The IMO Sub-Committee on Pollution Prevention and Response held its 5th session (PPR 5) from 5 – 9 February 2018 under the Chairmanship of Mr Sveinung Oftedal (NORWAY) and his Vice Chair, Dr Flavio Fernandes (BRAZIL); both were re-elected for 2019. Three Working Groups (WG) and two Drafting Groups (DG) were formed and chaired as follows:
| WG1 | Evaluation of Safety and Pollution hazards of chemicals, Ms J Contreras (NETHERLANDS) |
| WG2 | Ballast water management and anti-fouling systems, Mr C Wiley and Ms S Bailey (CANADA) |
| WG3 | Prevention of air pollution from ships, Mr W Lundy (USA) |
| DG1
DG2 |
Use of electronic record books and Revised Guidelines for the application of MARPOL Annex 1 requirements to FPSOs and FSUs, Ms A Sly (AUSTRALIA)
OPRC Guidelines, Mr C Rousseau (FRANCE) |
The meeting was attended by representatives from 73 Member Governments, 1 Associate Member of IMO, 1 Specialised Agency, 3 Observer Intergovernmental Organisations and 43 Non-Governmental Organisations.
Items of particular interest to InterManager Members are as follows:
Address by Secretary General. Welcoming delegates to the 5th meeting of the Pollution Prevention and Response Sub-Committee, the S-G stated that the previous year had been very successful as it heralded the entry into force of the Ballast Water Management Convention and the development of an initial IMO GHG strategy which is expected to be adopted at MEPC 72 in April this year. IMO’s contribution to address problems posed by climate change includes a mandatory data collection system for fuel oil consumption which enters into force shortly and will provide robust data on which to base future informed decisions. Since its creation in 1976, as the sub-committee on Bulk Chemicals, later to become BLG in 1996 and then PPR 5 years ago, work has resulted in highly restrictive limits for operational discharge of oil and chemical tanker washings, the ban of carriage and use of heavy grade oil in the Antarctic area, and a new four-category system for describing noxious and liquid substances to name but a few successes. This has been achieved through ongoing revision of MARPOL Annexes I and II, and by means of the International Bulk Chemical Code and the International Gas Carrier Code. The revision of MARPOL Annex VI, with a progressive reduction in SOx and NOx emissions from ships, and the development of comprehensive guidelines on the management of ballast water and biofouling provide excellent examples in illustrating IMO commitment towards the achievement of UN Sustainable Development Goals. The Secretary General went on to state that the most important item on the weeks agenda is that of consistent implementation of the 0.50% m/m global limit of the sulphur content of ships’ fuel oil, effective from 1 January 2020 and in his view ‘there is no turning back’! However, he expressed confidence that, with the assistance of an intersessional meeting, the vital work will be achieved in a timely manner.
Moving on to the BWM Convention, he noted with satisfaction the outcome of MEPC 71 which, inter alia, agreed a practical and pragmatic implementation schedule for ships in which to comply with regulation D-2 of the Convention; he looked forward to further work at this session, including Guidance on ballast water sampling and analysis, methodologies that may be used for enumerating viable organisms, System Design Limitations and finally, contingency measures for ports with challenging water qualities. Following the deep Water Horizon incident, revision and update of the IMO Dispersant Guidelines has been undertaken and he looked forward to the final draft of part IV being completed at this session.
Finally, the Secretary General highlighted a few other issues to be discussed such as : revision of chapters 17 and 18 of the IBC Code; a regulatory solution to the discharge of high-viscosity solidifying and persistent floating products; amendment of annex 1 to the AFS Convention to include controls on cybutryne; and, consideration of the impact on the Arctic of emissions of Black Carbon from international shipping. The S-G reminded delegates that submission of nominations for the 2018 IMO Award for Exceptional Bravery at Sea is open until 16 April and that the theme for this year’s World Maritime Day theme is “IMO 70: Our heritage – better shipping for a better future”.
- Safety and Pollution Hazards of Chemicals, also Review of MARPOL Annex II Requirements impacting on Cargo Residues and Tank Washings of High Viscosity and Persistent Floating Products. Following a general discussion in Plenary of the above items, WG1 was convened and in consideration of its extensive follow-up report requesting action, the Sub-Committee:
- Concurred with the evaluation of cleaning additives and their inclusion in the revision of MEPC.2/Circular;
- Noted that 50 tripartite agreements expire in December 2018 and that delay in carriage beyond that date should be avoided;
- Noted progress in developing draft amendments to MARPOL Annex II and consequential draft amendments to the IBC and BCH Codes addressing issues related to the discharge of persistent floating substances with a high viscosity and/or a high melting point;
- Agreed draft amendments to MARPOL Annex II for submission/approval/adoption by MEPC 73;
- Noted completion of revision to chapters 17, 18, and 19 of the IBC Code;
- Agreed draft amendments to the IBC Code for submission/approval/adoption by MEPC 73 and MSC 100;
- Agreed consequential draft amendments to the BCH Code for submission/approval/adoption by MEPC 73 and MSC 100;
- Authorised the Secretariat to effect editorial corrections where necessary whilst finalising text of IBC Code amendments;
- Noted that, owing to time constraints, no progress was made by WG1 on revising the Guidelines for the provisional assessment of liquid substances transported in bulk;
- Requested the GESAMP/EHS Working Group to take into account comment and reservations of WG1 with regard to the proposed flammability ratings in the GESAMP Hazard Profiles and advise the ESPH (Evaluation of Safety and Pollution Hazards of Chemicals) Working Group with regard to recommended cut-off values to be used when assessing mixtures containing components with long-term health effects;
- Noted progress on development guidance for assessing and classifying products under Annexes I and II of MARPOL, and agreed a draft MEPC circular on Guidelines for the carriage of energy-rich fuels and their blends for submission to MEPC 73; subject to approval, agreed to the inclusion of a new Annex 12 to the Circular for the purpose of listing substances deemed to be subject to MARPOL Annex I; and,
- Agreed requesting MEPC 73 to approve an intersessional meeting of the ESPH Working Group in the latter part of 2019.
- Ballast Water Management and Anti-Fouling Systems. The Sub-Committee noted that the BWM Convention entered into force on 8 September 2017 and the number of Contracting Governments is currently 67, representing almost 75% of world tonnage. Following Plenary discussion of 4 agenda items related to ballast water and anti-fouling systems, terms of reference were issued to WG2 which duly reported its conclusions back to Plenary, following which the Sub-Committee:
- Agreed that the proposal submitted to amend Annex 1 to the AFS Convention satisfies the requirements of Annex 2 to the AFS Convention and that a more detailed review of cybutryne is warranted;
- Will recommend extending the completion year output of amending Annex 1 to the AFS Convention and re-titling it “Amendment of Annex 1 to the AFS Convention to include controls on cybutryne, and consequential revision of relevant guidelines”;
- Will recommend that the Committee invites the submission of a comprehensive proposal containing all the information required in Annex 3 to the AFS Convention, taking into account the many concerns expressed at this session;
- Noted that there is no need to revise BWM.2/Circ.42/Rev.1 at this stage;
- Invited the Netherlands to submit information on the validation of the FCM (a method for particle characterisation) and PAM (a method of measurement for phytoplankton activity) as combined methods, whilst also addressing concerns expressed within the Working Group;
- Agreed draft Guidance on ‘System Design Limitations of ballast water management systems and their monitoring’ for submission to MEPC 73 with a view to approval and dissemination as a BWM.2 circular;
- Invited submissions to PPR 6 on specific examples of contingency measures acceptable to port States and implemented by the shipping industry for inclusion in an annex to the ‘Guidance on contingency measures under the BWM Convention (BWM.2/Circ.62)’;
- Invited submissions to PPR 6 containing comments and/or proposals on guidance for ports with challenging water quality; and
- Invited the Committee to note progress on consideration of matters described in document MEPC 71/4/21. This refers to draft guidance on shipboard contingency measures relating to ballast water exchange with water treated by BWMS in a port area where normal operations of BWMS for ballasting is not possible.
- Consideration of the Impact on the Arctic of Emissions of Black Carbon from International Shipping. 15 submissions were considered on this item, the most important being the report of the Correspondence Group which included an updated version of the draft Reporting protocol for voluntary measurement studies to collect Black Carbon data. Following a long discussion in Plenary, WG3 was instructed to finalise the reporting protocol and to identify the most appropriate Black Carbon measurements method. This it duly did, following which the Sub-Committee endorsed the reporting protocol together with a recommended measurement method for data collection. The Sub-Committee next established the Correspondence Group on ‘Investigation of appropriate control measures to reduce the impact of Black Carbon emissions from international shipping’, under the coordination of CANADA with a view to identifying candidate control measures to reduce the impact of Black Carbon emissions and assess the feasibility and appropriateness of such measures. The CG was also instructed to submit a written report to PPR 6.
- Review of the 2015 Guidelines for Exhaust Gas Cleaning Systems (Resolution MEPC.259(68)). It was recalled that MEPC 69 agreed a new output on ‘Review of the 2015 Guidelines for EGC systems’. The scope of work encompassed further refinement of the EGCS Guidelines including clarification of ‘EGC system’ and EGC units, also ; PAH (polycyclic aromatic hydrocarbons) monitoring; plus emission testing and approval of scrubbers in accordance with their relevant schemes. It also included specific guidance on accidental breakdown, instrument malfunction and perceived temporary non-compliance and transient performance of EGCS in addition to consequential amendments to the 2009 Guidelines for port State control under the revised MARPOL Annex VI (resolution MEPC.181(59)). Following consideration of five submissions on this agenda item, it was decided to establish a CG, under the coordination of FINLAND, tasked with developing a full revision of the 2015 Guidelines, also specific guidance on accidental breakdown, instrument malfunction etc (as above), and specifying consequential amendments to the 2009 Guidelines for port State control under the revised MARPOL Annex VI (resolution MEPC.181(59) whilst identifying any outstanding issues needing to be resolved by the Sub-Committee.
- Consistent Implementation of Regulation 14.1.3 of MARPOL Annex VI. An extremely long debate in Plenary led to terms of reference being issued to WG3 instructing it : to prepare a work plan for this output, develop Guidelines for consistent implementation of regulation 14.1.3 of MARPOL Annex VI, prepare draft TORs for an Intersessional Meeting and finalise draft amendments to MARPOL Annex VI for a prohibition on the carriage of non-compliant fuel oil for combustion purposes with a sulphur content exceeding 0.50%. In considering WG3’s evaluation of these instructions, the Sub-Committee:
- Agreed the proposed work plan to complete the output on ‘Consistent implementation of regulation 14.1.3 of MARPOL Annex VI’, also that for draft Guidelines on same; and,
- Approved draft terms of reference for an intersessional meeting on consistent implementation of regulation 14.1.3 of MARPOL Annex VI.
- Updated IMO dispersant Guidelines (Part IV) and Guide on Practical Methods for the Implementation of the OPRC Convention and the OPRC-HNS Protocol. Following short discussion of these two items, DG2 was instructed to finalise the above Guidelines and review the first draft of the Guide on practical methods of implementation. In considering DG2’s subsequent report, the Sub-Committee:
- Agreed the proffered final draft of part IV of the IMO Dispersant Guidelines for submission to MEPC 73, with a view to approval and subsequent publication; and
- Established a correspondence group on the OPRC guidelines with appropriate terms of reference under the coordination of NORWAY.
- Use of Electronic Record Books. DG1 was tasked to consider two items. The first, that of finalising the text of the draft 2018 Guidelines for application of MARPOL Annex 1 requirement to FPSOs and FSUs, was solved by means of drafting a resolution for submission to MEPC73. The second was rather more substantial, involving as it does, the use of Electronic Record Books for which terms of reference were issued. DG2’s subsequent report was approved in general by the Sub-Committee, and in particular:
- Noted the Group’s discussion on the retention of electronic record books (ERBs) upon any change of Company/flag;
- Agreed to remove the square brackets from the text in para. 4.4.5 of the draft Guidelines for the use of ERBs under MARPOL, ‘and IEC 60945, where applicable’;
- Agreed text of a draft MEPC resolution on the Guidelines for the use of electronic record books under MARPOL for submission to MEPC 73 (in conjunction with associated draft amendments to MARPOL and the NOx Technical Code);’
- Noted the Group’s discussion on the need for further clarification of the existing ODS (Ozone Depleting Substances) recording systems at MEPC 73;
- Agreed draft amendments to MARPOL Annexes I, II, V, and VI, and the NOx Technical Code for submission to MEPC 73;
- Will invite MEPC 73 to encourage ships which are using ERBs during the interim period, prior to the entry into force of the amendments, to share their experience; and also, request both flag and port States to provide relevant information on the use of the Guidelines to aid in the facilitation and use of ERBs;
- Agreed draft amendments to the ‘Procedures for Port State Control, 2017’ for submission to MEPC 73 for approval in principle, then forward them to the III Sub-Committee for inclusion in future amendments to the Procedures for PSC 2017; and
- Agreed draft amendments to the 2009 Guidelines for PSC under the revised MARPOL Annex VI for submission to MEPC, again, for approval in principle.
- Unified Interpretation (UI) on Engine Test Cycles Required by the NOx Technical Code 2008. As instructed by the Sub-Committee, WG3 considered the draft UI of para 3.2.1 of chapter 3 of the NOx Technical Code 2008 plus submissions by IACS ad IMarEST. However, following discussion and due to lack of sufficient support by Member Governments, it was agreed not to develop a UI on engine test cycles required by the NOx Technical Code 2008.
- Remaining Items Considered by WG 3. In consideration of the remaining items given to WG3 under its terms of reference, the Sub-Committee:
- Agreed to the draft 2018 Guidelines for the discharge of exhaust gas recirculation (EGR) bleed-off water, for submission to MEPC 73;
- Agreed to draft consequential amendments to the 2017 Guidelines addressing additional aspects of the NOx Technical Code 2008 with regard to particular requirements related to marine diesel engines fitted with Selective Catalytic Reduction (SCR) Systems, for consideration by MEPC 73 and adoption at MEPC 74;
- Noted the need to clean up regulation 14 of MARPOL Annex VI, also the Supplement Form to the IAPP Certificate;
- Agreed draft amendments to MARPOL Annex VI for urgent approval of a prohibition on the carriage of non-compliant fuel oil for combustion purposes with a sulphur content exceeding 0.50% for submission at MEPC 72; and
- Agreed that the term ‘Engine Operational Profile’ be used in lieu of ‘Map’ and that ‘Description’ should be used instead of ‘Definition’.
- Date of Next Meeting. The next meeting PPR 6 is currently scheduled from 18 to 22 February 2019.
Captain Paddy McKnight END
