BIMCO calls for prohibition on the carriage of non-compliant fuel oil in 2020

BIMCO calls for prohibition on the carriage of non-compliant fuel oil in 2020

Overview

The International Maritime Organization (IMO) Sub-Committee on Pollution Prevention and Response (PPR 5) will meet next week.

The 5th session of the International Maritime Organization (IMO) Sub-Committee on Pollution Prevention and Response (PPR 5) will be held in London from 6 to 10 February 2018.

The PPR is considering technical and operational matters related to prevention and control of pollution of the marine environment from ships.

PPR is the only Sub-Committee, which reports to both Marine Environment Protection Committee (MEPC) and Maritime Safety Committee (MSC).

Important items on the agenda

The agenda for PPR 5 includes the following important items:

Consistent implementation of regulation 14.1.3 of MARPOL Annex VI. - BIMCO welcomes the decision on implementation of the 0,50% m/m global sulphur limit. Since the effective date, 1 January 2020 is fast approaching, it is now time to discuss, agree and implement measures to promote consistent implementation.

BIMCO and other industry organisations have submitted a paper to PPR 5, suggesting a way forward in monitoring the sulphur limits and ensuring full compliance on the high seas. The proposal is to establish a prohibition on the carriage of fuel oil exceeding 0.50% m/m sulphur, which is intended for use as bunker. It is important to recognize that the proposed prohibition will not affect the carriage of high sulphur oil as cargo. It only concerns fuel oil carried for use onboard ships. To date, the BIMCO paper has been positively received, and we are looking forward to present and discuss the subject at PPR 5.

To ensure proper implementation, a set of guidelines have to be developed: a global system to handle non-availability of fuel oil, fuel quality standards, verification and control mechanisms, updated bunker delivery note as well as guidance for sampling and testing methods.

Another issue to be discussed at PPR 5, is the development of guidelines for the discharge of exhaust gas recirculation (EGR) bleed-off water in order to reduce NOx output. IMO has already developed guidelines for scrubbers (reduction of SOx), which makes it possible to operate on normal heavy fuel oil within sulphur emission control areas.

MARPOL Annex II requirements that have an impact on cargo residues and disposal of tank washings will be reviewed. BIMCO recognizes that the problem can result in large lumps of congealed cargo residues on beaches.

PPR 5 have also been asked to clarify how to register the amount of chemicals used for tank washing. Many owners are dealing with this matter on a daily basis, hence a proper interpretation of the regulation is necessary.

In connection with the review of the voluntary measurements to collect data on Black Carbon (BC) emissions from ships – BIMCO, together with the rest of the industry, have asked for proper justification and cost benefit analysis on BC. We believe that shipping accounts for only a very small portion of the BC emission. Data has been submitted, which will be reviewed at the meeting. Some observers have requested IMO to strengthen the BC requirements even before an adequate amount of data has been submitted and properly analysed.

The IACS’ interpretation of the NOx Technical Code will be reviewed. The 2008 NOx Code entered into force on 1 January 2016, which among other things regulates the certification of the engine. There are two ways to certify an engine: one refers to approval at the engine test bed, whereas the other is when the engine is installed onboard. Several delegations have requested alignment between the two certification schemes, which will be difficult, as they cover two completely different scenarios.

The Ballast Water Management Convention is now in force, and PPR 5 has been tasked to address an update of the guidelines for ballast water sampling (G2). This is required in order to ensure that the indicative ballast water sampling on board ships is carried out by a competent and certified person, who has received proper training and certification from relevant equipment manufacturers. Furthermore, the indicative sampling kits deployed by port state approved service providers must be able to issue and print reports on board automatically not manually. This is important so as to avoid manipulation of data. The onboard generated reports must be stamped and signed by the sampling inspector and master before being sent to the port state authority.

PPR 5 will review two additional methodologies that may be used for counting the viable organisms in the ballast water. The analytical methods for determining the number cover the size class of 10 to 50 μm. PPR 5 aims to give guidance on the best available test methods to use in accordance with the Ballast Water Management Convention and Guidelines (G8).

This issue of sampling the fuel oil is also a subject of focus at PPR 5. Currently there are no provisions in MARPOL Annex VI, requiring ships to have dedicated point(s) for the purpose of taking on-board samples in order to verify the sulphur content of the fuel oil used on board ships. Fuel testing is not free, and by not having a dedicated sampling point, it will be more expensive and time-consuming for authorities to test in-use samples from ships. BIMCO therefore supports to establish dedicated sampling point(s) on board, as the proposal at hand seems to be a pragmatic solution both when it comes to existing ships and new buildings.

Along the line of the same subject, PPR 5 will also discuss the procedures used when the fuel samples subsequently are tested in the laboratory. There are already robust procedures in place, however a common methodology is needed to ensure the quality of the results.

A brief report on the outcome of the meeting will be published shortly after the meeting.

 

Jeppe Skovbakke Juhl
in Copenhagen, DK

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