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IMO Sub-Committee On PPR 7 Agrees Draft Amendments To MARPOL Annex I

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Prohibiting the use and carriage for use as fuel of heavy fuel oil by ships in the Arctic waters- draft MARPOL amendments agreed.

The Sub-Committee on Pollution Prevention and Response (PPR) agreed draft amendments to MARPOL Annex I (addition of a new regulation 43A) to introduce a prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters on and after 1 July 2024.

The draft amendments will be submitted to the Marine Environment Protection Committee (MEPC 76) (19-23 October 2020) with a view to approval and circulation for adoption at MEPC 77 (spring 2021).

The prohibition would cover the use and carriage for use as fuel of oils having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s.

Ships engaged in securing the safety of ships, or in search and rescue operations, and ships dedicated to oil spill preparedness and response would be exempted.

Ships which meet certain construction standards with regard to oil fuel tank protection would need to comply on and after 1 July 2029.

A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that Party’s sovereignty or jurisdiction, up to 1 July 2029.

Currently, a MARPOL regulation prohibits the use or carriage of heavy grade oils on ships in the Antarctic; and under the Polar Code, ships are encouraged not to use or carry such oil in the Arctic.

Meanwhile, the Sub-Committee established a correspondence group to further develop draft guidelines on measures to reduce risks of use and carriage of HFO as fuel by ships in Arctic waters. The draft guidelines would cover ship operation, ship construction and heavy fuel oil bunkering, infrastructure and communication, enhancement of heavy fuel oil spill preparedness, early detection and response, and drills and training.

Implementation of the IMO 2020 sulphur limit – verifying sulphur content of fuel on board – guidelines agreed

IMO 2020, the 0.50% limit for sulphur in ships’ fuel oil, has been in effect since 1 January 2020, cutting sulphur oxide emissions from ships operating worldwide. From 1 March 2020, the carriage ban on non-compliant fuel oil (except for ships with exhaust gas cleaning systems installed) will enter into force under MARPOL Annex VI, helping to support implementation of the global sulphur limit.

To support the safe and consistent sampling of fuel oil being carried for use, and the enforcement of the carriage ban, the Sub-Committee finalised draft guidelines which provide a recommended method for the sampling of liquid fuel oil intended to be used or carried for use on board a ship.

The draft 2020 Guidelines for sampling of fuel oil intended to be used or carried for use on board a ship will be forwarded to the next session of the Marine Environment Protection Committee (MEPC 75), which meets 30 March to 3 April 2020, with a view to adoption.

Revised guidelines on exhaust gas cleaning systems (scrubbers) agreed

The Sub-Committee finalised its work on revising the 2015 Guidelines for exhaust gas cleaning systems (EGCS, also known as “scrubbers”).

The revision is aimed at enhancing the uniform application of the guidelines, in light of recent technical developments and experience gathered from approvals and operation of such alternative compliance systems.

The draft 2020 EGCS Guidelines will be submitted to MEPC 75 for adoption.

The Guidelines specify the criteria for the testing, survey, certification and verification of EGCS under regulation 4 of MARPOL Annex VI to ensure that they provide effective equivalence to the sulphur oxide emission requirements of regulations 14.1 or 14.4 of MARPOL Annex VI, as applicable. They cover continuous monitoring requirements and discharge water quality criteria, including minimum pH, maximum PAHs (Polycyclic Aromatic Hydrocarbons) concentration; provisions to minimize suspended particulate matter, including heavy metals and ash, and to prevent discharge of nitrates beyond specified levels.

The Guidelines note that discharge water quality criteria should be reviewed in the future as more data becomes available. Guidance for voluntary discharge water data collection, by means of a recommended procedure for sampling, is included.

The Guidelines are expected to be applied to new exhaust gas cleaning systems installed after a date to be decided by the Committee.

Discharges from exhaust gas cleaning systems – evaluating and harmonising rules and guidance

The Marine Environment Protection Committee (MEPC) at its last session in May 2019 asked the PPR Sub-Committee to look into evaluating and harmonising rules and guidance on the discharge of liquid effluents from EGCS.

To assist the discussions, a report from a task team established by the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) was submitted. This report contains the conclusions of the task team in relation to the available evidence on the environmental effects of discharge water from EGCS, as well as recommendations on the data, tools and approaches that could be used as basis for conducting a risk assessment of the possible effects of discharges.

Following discussion in a working group, the Sub-Committee agreed to recommend to the MEPC that its future work should look at evaluation and harmonisation of rules and guidance on the discharge of discharge water from EGCS into the aquatic environment, including conditions and areas.

The scope of the work should include:

  • risk assessment (development of risk assessment guidelines for the evaluation of possible harmful effects of the discharge water from EGCS, taking into account existing methods and mathematical models);
  • impact assessment (to consider developing impact assessment guidelines);
  • delivery of EGCS residues (developing guidance on delivery of EGCS residues to port reception facilities, regarding volumes and composition of residues);
  • regulatory matters (including assessing state of technology for EGCS discharge water treatment and control, identifying possible regulatory measures, developing a database of local/regional restrictions/conditions on the discharge water from EGCS;
  • database of substances (establishing a database of substances identified in EGCS discharge water, covering physico-chemical data, ecotoxicological data and toxicological data, leading to relevant endpoints for risk assessment purposes).

The MEPC was invited to approve the planned scope of work and to consider involving GESAMP for scientific advice.

Reducing the impact on the Arctic of Black Carbon emissions from international shipping.

Black Carbon in the context of international shipping is the product of incomplete combustion of carbon-based fuels. Black Carbon emissions contribute to climate change as a ‘Short-Lived Climate Pollutant’.

IMO has been looking at how to measure and report on Black Carbon emissions, as part of its work to consider the impact on the Arctic of Black Carbon emissions from international shipping. A reporting protocol for voluntary measurement studies to collect Black Carbon data and Black Carbon measurement methods for data collection have already been agreed.

The Sub-Committee noted a number of submissions, including proposals to look at the aromatic content of blends of fuel oil. A high aromatic content, among other factors, could increase Black Carbon emissions from ships.

The International Standardization Organization (ISO) advised the Sub-Committee that it was already in the process of monitoring properties of very low sulphur fuel oil and high sulphur fuel oil and would provide feedback on their performance. ISO also advised the Sub-Committee that it would also consider whether it was possible to add a further measure to provide an approximate indication as to whether a fuel is more paraffinic or aromatic, based on the characteristics already included in the ISO 8217 standard, which specifies the requirements for fuels for use in marine diesel engines and boilers.

The Sub-Committee established a correspondence group to advance the development of 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 methods (light absorption filter smoke number (FSN);  photo-acoustic spectroscopy (PAS); and laser induced incandescence (LII)), to make accurate and traceable (comparable) measurements of Black Carbon emissions; and investigate the linkages between the measurement systems and policy options.

Prohibiting cybutryne in anti-fouling systems 

The Sub-Committee finalised a proposed amendment to the IMO Convention for the Control of Harmful Anti-fouling Systems on Ships (AFS Convention), to include controls on the biocide cybutryne. The draft amendment will be forwarded to MEPC 75 for approval, with a view to adoption at MEPC 76.

The AFS Convention already prohibits the use of biocides using organotin compounds.

Revised guidance on commissioning testing of ballast water management systems agreed

Ballast water management systems (BWMS) may be used on ships to meet the requirements of IMO’s Ballast Water Management Convention, which has been in force since 2017 and aims to prevent the spread of invasive aquatic species in ballast water. An amendment to regulation E-1 of the BWM Convention, which is expected to be adopted by MEPC 75, mandates the commissioning testing of BWMS. The Sub-Committee completed its revision of guidance on this testing, which is intended to validate the installation of a BWMS by demonstrating that its mechanical, physical, chemical and biological processes are working properly.

Review of the Biofouling Guidelines

The Ballast Water Management Convention aims to prevent the spread of potentially harmful aquatic species in ballast water. But invasive species can also attach themselves to the outside of ships.

The Sub-Committee began its review of the IMO Biofouling Guidelines, which provide a globally consistent approach to the management of biofouling – the accumulation of various aquatic organisms on ships’ hulls.

The Sub-Committee identified key elements that require further attention and discussion, considered areas for potential revision of the Guidelines, and established a correspondence group on the review of the Biofouling Guidelines, to progress the relevant work and facilitate more effective deliberations at PPR 8.

IMO is executing the GEF-UNDP-IMO GloFouling Partnerships project which aims to drive actions to implement the Biofouling Guidelines. The project will also spur the development of best practices and standards for improved biofouling management in other ocean industries.

Marine plastic litter – draft circulars agreed

The Sub-Committee prepared a draft MEPC circular on Provision of adequate facilities at ports and terminals for the reception of plastic waste from ships and a draft MEPC circular on Sharing of results from research on marine litter and encouraging studies to better understand microplastics from ships.

A correspondence group was established to consider how to amend MARPOL Annex V and the 2017 Guidelines for the implementation of MARPOL Annex V (resolution MEPC.295(71)), to facilitate and enhance reporting of the accidental loss or discharge of fishing gear, as currently provided in regulation 10.6 of MARPOL Annex V, and consider the information to be reported to Administrations and the IMO, the reporting mechanisms and modalities.

This work is in the context of the IMO Action Plan to address marine plastic litter from ships, which aims to enhance existing regulations and introduce new supporting measures to reduce marine plastic litter from ships. The action plan was adopted by the MEPC in 2018.

The MEPC agreed actions to be completed by 2025, which relate to all ships, including fishing vessels. The action plan supports IMO’s commitment to meeting the targets set in the UN 2030 Sustainable Development Goal 14 (SDG 14) on the oceans.