The IMO Marine Environment Protection Committee (MEPC) held its 73rd session from October 22 to 26, 2018 and focused on a number of areas to improve shipping’s environmental footprint.
Ban of carriage of non-compliant fuel oil
MEPC 73 banned the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship. The carriage prohibition does not apply to ships employing an alternative arrangement, like scrubbers. The ban will enter into force on 1 March 2020.
Best practice for fuel oil suppliers
The Committee the Guidance on Best Practice for Fuel Oil Suppliers for assuring the quality of fuel oil delivered to ships. The Best Practices focuses on quality control during production of bunkers, in the supply chain and during transport, storage and transfer excluding low flashpoint fuels such as LNG, LPG or methyl/ethyl alcohols and pure biofuels.
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Sampling and testing should also be conducted and documented at each point of product custody transfer throughout the supply chain and at the receiving ship’s bunker inlet manifold.
Records of custody transfer of cargoes, certificates of quality, sample seal numbers and quality analysis reports should be documented as well.
2020 global sulphur limit
A proposal recommending the implementation of an experience-building phase, EBP, to monitor the implementation of the 0.50% sulphur cap was considered. The Committee was evenly split on the proposal and invited further concrete proposals on how to enhance the implementation of regulation 18 of MARPOL Annex VI, and especially on fuel oil quality and reporting of non-availability of compliant fuel oils.
Development of ship implementation plan for 0.50% global sulphur limit
The Committee approved guidance for developing a non-mandatory plan for ships to implement the 0.50% sulphur limit by the 1 January 2020 compliance date. Items recommended to be addressed by the plan include:
- Risk assessment and mitigation plan on the impact of new fuels;
- Modifications of the fuel oil system and tank cleaning;
- Fuel oil capacity and segregation capability;
- Procurement of compliant fuel;
- Fuel oil changeover and documentation and reporting.
The Plan should also address issues relating to the use of compliant fuel oil which include the capability/suitability of the ship’s equipment to handle different fuel types and associated characteristics.
Amendments to phase 3 EEDI reduction factors
The Committee agreed to draft revisions to MARPOL Annex VI, Chapter 4, regarding the submission of data which substantiates the revisions, concerning the calculation of the Required Energy Efficiency Design Index (Required EEDI).
The application of Phase 3 reduction factors for the following ship types which are contracted for construction on/after 1 January 2025 are proposed to be accelerated to 1 January 2022:
- Container Ships;
- General Cargo ships;
- Gas Carriers;
- Refrigerated Cargo Carriers;
- Combination Carriers;
- LNG Carriers;
- Cruise Passenger Ship (with non-conventional propulsion).
The Phase 3 reduction factor is proposed to be increased from the current 30% threshold to 40% for container ships.
The proposed amendments will be further considered at MEPC 74 in May 2019.
MARPOL fuel oil data collection system
The Committee approved three interpretations which implement collection and reporting ship specific data regarding fuel consumption which begins on 1 January 2019:
- Data relating to Boil-off Gas (BOG) consumed on board the ship for propulsion or operation will have to be collected and reported as fuel consumed under the Data Collection System.
- Ships which have their keel laid before 1 January 2019, but are delivered on or after 1 January 2019 should be provided with a Ship Energy Efficiency Management Plan (SEEMP), which will includes a description of the methodology that will be used to collect the fuel consumption data required.
- Fuel consumption source data is not required to be kept onboard the vessel if access to the source data can be provided by the Company.
EEDI survey and certification guidelines
The Committee adopted amendments to the 2014 Guidelines on Survey and Certification of the Energy Efficiency Design Index (EEDI), taking into account the 2017 update of the International Towing Tank Conference Recommended Procedure and the paragraphs renumbering of the 2018 EEDI calculation Guidelines.
Calculation of the attained EEDI
The Committee adopted amendments to the 2018 Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships. These guidelines provide paragraphs renumbering to make them more user friendly and including revised correction factor (fj) for power for ice classed ships and an alternative calculation method for ice classed ship designed and constructed based on an open water ship with same shape and size of hull with EEDI Certification.
EEDI regulations for ice-strengthened ships
The Committee approved draft amendments to exemption provisions on the application of EEDI (Attained and Required) requirements. The amendment replaces exemption for ‘cargo ships having ice-breaking capability’ with ‘Category A ships as defined in the Polar Code’. Category A ships are assigned to ships with certifications for the highest ice-strengthened structural capacity under the Polar Code.
Electronic Record Books
The Committee approved amendments on the acceptability of using electronic record books, in place of the following paper record books:
- MARPOL Annex I: Oil Record Book Part I (Machinery space operations) and Part II (Cargo/ballast operations);
- MARPOL Annex II: NLS Cargo Record Book;
- MARPOL Annex V: Garbage Record Book;
- MARPOL Annex VI: Ozone-depleting substances record book, the logbook on the on/off status of marine diesel engines for NOx Code Tier Standards and the logbook for fuel-oil-change-over operation when entering an ECA;
- NOX Technical Code: Record Book of Engine Parameters.
MARPOL Annex II Amendments
The Committee approved amendments to MARPOL Annex II which regulate cargo residues and tank washings of persistent floating products with a high viscosity and/or a high melting point – persistent floaters.
An approved MEPC.2/Circular contains a list of specific vegoils and waxes which are controlled by these amendments. When operating in the areas defined as North West European waters, Baltic Sea area, Western European waters and the Norwegian Sea the revised prewash procedure for persistent floaters which is to be included in a revised and approved Procedures and Arrangements Manual must be applied.
NOx technical code revisions
The Committee approved draft amendments to sub-paragraph 2.2.5.1 of the NOx Technical Code 2008 concerning certification requirements for Selective Catalytic Reduction (SCR) systems, with a view to adoption at MEPC 74 in May 2019. The amendments continue to specify the established principles that:
- A NOx-reducing device is to be included within the engine’s certification;
- The device must be recognized as a component of the engine;
- The device must be recorded in the engine’s Technical File.
Marine plastic litter from ships
The Committee adopted an Action Plan to prevent marine plastic litter entering the oceans through ship-based activities. Plastic litter includes both macroplastics and microplastics.
The actions in the Plan are projected to be completed by 2025 and include:
- Mandate application of the IMO Ship Identification Number Scheme for fishing vessels;
- Mandate marking of all fishing gear with the associated IMO Ship Identification Number;
- Revise MARPOL Annex V to require ships greater than 100 gt (currently 400 gt) to maintain on board a Garbage Record Book;
- Develop a mandatory system of reporting loss of containers at sea;
- Improve the effectiveness of port reception and treatment facilities for marine plastic litter;
- Require that Garbage Management Plans be approved under MARPOL Annex V.
BWM System Commissioning Test
The Committee approved guidance for validating the compliance of individual BWMSs. The guidance recommends that International Ballast Water Management Certificate should not be issued until commissioning testing has been successfully completed.
The guidance recommends that samples should be taken according with IMO’s G2 Guidelines for Sampling. Samples should be analyzed using the indicative analysis method which has a relatively quick indirect or direct measurement of parameters.
BW Management Plans
The Committee adopted Guidelines for Development of BWM Plans (G4), which recommend that new BWM Plans may include contingency measures to be taken in case the ballast water that has to be discharged does not comply with the D-2 biological standard.
Follow-up actions to the initial IMO strategy
The program of follow-up actions, which includes a timeline to 2023, contains the following streams of activity, but recognizes that further activity deemed necessary to implement the Initial IMO Strategy that may be developed:
- Short-term measures that can be considered and addressed under existing IMO regulations;
- Short-term measures that are not in progress and are subject to data analysis;
- Short-term measures that are not in progress and not subject to data analysis;
- Candidate mid-/long-term measures and action to address the identified barriers;
- Impacts on States considering geographic remoteness/connectivity to main markets, cargo value/type, transport dependency/ costs, food security, disaster response, cost-effectiveness and socio-economic progress and development;
- Fourth IMO GHG Study;
- Capacity-building, technical cooperation, research and development, particularly for least developed countries and small island developing states;
- Follow-up actions towards the development of the revised Strategy.
Further reduction of GHG emissions from ships
Trial measures include optimal ship routing, speed optimization, mandatory goal setting and speed-fuel curves for energy efficiency, improving energy efficiency of port activities, incorporating GHG reduction measures in the ship’s SEEMP, and using goal-based energy efficiency measures and alternative fuels.
