Very sorry for sending wrong report yesterday evening. I attached wrong report – entirely my fault, please forgive me.
Here is the correct report from our excellent reporter – Capt. Paddy McKnight.
The IMO Sub-Committee on Pollution Prevention and Response held its 8th session (PPR 8) remotely from 22 – 26 March 2021 under the Chairmanship of Dr Flavio Fernandes (BRAZIL) and his Vice Chair, Dr Anita Makinen (FINLAND), both of whom were subsequently re-elected for 2022.
The meeting was attended by representatives from Member Governments, Associate Members of IMO, Intergovernmental Organisations and Non-Governmental Organisations.
Items of particular interest to InterManager Members are as follows:
WELCOMING ADDRESS. The Secretary General of IMO, Mr Kitack Lim, welcomed delegates to the eighth session of the Sub-Committee, this being its first remote session. He spoke of how the regulatory framework applicable to ships has evolved in part as a result of work carried out by the Sub-Committee, giving 2 notable examples:
- The prohibition of the carriage of fuel that is non-compliant with the 0.5% Sulphur limit by ships which entered into force on 1 March 2020 to support enforcement of the global sulphur limit, otherwise known as IMO 2020; and,
- The revised carriage requirements for chemicals transported in bulk as set out in the IBC Code [International Code for the Construction and Equipment of ships carrying Dangerous Chemicals in Bulk] which entered into force on 1 January 2021.
He next referred to the challenges of the COVID 19 pandemic and its serious impact on global trade, travel, also in particular, the burden placed on Seafarers. He spoke of working tirelessly with UN sister organisations and social partners to ensure the global recognition of Seafarers as “key-workers” and to prioritise their vaccination, thereby facilitating their safe movement across borders.
This led him on to the theme for this year’s World Maritime Day of “Seafarers: at the core of shipping’s future”. This provides a unique opportunity to send a clear message to the world to help protect seafarers’ rights and raise awareness of their exceptional contribution as key and essential workers on the front line, delivering world trade despite the ongoing pandemic.
Turning to the business ahead, he stated that, given there is less time available for remote meetings, the MEPC had approved a reduced agenda for this session. However, the report of ESPH 26 [Evaluation of Safety and Pollution Hazards] and that of the five Correspondence Groups established at PPR 7 are all available for consideration. Building on the basis of such work carried out intersessionally, he encouraged progress on a number of substantive agenda items for this session such as the:
- Review of the biofouling guidelines;
- Revision of MARPOL Annex IV;
- Reduction of the impact on the Arctic of emissions of Black Carbon from international shipping;
- Work linked to the Action Plan to address Marine Plastic Litter from Ships; and,
- Development of a standard for the verification of ballast water compliance monitoring devices.
In closing, the Secretary General remarked that, notwithstanding the reduced agenda, this is a diverse set of subjects and he wished the Sub-Committee well in its work.
SAFETY AND POLLUTION HAZARDS OF CHEMICALS AND PREPARATION OF CONSEQUENTIAL AMENDMENTS TO THE IBC CODE. The Sub-Committee considered the report of ESPH 26 (PPR 8/3), together with related documents submitted to this session and took action as follows:
Outcome of GESAMP/EHS 57. The outcome of the discussions of GESAMP/EHS 57 [Group of Experts on the Scientific Aspects of Marine Environment Protection/Environment, Health & Safety] together with the revised GESAMP Composite List were noted by the Sub-Committee. In this context, following an intervention by the delegation of Germany as to the provision of advice on how best to assess mixtures against the new discharge requirement in regulation 126.96.36.199 of MARPOL Annex II, the Secretariat was requested to convey an invitation to the GESAMP/EHS working Group to start consideration of this matter at their next meeting.
Evaluation of products and cleaning additives. With regard to the provisional categorisation of liquid substances, the Sub-Committee:
- Concurred with the evaluation of products and their respective inclusion in lists 1, 3, and 5 of MEPC.2/Circ.26, with validity for all countries and with no expiry date;
- Noted that for three products already listed in chapter 17 of the IBC Code that had been subsequently reassessed by the Group (creosote (coal tar)); sodium chlorate solution (50% or less); and ethyl tert-butyl ether, a distinguishing qualifier has been appended to the corresponding product names in list 1 of MEPC.2/Circ.26, to facilitate shipment of the products with the updated carriage requirements; and,
- Concurred with the evaluation of cleaning additives and noted their inclusion in annex 10 to MEPC.2/Circ.26 published on 1 December 2020
Decisions with regard to the categorisation and classification of products. Having noted the draft amendments to the Decisions with regard to the categorisation and classification of products (PPR.1/Circ.7) that had been prepared by the Group, the Sub-Committee instructed the ESPH Technical Group to continue its practice of recording its decisions with a view to preparing a draft revision of the Circular, as appropriate.
Draft IP Code. The Sub-Committee recalled that SDC 6, in considering the draft International Code of Safety of Ships Carrying Industrial Personnel (the draft IP Code), had agreed to refer the sections relating to dangerous liquid chemicals in bulk to PPR for consideration, and also that ESPH 26 should consider the relevant sections of the draft IP Code. The Sub-Committee concurred with modifications to the text of the draft IP Code as proposed by the Group (set out in annex 7 to document PPR 8/3) and requested the Secretariat to advise the SDC Sub-Committee accordingly.
Carriage of waste vegetable oils extracted from effluent water. Document PPR 8/3/1 submitted by UK contained a proposal for generic carriage requirements for “Palm oil mill effluent (POME) technical oil” to be included in the MEPC.2/Circular for all countries and with no expiry date, and subsequently in chapter 17 of the IBC Code. Following discussion, and taking into account that the products described were being transported in significant quantities under incorrect product names, agreement was given to a generic entry for “Palm oil mill effluent (POME) technical oil” for inclusion in list 1 of the MEPC.2/Circular with validity for all countries and with no expiry date, subject to the endorsement of MEPC 76.
REVIEW OF THE 2011 GUIDELINES FOR THE CONTROL AND MANAGEMENT OF SHIPS’ BIOFOULING TO MINIMISE THE TRANSFER OF INVASIVE AQUATIC SPECIES (RESOLUTION MEPC.207(62)).
The Sub-Committee recalled that PPR 7 had established a Correspondence Group on Review of the Biofouling Guidelines, under the coordination of Norway. Two documents were submitted for consideration, the first by the Correspondence Group and the second, a commenting paper on the CG report. In the ensuing discussion, there was overwhelming support for the proposals in the report of the CG on Review of the Biofouling guidelines regarding the way forward, including re-establishing the Group and an extension to the target completion year of this output to 2023.
Many delegations expressed a view that macrofouling cleaning should not be confined to a dry-dock since they considered that the effective removal and capture of the macrofouling during in-water cleaning could be ensured if best practices were followed. Others supported the view that elements contained in document PPR 8/4/1 and the Roadmap therein deserved further consideration.
Other delegations noted that further thought should be given to the difficulties in checking the presence of remaining biofouling, especially microfouling, following hull cleaning. Addressing such issues, as well as the increased flexibility regarding macrofouling removal, would make Biofouling Guidelines more realistic and practical.
Following completion of discussion on this issue, the Sub-Committee re-established the CG on Review of the Biofouling Guidelines, under the coordination of Norway, with terms of reference contained in PPR 8/4 as the basis and taking into account the information and feedback on specific issues together with the comments made at PPR 8.
In order to complete the work, MEPC 76 will be invited to extend the target completion year to 2023.
REDUCTION OF THE IMPACT ON THE ARCTIC OF EMISSIONS OF BLACK CARBON FROM INTERNATIONAL SHIPPING. It was recalled that at its previous session, the Sub-Committee had:
- Agreed to draft terms of reference noting that a reduction of the impact on the Arctic of Black Carbon emissions from international shipping could include non-mandatory instruments such as guidance;
- Invited submissions on further concrete proposals to this session on the preferred way forward; and,
- Established the CG on reduction of the impact on the Arctic of Black Carbon emissions from International Shipping to progress the work intersessionally.
Documents were submitted as follows:
- PPR 8/5 and PPR 8/INF.2 (Canada) providing the report of the CG on Reduction on the Impact on the Arctic of Black Carbon Emissions from International Shipping;
- PPR 8/5/1 (Finland and Germany), presenting the final results of a Black Carbon measurement campaign on a single cylinder 4-stroke medium speed research engine, the aim of which was to analyse the impact of fuel oil quality on Black Carbon emissions, together with the composition of the particulate matter in the exhaust gas and a detailed fuel oil analysis of the VLSFOs used in the campaign;
- PPR 8/2 (ISO), commenting on PPR 8/5/1, providing information as to the considerations by ISO TC28/SC4/WG6 in the context of the current review of the ISO 8217 standard, as well as information on the fuel quality review, also carried out by WG6.
- PPR 8/5/3 (IPIECA and IBIA) offering additional information relevant to putting the results of PPR 8/5/1 in perspective, stating that in particular, the results presented could not be seen as representative of Black Carbon emissions of VLSFOs and that extreme care should be taken in drawing conclusions regarding the impact of VLSFOs in general on the basis of those results;
- PPR 8/5/4 (FOEI et al.) commenting on the CG report, reflecting on the trends of Black Carbon emissions from shipping; highlighting that switching to cleaner fuels, such as distillate oil fuels did not require Black Carbon measurement and in addition, offered three possible regulatory routes for requiring a switch to cleaner fuels: (1). Establishing an Arctic Emission Control Area. (2). Using fuels with a maximum sulphur content of 0.1% in Arctic waters, and (3). Adding a new chapter to MARPOL Annex VI on “Special requirements for the control of emissions from ships operating in polar regions”.
- In addition, a further two information documents were submitted by Canada informing the Sub-Committee of the establishment of a Canadian international Technical Working Group on the Development of a Standardised Sampling, Conditioning and Measurement Protocol for Black Carbon Emissions from Marine Engines; also, provision of information on the differences between the maritime sector and other transportation sectors in terms of engine technologies, fuel compositions and characteristics of particulate matter (PM) emissions.
Following a prolonged discussion around the various submissions where there was little agreement, the Chairman tabled a discussion paper in which he proposed revised terms of reference for further work on the reduction of the impact on the Arctic of Black Carbon Emissions from International Shipping. In it, he observed that, with regard to potential regulatory options, taking into account the outcome of MEPC 74, the submissions received, the discussion of the CG and in Plenary as well as much informal consultation, viewpoints are likely to be too diverse to agree on a specific set of voluntary or mandatory control measures at this session. He therefore concluded that a phased approach consisting of the development of the guidelines in the short-term with the potential for mandatory measures being introduced in the longer-term if necessary and as experience is gained, may provide a more defined way forward for this output. Such an option would provide an opportunity for the work carried out so far, namely the agreed definition of Black Carbon, the Reporting protocol for voluntary measurement studies to collect Black Carbon, the identified Black Carbon measurement methods and candidate control measures, and any other recommendation, as appropriate, to be compiled and made available as a single guidance document for Member States and the shipping industry to use.
Taking into account that MEPC 74 noted that action considered in respect of reducing the impact of Black Carbon emissions from international shipping could include non-mandatory instruments such as guidance (MEPC 74/18, paragraph 5.67), draft revised Terms of Reference for further work on the reduction of the impact on the Arctic of Black Carbon Emissions from international shipping were drawn up as follows:
- Develop, as a starting point, guidelines on recommendatory goal-based control measures to reduce the impact on the Arctic of Black Carbon emissions from international shipping, taking into account the identified candidate control Measures;
- Further consider regulating or otherwise directly control Black Carbon emissions from marine diesel engines (exhaust gas) to reduce the impact on the Arctic of Black Carbon emissions from international shipping, taking into account the identified candidate control measures;
- Further consider the recommended Black Carbon measurements (FSN,PAS,LII) to be used in conjunction with regulations to control Black Carbon emission from diesel engines;
- Develop a standardised sampling, conditioning and measurement protocol, including a traceable reference method and an uncertainty analysis, taking into account the three most appropriate Black Carbon measurement measures (FSN, PAS, LII), to make accurate and traceable (comparable) measurements of Black Carbon emissions. This measurement system should not preclude consideration and agreement on policy options to avoid or otherwise limit Black Carbon emissions from ships, as its development would in fact benefit from guidance on how possible regulations would be applied; and;
- Submit a report to MEPC 79 in 2022.
DEVELOPMENT OF MEASURES TO REDUCE RISKS OF USE AND CARRIAGE OF HEAVY FUEL OIL AS FUEL BY SHIPS IN ARCTIC WATERS. The Sub-Committee had for its consideration document PPR 8/6 (Russian Federation) providing the report of the CG. It had been tasked to further develop the draft Guidelines on measures to reduce the risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters and to submit a written report. The draft guidelines submitted to PPR 6, and then considered by the working group during PPR 7, were redrafted with the aim of finalising the document. The Guidelines would contain a set of practical recommendations for operators planning voyages in the Arctic using HFO as well as for the Administrations of the Arctic coastal States and ship operators flying the flag of that State in respect of what should be done to minimise the risk of an HFO spill and thus to qualify for mitigation(s) if applicable.
As a result of Group discussion, two versions of the draft Guidelines were prepared. First, the draft Guidelines in conventional IMO format, and another version with section I “Operators Guidelines on Mitigation Measures to Reduce Risks of Use and Carriage for use of HFO as Fuel by Ships in Arctic Waters” and section II “Maritime Administration’s Guidelines on Mitigation Measures to Reduce Risks of Use and Carriage for use of HFO as Fuel by Ships in Arctic waters”.
The Sub-Committee was invited to decide which of the two versions of the guidelines (the consolidated or with responsibilities of MA and OP restructured into separate sections) should be chosen and to consider the relevant version of the draft Guidelines for finalisation of the text with a view to approval.
In the event, a majority of the Sub-Committee supported the second version described in the CG’s report and will request the NCSR Sub-Committee to review Sections 2 (Navigational Measures) and Section 5 (Communications) of the Guidelines. Additionally, advice from the SDC (Ship Design and Construction) Sub-Committee will be sought on paragraph 4.4 regarding the location of fuel oil tanks. Training aspects will be examined by the HTW Sub-Committee prior to PPR 9 and a Drafting Group will prepare a Resolution plus sunset clause with a target date extended to 2022.
REVISION OF MARPOL ANNEX iv AND ASSOCIATED GUIDELINES TO INTRODUCE PROVISIONS FOR RECORD-KEEPING AND MEASURES TO CONFIRM THE LIFETIME PERFORMANCE OF SEWAGE TREATMENT PLANTS. Many submissions were submitted in respect of this item as follows:
- PPR 8/7, The Report of the Correspondence Group including draft amendments to MARPOL Annex IV and the 2012 Guidelines on implementation of effluent standards and performance tests for STPs;
- PPR 8/7/1 China), proposing amendments to MARPOL Annex IV to reduce the pollution risks of overflow from sewage treatment plants and proposing amendments to MARPOL Annex IV enhancing the managing of overflows ;
- PPR 8/7/2 (China), commenting on document PPR 8/7 regarding the discharge of “stored effluent” and proposing that the requirements developed by the Group be reconsidered based on test results provided in the document;
- PPR 8/7/3 (China), commenting on the CG report on Amendments to MARPOL Annex IV and associated guidelines, proposing that due consideration be given to the additional workload for the crew following implementation of the draft amendments to MARPOL Annex IV and the burden on shipowners during recovery of the Industry after COVID-19;
- PPR 8/7/4 (Iran), presenting information about the lack of effectiveness of type-approved STPs installed on board ships and providing recommendations to improve their performance;
- PPR 8/7/5 (Norway), providing a rationale for additional amendments to the guidelines associated with MARPOL Annex IV, including the use of accredited facilities for testing STPs, more detailed coverage of onboard type approved tests, also figures to reflect type approval test conditions ashore and on board and to illustrate the conditions of commissioning and performance test on board; the type of mean used for STP approval calculations, and providing comments and information relating to commissioning tests, performance tests and indicative monitoring ;
- PPR 8/7/6 (Norway), proposing amendments to the 2012 Guidelines, based on the rationale provided in PPR 8/7/5;
- PPR 8/7/7 (FOEI, WWF, Pacific Environment and CSC), suggesting that a potential unintended consequence of the draft amendments to MARPOL Annex IV developed by the CG could be that comminuting and disinfecting systems (CDSs) may become more attractive as a low cost option and a simpler way to meet the new requirements being developed for STPs, taking into account that there are no formal effluent standards for type approved CDSs and they are simpler than STPs. The document puts forward several proposals on how this matter could be addressed;
- PPR 8/7/8 (India, Japan, Liberia, Panama, Republic of Korea, CLIA, BIMCO and ICS), commenting on PPR 8/7, specifically in relation to bad effluent quality from existing STPs, proposing that the CG be re-established and that further items be added to the terms of reference of the Group. These include identifying the operational issues that make the ability of STPs worse and the operational measures for addressing the issues with concrete evidence; further, to identify the legal framework to monitor the level of improvement of effluent quality from STPs installed on existing ships and subsequently to consider regulations for existing ships in MARPOL Annex IV;
- PPR 8/7/9 (IACS), providing comments on PPR 8/7 and proposals to facilitate consideration and development of amendments to MARPOL Annex IV and associated guidelines, in particular in relation to the application provisions in draft regulations 9.3, 11B.1 and 11B.3 of MARPOL Annex IV, the requirements applicable to electronic record systems and hard copies of the sewage record book, and the use of “online measurement”;
- PPR 8/7/10 (FOEI WWF, Pacific Environment and CSC), commenting on PPR 8/7, proposing that grey water be removed from the list of sources of dilution in the amendments to the 2012 Guidelines considering that grey water may contain high level of nutrients, bacteria and solids which add to the loading of STPs and may impair their performance. Instead, grey water should be thought of as a type of wastewater that requires treatment;
- PPR 8/7/11 (FOEI, WWF, Pacific Environment and CSC), commenting on PPR 8/7. Specifically, the co-sponsors maintain that MARPOL Annex IV and the draft amendments being developed do not provide adequate protections for waters that are sensitive and/or significant for ecological, cultural or scientific reasons, notwithstanding provisions for Special Areas in MARPOL Annex IV and the Arctic and Antarctic vis-à-vis the Polar Code. They therefore propose that the Sub-Committee develop a rule prohibiting such discharge in these areas; and,
- PPR 8/7/12 (CLIA), commenting on PPR 8/7 and inter alia, agreeing with the goals of the CG to introduce provisions for record-keeping and measures to confirm the lifetime performance of STPs, highlighting the proposals within the CG report that in CLIA’s view accomplish these goals and should be taken forward. Proposals in the CG report that would cause significant impact to industry and/or require further analysis should be identified and considered for inclusion in the set of proposed amendments, e.g. the requirement for stored effluent discharge, the requirement for a separate holding tank and the inclusion of indicative monitoring within the STP testing scheme.
Having noted the progress made by the CG and the Group’s summaries of areas that require further work, the Sub-Committee agreed, in principle, to re-establish the CG on Amendments to MARPOL Annex IV and Associated Guidelines to further the work intersessionally taking into account the views expressed in relation to the documents at the current session. In this regard, the Sub-Committee noted a broad range of views, including the following:
- Due consideration should be given to keeping the administrative burden of the measures being developed to a minimum, in particular their impact on crew workload, and on how electronic recording could be utilised;
- Appropriate maintenance and operation of STPs are key elements for addressing bad effluent quality of existing STPs installed in ships and should be addressed rather than relying on retrofitting new equipment or the retrospective addition of new testing requirements to type-approved systems;
- Using the manual supplied by the STP manufacturer and following the ship’s safety management system is more relevant for existing ships rather than developing prescriptive operational requirements in MARPOL Annex IV;
- The exclusion of grey water from the list of diluents would make type-approved systems, such as many of the advanced water treatment plants installed on cruise ships, non-compliant since they had been approved with the inclusion of grey water as a diluent;
- The management of sewage overflow should be considered;
- If effluents meet the standards for discharge, irrespective of whether they are stored or not, then discharge restrictions should not apply; consequently the draft requirements for stored effluent should be further considered;
- Measures should be proportionate, practical and based on evidence and studies that are representative of conditions on board a ship;
- The application provisions of the requirements to new and existing ships should be clear;
- Segregation of different effluents would facilitate the identification of applicable MARPOL requirements for each effluent type;
- The availability of reception facilities is an important consideration;
- Indicative monitoring is a viable tool for assessing the performance and functionality of the installed STPs and measures in that regard deserve further elaboration;
- Measures should be goal-based and technology neutral;
- Caution should be exercised when considering the application of regional approaches, such as the regulations of the US State of Alaska on commissioning testing, compared to internationally trading ships covered by MARPOL Annex IV;
- The impact of the COVID-19 pandemic on the shipping industry should be taken into account; and,
- The potential for the draft amendments to MARPOL Annex IV to lead comminuting and disinfecting systems (CDSs) becoming more widely used should be further considered.
The delegation of the United States made a statement in relation to the importance of addressing operational limitations of existing STPs whilst the observer from CLIA also made a statement with regard to the impact of the COVID-19 pandemic. The Sub-Committee agreed that the outcome of the Correspondence Group provided a solid basis for future work and, in the light of the broad range of comments on the proposals submitted to this session, also agreed that all documents, bar one, should be considered in detail intersessionally. Unfortunately, the proposals in document PPR 8/7/11 to prohibit the discharge of sewage in sensitive areas falls outside the scope of the current output. However, should Member States wish to address the matter, proposals can be submitted to MEPC with a view to either expand the scope of the current output or propose a new output.
The Sub-Committee re-established the Correspondence Group on Amendments to MARPOL Annex IV and Associated Guidelines, under the coordination of Norway with the following terms of reference:
- Further develop the draft amendments to MARPOL Annex IV using annex 1 to document PPR 8/7 as a basis;
- Develop draft amendments to the 2012 Guidelines on implementation of effluent standards and performance tests for STPs with a focus on (using annex 2 to document PPR 8/7 as a basis): (1) type approval ashore, including the development of draft amendments for type approval on board. (2) procedures for performance tests to be performed after the STP installation (including content of appendix II). (3) indicative monitoring schemes and acceptable parameters. (4) guidance on other installation or testing requirements; and, (5) guidance on developing a sewage management plan and sewage record book;
- Review the scope of application of the draft amendments to MARPOL Annex IV to new and existing ships, including draft appendix II, taking into account the general principle that ships should not be unduly penalised and, in parallel, address the matters described in paragraphs 10.1 and 10.2 of document PPR 8/7/8;
- Identify the relevance for amending the Recommendation on standards for the rate of discharge of untreated sewage from ships (resolution MEPC 157(55)) for discharge rate of sewage sludge;
- Review the need to provide adequate port reception facilities;
- Further consider document PPR 8/7/7 and advise the Sub-Committee how to proceed;
- Further review the draft amendments to MARPOL Annex IV taking into consideration the amendments to associated guidelines; and,
- Submit a written report to PPR 9
In light of current circumstances and in order to make as much progress as possible intersessionally, the Sub-Committee agreed that the coordinator of the CG should have the flexibility to convene virtual meetings, but only as a complement to the [written] work of the CG and taking into account relevant decisions by the Council and MEPC.
FOLLOW-UP WORK EMANATING FROM THE ACTION PLAN TO ADDRESS PLASTIC LITTER FROM SHIPS, It was recalled that MEPC 74 had approved the scope of work of PPR in relation to marine plastic litter from ships and had agreed to add output 4.3 on “Follow-up work emanating from the Action Plan to address marine plastic litter from ships” to the provisional agenda of PPR 7 with four sessions to complete the work. The Sub-Committee also recalled that at its previous session it had established the CG on Marine Plastic Litter from Ships, under the coordination of France.
Two documents were submitted for consideration:
- PPR 8 (France), providing the report of the CG, including the draft amendments to MARPOL Annex V that had been developed by the Group together with a draft skeleton of the associated draft MEPC resolution on adoption, a non-exhaustive list of the functionalities for a proposed new GISIS module on reporting the loss or discharge of fishing gear, and draft terms of reference for a proposed working group; and,
- PPR 8/8 (Palau, UAE and Vanuatu), commenting on document PPR 8 and providing justifications as to the need to report the identification of the fishing vessels and the markings of any lost or discharged fishing gear.
Following a short discussion, it was agreed that both documents should be forwarded to PPR 9 following which ITF observed that the impact on coastal States has yet to be considered whilst Vanuatu argued strongly for a working group to be established at PPR 9 and this proposal was endorsed by Palau. The Chairman stated that he did not wish to have a correspondence group before PPR 9 but that he would recommend an extension of the output on this issue to 2023. Finally, Argentina pointed out that Fishing is the responsibility of FAO.
BIENNIAL STATUS REPORT AND PROVISIONAL AGENDA FOR PPR 9. The Sub-Committee updated the biennial status report for the 2020-2021 biennium, prepared its proposed biennial agenda for the 2022-2023 biennium, and the provisional agenda for PPR 9 for consideration by MEPC 76.
Correspondence groups established at this session. The following CGs will report to PPR 9:
- Review of the Biofouling Guidelines;
- Amendments to MARPOL Annex IV and associated Guidelines; and,
- Development of a Protocol for verification of Ballast Water Compliance Monitoring devices.
Arrangements for the next session. The following working, technical and drafting groups may be established at PPR 9 whereby the Chair, taking into account the submissions received on the respective subjects will advise the Sub-Committee before PPR 9, the final selection of such groups:
- WG on Marine Biosafety;
- WG on Prevention of Air Pollution from Ships;
- WG on MARPOL Annexes IV and V;
- TG on Evaluation of Safety and Pollution Hazards of Chemicals; and,
- DG on Arctic matters and HNS
Intersessional meetings. MEPC 75 approved the holding of an intersessional meeting of the ESPH Technical Group in 2021 and permission will be requested of MEPC 76 to hold a similar meeting of the ESPH Technical Group in 2022.
Date for the next session. The Sub-Committee noted that, due to the uncertainty surrounding the modalities of meetings (physical, remote or hybrid) in 2022, the preliminary programme of meetings for 2022 has not yet been prepared but are expected to be published shortly after Council 125 meets in July 2021.
ANY OTHER BUSINESS.
Development of a standard for verification of ballast water compliance monitoring systems. It was recalled that, following consideration of document MEPC 74/11 (Denmark), MEPC 74 had invited submission of concrete proposals for the development of a standard for verification of ballast water compliance monitoring systems to PPR 7 taking account of the comments made by the Ballast Water Review Group at that session.
The Sub-Committee also recalled that, following consideration of five documents on this subject at PPR 7, interested parties were invited to submit further proposals (to PPR 8) on the development of a standard for verification of ballast water compliance monitoring systems which resulted in:
- PPR 8/11 (Canada et al) containing revised proposed text of a draft protocol for verifying ballast water compliance monitoring devices using laboratory and field tests, which may be used during commissioning, data gathering during the experience-building phase, compliance testing by port State control or self-monitoring;
- PPR 8/11/1 (France), commenting on document PPR 8/11, providing several general comments on the revised protocol for the verification of ballast water compliance monitoring devices proposed in PPR 8/11, and suggesting specific changes on the proposed protocol to address those comments; and,
- PPR 8/11/2 (France and IACS), also commenting on document PPR 8/11 and suggesting further specific changes to the proposed protocol.
Recalling it had been envisaged that no working groups would be established at this session, the Sub-Committee noted that the scope and extent of comments/proposals contained in documents PPR 8/11/1 and PPR 8/11/2 would not allow the finalisation and agreement on the proposed protocol for the verification of ballast water compliance monitoring devices at this session given the time constraints of a virtual meeting, the best way forward might be to establish a correspondence group to progress the matter and report to PPR 9.
In this regard, noting also the importance of the protocol in a number of contexts including the experience-building phase, port State control and commissioning testing, a number of technical topics arising from the submitted documents were highlighted by various delegations that require further consideration and/or on which there may be divergent views, including the following:
- Whether to distinguish between viable and non-viable organisms;
- The range of ballast water management technologies that should be covered;
- The need for field tests necessary in order to capture real-life circumstances although some tests may not be feasible on board ships;
- The organism categories under regulation D-2 to be included in the tests, notably with regard to the indicator microbes;
- The need for clear criteria for accuracy and reliability;
- Concerns regarding the capabilities of such devices under diverse water qualities; and,
- The effect on the accuracy of such devices of environmental factors including the presence of dead algae, humic acid and turbidity.
One delegation noted that there is ongoing work at ISO that may be similar in scope and that the verification of BW compliance monitoring devices is not required by the BWM Convention, questioning the need to continue this work by the Organisation.
Establishment of the Correspondence Group on Development of a Protocol for Verification of Ballast Water Compliance Monitoring Devices. Following discussion, the Sub-Committee established the Correspondence Group under the coordination of the United Kingdom, with the following terms of reference:
- Prepare an updated draft protocol for verification of ballast water compliance monitoring devices, using document PPR 8/11 as the basis, and taking into account the comments and proposals in documents PPR 8/11/1 and PPR 8/11/2; and,
- Submit a report to PPR 9.
Member States and international organisations were encouraged to contact the Coordinator of the Correspondence Group, with a view to participating and contributing to the work of the Group, including the provision of further information on technical matters such as those highlighted during the discussion.
Captain Paddy McKnight