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Australia is one of the world leaders in enforcing regulations to prevent the introduction of invasive species into its unique marine environment via ballast water discharge and bio-fouling.

Container ship in the harbor in Asia at sunset

As a geographically isolated country, Australia relies heavily on shipping for exporting the natural resources our economy is built on. In addition, Australia is one of the world leaders in enforcing regulations to prevent the introduction of invasive species into its unique marine environment via ballast water discharge and bio-fouling.

Shipping is regulated globally by the International Maritime Organization (IMO) including the management of ballast water discharges. The regulation D-1 of the ballast water management convention requires ships to exchange ballast water in mid-ocean to limit the transfer of harmful organisms and pathogens from other ports. The implementation of the Convention phases out the regulation D-1 and sees an increasing number of vessels required to meet the regulation D-2. This regulation sets out the discharge standard which will eventually require all vessels to treat their ballast on-board using Ballast Water Management Systems (BWMS). By 2024, it is expected that all vessels will be fitted with a BWMS.


To ensure compliance with the D-2 discharge standard, the IMO has determined allowable discharge limits based on 3 different organism size classes: ≥50 μm, ≥10 μm to <50 μm and <10 μm. BWMS must undergo a rigorous Type Approval testing ensuring that they are fit for purpose and can treat the water according to the standard. However, installations arrangements are unique to each vessel and so are vessels’ ballast water operations. Therefore, it is important to undertake regular compliance testing once the BWMS are installed to ensure the objectives of the convention are met.

To determine the possibility of undertaking in-situ compliance testing and therefore evaluating the enforceability of the convention, the IMO has entered the Experience Building Phase (EBP) and request States to engage in the production of data by undertaking sampling and analysis according to the D-2 regulations.

Sampling and analysing against the D-2 discharge standard requires a representative, isokinetic sample of 3 cubic meters to be taken and analysed during normal vessel operation discharge.
To support the IMO in achieving the goals of the EBP, the Australian Department of Agriculture, Water and the Environment (DAWE) needed a partner with long global expertise in such compliance work, combining field work on-board vessels together with high quality laboratory analyses.


SGS approached DAWE with a bespoke solution which has been designed to solve this emerging challenge.

Initially, SGS worked with the Australian Government to outline best practices using cutting edge equipment to sample according to the IMO’s guidelines. SGS Australia received support from its Global Marine Services Team who supplied expertise to ensure smooth transfer of knowledge, technology and procedures developed over many years to roll out the project.

The SGS ballast water sampler was designed specifically to meet the D-2 discharge standards. The unit enables trained surveyors to take an isokinetic, representative sample of the ballast water discharge across a wide range of operational flow velocities while maintaining the integrity of living organisms.

The unit is designed to be run as a closed loop system, eliminating the need for disposal of discharge water to the bilge, but can also be operated in an open loop configuration when required.

SGS overcame several challenges throughout the testing process including:


Sourcing vessels that were using BWMS and were willing to participate in a voluntary study and explaining the purpose and requirements took considerable time. Liaising between vessel Masters, Ship owners and shipping agents was a significant component of the project and required great assistance from DAWE staff who provided information on incoming vessels to help determine possible targets.

Sampling and Connection:

Ensuring the sampling instrument connected to the various sample points installed on the treatment systems presented challenges. The large variation in installations often required on the spot adaptation or fabrication of new attachments to allow sampling to take place. This was central in the success of the project in order to ensure no undue delay to the vessels.

Sampling & holding times:

The IMO stipulate a maximum 6 hours of holding time between sample collection and commencement of analysis, meaning the ability to conduct analysis on a 24/7 basis was paramount in an industry that works around the clock.


Although a challenge for many industries, Covid 19 had large ramifications for boarding vessels entering port from overseas at the height of the pandemic. Liaison with Port Authorities and Health authorities was undertaken to ensure continuation of the project. Internally, risk assessment and implementation of several health and safety processes to ensure H&S of both the crew and samplers was undertaken, allowing the study to continue safely.


In total 41 sampling events took place between 2019 and 2020 in the ports of Fremantle, Bunbury, Sydney and Gladstone. SGS was able to provide high quality data and reports with several significant findings which puts Australia at the forefront of both ballast water management policy development and Biosecurity.

Thanks to a very professional collaboration, the Australian Government and SGS have been able to produce what is expected to be the most comprehensive datasets available to date to support the success of the IMO EBP. Utilizing SGS’s sampling and testing methods and its global compliance experience, DAWE has also enhanced their expertise which will aid with the implementation of the BWM convention and other environmental regulations applying to shipping.

About SGS

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognised as the global benchmark for quality and integrity. With more than 89,000 employees, SGS operates a network of over 2,600 offices and laboratories around the world.

SGS’s Marine Services support the shipping industry in verifying the compliance with Environmental and Health and Safety regulations at national and international levels servicing vessels in more than 300 ports globally.

SGS are constantly looking beyond customers’ and society’s expectations to deliver market leading services wherever they are needed. As the leader in providing specialized business solutions that improve quality, safety and productivity and reduce risk, SGS help customers navigate an increasingly regulated world.
SGS’s independent services add significant value to our customers’ operations and ensure business sustainability.