The IMO’s Sub-Committee on Pollution Prevention and Response held its 1st Session (PPR 1) from Monday 3 through Friday 7 February 2014 under the Chairmanship of Mr Sveinung Oftedal (NORWAY) and his Vice-Chair, Dr Flavio Fernandes (BRAZIL); both were subsequently re-elected for 2015. This Sub-Committee with the acronym PPR has assumed responsibility for matters formerly dealt with by the BLG (Bulk Liquids and Gases) Sub-Committee prior to re-organisation of IMO’s Sub-Committees this year. Three working groups (WG) and one drafting group (DG) were formed and chaired as follows:
WG1 Evaluation of Safety and Pollution, Hazards of Chemicals, Dr D MacRae (UK)
WG2 Prevention of Air Pollution from Ships, Mr W Lundy (USA)
WG3 Development of the OSV Chemical Code, Mrs C Henrichsen (DENMARK)
DG1 Ballast Water Management, Mr C Wiley (CANADA)
The following is a selection of salient points from the meeting of most interest to InterManager members:
- REPORT OF THE NINETEENTH SESSION OF THE WORKING GROUP ON THE EVALUATION AND SAFETY OF POLLUTION HAZARDS (ESPH) OF CHEMICALS. A number of on-going items from ESPH 19 (October 2013) were highlighted, in particular:
- evaluation of trade-named mixtures presenting safety hazards and their inclusion in list 3 of the draft MEPC .2/Circular;
- progress on the revision of chapter 21 of the IBC Code; and
- the consequences of the discharge of high viscosity products, based on an increasing number of incidents recently.
- REPORT OF ESPH WG1. The Sub-Committee approved WG1’s report in general and, of particular interest:
- agreed the evaluation of new products and their consequential inclusion in the IBC Code;
- agreed to the evaluation of trade-named mixtures presenting safety hazards;
- endorsed reviewing procedures for evaluating complex mixtures;
- concurred with the evaluation of cleaning additives, subject to endorsement by MEPC 66;
- agreed a draft MSC-MEPC Circular on products requiring oxygen-dependent inhibitors for approval by MSC 66 and MSC 93;
- information related to the discharge of high-viscosity and persistent floating products, inviting same for discussion at ESPH 20;
- agreed new text on the use of cleaning products for endorsement at MEPC 66;
- noted the need for further clarification at MSC 93, as a consequence of the new SOLAS regulation related to the prohibition of the blending of bulk liquid cargoes and production processes during sea voyages, for which proposals were requested, and;
- the holding of an intersessional meeting of the ESPH Working Group in 2015 subject to MEPC and MSC approval.
- REPORT OF THE OFFSHORE VESSEL (OSV) CHEMICAL CODE WG3. It was suggested that the threshold value for the amount of cargo carried in any single voyage should be raised from 800m3 to 1200m3, the latter capacity being commensurate with a single 85m vessel commonly specified. However, working group agreement was not achieved and this proposal together with that for a corresponding damage stability standard option for OSVs will be referred to the SDC Sub-Committee for advice and input. Similarly proposed firefighting requirements will be sent to the SSE Sub-Committee for advice and input. Concern was expressed that there are currently a number of IMO codes and guidelines that apply to offshore supply vessels with which the damage stability requirements of those instruments are not aligned. Thus it was agreed to request the SDC Sub-Committee to determine which stability standards would offer an equivalent level of safety when conducting operations in different modes. Finally, the Correspondence Group on the Development of the OSV Chemical Code will be re-established and coordinated by DENMARK.
- ADDITIONAL GUIDELINES FOR IMPLEMENTATION OF THE BWM CONVENTION. The number of Contracting Governments to the BWM Convention is now 38, representing 30.38% of the world tonnage thus still short of the necessary ratification tonnage. There was much support for the development of guidance on the use of ballast water management systems during stripping operations, but also concern over the scope of the draft guidance, as well as possible technical challenges with regard to ballast water sampling and the compatibility and relationship of the draft guidance with the provisions of the BWM Convention and relevant guidelines. However, DG1 made light work of such fears and produced suitable draft Guidance on stripping operations using educators for approval by MEPC 66 and subsequent dissemination as a BWM circular. In considering the use of fresh water as ballast water with its implications for corrosion protection in ballast tanks, most delegations expressed the view that, whilst fresh water may pose a potential risk of enhanced corrosion in ballast tanks, long experience with using ballast water from lakes, rivers and other fresh water sources indicates that additional corrosion effects, if at all evidenced, are minimal and need not be considered further. With regard to ballast water sampling, analysis and port State control, it was recalled that MEPC 65 had approved a BWM circular on the subject having agreed in principle with recommendations related to a trial period for reviewing, improving and standardising the Guidance. Meanwhile, Member Governments and international organisations were invited to submit further information and proposals related to ballast water sampling, analysis and contingency measures to PPR2, with a view to further developing and improving the relevant guidance documents and guidelines.
- PRODUCTION OF A MANUAL ENTITLED ‘BALLAST WATER MANAGEMENT – HOW TO DO IT’. Despite the fact that the BWM Convention already possesses the most extensive and comprehensive set of Guidelines to any IMO instrument, ever, MEPC 65 invited Member States and other bodies to fund the development of such a manual. In addition to financial support previously promised by Transport Canada, the Danish Ministry of Environment has also allocated DKK 50,000 for production of the manual in addition to pledges of support by FRANCE, the Republic of KOREA and SINGAPORE. The IMO Secretariat will act as a focal point to initiate development of the Manual, in consultation with delegations contributing to the work, using funds available under the ITCP, with a view to submitting a first draft to PP2 for consideration.
- PREVENTION OF AIR POLLUTION FROM SHIPS. WG2 gave full consideration to two major items, the first, Black Carbon and the second, a review of relevant non-mandatory Instruments as a consequence of the amended MARPOL annex VI and the NOx Technical Code.
- BLACK CARBON. Four definitions were considered by the WG of which two were referred back to the Sub-Committee :
(1) Equivalent Black Carbon (eBC), derived from optical absorption methods, that utilise a suitable mass-specific absorption coefficient, and
(2) Light-Absorbing Carbon (LAC), defined as light absorbing carbonaceous compounds (LAC), resulting from the incomplete combustion of fuel oil. Both definitions were supported by appropriate measurement methods using variously, characteristics such as (a) Particulate Matter components detected (b) applicable fuel types (c) applicable test conditions (d) advantages (e) drawbacks and (f) ways to overcome drawbacks. Pending an agreed definition of Black Carbon emissions from international shipping, possible control measures to reduce their impact were not considered further.
- REVIEW OF RELEVANT NON-MANDATORY INSTRUMENTS AS A CONSEQUENCE OF THE AMENDED MARPOL ANNEX VI AND THE NOx TECHNICAL CODE. The Sub-Committee agreed to the WGs submission of draft 2014 Guidelines in respect of the information to be submitted by an Administration to IMO covering the certification of an approved method as required under regulation 13.7.1 of MARPOL Annex VI with a view to adoption by MEPC resolution. Of particular note, the draft Guidelines make clear that the Approved Method may not be applicable to marine diesel engines that have been modified since manufacture. Topics discussed in respect of future amendments to the 2009 Guidelines for exhaust gas cleaning systems (EGCS) included: CO2 measurement, washwater-position and dimension of the sea water outlet, pH criteria, also alarms and monitoring.
Finally, a new draft priority list of developing other guidelines and guidance document under MARPOL Annex VI and the NOx Technical Code 2008 was agreed as follows:
(1) Equivalent methods set forth in regulation 4 of MARPOL Annex VI
(2) Dual-fuel operation utilising a proportion of high sulphur content-non-compliant fuel oil
(3) On-board blending of fuel
(4) Status of blends of petroleum and non-petroleum based fuel-oils
(5) Dry based Exhaust Gas Cleaning Systems
(6) Nox-reducing devices
- DISPOSAL OF COOKING OIL. A submission to MEPC 65 by the MARSHALL ISLANDS sought to achieve a common understanding on the disposal of cooking oil by way of the ship’s oil residue (sludge) tank, as listed on the Supplement to the IOPP Certificate. In particular, confirmation was requested regarding the proposed means in which to document the disposal of cooking oil in such a manner (Recording the collection of cooking oil as a Code I entry in the Oil Record Book, Part I only). In its submission PPR1/15, ITALY expressed the view that, in accordance with MARPOL Annex V, cooking oil should be considered as garbage and discharged to a reception facility or be disposed by incineration, not allowing its transfer to the sludge oil tank. This latter view was supported by the majority of Member States that spoke whilst the remainder preferred the more pragmatic and practical approach of transferring the used cooking oil to the sludge oil tank. For consideration, the volume of disposable used cooking oil in non-passenger ships is extremely limited and to store it in order to accumulate sufficient volume suitable for shore recycling unrealistic, added to which is its potential as a safety hazard.
With a view to providing further clarity, interested Member Governments and international organisations were invited to submit relevant proposals, including text for a draft unified interpretation to MARPOL Annex V, to PPR2 for consideration.
Captain Paddy McKnight END