As the Indian Register of Shipping informs, the regulation 12 of MARPOL Annex VI bans the installation of equipment containing ODS, including hydrochloroflurocarbons (HCFCs) on ships constructed on or after 1st January 2020. This aligns with the requirements of an international agreement on substances that damage the ozone Layer, called the Montreal Protocol 1987.
The Montreal Protocol was established to stop the production and import of ozone depleting substances that harm the ozone. It aims to reduce their concentration in the atmosphere in order to help protect the earth’s ozone layer.
The Montreal Protocol has set phase out timetable for all the major ozone depleting substances, including chlorofluorocarbons (CFCs), halons, HCFCs and other ODS. The global phase out timetable across the sectors for HCFCs is the following:
The phase out target date for maritime sector is set as 1st January 2020.
More specifically, the application of HCFCs is mainly found in:
- Refrigeration and air conditioning equipment;
- Heat pumps;
- Foam applications e.g. extruded polystyrene foams, as a blowing agent in rigid polyurethane foams (used largely for insulation purposes);
- Solvent applications for purposes such as lubricants, coatings and cleaning fluids for electrical, electronic or photographic equipment (e.g. precision inertial guidance systems, and oxygen components and piping systems in aircraft carriers and hospital ships);
- Portable fire extinguishers in applications such as used in telecommunication facilities, computer rooms, commercial shipping, pleasure craft etc.
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What is more, new installations that include HCFCs are not allowed on vessels built on or after 1st January 2020. However, systems and equipment with HCFCs on current vessels are allowed to continue operating and may be recharged as necessary with prohibition of the deliberate discharge of ODS to the atmosphere.
The phasing out of HCFCs will impact existing systems and equipment servicing and maintenance after 1st January 2020. Procurement of any small quantity of HCFCs for replenishment purposes may become a big challenge. Some of the challenges may include:
- Inflated prices;
- Global sourcing efforts;
- Increased breakdown time;
- Legal and logistic issues;
- Longer port stay.
Another important fact is that few countries may enforce complete ban on servicing and maintenance of existing systems and equipment that include HCFCs within their jurisdiction.
Ships with onboard installations of existing systems and equipment containing HCFCs are possible to have detailed inspections by the port state control (PSC) authorities. The records regarding usage, servicing, maintenance, HCFCs consumption will be verified strictly towards compliance.
In order to prevent future troubles due to this kind of situations, owners and operators of the ships are suggested to take stock of current systems and equipment with HCFCs installed on their ships.
A suitable evaluation of these systems and equipment with potential alternative solutions may be also conducted and a conscious decision of continuation with the current systems and equipment or appropriate modification using non-ODS substances shall be taken.
What is more, the Indian Register of Shipping recommends that ship owners and operators who would like to continue with the existing systems and equipment must make sure that at the time of servicing or decommissioning the systems or equipment containing HCFCs, the HCFC is collected in a controlled manner and should not be reused onboard, be landed to appropriate reception facilities for banking or destruction.
Finally, any redundant equipment or material that has HCFC is landed ashore for appropriate decommissioning or disposal. This also applies during ship recycling.
