What is BWM.2/Circ.70/Rev.1?

BWM.2/Circ.70/Rev.1 is the IMO guidance for commissioning testing of installed ballast water management systems. It defines the verification testing required after retrofit to confirm the BWMS is installed and operates as designed.

What happens when a commissioning test fails?

When a commissioning test fails, the manufacturer, yard, and crew often blame each other. The vessel cannot trade until the system passes. Independent diagnosis from the test data logs often identifies the root cause without requiring another full test attempt.

How long does diagnosis take?

For most failures, we provide a root-cause hypothesis with supporting data within 72 hours of receiving the data logs. On-site work, when needed, is scoped against a specific deliverable rather than open-ended T&M.

Can we discharge ballast water if a compliance test fails?

No. Hold the ballast water onboard until the cause is identified and the water is verified as compliant. Contact your flag administration, class society, and the port state, and follow your ballast water management plan and contingency guidance.

How can we tell whether the problem is the system or the sampling?

Repeat the sample at the correct sampling point, using clean equipment and proper handling, and compare the result against the system's logged operating data. If the logs show normal operation but the sample fails, check the sampling procedure, the sampling point, and the analysis method.

How do we prevent a repeat of the problem?

Follow the manufacturer's maintenance and sensor calibration schedule, replace consumables on time, and review operating data regularly rather than only after a failure. Training crew on the system's alarms and limits also helps catch problems before a discharge.

Commissioning & Troubleshooting

When your commissioning test fails and the manufacturer has disappeared, we've got 10+ years of experience getting BWMS back to work.

Independent commissioning support

Stuck with a system that won't pass commissioning

After your retrofit is finished, it is time for the commissioning testing required by BWM.2/Circ.70/Rev.1. Sometimes that testing goes smoothly. But what happens if your system fails?

Newly retrofitted ballast water treatment unit in a ship engine room

The reality

The post-retrofit reality

That commissioning testing is meant to verify your BWMS is installed correctly and operates as designed. In theory, the manufacturer or their appointed service provider handles it. In practice, many shipowners find themselves stuck with a system that doesn't pass commissioning and a manufacturer that isn't answering the phone.

Every manufacturer provides crew training. But that training happens as the vessel is leaving the yard, amid the confusion of closing up the hull, preparing the ship to go back to sea, and restoring order after the chaos of a yard period.

FastBallast compliance monitor used during commissioning

Independent support

Where is the manufacturer?

Where is the manufacturer when the commissioning test fails? Is the problem that the system itself is not working? What if they blame the installation, or worse, the crew? Where can you turn to resolve the issues and get your testing done?

We work independently of any manufacturer. Our job is to get your system working, regardless of who made it or who installed it. We have hands-on experience with systems from all major manufacturers and many smaller ones.

BWMS filter and UV treatment unit inspected during commissioning — On-board inspection during commissioning

Ballast water treatment tank in a ship engine room

What goes wrong

Common commissioning failures

Failed biological efficacy testing
Flow rate not meeting design specifications
Sensor errors and calibration issues
Control system logic problems
Piping and installation deficiencies
Manufacturer support unavailable

Independent verification of BWMS performance from the data logs

What you get

How we get you running

Pre-test data log review to identify issues early
On-site troubleshooting during commissioning
Root cause analysis of failed tests
Corrective action planning and implementation
Independent verification of system performance
Documentation for class and flag state
Confirmatory tests before we leave – with the approved instruments

Ballast water sample bottles collected for analysis

From the data

Troubleshooting from the data

We can help get your crews and vessels back to operation quickly and safely. With more than a decade of experience testing systems on board and getting a BWMS back to work, we know how to identify why your system is not performing and to stop you wasting money on test after test with no hope of success. Often we can do this simply by analyzing the data logs from your previous tests.

Save money on repeated failed tests

Every failed commissioning test costs money: surveyor fees, port time, crew overtime, and schedule disruption. Find the root cause before you test again and you are far more likely to pass. Many clients come to us after two or three failures, and our job is to make the next attempt the one that succeeds.

Troubleshooting guide

Troubleshooting a Ballast Water Management System That Isn't Meeting Discharge Requirements

Confirm the result is real

When a BWMS fails to meet the D-2 discharge standard, start by confirming that the result is real before changing anything on the system. Make sure you verify how the sample was taken and analyzed: was it representative? Were the sampling point and lines clean? And was the method and holding times appropriate? Repeat the test if possible.

Check the logged data against type approval

Then compare the system's logged operating data for the ballasting operation against its type-approval parameters. Look at flow rate, filter differential pressure, UV intensity or electrochlorination dose, TRO levels, neutralization (where applicable), and any alarms or bypass events.

Check sensors and consumables

Sensors that are out of calibration or have drifted are a common cause of a system that appears to be performing but is not. The same goes for worn consumables such as UV lamps, electrodes, or chemical supplies.

Check the water and the tanks

If the equipment and data are in order, look at the conditions around the system. Water quality factors like high turbidity, low UV transmittance, low salinity, or cold water can reduce treatment effectiveness and may be outside the system's approved design limitations. Sediment, biofilm, or regrowth in tanks and piping can allow organisms to bypass or avoid treatment, so check tank condition and cleaning history.

What to do with the ballast meanwhile

Do not discharge ballast water that has not been verified as compliant. Record the findings in the ballast water record book and engage the OEM of your BWMS as soon as possible, and make sure you consult your flag administration and the local port state on contingency options. Document each step taken and keep the full data record. It supports the investigation and shows due diligence to inspectors.

Frequently Asked Questions

No. Hold the ballast water onboard until the cause is identified and the water is verified as compliant. Contact your flag administration, class society, and the port state, and follow your ballast water management plan and contingency guidance.
Repeat the sample at the correct sampling point, using clean equipment and proper handling, and compare the result against the system's logged operating data. If the logs show normal operation but the sample fails, check the sampling procedure, the sampling point, and the analysis method.
Follow the manufacturer's maintenance and sensor calibration schedule, replace consumables on time, and review operating data regularly rather than only after a failure. Training crew on the system's alarms and limits also helps catch problems before a discharge.

Need Commissioning Help?

Tell us about your system and the issues you are facing, and we'll start diagnosing from your test data.