IMO’s Sub-Committee on Pollution Prevention and Response (PPR) met from 18 to 22 February at IMO headquarters and focused on finalizing draft Guidelines on the implementation of the 0.50% sulphur limit under MARPOL Annex VI. After discussions, the Sub-Committee agreed to the results below.
PPR 6 agreed draft Guidelines for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, along with other relevant guidelines.
They also formed a package helping the industry adapt the regulation easier.
IMO has already issued its ship implementation planning guidance, to help shipowners prepare.
- Draft Guidelines on consistent implementation of the 0.50% sulphur limit
The draft Guidelines agreed include:
- sections on the impact on fuel machinery systems that result from new fuel blends and types;
- verification issues and control mechanism and actions, including port State control and samples of fuel oil used on board;
- a standard reporting format for fuel oil non-availability (fuel oil non-availability report (FONAR);
- possible safety implications relating to fuel oils meeting the 0.50% sulphur limit.
Mainly, MEPC 74 (May 2019) is to adopt these guidelines.
- Draft circular on delivery of compliant fuel oil by suppliers
The draft circular states that Members States should urge fuel oil suppliers to take into account:
- MEPC.1/Circ.875 Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships;
- MEPC.1/Circ.875/Add.1 Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.
- Draft amendments to MARPOL Annex VI on sulphur content definition and sampling
The Sub-Committee agreed draft amendments to MARPOL Annex VI, to be approved by MEPC 74 and subsequent adoption by MEPC 75 (Spring 2020), with an expected force date of mid-2021.
Draft amendments to Regulation 2 Definitions, to include new definitions for
- “Sulphur content of fuel oil”: meaning the concentration of sulphur in any fuel oil, measured in % m/m as tested in accordance with standard acceptable to the Organization;
- “Low-flashpoint fuel”: gaseous or liquid fuel having a flashpoint lower than otherwise permitted under paragraph 2.1.1 of SOLAS regulation II-2/4;
- “MARPOL delivered sample”: the sample of fuel oil delivered in accordance with regulation 18.8.1 of MARPOL Annex VI;
- “In-use sample”: the sample of fuel oil in use on a ship;
- “On board sample”: the sample of fuel oil intended to be used or carried for use on board that ship.
Fuel oil sampling and testing: Draft amendments to Regulation 14 Sulphur oxides (SOX) and particulate matter, to add new paragraphs related to in-use and on board fuel oil sampling and testing, to add new paragraphs to require one or more sampling points to be fitted or designated for the purpose of taking representative samples of the fuel oil being used or carried for use on board the ship.
The representative samples of the fuel oil being used on board are to be taken in order to verify the fuel oil complies with the regulation.
Appendix I amendments to the International Air Pollution Prevention (IAPP) certificate – Draft consequential amendments to update the IAPP certificate to add a reference to sampling points and also to note where there is an exemption to the provision for low-flashpoint fuel.
Appendix VI Fuel verification procedure for MARPOL Annex VI fuel oil sample Draft consequential amendments to verification procedures, to cover verification of the representative samples of in-use fuel oil and on board fuel oil.
- Draft amendments to on board sampling guidance
PPR 6 agreed to draft 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil that is used on board vessels, updating the previous version.
MEPC 74 (May 2019) is expected to approve these guidelines.
- Draft 2019 port State control guidelines
The Sub-Committee agreed to draft 2019 Guidelines for port State control under MARPOL Annex VI, updating the 2009 guidelines. MEPC 74 (May 2019) is expected to adopt these guidelines.
- Draft interim guidance for port State control on contingency measures for addressing non-compliant fuel oil
The Sub-Committee developed draft interim guidance for port State control on contingency measures for addressing non-compliant fuel oil and invited concrete proposals to MEPC 74.
It regards possible actions to be taken, following discussions between ship, flag State and port State, when a ship is found to have on board non-compliant fuel oil either as a consequence of compliant fuel oil being not available when the ship bunkered fuel oil or the ship identifying through post bunkering testing that the fuel oil on board is non-compliant.
MEPC 74 (May 2019) is expected to consider these draft interim guidelines further.
- Draft unified interpretation
The Sub-Committee agreed a draft unified interpretation to regulation 14.1 of MARPOL Annex VI, for submission to MEPC 74 for approval, which confirms that regulation 14.1 of MARPOL Annex VI for the prohibition on carriage of non-compliant fuel oil should also be applied to the fuel oil of emergency equipment.
The Sub-Committee is revising the 2015 Guidelines on Exhaust Gas Cleaning Systems (EGCS).
The Sub-Committee highlighted the progress made by the Correspondence Group on review of the 2015 EGCS Guidelines.
It agreed to request an extension of the target completion year to 2020 with a view to continuing the work on the review at PPR 7.
They also greed to forward a new draft Appendix 6 to the EGCS guidelines, developed by the correspondence group, to MEPC 74 (13-17 May) for review and finalization, with a view to potentially issuing it as an MEPC circular.
The proposed draft Appendix 6 provides Guidance on temporary indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the EGCS fails to meet the requirements of the Guidelines. It aims to address situations in which there is a malfunction of the EGCS system.
The Sub-Committee reviewed a submission from the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP), an advisory body that advises the United Nations (UN) system on the scientific aspects of marine environmental protection. GESAMP provided comments received from four GESAMP members.
The Sub-Committee also heard from Member States who had carried out studies and preliminary studies related to washwater discharge and the impact on the marine environment.
The Sub-Committee urged interested Member States and international organizations to proceed to further scientific research and submit results to future sessions to facilitate the work on the revision of the 2015 EGCS Guidelines.
The Sub-Committee requested the IMO Secretariat to explore the possibility of GESAMP carrying out a review of the relevant scientific literature and also overseeing a modelling study of the impacts of discharge washwater from exhaust gas cleaning systems.
The Sub-Committee also invited Member States and organizations in consultative status to submit further scientific studies and information.
- Controls on the biocide cybutryne in anti-fouling systems agreed
IMO Convention for the Control of Harmful Anti-fouling Systems on Ships is to ban a second compound/active ingredient used in biocides in anti-fouling systems on ships.
For the time being, AFS Convention controls only one active compound. Thus, it bans the use of biocides using organotin compounds (TBT).
The Sub-Committee agreed that new controls on the biocide cybutryne, commonly known as Irgarol-1051, have to be included in the AFS Convention.
Draft amendments to the AFS Convention’s Annex 1 (Controls on anti-fouling systems) to include controls on cybutryne were opted for consideration by MEPC 74, with a view to approval and subsequent adoption. Related draft amendments to the model form of the International Anti-fouling System Certificate were also agreed.
The proposed amendments can be adopted by MEPC 75, and would enter into force under the tacit acceptance procedure, a minimum of 18 months after adoption (the date will be decided by the MEPC).
The Sub-Committee invited proposals to PPR 7 on consequential amendments to the Guidelines for brief sampling, survey and certification, and inspection of anti-fouling systems on ships.
MEPC may also consider the revisions of the Revised guidance on best management practices for removal of anti-fouling coatings from ships, including TBT hull paints (LC-LP.1/Circ.31/Rev.1) and the Inventory of Hazardous Materials under the Hong Kong Convention, in light of the introduction of controls of cybutryne under the AFS Convention.
A definition for heavy fuel oil was noted as: heavy fuel oil means fuel oils having a density at 15ºC higher than 900 kg/m3 or a kinematic viscosity at 50ºC higher than 180 mm2/s.
The Sub-Committee agreed on a draft methodology for analysing impacts of a ban on heavy fuel oil for the use and carriage as fuel by ships in Arctic waters
The Sub-Committee invited submissions to PPR 7, especially those by Arctic States, containing impact assessments guided by but not limited to the methodology.
The methodology sets out four steps to assess the impact of a ban:
- determination of the study area;
- assessment of the costs to Arctic indigenous and local communities and industries;
- assessment of the benefits of an HFO ban to Arctic indigenous and local communities and ecosystems;
- consideration of other factors that could either ameliorate adverse impacts of a ban or accommodate specific situations.
Meanwhile, a correspondence group was instructed to develop guidelines on measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters.
The guidance could include sections on:
- navigational measures;
- ship operations;
- infrastructure (onshore and offshore) and communications;
- enhanced preparedness for emergencies of oil spills, early spill detection and response;
- drills and training;
- economic assessment of potential measures.
- Addressing the impact on the Arctic of Black Carbon emissions
The Sub-Committee resulted to a number of possible control measures to decrease the impact on the Arctic of Black Carbon emissions from international shipping.
- Guide to implement pollution prevention and response treaties agreed
The Sub-Committee agreed the draft Guide on practical implementation of the pollution prevention and response treaties (OPRC Convention and the OPRC-HNS Protocol).
The Guide aims to:
- promote understanding of the overall OPRC Convention and OPRC-HNS Protocol concept;
- explain the benefits of participation in this international regime;
- provide a step-wise approach for the planning, preparedness and implementation process at national and regional levels;
- identify existing publications and support mechanisms to assist with implementation.
The International Convention on Oil Pollution Preparedness, Response and Co-operation (‘OPRC Convention’) was adopted in 1990 to define appropriate levels of planning and preparation for marine oil pollution.
To broaden the scope of the OPRC Convention, the Protocol on Preparedness, Response and Co-operation to Pollution Incidents by Hazardous and Noxious Substances (OPRC-HNS Protocol) was adopted in 2000.
- Revised guidelines for provisional assessment of liquid substances in bulk
The Sub-Committee agreed the draft revised MEPC circular on the Guidelines for the provisional assessment of liquid substances transported in bulk. The draft will be submitted to MEPC 74 for approval.
