Sub-Committee on Pollution Prevention and Response (PPR), 5th session, 5-9 February 2018

Implementing the 2020 sulphur limit – ban on carriage of non-compliant high sulphur fuel oil agreed

IMO has agreed to move forward with a prohibition on the carriage of fuel oil for use on board ships, when that fuel oil is not compliant with a new low sulphur limit which comes into force from 2020.  The aim of the new limit is to reduce sulphur oxide (SOx) emissions from ships to improve air quality and protect the environment.

The 0.50% limit on sulphur in fuel oil on board ships (outside designated emission control areas or ECAs, where the limit is 0.10%) will come into effect on 1 January 2020.

To help ensure consistent implementation of this regulation, IMO’s Sub-Committee on Pollution Prevention and Response (PPR), which met (5-9 February) at IMO headquarters, London, agreed draft amendments to the MARPOL Convention on the prevention of pollution from ships (MARPOL Annex VI) to prohibit the carriage of non-compliant fuel oil, such that the sulphur content of any fuel oil used or carried for use on board ships shall not exceed 0.50%.

The exception would be for ships fitted with an approved “equivalent arrangement” to meet the sulphur limit – such as an exhaust gas cleaning system (EGCS) or so-called “scrubber” – which are already permitted under regulation 4.1 of MARPOL Annex VI. These arrangements can be used with “heavy” high sulphur fuel oil as EGCS clean the emissions and therefore can be accepted as being at least as effective at meeting the required sulphur limit. For a ship without an approved equivalent arrangement the sulphur content of any fuel oil carried for use on board shall not exceed 0.50%. 

Under regulation 3.2 of MARPOL Annex VI a ship undertaking trials for ship emission reduction and control technology research can be exempted by the Administration of a Party to Annex VI.

The Sub-Committee forwarded the proposed draft amendments to the Marine Environment Protection Committee (MEPC 72) meeting in April 2018, for urgent consideration. Once approved by MEPC 72, the draft amendments could be adopted at MEPC 73 (October 2018) and could enter into force on 1 March 2020 (just two months after the 0.50% limit comes into effect). 

To assist with consistent implementation, the Sub-Committee agreed to develop a single set of Guidelines covering all relevant aspects and also agreed the outline of draft Guidelines for consistent implementation of regulation 14.1.3 of MARPOL Annex VI (the regulation on the 0.50% limit). The guidelines would cover:

• Preparatory and transitional issues, relating to how ships can prepare for implementation, including relevant time schedules;
• Impact on fuel and machinery systems resulting from new fuel blends or fuel types;
• Verification issues and control mechanism and actions, including port State control and in-use fuel oil samples;
• Fuel oil non-availability: guidance, information sharing and standard reporting format;
• Safety implications relating to the option of blending fuels;
• Other useful guidance/information that assist Member States and stakeholders, including guidance addressing quality assurance and integrity of the supply chain.

The Sub-Committee agreed the terms of reference for its Intersessional Meeting on consistent implementation of regulation 14.1.3 of MARPOL Annex VI, to be held 9 to 13 July 2018.

A work plan for the Sub-Committee was agreed, to include:

• development of the draft Guidelines for consistent implementation of regulation 14.1.3 of MARPOL Annex VI at the intersessional meeting, with a recommendation that these could be presented directly from the working group to MEPC 73 (October 2018);
• development of draft amendments to MARPOL Annex VI at the intersessional meeting, for finalization at PPR 6 for approval at MEPC 74, with a view to adoption at MEPC 75 (Spring 2020) with an expected entry into force in summer 2021, relating to definition of "Sulphur content" (regulation 2); and testing and verification procedure of in-use fuel oil samples (amendments to regulation 14 and associated consequential amendments to regulation 18 and appendix VI);
• development of draft amendments, as appropriate, to existing guidelines at the intersessional meeting and finalization at PPR 6 for adoption by MEPC 74, namely to the  2009 Guidelines for port State control under the revised MARPOL Annex VI (resolution MEPC.181(59));  2010 Guidelines for monitoring the worldwide average sulphur content of fuel oils supplied for use on board ships (resolution MEPC.192(61), as amended by resolution MEPC.273(69)); and Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864).

The urgency of the matter was recognised to the extent that MEPC 72 (April 2018) will be requested to consider whether the output on ship implementation planning for 2020 from the PPR intersessional meeting in July 2018 should be forwarded to MEPC 73 (October 2018).

Consistent implementation of the 0.50% sulphur limit for all ships will ensure a level playing field is maintained, with the result that the expected improvement of the environment and human health will be achieved. Sulphur oxides (SOx) are known to be harmful to human health, causing respiratory symptoms and lung disease. In the atmosphere, SOx can lead to acid rain, which can harm crops, forests and aquatic species, and contributes to the acidification of the oceans.

Black carbon: reporting protocol and most appropriate measurement methods agreed
Black Carbon is the product of incomplete combustion of carbon-based fuels. Black Carbon emissions from ships 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.

The Sub-Committee agreed the Reporting protocol for voluntary measurement studies to collect Black Carbon data as well as most appropriate Black Carbon measurement methods for data collection.

The Sub-Committee encouraged Member States and international organizations to continue to collect Black Carbon data, using the agreed reporting protocol and the agreed measurement methods, and submit relevant data to the next session of the Sub-Committee. 

Draft Guidelines for discharge of exhaust gas recirculation bleed-off water agreed
The Sub-Committee agreed draft 2018 Guidelines for the discharge of exhaust gas recirculation (EGR) bleed-off water, for submission to MEPC 73, with a view to adoption.

One method for reducing NOX emissions to meet Tier III NOX emission levels when operating in a NOX Tier III emission control area is to use Exhaust Gas Recirculation (EGR), which is an internal engine process resulting in a NOX reduction which will meet the requirements of the regulation. By means of this process, condensate of exhaust gas will be generated and discharged as bleed-off water, which should be handled differently depending on the fuel oil sulphur content. EGR may also be used as a Tier II compliance option.

The guidelines cover the discharge of EGR bleed-off water.

The Sub-Committee also agreed draft amendments to the NOX Technical Code 2008 relating to certification requirements for selective catalytic reduction (SCR) systems.

Ballast Water Management guidance agreed
The Sub-Committee considered matters relating to the implementation of the Ballast Water Management Convention.

Draft Guidance on System Design Limitations of ballast water management systems and their monitoring, was agreed, for submission to MEPC 73 with a view to approval.

Meanwhile, the Sub-Committee invited submissions to the next session on specific examples of contingency measures acceptable to port States and implemented by the shipping industry, which could then be included in an annex to the Guidance on contingency measures under the BWM Convention; and further submissions related to ports with challenging water quality.

Revised Guidelines for FPSOs and FSUs agreed
The Sub-Committee agreed the 2018 Guidelines for the application of MARPOL Annex I requirements to floating production, storage and offloading facilities (FPSOs) and floating storage units (FSUs), for submission to MEPC 73, for consideration, with a view to adoption.

The Guidelines update previous versions to provide guidance and interpretation information which may be specifically applicable to FPSOs and FSUs used for the offshore production and storage or for the offshore storage of produced oil.  FPSOs and FSUs are a form of floating platform and subject to the provisions of MARPOL Annex I that relate to fixed and floating platforms. However, some of the environmental hazards associated with the quantities of produced oil stored on board operational FPSOs and FSUs are similar to some of the hazards related to oil tankers. The guidelines outline those relevant requirements of MARPOL Annex I related to oil tankers which could be adapted to address those hazards.

Guidelines and amendments for use of electronic record books agreed
The Sub-Committee agreed to draft Guidelines for the use of electronic record books under MARPOL, for submission to MEPC 73 for consideration, with a view to approval in principle and subsequent adoption at MEPC 74, in conjunction with associated draft amendments to MARPOL and the NOX Technical Code.

The guidelines note that recording and reporting should be encouraged as it may have many benefits for the retention of records by companies, crew and officers. The guidance aims to provide standardized information on approving an electronic record book to ensure the obligations of MARPOL are met and that there is a consistent approach to approving such systems.

The amendments provide for the use of an electronic record book (a device or system, approved by the Administration, used to electronically record the required entries for discharges, transfers and other operations) in lieu of a hard copy record book.

The MEPC was invited to encourage ships using electronic record books during the interim period, prior to the entry into force of the amendments, to share their experience; and to encourage both flag and port States to provide information on the use of the guidelines. 

The format for the recording of discharges under MARPOL is provided in the appendixes to the relevant MARPOL Annexes. Traditionally, the format of these record books has been in a hard copy provided by the Administration. However, as companies and shipowners increasingly focus on ways to operate in an environmentally responsible manner and aim to reduce the heavy burden associated with paper work through electronic means, the concept of operational logs in an electronic format has become a popular consideration.

Related draft amendments to the IMO Procedures for Port State Control, to note that record books may be presented in electronic format, were also agreed.

Guidelines for the use of dispersants agreed
Continuing its valuable work in the field of spill preparedness and response, the Sub-Committee finalized, for approval by MEPC, part IV of the Guidelines for the use of dispersants for combating oil pollution at sea, which focuses on the sub-sea application of dispersant.

This is the final part of the revision and update of the IMO Dispersant Guidelines which was initiated following the Deepwater Horizon to reflect the latest developments in this field of response. The guidelines, once published in their entirety, will provide useful and practical advice to Governments in preparing for and responding to oil spills at sea.

Discharge of high-viscosity products – draft MARPOL amendments agreed
The Sub-Committee agreed draft amendments to MARPOL Annex II to strengthen discharge requirements for tank washings containing high-viscosity, solidifying and persistent floating products (such as certain vegetable oils), in specified sea areas.

The draft amendments follow concerns about the environmental impact of permissible discharges of such products.

The new requirements would cover persistent floating substances with a high viscosity and/or a melting point greater than or equal to 0ºC. Under the new requirements, a chemical tanker that would unload a cargo of such a substance would have to carry out a prewash of its tanks and the residue/water mixture generated during the prewash would have to be discharged to a reception facility at the port of unloading. It is proposed that the requirements would be applied in North West European waters; the Baltic Sea area; the Western European waters; and Norwegian waters north of 62° N.

The draft amendments will be forwarded to MEPC 73 in October 2018 for approval and subsequent adoption

Revision of IBC Code completed
The Sub-Committee completed its revision of the International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code), including revised product lists and index. The revised chapters 17 (Summary of minimum requirements), 18 (List of products to which the code does not apply), 19 (Index of Products Carried in Bulk) and 21 (Criteria for assigning carriage requirements for products subject to the IBC Code) and other amendments will be forwarded to MEPC 73 and to the Maritime Safety Committee (MSC 100) later in 2018 for approval and subsequent adoption.    

The comprehensive review of the IBC Code aims to harmonize the requirements for individual substances with the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and the 2014 edition of the Revised Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) hazard evaluation procedure for chemical substances carried by ships.

The Sub-Committee also agreed a draft MEPC circular on Guidelines for the carriage of energy rich fuels and their blends, for submission to MEPC 73 (October 2018) with a view to approval.

Cybutryne controls in anti-fouling convention to be considered
The Sub-Committee considered an initial proposal to include controls on the biocide cybutryne in the Convention for the Control of Harmful Anti-fouling Systems on Ships (AFS Convention) and agreed that a more detailed review of cybutryne is warranted. The development of the proposed amendment to the AFS Convention is expected to take two sessions, concluding in 2020.

The proposal noted that cybutryne has been used since the mid-1980s and is often combined with copper or copper compounds in anti-fouling paints. Extensive scientific studies have shown that cybutryne has the potential to cause adverse effects to non-target organisms. Results from toxicity studies have concluded that cybutryne is highly toxic to aquatic species.

The AFS Convention prohibits the use of harmful substances in anti-fouling paints used on ships. Currently, organotin compounds are the only banned substances listed in the treaty’s Annex 1. 

The AFS Convention sets out the process for considering new substances to be included in the list of controlled substances in the treaty’s Annex 1. First, an initial proposal is submitted, outlining the substance, its potential harm and a recommendation on restrictions.  On the basis of that information, the Committee decides if a more in-depth review is needed and if so, requests a comprehensive proposal. This comprehensive proposal is reviewed by a technical group established by the Committee, and the proposed controls to be included in Annex I are put forward for adoption in accordance with the procedures for amendments specified in Article 16 of the Convention. .

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