Here are the key points raised at the latest Pollution Prevention and Response (PPR) meeting held in March this year. All of these are hot topics for the shipping industry and may have important – and perhaps expensive – implications for shipowners and operators. This article gives only an overview rather than drilling deep into detail.
One important matter – scrubber washwater – is under review directly by an MEPC ISWG and was not on the agenda.
HFO in Arctic Waters
In November 2020 at MEPC the IMO approved a ban on HFO as a fuel in the Arctic but in a limited fashion that will allow its use to continue until July 2029 and delayed the implementation of the ban until 2024. Ships flying the flag of Arctic coastal nations can be exempted from the ban by the flag state when operating in domestic waters.
PPR was designated to develop guidelines for ships operating until the ban comes into effect and for any exempted ships to follow thereafter. A Correspondence Group report detailing the guidelines was considered and will now be reviewed by the NCSR (Navigation, Communications and Search and Rescue) Sub-Committee for commentary on navigational guidance, and by the HTW (Human Element, Training and Watchkeeping) Sub-Committee for commentary on crew training that may be needed. These reviews should allow PPR 9 in 2022 to finalise the guidelines and pass them to the subsequent MEPC for approval and adoption.
Reducing impact of Black Carbon in Arctic
This has been an agenda topic for some time with difficulty encountered in agreeing on measuring methods. Three measurement methods (Filter Smoke Number (FSN); Photo Acoustic Spectroscopy (PAS); and Laser Induced Incandescence (LII)) have been identified and several participants supported FSN as the most consistent BC measurement method, although it was reported it may not be suitable for continuous monitoring equipment. Fuel quality has recently been identified as a contributing factor to production of Black Carbon and this was also discussed.
The meeting proposed that to progress both issues, goal-based Guidelines should be developed for international shipping. The proposal is to be submitted to MEPC 76 in June 2021 and further discussed at PPR 9 in 2022.
Ballast water treatment verification
Several methods of rapid compliance testing technology have been developed to demonstrate if a ballast water management system is working and in compliance with the D2 discharge standard. Despite the use of these systems and the various water conditions in which they may be used, there is no widely accepted protocol for validating such devices.
PPR 8 debated the possible issues including a conflict with the ISO which is also developing standards. It was agreed that work should continue, and a re-established Correspondence Group will progress the development of a standard for verification of ballast water compliance monitoring devices and submit a report to PPR 9.
Hazardous Bulk Cargoes
The meeting considered the regular report of the Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals (ESPH) responsible for maintaining the MEPC.2 Circular, Provisional Categorization of Liquid Substances in Accordance with MARPOL Annex II and the IBC Code, to provide carriage guidance for substances which have not yet been fully categorised and reflected in the IBC Code. It was reported that eight pure products and three trade-named products were added or revised in the MEPC.2 Circular and eight cargo tank cleaning additives were added in the MEPC.2 Circular.
The meeting also identified a new cargo type Palm oil mill effluent (POME) which is regularly shipped but without specific carriage requirements. It was proposed to include this cargo in the circular and this proposal will be considered at MEPC 76.
Review of 2011 Biofouling Guidelines
A topic which has moved up the agenda in recent years, biofouling is now seen as the major vector for transferring invasive alien species. It is generally considered that this subject will gain in importance as the ballast water management regime matures. A possible convention or code on biofouling is anticipated at some future point.
The review of the existing voluntary guidelines is expected to result in significant changes and formal definition of vague common terms such as “microfouling” and “macrofouling”. A re-established Correspondence Group on this subject will progress this work and is likely to recommend to the MEPC to extend the target completion date for this work to 2023. The Correspondence Group has been tasked to revise the Biofouling Guidelines (using a framework for the new guidance document which has already been drafted) and submit a report to PPR 9 (Spring 2022).
Marine Plastic litter from ships
Discussion mostly centred on lost and discarded fishing gear. A new Appendix III to MARPOL Annex V has also been drafted to identify the information that is to be submitted to the IMO on lost/discharged fishing gear, once this information is finalised and agreed.
The topic is also on the agenda for MEPC 76 and after this a working group will be established at PPR 9 to consider the reports from other parties and progress work on amendments to MARPOL Annex V, including draft amendments to the 2017 Guidelines for the Implementation of MARPOL Annex V (MEPC.295(71)) to support the implementation of the proposed MARPOL Annex V amendments. The target completion date for these amendments will be extended from 2021 to 2023, pending approval by the MEPC.
Sewage Treatment Plants
The Sub-Committee considered the report of a Correspondence Group which was tasked to progress revisions to MARPOL Annex IV aimed at enhancing and monitoring the performance of sewage treatment plants.
New regulations would also require ships equipped with sewage treatment plants to maintain onboard a Sewage Management Plan and a sewage record-keeping book. Sampling points for the STP effluent would also be required to be fitted to facilitate performance monitoring. A new Appendix II to MARPOL Annex IV would provide testing standards for STP effluent, and a new Appendix III would provide a format of the Sewage Record Book.
The discussions centred around the need for rules not to require replacement of existing systems or increase administrative burdens on ships’ crew. It was also highlighted that crew numbers are the main factor in determining necessary on board facilities.
Some delegates were concerned that the development of new regulations for sewage treatment plants could discourage their installation in favour of other permitted methods (comminuting and disinfecting systems) which have fewer associated regulations. The impact of COVID 19 on the cruise industry and timed needed for subsequent return to normality was cited as a factor to be considered when determining a timeline for new regulatory requirements in MARPOL Annex IV.
A re-established Correspondence Group was given the task of working to finalise the work with a reported to be submitted to PPR 9 allowing for possible introduction in 2023.