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What happened at the 10th IMO sub-committee on pollution prevention and response

Published: 01 May 2023

The 10th session of the IMO Sub-Committee on Pollution Prevention & Response from 24 to 28 April discussed biofouling management, reducing the risk of environmental damage from plastic pellet losses, Black Carbon’s impact on the Arctic and the use of Electronic Bunker Delivery Notes (e-BDN) amongst other topics.

Revised Biofouling Management Guidelines

PPR 10 saw the completion of the review of the 2011 Guidelines for the Control and Management of Ships’ Biofouling to Minimize the Transfer of Invasive Aquatic Species providing new guidance to ships on how to best manage biofouling including through performance monitoring, inspections and in-water cleaning- either proactive or reactive. New templates on inspection and cleaning report, Biofouling management plan (BFMP) and Biofouling record book (BFRB) have also been added to the new set of guidelines.


Electronic Bunker Delivery Notes (eBDN)

PPR has agreed a unified interpretation to MARPOL Annex VI, as an interim step towards facilitating the use of eBDN. The unified interpretation has to be approved by MEPC 80 in July 2023 and the text is proposed to read:

“The Bunker Delivery Note (BDN) required by regulation 18.5 (of MARPOL Annex VI) is acceptable in either hard copy or electronic format provided it contains at least the information specified in appendix V to MARPOL Annex VI and is retained and made available on board in accordance with regulation 18.6. In addition, an electronic BDN should be protected from edits, modifications or revisions and authentication be possible by a verification method such as a tracking number, watermark, date and time stamp, QR code, GPS coordinates or other verification methods."

BIMCO fully support the use of eBDNs. It is important to ensure that they are protected once signed and can be authenticated and verified by authorities and relevant stakeholders.

Reducing Black Carbon’s impact on the Arctic

PPR continued to progress the work on reducing impact on the Arctic of Black Carbon emissions from ships operating in or near the Arctic.

The intention is, in 2024 or 2025, to issue guidelines recommending data collection and reporting of black carbon emissions for existing ships in order to enhance development of recommendations and regulations to reduce the impact on the Arctic of Black Carbon emissions. Work also is progressing on recommendatory goal-based control measures for new ships and best practices for existing ships.

The environmental risk associated with maritime transport of plastic pellets

PPR discussed, in some length, the best options for reducing the environmental risk associated with the maritime transport of plastic pellets in freight containers with the view to issue a MEPC circular in 2024. The draft circular will first be submitted to the Sub-Committee on the Carriage of Cargoes and Containers (CCC) for their input on possible, if any, recommended packaging measures, before finalisation.

The major topics of discussion included the definition and size limit of plastic pellets, packaging requirements, and potential instruments to form a legal basis for mandatory provisions governing the maritime transport of plastic pellets in freight containers. These topics will continue to be discussed at future sessions of both CCC and PPR.

PPR reached an agreement that pellets should not be carried in bulk and invited interested Member States and international organizations to submit relevant proposals to a future session of the Sub-Committee on potential regulatory changes that may be needed to prevent the shipment of plastic pellets in bulk whilst at the same time, seeking CCC to provide input on such shipments. 

2015 Guidelines for the development of the Inventory of Hazardous Materials (resolution MEPC.269(68)) amended to include cybutryne

Following the entry into force of the respective controls in the AFS Convention PPR recommended that a consequential amendment be made to the Inventory of Hazardous Materials to assist compliance with regulation 5 (Inventory of Hazardous Materials) of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009. As such, pending approval by MEPC 80, cybutryne will now sit alongside anti-fouling systems containing organotin compounds as a biocide.

Discussions at future sessions

As well as continuing discussions on the topics covered above the next session of PPR (PPR 11), which is tentatively proposed to take place from 19 to 23 February 2024, the next session will further look at draft amendments to the 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants and other issues related to MARPOL Annex IV such as port reception facilities, the evaluation and harmonization of rules and guidance on the discharge of scrubber water from EGCS into the aquatic environment and the development of measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters

Any members wishing to discuss any of the topics covered by PPR are invited to contact the secretariat.


Christian Baekmark Schiolborg


Christian Baekmark Schiolborg

Manager, Marine Environment

Copenhagen, Denmark