OPPTS 

850.1075)

>100 100 

Nautilus 

Environmental, 

2009 

F = Fish, C = Crustacean, A = Algae; * Samples neutralized with sodium bisulfite. 
GESAMP-BWWG 12/6 

ANNEX 7 

Page 28 

I:\MEPC\60\2-16.doc 

Table A10 : Chronic Aquatic Ecotoxicity - Treated Ballast Water 

Test 

Substance 

F

C

A 

Species 

Days after 

hypochlorite 

treatment, plus 

neutralization 

Test Type 

E(L)C50 

% 

Sample 

NOEC 

% 

Sample 

References/ 

comments 

Seawater (average salinity 36 PSU)

F Menidia 

beryllina 2 days 

7-day 

survival 

(EPA R821-02-

014) 

>100 100 

Nautilus 

Environmental, 

2007 

F Menidia 

beryllina 2 days 

7-day 

survival 

(EPA R821-02-

014) 

>100 100 

Nautilus 

Environmental, 

2007 

C Americamysis 

bahia 2 days 

7-day 

survival 

(EPA R821-02-

014) 

>100 100 

Nautilus 

Environmental, 

2007 

C Americamysis 

bahia 2 days 

7-day 

survival 

(EPA R821-02-

014) 

>100 100 

Nautilus 

Environmental, 

2007 

B Mytilus 

galloprovincialis 2 days 

48 h larval 

development

(EPA 600-

R-95-136) 

>100 100 

Nautilus 

Environmental, 

2007 

A Macrocystis 

pyrifera 2 days 

48 h 

germination

(EPA 600-

R-95-136) 

>100 100 

Nautilus 

Environmental, 

2007 

15.0 

mg/L 

HOCl 

A Macrocystis 

pyrifera 2 days 

48 h germ 

tube length 

(EPA 600-

R-95-136) 

>100 100 

Nautilus 

Environmental, 

2007 

F = Fish, C = Crustacean, B = Bivalve, A = Algae 

___________