The IMO’s Sub-Committee on Bulk Liquids and Gases (BLG) held its 17th session from Monday 4 through Friday 8 February 2013 under the Chairmanship of Mr S Oftedal (NORWAY); the Vice Chairman, Mr R Zhang (CHINA) was also present. Three working groups and two drafting groups were formed:

WG1 Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments, chaired by Mr D McRae (UK)

WG2 Development of guidelines for uniform implementation of the 2004 Ballast Water Measure Convention (BWM) and development of international measures for minimising the transfer of invasive aquatic species through biofouling of ships, chaired by Mr C Wiley (CANADA)

WG3 Development of international code of safety for ships using gases or other low-flashpoint fuels, chaired by Ms T Stemre (NORWAY)
DG1 Development of the revised IGC Code, chaired by Dr S Ota (JAPAN)
DG2 Consideration of Black Carbon impact from international shipping on the Arctic, also an IACS unified interpretation and a review of non-mandatory instruments as a consequence of the amended Marpol Annex VI and the NOx technical code, chaired by Mr W Landy (USA)

Salient points from the meeting on items of particular interest to Intermanager members are as follows:
• REPORT OF ESPH 18. The ‘Evaluation of Safety and Pollution Hazards’ (ESPH) working group report of the 18th intersessional meeting was approved, in particular:

(1) Note was taken that 25 (out of 29) cleaning additives were added to the approved list.

(2) Concurred that biofuel blends for shipments under MARPOL Annex II should be fully assessed before they can be transferred to Guidelines for the carriage of blends of petroleum oil and biofuels.

(3) A proposed solution relating to the reissue of chemical code certificates of fitness (COF) when the IBC Code is amended whereby the adoption date of the IBC Code and amendments rather than the entry-into-force date, should be the starting point for beginning to reissue. This would be done in advance of the entry into force of the IBC Code amendments and would have an expiration date which is the same as that on the existing certificate.

(4) The use of ventilation to remove cargo residues from a tank instead of a prewash, subject to the permission of the Government of the receiving country. This is generally granted by a MARPOL surveyor as a signature in the Cargo Record Book through in the event of Surveyor ‘no-show’, the vessel must demonstrate through documentary evidence that it has given adequate prior notice requiring such attendance.

(5) Continuing discussions on the options to develop the criteria for assessing products based on the GESAMP Hazard Profile together with a consideration of physical properties.

• THE 2004 BALLAST WATER MANAGEMENT CONVENTION (BWM). INTERMANAGER was co-signatory of a submission (together with the BAHAMAS, GREECE, JAPAN, LIBERIA, PANAMA, ICS, BIMCO, INTERTANKO, SIGTTO and INTERCARGO) arguing that sampling exercises should not be undertaken before IMO concludes robust, transparent and simple PSC sampling guidelines. The Sub-Committee agreed and a draft circular on Guidance relating to ballast water sampling and analysis for trial use will be forwarded to MEPC 65. The recommended trial period is two to three years following entry into force of the Convention and Member States are encouraged to begin using the sampling and analysis procedures for scientific and research purposes, reporting their findings to the Sub-Committee. Of note, the USA reserved its position on the suggested principle of ‘No criminal sanctions solely on the basis of sampling’, given that details of the proposal still need to be worked out.

The WG2 report will now be forwarded to the FSI Sub-Committee which will be invited to finalise the Guidelines for port State control under the 2004 BWM Convention. This is a matter of urgency prior to entry into force, in order to facilitate the trial period and ratification of the Convention.
GERMANY submitted a document proposing detailed self-monitoring standards for BWMs, proposing that Administrations should not execute criminal sanctions (or detentions) under article 8 on the basis of solely the result of sampling. However, such matters come under the purview of FSI and are not within the mandate of BLG, but in any case, JAPAN argued that sampling exercises under the BWM Convention should not be excised by Port States or a Port State Control Officer before IMO concludes robust, transparent and simple PSC sampling guidelines.

A draft Circular on BW management for Offshore Support Vessels will be forwarded to MEPC 65, as also will be one pertaining to guidance for evaluating the Guidelines to control and manage ship’s biofouling in order to minimise the transfer of invasive aquatic species.

A further paper co-sponsored by INTERMANAGER (in addition to Liberia, the Marshall Islands, ICS, INTERTANKO, INTERCARGO, IPTA, IPPIC and NACE International), gained unanimous support. It successfully proposed amendments to the BWM Circular and Resolution in order to improve the robustness and transparency of the BWM Type approval process.
Member Governments and international organisations were invited to submit proposals to BLG 18 on how best to proceed with the development of a manual on ‘Ballast Water Management – How to do it’.
Recommendations by co-sponsors IPPIC and NACE International on corrosivity of ballast tank coatings, ballast piping systems and anodes, will be forwarded to the GESAMP – Ballast Water Working Group for consideration and action as appropriate at their next meeting.

• DEVELOPMENT OF INTERNATIONAL CODE OF SAFETY FOR SHIPS USING GASES AND OTHER LOW-FLASHPOINT FUELS. It was decided that compressed natural gas (CNG) should be part of section A-1 as part of the requirements for the storage tank.
Portable tanks must have the same level of safety as other tanks and comply with all requirements of the Code, in addition to which the majority view purported them to be covered by the Intact Stability Code when making stability calculations. Note was taken of progress made by the WG w.r.t. requirements for arrangement of entrances and other openings, however SIGTTO reserved its position on the issue of allowing air locks to be used below deck without applying the relevant IEC standard in full. Views on the definition of hazardous areas were extremely divided and it was decided that matters of equipment, including generators, be considered at the next session. Similarly, noting the WG’s discussions on monitoring and safety functions, it was decided that the matter of fixed gas detection in all ventilation inlets should also be deferred to the next meeting. Note was taken of the WG’s discussions on how to accommodate fuels other than natural gas within the IGF Code and endorsed their view that an alternative design must meet the functional requirements of the IGF Code, subsequently agreeing to draft SOLAS amendments in order to extend the application of the Code to other fuels.

A further draft amendment to SOLAS developed by the WG was agreed in principle which would make the IGF Code mandatory; it will be part of a package submitted to MSC for approval together with the draft IGF Code.

Despite GERMAN reservations, the Correspondence Group on the IGF Code was re-established under the coordination of NORWAY and instructed to:
(1) Finalise the general part of the draft IGF Code
(2) Finalise the related draft SOLAS amendment
(3) Consider further developments of the proposals for low-flashpoint oil and Methyl/Ethyl Alcohol; and
(4) Submit a report to BLG 18

• DEVELOPMENT OF A REVISED IGC CODE. The DG, as instructed, made a considerable number of editorial modifications to the draft revised International Code for the Construction and Equipment of Ships carrying Liquefied Gases in Bulk (IGC Code).
The modified text of the application provisions clarify the applicability of the revised IGC Code to new ships only and delete references to MARPOL. ‘Personal protection requirements for individual products’ will be replaced by text similar to that contained in the IBC Code and modifications to the emergency shutdown (ESD) systems were agreed for inclusion in the draft Code. Limit state methodologies, also gas detection systems and gas inerting were both discussed and proposed modifications included in the draft code.

• CONSIDERATION OF THE IMPACT ON THE ARCTIC OF EMISSIONS OF BLACK CARBON FROM INTERNATIONAL SHIPPING. There was a lack of agreement on the definition of Black Carbon but one that found the most common ground was:
‘Black Carbon from international shipping is formed by incomplete combustion of hydrocarbon fuels, and is the most effective component of particulate matter (PM) by mass, at absorbing solar energy’.
More work will be done in finalising an appropriate definition focussing on the development of a technical, rather than a political one and following a protracted discussion, it was agreed to form a correspondence group under the coordination of the UNITED STATES, which was instructed to:
(1) develop a technical definition for Black Carbon emissions from international shipping;
(2) identify the most appropriate method for measuring such emissions;
(3) further identify, collate and investigate appropriate measures by which to control the impact of the emissions; and
(4) report to BLG 18.

• REVIEW OF RELEVANT NON-MANDATORY INSTRUMENTS AS A CONSEQUENCE OF THE AMENDED MARPOL ANNEX VI AND THE NOx TECHNICAL CODE. The Sub-Committee approved for submission to MEPC 65, the report of the Drafting Group on matters related to MARPOL Annex VI and the NOx Technical Code 2008 in general and, in particular agreed to:

(1) draft guidelines in respect of non-identical replacement engines not required to meet the Tier III limit;

(2) draft amendments to the NOx Technical Code 2008 concerning use of dual fuel engines;

(3) a draft editorial amendment ensuring consistency in the use of the term ‘gas fuel’ within the NOx Technical Code 2008 and,

(4) the unified interpretation on the ‘time of the replacement or addition’ of an engine for the applicable NOx Tier standard for the supplement to the IAPP Certificate.

In addition, the Sub-Committee agreed expanded terms of reference for the correspondence group to further develop draft guidelines outlining the information to be submitted by an Administration to IMO in respect of an Approved Method, also to develop necessary draft guidelines on NOx-reducing devices under the revised NOx Technical Code 2008.

Plenary discussion on washwater discharge criteria for exhaust gas cleaning systems provoked a lively, prolonged debate and the expression of many polarised views. Proposed amendments to the 2009 Guidelines were not agreed and further information was requested for submission on:

(1) the impact on the marine environment of discharging washwater with low Ph value, and
(2) current availability of Exhaust Gas Cleaning Systems to meet the requirements as set out in the 2009 Guidelines and those that cannot.

Another spirited debate ensued whilst discussing emission controls. The USA proposed including emissions averaging schemes in the draft guidelines, arguing that a well-designed, regionally-limited emission programme would reduce emissions whilst providing shipowners with compliance flexibility and less compliance cost. The Clean Shipping Coalition (CSC) on the other hand stated that such a scheme carries the potential to seriously weaken the integrity of MARPOL Annex VI and recommended that an explicit moratorium be placed on approval or adoption of any sulphur emissions trading, aggregate emissions ceilings or similar scheme for application in the North American ECA or elsewhere. However, following a longish debate, the busy reader will be relieved to learn that this particular MBM shuttlecock has been bounced back to MEPC ‘for further consideration’.

A much shorter debate led to agreement in reporting to MEPC 65 that mandatory requirements of continuous NOx monitoring to demonstrate compliance with the Tier III NOx emission limit is not appropriate at this stage.

The Sub-Committee noted that DSC 17 had prepared a draft amendment to SOLAS recommending that the highest priority be given to developing relevant SOLAS carriage requirements for oxygen meters. IACS pointed out that, since testing instruments for the atmosphere of cargo spaces is already addressed in SOLAS, possible duplication of equipment should be borne in mind when submitting documents to DSC 18.

Finally, note was taken by the Secretary-General of comments on the proposed reform of the sub-committees, in particular regarding the potential re-allocation of responsibilities within BLG and DSC, ie the establishment of two new sub-committees, one to deal with environment-related matters and the other, those issues related to cargo. A framework document outlining the proposed new committee structure will be published at the end of this month.

Captain Paddy McKnight


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