IMO SUB-COMMITTEE ON POLLUTION PREVENTION AND RESPONSE 19 – 23 JANUARY 2015

The IMO Sub-Committee on Pollution Prevention and Response held its 2^nd Session from Monday 19 through Friday 23 January 2015 under the Chairmanship of Mr Sveinung Oftedal (NORWAY) and his Vice Chair, Dr Flavio Fernandes (BRAZIL) both of whom were subsequently re-elected for 2016. It will be recalled that this Sub-Committee with the acronym PP2 is now responsible for matters formerly dealt with by the BLG (Bulk Liquids and Gases) Sub-Committee resulting from last year’s re-organisation of IMO’s sub-committee structure. Three Working Groups (WG) and one Drafting Group (DG) were formed and chaired as follows:

In addition, the Correspondence Group (CG) established at MEPC 67 and tasked with conducting a review of the Guidelines for Approval of Ballast Water Management Systems (G8) convened and conducted its work in the margins of PPR2, during lunch-breaks and on completion of Plenary.

Following, are salient points of most interest to InterManager Members:

• STATEMENTS BY DELEGATIONS.

• GREECE and ITALY, relating to the SAR operation for the ro-ro passenger ship NORMAN ATLANTIC, which caught fire en route from the port of Patras to Ancona;
• BAHAMAS, a propos sinking of the bulk carrier BULK JUPITER off Vietnam; also
• CYPRUS and POLAND with respect to the sinking of the cement carrier CEMJFORD off the UK coast.

Condolences were expressed to the families and friends of all those who lost their lives in these accidents.

• REPORT OF THE WG ON AIR POLLUTION FROM SHIPS. The Sub-Committee approved WG2’s report in general and in particular:

1. agreed draft amendments to the 2009 Guidelines for exhaust gas cleaning systems for adoption by MEPC 68;
2. noted that the provisions of MARPOL Annex VI should be amended, clarifying that fuel oils other than those meeting the sulphur limit values in regulation 14 can continue to be supplied to a ship for use with an equivalent method allowed under regulation 4 of MARPOL Annex VI;
3. noted the need for amendments to Appendix V of MARPOL Annex VI (Bunker Delivery Note declaration) and that, despite extensive deliberation within the WG, agreement had not been reached on the text of such draft amendments;
4. agreed draft amendments to the NO_x, technical Code 2008 concerning testing of gas-fuelled engines and dual fuelled engines for the NO_x Tier III strategy and adoption by MEPC 68; similar draft amendments in respect of marine diesel engines fitted with Selective Catalytic Reduction (SCR) systems were agreed likewise for adoption by MEPC;
5. noted a definition for Black Carbon known as ‘Bond et al’ proposed by CANADA and concurred that it should be recommended to MEPC.   The definition is measurement method neutral and widely supported by the scientific community, although CHINA, INDIA and the RUSSIAN FEDERATION disputed the latter assertion; and
6. noted that because of the need for studies to identify the best measurement methods for Black Carbon emissions from international shipping, it was not possible at this stage to consider possible control measures to reduce the impact of Black Carbon emissions.

• EVALUATION OF SAFETY AND POLLUTION HAZARDS OF CHEMICALS (ESPH) AND PREPARATION OF CONSEQUENTIAL AMENDMENTS. In consideration of the ESPH (WG1) report, the Sub-Committee:

1. agreed to the establishment of a generic entry for used cooking oil in List 1 of the MEPC.2/Circular, with validity for all countries, without an expiry date, subject to MEPC 68 endorsement;
2. agreed to the valuation of trade-named mixtures presenting safety hazards and their inclusion in list 3 of the MEPC.2/Circular with validity for all countries, without an expiry date, subject to MEPC 68 endorsement;
3. concurred with the evaluation of cargo tank cleaning additives (six submitted of which three were adjudged compliant with the criteria in MEPC.1/Circ.590) for MEPC 68 endorsement;
4. noted that tripartite agreements for 19 products will reach their expiry dates in December 2015 and invited Member States to take action in order to avoid any delays in the carriage of these products beyond their expiry dates;
5. noted progress made in revising chapter 21 of the IBC Code and also, revision of Guidelines for the provisional assessment of liquid substances transported in bulk;
6. agreed draft unified interpretations (UI) of SOLAS and the IB Code for products requiring oxygen-dependent inhibitors for submission to MEPC 68 and MSC 95;
7. agreed a draft MEPC (68) circular on Guidance for issuing a revised Certificate of Type Approval for oil content meters intended for monitoring the discharge of oil-contaminated water from the cargo tank areas of oil tankers; and
8. agreed a draft MEPC (68) circular on the Revised PPR Product Data Reporting Form and related guidance notes.

• GUIDELINES FOR PORT STATE CONTROL UNDER THE 2004 BWM CONVENTION INCLUDING GUIDANCE ON BALLAST WATER SAMPLING AND ANALYSIS. Since PPR1 six more States (GEORGIA, JAPAN, JORDAN, REPUBLIC of the CONGO, TONGA and TURKEY) have acceded to the BWM Convention, bringing the number of Contracting Governments to 44, representing 32.86% of world GT, 2.16% short of that required for adoption. In addition, the delegations of ARGENTINA and INDONESIA informed the Sub-Committee of their ongoing preparations for Convention ratification. The Sub-Committee then agreed proposed amendments to the Guidance on BW sampling and analysis set out in BWM.1/Circ.42, for MEPC 68 approval, noting that a new indicative analysis method developed in Japan plus methods currently described in the Guidance, may still need further assessment during the trial period.

• MANUAL ENTITLED ‘BALLAST WATER MANAGEMENT – HOW TO DO IT’.   In course of development, it is planned that the final version of the manual will be submitted to PPR3 (15-19 February 2016) for consideration.

• REVISED GUIDELINES FOR THE INVENTORY OF HAZARDOUS MATERIALS.   Three States only, namely the REPUBLIC of the CONGO, FRANCE and NORWAY have ratified or acceded to the Hong Kong International Convention of the Safe and Environmentally Sound Recycling of Ships, 2009 (the Hong Kong Convention).       The Sub-Committee established WG3 to prepare the final text of Revised Guidelines for the development of the Inventory of Hazardous Materials, utilising the report of the CG specific to this issue set up at MEPC 67. This was duly accomplished following which the Secretariat was requested to prepare a consolidated MEPC resolution reflecting WG3’s recommended amendments for approval and adoption at MEPC 68.

• GUIDANCE FOR INTERNATIONAL OFFERS OF ASSISTANCE IN RESPONSE TO A MARINE OIL POLLUTION ACCIDENT.   It was recalled that PPR1 had established an inter sessional correspondence group (CG) to finalise draft guidance on offers of assistance in response to marine oil pollution accidents. In pursuance of that CG work, a PPR2 drafting group was set up and its subsequent report to the Sub-Committee was approved in general; in particular, the Sub-Committee:

1. agreed to the draft Guidelines on international offers of assistance in response to a marine oil pollution incident for submission to MEPC 68;
2. agreed to the draft part III of the IMO Dispersant Guidelines for submission to MEPC 68, together with parts I and II of the IMO Dispersant Guidelines which have already been approved by MEPC 65; and
3. re-established the CG on OPRC-HNS related manuals, guidelines and guidance.

• DRAFT UI OF MARPOL Annex V RELATING TO THE DISPOSAL OF COOKING OILS. In proposing a UI of regulation 3.3 of MARPOL Annex V, ITALY argued that the disposal of cooking oil can be performed only by discharge to a reception facility or by incineration as described in the Garbage Record Book; also, in cases where reception facilities are not available, fuel blending of such used cooking oil to recycle it should also be considered an appropriate solution if performed according to technical instructions to be included in the Garbage Management Plan. Whilst others shared the view that used cooking oil should be discharged to a reception facility or by incineration, they did not support incorporating the option of blending used cooking oil with fuel oils in any draft UI. A few Member States, led appropriately by the COOK ISLANDS and supported by NGO’s, most notably INTERCARGO, recommended disposal of the minute amounts of cooking oil via the sludge tank, it being the most pragmatic solution without causing an unnecessary burden to the ship or ports. Given these divergent views (certainly not unified!) and until agreement is reached, the disposal of used cooking oil will continue to comply with the requirements in MARPOL Annex V.

Captain Paddy McKnight