Class and Statutory News

PPR 6 - 18 TO 22 FEBRUARY 2019 MAJOR OUTCOMES OF THE 6TH SESSION OF THE SUB-COMMITTEE FOR POLLUTION PREVENTION

Mar. 3 2019

PPR 6 - 18 TO 22 FEBRUARY 2019 MAJOR OUTCOMES OF THE 6TH SESSION OF THE SUB-COMMITTEE FOR POLLUTION PREVENTION

The main topic which PPR 6 addressed was the implementation of the Sulphur cap 2020.

PPR 6 agreed to the draft 2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL  Annex VI, for submission to MEPC 74, with a view to adoption, recalling that the draft MEPC circular on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, which had been approved by MEPC 73 as MEPC.1/Circ.878.

PPR 6 also agreed to the draft MEPC Circular 2019 guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships, as amended, for submission to MEPC 74, with a view to approval, and to the draft guidance for port State control on contingency measures for addressing non-compliant fuel oil with a view to considering possible concrete proposals, as a matter of urgency, at MEPC 74.

But PPR 6 made no progress on the revision of the 2015 EGCS Guidelines, even if this issue is very relevant owing to the 2020 deadline .

Some progress were accomplished concerning HFO carriage and balck carbon impact in  Arctic waters.

 

 

PPR 6 - 18 to 22 February 2019

major outcomes of the 6th session of the Sub-Committee for pollution prevention

 

 

 

 

The main topic which PPR 6 addressed was the implementation of the Sulphur cap 2020.

 

PPR 6 agreed to the draft 2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL  Annex VI, for submission to MEPC 74, with a view to adoption, recalling that the draft MEPC circular on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, which had been approved by MEPC 73 as MEPC.1/Circ.878.

 

PPR 6 also agreed to the draft MEPC Circular 2019 guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships, as amended, for submission to MEPC 74, with a view to approval, and to the draft guidance for port State control on contingency measures for addressing non-compliant fuel oil with a view to considering possible concrete proposals, as a matter of urgency, at MEPC 74.

 

PPR 6 made no progress on the revision of the 2015 EGCS Guidelines, despite a draft text being available in the annex to the CG report and a number of papers providing detailed proposals for changes to this draft.

 

Plenary tacitly agreed with the Chair’s proposal not to task the Air Pollution Working Group at PPR 6 to consider the Guidelines. The Sub-Committee also tacitly concurred with the Chair’s proposal not to re-establish the CG to progress the revision of the Guidelines. Of interest was the reason the Chair gave for not re-establishing the CG between PPR 6 and PPR 7 – the knowledge that the EU Member States have submitted a paper to MEPC 74 seeking to modify the scope of this output.

 

Hence, PPR 6 decided to forward the abovementioned comments to MEPC 74, and also the outcome of a report from Germany about exhaust from scrubbers in its harbors.

 

Notwithstanding this agreement, some delegations has drawn a parallel with BWM System and wonders if it is the most opportune message for PPR is to send 10 months before the deadline that there are uncertainties on open-loop scrubbers. With a risk to penalize the early movers.

 

PPR 6 agreed to :

  •     the draft amendments to regulations 1, 2, 14 and 18 and appendices I and VI of MARPOL Annex VI, for approval at MEPC 74, with a view to adoption at MEPC 75 (item 9) ;

  •     the draft modifications to the draft amendments to the IBC Code, to be considered and adopted together with the amendments to the IBC Code, by MEPC 74 and MSC 101 (item 3) ;

  •     draft amendments to chapter 1 of the IBC Code to make appropriate reference to the RO Code, for adoption together with the amendments to the IBC Code by MEPC 74 and MSC 101 (item 3);

  •     the draft amendment to annex 1 (Controls on anti-fouling systems) to the AFS Convention to include controls on cybutryne, for consideration by MEPC 74, with a view to approval (item 4)

  •     the draft amendment to the model form of the International Anti-fouling System Certificate, for consideration by MEPC 74, with a view to approval (item 4) 

 

PPR 6 also agreed to :

  •    the draft 2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL  Annex VI, for submission to MEPC 74, with a view to adoption (item 8) ;

  •     the draft MEPC Circular 2019 guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships, as amended, for submission to MEPC 74, with a view to approval (item 8) ;

  •     the draft joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 and for approval at MSC 101 (item 8) ;

  •     the draft 2019 Guidelines for port State control under MARPOL Annex VI, for submission to MEPC 74, with a view to adoption (item 8) ;

  •     the draft unified interpretation of regulation 13.2.2 of MARPOL Annex VI, , in relation to the time of the replacement or addition of an engine, with a view to replacing section 7 of MEPC.1/Circ.795/Rev.3on  Unified  interpretations to MARPOL Annex VI subject to the interpretation being approved by MEPC 74 (item 16) ;

  •     the draft revised unified interpretation of regulation 16.9 of MARPOL Annex VI, , with a view to replacing  section 9 of MEPC.1/Circ.795/Rev.3, subject to  the interpretation being approved by MEPC 74 (item 16) ;

  •     a draft unified interpretation to regulation 13.5.3 of MARPOL Annex VI, for inclusion in a revision of MEPC.1/Circ.795/Rev.3, subject to the interpretation being approved by MEPC 74 (item 16) ;

  •     the draft MEPC 1/Circ on Guidance on the implementation of provisional categorization of liquid substances in accordance with MARPOL Annex II and the IBC Code related to paraffin-like products, to be approved by MEPC 74 (item 3);

  •     draft MSC-MEPC circular containing the Revised guidelines for the carriage of blends of biofuels and MARPOL Annex I cargoes, for subsequent approval by MEPC 74 and MSC 101 (item 3);

  •     the draft revised MEPC.1/Circ 512/ Rev 1 on the Guidelines for the provisional assessment of liquid substances transported in bulk, with a view to subsequent approval by MEPC 74 (item 3);

  •     the draft revised PPR circular on Decisions with regard to the categorization and classification of products with a view to subsequent approval by MEPC 74 (item 3) 

PPR 6 concurred with :

  •     the evaluation of products and noted their respective inclusion in lists 1, 2, 3 and 5 of MEPC.2/Circ.24, with validity for all countries and with no expiry date (item 3); .

  •     the evaluation of cleaning additives and noted their inclusion in annex 10 to MEPC.2/Circ.24 (item 3) ;

  •     the assessment by ESPH 24 regarding the seven classes of alkanes as energy-rich fuels and noted their inclusion in the new annex 12 (Energy-rich fuels subject to Annex I of MARPOL) to MEPC.2/Circ.24 (item 3) 

PPR 6 also :

  •    noted the draft guidance for port State control on contingency measures for addressing non-compliant fuel oil with a view to considering possible concrete proposals, as a matter of urgency, at MEPC 74 (item 8) ;

  •     agreed to the finalized draft methodology for analysing impacts of a ban on heavy fuel oil for the use and carriage as fuel by ships in Arctic waters (item 12) ;

  •     requested the Secretariat to prepare a draft amendment to BWM.2/Circ.67, incorporating the link to the standard operating procedures (SOPs) for collection of treated ballast water samples, with a view to approval by MEPC 74 (item 4)

  

 

Item 3 - Safety and pollution hazards of chemicals and preparation of consequential amendments to the IBC code

 

Outcome of GESAMP/EHS 55

 

Regarding the development of a recommendation concerning cut-off values to be used when assessing mixtures, GESAMP/EHS 55 had been unable to finalize the development of recommended cut-off values due to time constraints, but had nonetheless developed text describing the procedure for assigning ratings to mixtures which would form the basis for developing a simplified recommendation at GESAMP/EHS 56.

Evaluation of products and cleaning additives

 

PPR 6 concurred with the evaluation of products and noted their respective inclusion in lists 1, 2, 3 and 5 of MEPC.2/Circ.24, with validity for all countries and with no expiry date.

 

PPR 6 also concurred with the evaluation of cleaning additives and noted their inclusion in annex 10 to MEPC.2/Circ.24, recalling that MEPC.2/Circ.24 had been published on 1 December 2018.

 

There was a need to update the Tank cleaning additives guidance and reporting form (MEPC.1/Circ.590) to provide clearer guidance on the types of products that could be submitted, as many of the cleaning products considered were for the cleaning of tanks carrying oil products, removal of cement products, or not intended for the cleaning of NLS tanks.

 

Consequently, PPR 6 concurred that a revision of MEPC.1/Circ.590 was needed, with expanded guidance on what can be considered as a cleaning additive for the cleaning of NLS cargo residues, and requested interested members to submit proposals to ESPH 25 for further consideration.

 

Revision of MEPC.1/Circ.512 and BLG.1/Circ.33, and the development of guidance for assessing and classifying complex chemical mixtures

 

PPR 5 had, following the finalization of the draft revised chapters 17, 18, 19 and 21 of  the IBC Code, instructed the ESPH Working Group to capture all relevant decisions in relation to the assignment of carriage requirements under the IBC Code by updating BLG.1/Circ.33 and MEPC.1/Circ.512.

 

ESPH 24 had developed the draft text for such guidance and included it as a new section 9 in the draft revised MEPC.1/Circ.512.

 

PPR 6 has instructed ESPH to finalize :

  •      the draft revised MEPC.1/Circ.512, including the guidance for the assessment of complex petrochemical mixtures, based on annex 4 to document PPR 6/3; and

  •      a draft PPR.1 circular on Decisions with regard to the categorization and classification of products.

 

Inclusion of energy-rich fuels in new annex 12 to MEPC.2/Circ.24 and consequential modifications and amendments required

 

MEPC 73 had approved the Guidelines for the carriage of energy-rich fuels and their blends (MEPC.1/Circ.879) and had endorsed the consequential inclusion of a new annex 12 to the MEPC.2/Circular on the Provisional categorization of liquid substances in accordance with MARPOL Annex II and the IBC code, for the purpose of listing substances that were deemed to be subject to MARPOL Annex I.

 

PPR 6 concurred with the assessment by ESPH 24 regarding the seven classes of alkanes as energy-rich fuels and noted their inclusion in the new annex 12 (Energy-rich fuels subject to Annex I of MARPOL) to MEPC.2/Circ.24.

 

Following the inclusion of the seven classes of alkanes in annex 12 to MEPC.2/Circ.24, consequential modifications to the draft revised chapter 17 of the IBC Code were necessary prior to its adoption by MEPC 74.

 

Similarly, consequential amendments to the 2011 Guidelines for the carriage of blends of petroleum oil and biofuels, as amended (MEPC.1/Circ.761/Rev.1) were also necessary.

 

PPR 6 has instructed ESPH to prepare the consequential modifications and amendments abovementioned.

 

Review of MEPC.2/circular – provisional classification of liquid substances transported in bulk and other related matters

 

ESPH 24 had reviewed a draft of MEPC.2/Circ.24 which had been finalized and disseminated in December 2018.

 

PPR 6 approved the draft MEPC 1/Circ on Guidance on the implementation of provisional categorization of liquid substances in accordance with MARPOL Annex II and the IBC Code related to paraffin-like products, to be approved by MEPC 74.

 

Modifications to the draft amendments to the IBC code

 

PPR 6 endorsed the draft modifications to the draft amendments to the IBC Code, to be considered and adopted together with the amendments to the IBC Code, by MEPC 74 and MSC 101.

 

MARPOL  Annex  II,  regulation  8.2.2  and  SOLAS  regulation XI-1/1 had recently been updated to make reference to the Code for Recognized Organizations (RO Code), whereas the IBC Code, which was subject to mandatory requirements under these two Conventions, had not been updated and therefore still referred to the Guidelines for the authorization of organizations acting on behalf of the Administration (A.739(18)), as amended by resolution MSC.208(81), and the Specifications on the survey and certification functions of recognized organizations acting on behalf of the Administration (A.789(19)).

 

This had resulted in inconsistent definitions of  "Recognized Organizations" between the IBC Code and the   MARPOL and SOLAS Conventions.

 

ESPH 24 had noted that, as a result of the addition of annex 12 to MEPC.2/Circ.24, consequential modifications to the draft revised chapters 17 and 19 of the IBC Code would need to be introduced prior to its adoption (i.e. deletion of the entries that had been included in annex 12 to MEPC.2/Circ.24, as well as deletion of their corresponding biofuel blend entries).

 

Taking into account the above considerations, PPR 6 prepared draft amendments to chapter 1 of the IBC Code to make appropriate reference to the RO Code, and amended chapters 17 and 19 by deleting a number of entries in the respective tables in these chapters. The full set of modifications to the amendments are to be considered and adopted together with the amendments to the IBC Code by MEPC 74 and MSC 101.

 

Chapter 1 – General

 

1   A new paragraph 1.3.30 is added as follows:

 

"1.3.30                Recognized organization is an organization authorized by an Administration in accordance with MARPOL Annex II regulation

8.2.2 and SOLAS regulation XI-1/1."

 

2   The existing paragraph 1.3.30 and subsequent paragraphs are renumbered as 1.3.31 to 1.3.39.

 

3   Paragraph 1.5.1.2 is replaced by the following:

 

"1.5.1.2               The recognized organization, referred to in 1.3.30, shall comply with the provisions of the SOLAS and MARPOL Conventions, and with the Code for recognized organizations (RO Code)."

 

Revision of the guidelines for the carriage of blends of petroleum oil and biofuels

 

PPR 6 endorsed the draft MSC-MEPC circular containing the Revised guidelines for the carriage of blends of biofuels and MARPOL Annex I cargoes, for subsequent approval by MEPC 74 and MSC 101.

 

A proposal to convert all references to "petroleum oil" to "MARPOL Annex I cargo", since the definition of the former term did not include the energy-rich fuels set out in annex 12 to the MEPC.2/Circular, was agreed.

 

PPR 6 agreed to delete the table listing the biofuel blends to avoid the need to update the circular whenever new blends were to be added or removed. Instead, reference would be made to the carriage requirements for the biofuel blends set out in either chapter 17 of the IBC Code or list 1 of the MEPC.2/Circular.

 

Revision of mepc.1/circ.512 – guidelines for the provisional assessment of liquid substances transported in bulk

 

PPR 6 concurred with the draft revised MEPC.1/Circ 512/ Rev 1 on the Guidelines for the provisional assessment of liquid substances transported in bulk, with a view to subsequent approval by MEPC 74.

 

Revision of BLG.1/circ.33 –decisions with regard to the categorization and classification of products

 

PPR 6 approved the draft revised PPR circular on Decisions with regard to the categorization and classification of products with a view to subsequent approval by MEPC 74.

 

Draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel

 

CCC 5 had agreed, in principle, to the draft Interim Guidelines for the safety of ships using methyl/ethyl alcohol as fuel. MSC 100 had endorsed the referral of the relevant parts of the draft Interim Guidelines identified by the Working Group on Amendments to the IGF Code and Development of Guidelines for Low-flashpoint Fuels to PPR 6, SDC 6, SSE 6 and HTW 6 for consideration and to advise CCC 6 accordingly.

 

PPR 6 considered and approved paragraph 5.3.2 of the draft Interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel.

 

 

 

Item 4 - Revised guidance on ballast water sampling and analysis

 

Following the approval by MEPC 72 of the Data gathering and analysis plan for the experience-building phase associated with the BWM Convention (BWM.2/Circ.67), PPR 5 considered document from ICES about the addition of an annex on analytical procedures for sampling and analysis to the data gathering and analysis plan for the experience-building phase

 

This document proposes standard operating procedures for the collection of treated ballast water samples for use by scientific researchers. These procedures are recommended for use by any research groups that will collect data on the biological efficacy of ballast water management systems, with a view to collecting comparable data that may be later pooled for analysis during the experience-building phase.

 

The Working Group on Ballast and Other Ship Vectors (WGBOSV) is a joint working group that follows and supports the work of its three umbrella organizations: the International Council for the Exploration of the Sea (ICES), the Intergovernmental Oceanographic Commission of UNESCO (IOC), and the International Maritime Organization (IMO).

 

WGBOSV met from 15 to 17 March 2017 to address six terms of reference, including "evaluate methods for collection and analysis of ballast water samples to inform national and/or international procedures for compliance testing of ballast water management systems". Following the meeting, a subset of WGBOSV members developed standard operating procedures (SOPs) for collection of treated ballast water samples using an inline sample port based on best available science, which could be used globally to ensure the data generated by multiple research groups interested in assessing the biological efficacy of ballast water management systems will be comparable.

 

PPR 6 agreed that, rather than including an annex in BWM.2/Circ.67 containing the SOPs, it was preferable to insert the link to the SOPs and subsequently requested the Secretariat to prepare a draft amendment to BWM.2/Circ.67, incorporating the link to the SOPs, with a view to approval by MEPC 74.

 

PPR 6 had also for its consideration the proposal from Denmark for the development of a methodology for verification of ballast water compliance monitoring systems and take action as appropriate.

 

There is currently no international (official) standard method for certifying indicative ballast water monitoring instruments for viable organisms ≥ 10 – 50 µm and organisms ≥ 50 µm.

 

Indicative methods provide an estimate of the viable organisms in ballast water samples much faster than laboratory-based analysis methods used for performance evaluation of BWMS in compliance with the relevant ballast water guidelines and standards.

 

Numerous methods for indicative and detailed analysis of ballast water for trial use in accordance with the Ballast Water Management Convention (BWM Convention) and Guidelines (G2) are mentioned in BWM.2/Circ.42, and more methods are under development

 

However, there are no international standard methods for certification of these indicative methods. A standard certification method would be useful for definition of minimum standards for indicative methods and instruments, and would furthermore provide a possibility for comparison of different measurement systems.

 

There was overwhelming support for the development of a standard for verification of ballast water compliance monitoring systems and several delegations expressed an interest in contributing to this work.

 

Hence, PPR 6 invited the delegation of Denmark and other interested delegations to submit a concrete proposal under the output "Urgent measures emanating from issues identified during the experience-building phase of the BWM Convention" at a future session of MEPC.

 

 

 

Item 6 – Amendment of annex 1 to the AFS convention to include controls on cybutryne, and consequential revision of relevant guidelines

 

The AFS   Convention   had   entered   into   force   on 17 September 2008 and that the number of Contracting Governments was currently 83, representing 95.95% of the world's merchant fleet tonnage.

 

MEPC 71 agreed to include a new output on "Consideration of the initial proposal to amend annex 1 to the AFS Convention to include controls on cybutryne" in PPR's biennial agenda for 2018-2019 and in the provisional agenda for PPR 5 with a target completion year of 2018.

 

PPR 5 agreed that a more detailed review of cybutryne was warranted. PPR 5 also recommended to the MEPC that the target completion year of the output be extended to 2020.

 

PPR 6 had for its consideration a comprehensive proposal to amend annex 1 to the AFS Convention and relevant supplementary information.

 

Evaluation of the association between cybutryne and related adverse effects observed in the environment or on human health

 

One delegation expressed the view that the adverse effects of cybutryne were observed only in specific locations, which might make controls at the local or regional level more appropriate than global controls under the AFS Convention. However, PPR 6 agreed that the adverse effects of cybutryne could be considered global, as demonstrated by modelling and monitoring studies, and that global controls would be better with a view to having in place consistent requirements applicable for all international shipping.

 

Reductions in the concentrations of cybutryne were recorded in areas where anti-fouling systems containing cybutryne had already been regionally banned and monitored. It was therefore agreed that commensurate reductions would be expected globally following the introduction of controls on cybutryne under the AFS Convention.

 

PPR 6 encouraged Member States to conduct such baseline studies prior to the entry into force of controls on cybutryne, in order to allow the subsequent determination of the effectiveness of these controls.

 

Consideration of specific control measures

 

PPR 6 agreed to the draft amendment to annex 1 (Controls on anti-fouling systems) to the AFS Convention to include controls on cybutryne, for consideration by MEPC 74, with a view to approval.

 

Ships should not apply or re-apply anti-fouling systems containing cybutryne from 3 October 2021 and should either not bear or seal such anti-fouling systems from 3 October 2026. This timeline would allow sufficient lead time for stakeholders and industry to prepare, including the development of appropriate sealer coats.

 

PPR 6 thus agreed that, following the evaluations and considerations already undertaken, it was clear that international controls pursuant to the AFS Convention were warranted for cybutryne.

 

Form of the International Anti-fouling System Certificate

 

PPR 6 agreed to the draft amendment to the model form of the International Anti-fouling System Certificate, for consideration by MEPC 74, with a view to approval.

 

In its current version, it was recognized that the IAFSC only referred to "an anti-fouling system controlled under annex 1", which would include cybutryne and any other harmful substances that might be controlled in the future. On the other hand, it was noted that the second to fourth compliance options on the IAFSC required the insertion of dates relating to controlled anti-fouling systems' application, removal or sealing, and that these dates could be different for organotin compounds and cybutryne in light of the respective controls.

 

Consequential revision of relevant guidelines

 

In addition to the amendment of annex 1 to the AFS Convention to include controls on cybutryne, this output also entailed the consequential revision of relevant guidelines. This included the Guidelines for brief sampling of anti-fouling systems on ships (resolution MEPC.104(49)), the 2010 Guidelines for survey and certification of anti-fouling systems on ships (resolution MEPC.195(61)) and the 2011 Guidelines for inspection of anti-fouling systems on ships (resolution MEPC.208(62)).

 

In addition, it was identified that the Revised guidance on best management practices for removal of anti-fouling coatings from ships, including TBT hull paints (AFS.3/Circ.3/Rev.1) might also have to be revised.

 

Therefore, PPR 6 invited proposals to PPR 7 on amendments to the Guidelines for brief sampling, survey and certification, and inspection of anti-fouling systems on ships (resolutions MEPC.104(49), MEPC.195(61) and MEPC.208(62),

 

Links to the Hong Kong Convention

 

Organotin compounds were included in the items to be listed in the Inventory of Hazardous Materials under the Hong Kong Convention and that this should also be the case for cybutryne when the respective controls entered into force.

 

 

 

Item 7 - Consideration of the impact on the Arctic of emissions of black carbon from international shipping

 

The work plan for consideration of the impact on the Arctic of emissions of Black Carbon from international shipping, entailed the following steps :

.1             develop a definition for Black Carbon emissions from international shipping

.2             consider measurement methods for Black Carbon

.3             investigate appropriate control measures  to  reduce  the  impact  of  Black Carbon emissions

 

MEPC 68 had approved the definition for Black Carbon emissions from international shipping (and PPR 5 had agreed to the Reporting protocol for voluntary measurement studies to collect Black Carbon data and identified the three most appropriate Black Carbon measurement methods for data collection. In addition, PPR 5 had established a Correspondence Group on Investigation of Appropriate Control Measures to Reduce the Impact on the Arctic of Black Carbon Emissions from International Shipping, to identify candidate control measures to reduce the impact on the Arctic of Black Carbon emissions.

 

These measures are :

1.    Fuel type

2.    Fuel treatment

3.    Exhaust gas treatment

4.    Engine and propulsion system design

5.    Ship design

6.    Operational measures

7.    Regulatory measures (use of current or new regulatory  measures  in MARPOL Annex VI)

8.    Other measures

 

PPR 6 agreed that it had completed the work with respect  to  all  the  terms  of  reference  given  by  MEPC  62  and  consequently  invited   the Committee to provide  instruction on  further work  on  the reduction of  the impact  on  the Arctic of Black Carbon emissions from international shipping, taking into account:

  •     the approval of the Bond et al. definition as the definition of Black Carbon for international shipping

  •     the agreed Reporting protocol for voluntary measurement studies to collect black carbon data

  •     the agreed Reporting protocol for voluntary measurement studies to collect black carbon data

  •     a compilation of candidate control measures to reduce the impact on the Artic of Black Carbon emissions from international shipping.

 

Noting the above, PPR 6 invited MEPC 74 to note that the work on this output had been completed.

 

However, further work may be required before any of the recommended Black Carbon measurement methods could be used to regulate or otherwise directly control Black Carbon emissions from marine engines or ships. A standardized sampling, conditioning and measurement protocol, should not preclude consideration and agreement on policy options to avoid or otherwise limit Black Carbon emissions from ships

 

 

 

Item 8 - Consistent implementation of regulation 14.1.3 OF MARPOL ANNEX VI

 

Guidance on the development of a ship implementation plan for the consistent implementation of the 0.5% sulphur limit under MARPOL Annex VI

 

It was recalled that the draft MEPC circular on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, which had been approved by MEPC 73 as MEPC.1/Circ.878.

 

Draft 2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI

 

PPR 6 agreed to the draft 2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL  Annex VI, for submission to MEPC 74, with a view to adoption.

 

PPR 5 had agreed to develop a single set of guidelines on "Consistent implementation of regulation 14.1.3 of MARPOL Annex VI".

 

The Intersessional Meeting on Consistent implementation of regulation 14.1.3 of MARPOL Annex VI agreed to develop a draft MEPC circular on guidance on ship implementation planning for 2020.

 

The ship implementation plan would not have a mandatory nature and would not need to be endorsed by the Administration.

 

The content of the guidelines address the following issues:

 

1           Introduction

1.1           Objective

2           Ship implementation planning for 2020

3           Impact on fuel and machinery systems

3.1           Distillate fuels

3.2           Distillate fuel with FAME content

3.3           Residual fuels

3.4           Key technical considerations for shipowners and operators

3.5           ISO Standard for residual fuels

3.6           Cylinder lubrication

4           Verification issues and control mechanism and actions

4.1           Survey and certification by Administrations

4.2           Control measures by port States

4.3           Control on fuel oil suppliers

4.4           Information sharing related to non-compliances under MARPOL Annex VI

5           Fuel oil non-availability

5.1           Guidance and information sharing on fuel oil non-availability

5.2           Standard format for reporting fuel oil non-availability

6           Possible safety implications relating to fuel oils meeting the 0.50% m/m sulphur limit

 

PPR 6 agreed the Fuel Oil Non-Availability Report (FONAR) as set out in the appendix 1 to the draft guidelines on consistent implementation of the 0.50% sulphur limit. It noted note that regulation 18.2.4 of MARPOL Annex VI does not provide for the FONAR to be reported to the port that has not provided the compliant fuel oil contrary to regulation 18.1 of MARPOL Annex VI, and that the port reception facility module in GISIS may provide a model to address this issue.

It must be recalled that an industry guidance document is being developed as part of a multi-stakeholder exercise to address the impact of new fuel blends or fuel types on fuel and machinery systems, and to provide guidance on the handling, storage and use of such fuels.

 

Good progress has been made by two sub-groups of experts from 16 organizations representing shipping, refining, fuel suppliers and standards organizations, as well as other interested parties. The joint industry group intends to consider options to use the guidance as a basis for developing training materials for the relevant stakeholders.

 

Draft guidance for port State control on contingency measures for addressing non-compliant fuel oil

 

Draft guidance for port State control on contingency measures for addressing non-compliant fuel oil had been prepared by the Secretariat based on BWM.2/Circ.62 on contingency measures under the BWM Convention.

 

PPR 6 noted the draft guidance for port State control on contingency measures for addressing non-compliant fuel oil with a view to considering possible concrete proposals, as a matter of urgency, at MEPC 74.

 

(…) The ship and the port State should consider the following as possible contingency measures:

.1             actions predetermined in the Ship implementation plan for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI (MEPC.1/Circ.878);

.2             discharging non-compliant fuel oil to another ship to be carried as cargo or to an appropriate shipboard or land-based reception facility, if practicable and available;

.3             managing the non-compliant fuel oil in accordance with a method acceptable to the port State; and

.4             operational actions, such as modifying sailing or bunkering schedules and/or retention of non-compliant fuel oil on board the ship. The port State and the ship should consider any safety issues and avoid possible undue delays.

(…)the non-compliant fuel oil may be discharged to the port or retained on board, as acceptable to the port State. Port State consideration may include environmental, safety, operational and logistical implications of allowing or disallowing the carriage of non-compliant fuel oil.

 

2019 guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships

 

PPR 6 agreed to the draft MEPC Circular 2019 guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships, as amended, for submission to MEPC 74, with a view to approval.

 

The in-use representative sample or samples should be obtained from a designated sampling point or points. The number and location of designated fuel oil sampling points should be confirmed by the Administration following consideration of possible fuel oil cross-contamination and service tank arrangements.

 

This circular will supersede MEPC.1/Circ.864.

 

Draft MSC-MEPC Circular on Delivery of compliant fuel oil by suppliers

 

PPR 6 agreed to the draft joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 and for approval at MSC 101.

 

It is not possible up to now for competent authorities to enforce regulation 18.3 of MARPOL Annex VI and that in making reference to the provision it should be clear what are the explicit obligations of a Party to MARPOL Annex VI and avoid making additional requirements.

 

(…) 3    A Party to MARPOL Annex VI is required to take all reasonable steps to promote the availability of fuel oils that comply with MARPOL Annex VI. Fuel oil for combustion purposes delivered to and used on board ships to which MARPOL Annex VI applies shall meet the requirements set out in regulation 18.3 of MARPOL Annex VI.

4           Pursuant to regulation 18.9 of MARPOL Annex VI, Parties undertake to ensure that appropriate authorities designated by them take action as appropriate against fuel oil suppliers that have been found to deliver fuel oil that does not comply with that stated on the bunker delivery note.

5           Members States should urge fuel oil suppliers to take into account the following guidance, as relevant:

·      MEPC.1/Circ.875 Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships.

·      MEPC.1/Circ.875/Add.1 Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.

6           Member States are invited to bring this guidance to the attention of Administrations, recognized organizations, port authorities, shipowners, ship operators, fuel oil suppliers, shippers/manufacturers and other parties concerned.(…)

 

 

Draft amendments to the 2009 Guidelines for port State control under the revised MARPOL Annex VI (resolution MEPC.181(59))

 

MEPC 73 had instructed PPR 6 to clarify the matter of the carriage ban on non-compliant fuel oil being not applicable when an alternative arrangement approved under regulation 4.1 of MARPOL Annex VI was used on board a ship as part of its ongoing work in updating the 2009 PSC Guidelines for port State control under the revised MARPOL Annex VI (resolution MEPC.181(59)).

 

PPR 6 agreed to  the draft 2019 Guidelines for port State control under MARPOL Annex VI, for submission to MEPC 74, with a view to adoption.

 

MEPC 73 had further approved, in principle, the draft amendments to the 2009 PSC Guidelines concerning the use of electronic record books under MARPOL, with a view to adoption at a future session in conjunction with other amendments to the 2009 Guidelines being developed by the PPR.

 

III 5 had invited PPR 6 to undertake a technical review of the draft amendments to the 2009 Guidelines, as prepared by III 5 and amendments to the 2009 PSC Guidelines related to exhaust gas cleaning systems, set out in document.

 

 

 

Item 9 - Amendments to regulation 14 of MARPOL Annex VI to require a dedicated sampling point for fuel oil

 

PPR 6 agreed to the draft amendments to regulations 1, 2, 14 and 18 and appendices I and VI of MARPOL Annex VI, for approval at MEPC 74, with a view to adoption at MEPC 75.

 

ISWG-AP1 included developped the following draft amendments to MARPOL Annex VI with an expected entry into force in summer 2021:

.1         definition of "Sulphur content" (amendments to regulation 2) referring to a specific version of ISO 8754 in a footnote ;

.2         testing and verification procedure of in-use fuel oil samples (amendments to regulation 14 and associated consequential amendments to regulation 18 and appendix VI).

 

Regulation 1 of MARPOL Annex VI

 

PPR 6 considered a need to make consequential amendments to regulation 1 of MARPOL Annex VI to reflect that the provisions for a ship to have a designated sampling point, as required in the draft amendments to regulation 14, would be phased in but would not be applicable to all ships.

 

The Sub-Committee identified that regulation 1 of MARPOL Annex VI could be amended to remove the reference to those specific regulations providing exemptions to certain provisions, so avoiding the need for the provision to be amended further as a consequence of possible future amendments to MARPOL Annex VI.

 

Regulation 2, 14.8 and 18.8.2

 

PPR 6 agreed to use the term "MARPOL delivered" for fuel oil delivered in accordance with regulation 18.8.1 of MARPOL Annex VI. It prepared an additional draft amendment to regulation 14.8 for onboard sampling of fuel oil not in-use by the ship.

 

Regulation 2

Definitions(…)

53            MARPOL delivered sample means the sample of fuel oil delivered in accordance with regulation 18.8.1 of MARPOL Annex VI.

54            MARPOL in-use sample means the sample of fuel oil in use on a ship.

55            MARPOL onboard sample means the sample of fuel oil intended to be used or carried for use on board that ship."

 

 

 

Item 10 - standards for shipboard gasification of waste systems and associated amendments to regulation 16 of MARPOL Annex VI

 

PPR 5 had established a Correspondence Group on Standards for Shipboard Gasification of Waste Systems and Associated Amendments to Regulation 16 of MARPOL Annex VI and had instructed it to further develop generic draft standards for shipboard gasification of waste systems and associated amendments to regulation 16 of MARPOL Annex VI and the IAPP Certificate.

 

It had been agreed that draft standards for shipboard gasification of waste systems should be generic and technology neutral and that amendments to regulation 16 of MARPOL Annex VI were not required as the regulation already accommodated alternative designs of shipboard thermal waste treatment devices. Similarly amendments to the IAPP Certificate were not necessary, as it contained specific reference to requirements under regulation 16.

 

Having noted that draft standards for shipboard gasification of waste systems had not yet been developed to a point where they could be presented as a draft IMO instrument, PPR 6 agreed to request MEPC 74 to retain the item on the biennial agenda of the PPR for the next year and invited interested Member Governments and international organizations to submit concrete proposals for draft standards.

 

 

 

Item 11 – Review of the 2015 Guidelines for exhaust gas cleaning systems (resolution MEPC.259 (68))

 

PPR 5 established the Correspondence Group on Exhaust Gas Cleaning Systems and was instructed to :

.1         further refine the 2015 Guidelines for exhaust gas cleaning systems (resolution MEPC.259(68)), including clarification of the terms "EGC system" and "EGC unit"; PAH (polycyclic aromatic hydrocarbons) monitoring; emission testing; approval of scrubbers in accordance with Schemes A   and B;

.2         develop specific guidance on accidental breakdown, instrument malfunction and  perceived  temporary  non-compliance  and  transient  performance   of EGCS;

.3         develop consequential amendments to the 2009 Guidelines for port State control under the revised MARPOL Annex VI (resolution MEPC.181(59));

 

The Correspondence Group was not able to resolve the following issues:

.1         the use of language of a mandatory nature in the SOX Emission Compliance Certificate ;

.2         the date of application of the new EGCS Guidelines ;

.3         definition of "12-hour period";

.4         definition of PAH ;

.5         the use of ultraviolet light for PAH measurement;

.6         the need to make measurements on the nitrate concentration of discharge water ;

.7         reference to US EPA 180.1

.8         discharge water monitoring data recording frequency

 

PPR 6 made no progress on the revision of the 2015 EGCS Guidelines, despite a draft text being available in the annex to the CG report and a number of papers (including one from IACS) providing detailed proposals for changes to this draft.

 

Plenary tacitly agreed with the Chair’s proposal not to task the Air Pollution Working Group at PPR 6 to consider the Guidelines. The Sub-Committee also tacitly concurred with the Chair’s proposal not to re-establish the CG to progress the revision of the Guidelines. Of interest was the reason the Chair gave for not re-establishing the CG between PPR 6 and PPR 7 – the knowledge that the EU Member States have submitted a paper to MEPC 74 (MEPC 74/14/1) seeking to modify the scope of this output.

 

Hence, PPR 6 decided to forward the abovementioned comments to MEPC 74, and also the outcome of a report from Germany about exhaust from scrubbers in its harbors.

 

Notwithstanding this agreement, Cook Islands has drawn a parallel with BWM System and wonders if it is the most opportune message for PPR is to send 10 months before the deadline that there are uncertainties on open-loop scrubbers. With a risk to penalize the early movers.

 

ICS also considered that it is unfortunate that this discussion is hold so late. CLIA recalled that huge investment on existing guidelines from IMO was achieved, and there should be no restrictive action without science evidence

 

IPIECA shared the same point of view than the one expressed by ICS but added some refinements. Owing to lack of up take in scrubber technology, the industry took a challenge through new products ‘formulation and new blended products, waiting for mid-2019 for the issuance by ISO whether fuels are compatible . Indeed, ISO indicated that 0.50% max sulphur fuel oils will be fully capable of being categorized within the existing ISO 8217 standard and that the publicly available specifications (PAS) under development expected to be published in 2019 will provide guidance as to the application of the existing ISO 8217 standard to such fuel oils. But people are still waiting 10 months before the deadline.

 

The Plenary has noted the concerns expressed. Plenary agreed to request to MEPC the extension of the completion date for this task to 2020 in the view to pursue the work at PPR 7, next year.

 

PPR 6 had for its consideration a report from its scientific body - GESAMP – which states the following

  •     "a generalized marine environmental risk assessment should be developed, at least for some model harbours";

  •      a generalized marine environmental risk assessment should be developed for the wider marine environment as vulnerable areas may well be found outside harbours in coastal areas as well as elsewhere;

  •      there should be a requirement to monitor the flow rates of washwater discharges throughout the periods of discharges. This will enable reliable estimations of the global volumes of washwater discharges and thus enable a reliable generalized marine environmental risk assessment as suggested above. 

A consensus was reached on the need of further studies.

 

It is worthy to underline that Japan has made a presentation gave on "washwater discharge from open-looped SOx scrubber system". One of the main outcome of this study is that "there would not be a scientific justification to prohibit the use of open-loop scrubber, as long as the IMO's discharge criteria were met".

 

 

 Item 12 - Development of measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in arctic waters

 

MEPC 71 had agreed to include a new output on "Development of measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters" in its 2018-2019  biennial  agenda.

 

MEPC 72 had approved the following scope of work for the PPR :

.1         develop a definition of heavy fuel oil (HFO) taking into account regulation 43 of MARPOL Annex I;

.2         prepare a set of guidelines on mitigation measures to reduce risks of use and carriage of HFO as fuel by ships in Arctic waters ;

.3         on the basis of an assessment of the impacts, develop a ban on HFO for use and carriage as fuel by ships in Arctic waters, on an appropriate timescale.

 

Development of a definition of HFO

 

PPR 6 took note of the following working definition of heavy fuel oil in Arctic waters :

 “Heavy fuel oil means fuel oils having a density at 15ºC higher than 900 kg/m3 or a kinematic viscosity at 50ºC higher than 180 mm2/s.”

 

Many delegations expressed the view that the definition of HFO agreed might need to be amended in light of the 2020 fuel oil sulphur limit. In this connection, it was agreed that submissions can be made to PPR at a future session on further refinement of the definition.

 

Draft Guidelines on mitigation of risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters

 

PPR 6 considered the development of draft guidelines on mitigation of risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters.

 

The Russian Federation proposed a number of potential measures to reduce the risks of use and carriage of heavy fuel oil (HFO) as fuel by ships in Arctic waters, including navigational measures, measures pertaining to ship operation, infrastructure and communications, emergency preparedness for oil spills and early spill detection as well as seafarers professional training.

 

The Russian Federation also informed on the work to preserve the Arctic marine environment carried out by the Arctic Council Member States within the Protection of the Arctic Marine Environment (PAME) Working Group. PAME, for example, following the AMSA recommendations, is carrying out a project on heavy fuels in the Arctic. In stage II of the project in 2013 a report was delivered on heavy fuels in the Arctic covering potential options to reduce the risk of pollution of the Arctic marine environment by ships using heavy fuels. In stage III of the project, the PAME Expert Group on shipping developed proposals to mitigate risks associated with the use and carriage of heavy fuels in the Arctic.

 

The guidelines would provide flag Administrations and ship operators with a comprehensive overview of existing measures, as well as potential new measures, when navigating in Arctic waters.

 

PPR 6 welcomed, in general, the proposed guidelines, but noted the need for further clarity by identifying links between the proposed guidelines and existing IMO instruments, notably the Polar Code as well as information on Particularly Sensitive Sea Areas (PSSAs), and the guidance developed by the Arctic Council's Working Groups on the Protection of the Arctic Marine Environment (PAME) and Emergency Prevention, Preparedness and Response (EPPR) and other ongoing initiatives.

 

PPR 6 noted the need for further clarity on whether the guidelines would mostly consist of a compilation of existing measures, or whether it would also identify other new measures.

 

The Sub-Committee recognized its limited competence in relation to some of the proposed topics, in particular those related to navigation measures, ship reporting and ship operations.

 

In view of the limited available time to review the full document, PPR 6 agreed to establish a Correspondence Group to work intersessionally to further develop the guidelines and to report to PPR 7

 

Methodology for an assessment of the impacts of a ban on HFO use and carriage as fuel by ships in Arctic waters

 

PPR 6 agreed to the finalized draft methodology for analysing impacts of a ban on heavy fuel oil for the use and carriage as fuel by ships in Arctic waters.

 

Germany and others proposed a methodology for assessing the impacts of a ban on HFO in Arctic waters, combining the approaches presented at MEPC 73 by United States and Finland.

 

Impact assessments should not be used to delay, but instead, to inform the development of policy options for measures to reduce impacts of the use and carriage as fuel of HFO by ships in Arctic waters. To this end, combined impact assessment methodology could be as follows :

 

Step 1: Defining the problem

Step 2: Defining policy objectives

Step 3: Development of policy options

Step 4: Analysis of impacts

Step 5: Comparison of policy options and recommendation of preferred option(s)

 

Canada is of the view that Arctic communities and economies will benefit from reduced risk of an HFO spill. However, Canada also notes that economic and social impacts to Arctic Indigenous communities and Arctic inhabitants of moving to more expensive diesel or alternative fuels are potentially significant and must be considered so as to avoid undesirable impacts on already vulnerable communities.

 

Existing impact assessments

 

Some delegations expressed the view that developing Guidelines on mitigation measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters should be done prior to considering a regulatory ban on HFO. Some other delegations expressed the view that the instructions from MEPC indicated that both measures should be developed in parallel.

 

PPR 6 decided that the documents it had for its consideration on this topic should be forwarded to PPR 7, recognizing that submitting States and organizations could submit additional information to meet the new impact assessment methodology for an assessment.

 

Develop a ban on HFO for use and carriage as fuel by ships in Arctic waters, on an appropriate timescale

 

PPR 6 considered that MARPOL Annex I would be the most appropriate instrument for a ban on HFO in Arctic waters

 

With regard to developing a ban on HFO for use and carriage as fuel by ships in Arctic waters, on an appropriate timescale, and on the basis of an assessment of the impacts, PPR 6 agreed that, in view of the fact that the impact assessment methodology had just been developed, the lack of impact assessments carried out in accordance with the finalized methodology, work on this matter would need to be deferred to PPR 7.

 

 

 

Item 13 - Review of the IBTS guidelines and amendments to the IOPP certificate and oil record book

 

PPR 5 had noted the support for the development of a set of consolidated Guidelines and had invited interested Member Governments and international organizations to work together intersessionally and submit a draft  of  the  consolidated  IBTS Guidelines and draft amendments to the IOPP Certificate and Oil Record Book to PPR 6, taking into account comments made with regard to proposals concerning discharge of clean drains and evaporation as a means of disposal of water in the sludge tank

 

With regard to the issue of evaporation, some delegations supported its deletion from the IBTS Guidelines as an acceptable means of disposal of water in the sludge tank, due to its negative impact to the environment. Conversely, other delegations supported the continued acceptance of evaporation as a means for such disposal, with the addition of appropriate controls and record-keeping provisions.

 

Taking note of the progress accomplished on the review of the IBTS guidelines, PPR 6 decided to establish a Correspondence Group to prepare a draft consolidated IBTS Guidelines and draft amendments to the IOPP Certificate and Oil Record Book.

 

 

Item 16 - unified interpretation to provisions of imo environment-related conventions

 

Unified Interpretation of regulation 13.2.2 of MARPOL Annex VI

 

PPR 6 agreed to the draft unified interpretation of regulation 13.2.2 of MARPOL Annex VI, , in relation to the time of the replacement or addition of an engine, with a view to replacing section 7 of MEPC.1/Circ.795/Rev.3on  Unified  interpretations to MARPOL Annex VI subject to the interpretation being approved by MEPC 74.

 

It had had for its consideration document PPR 6/16 (IACS), providing a copy of revision 1 of IACS Unified Interpretation (UI) MPC98, relating to the "time of the replacement or addition of the engine" for the applicable Tier standard in accordance with regulation 13.2.2 of MARPOL Annex VI.

 

IACS UI MPC98 (Rev.1) reflects the amendments to MARPOL Annex VI concerning the designation of the Baltic Sea and the North Sea Emission Control Areas for NOX Tier III control, which had been adopted by resolution MEPC.286(71). IACS had modified the text in the UI so further changes could be avoided if new NOX Tier III emission control areas were designated.

 

Reg 13.2.2 of MARPOL ANNEX VI reads :

 

For a major conversion involving the replacement of a marine diesel engine with a non-identical marine diesel engine or the installation of an additional marine diesel engine, the standards in this regulation in force at the time of the replacement or addition of the engine shall apply.

 

Interpretation

 

The "time of the replacement or addition" of the engine is to be taken as the date of:

a.              the contractual delivery date of the engine to the ship;* or

b.             in the absence of a contractual delivery date, the actual delivery date of the engine to the ship,* provided that the date is confirmed by a delivery receipt; or

c.              in the event the engine is fitted onboard and tested for its intended purpose on or after six (6) months from the date specified in sub-paragraphs of regulation 13.5.1.2, as appropriate, the actual date that the engine is tested onboard for its intended purpose applies in determining the standards in this regulation in force at the time of the replacement or addition of the engine.

 

Entry of the date in a), b) or c), provided the conditions associated with those dates apply, is to be made in the item 8.a "Major conversion – According to Reg. 13.2.1.1 &13.2.2" of the IAPPC Supplement.

 

If the engine is not tested within six (6) months after the date specified in sub-paragraphs of regulation 13.5.1.2, as appropriate due to unforeseen circumstances beyond the control of the shipowner, then the provisions of "unforeseen delay in delivery" may be considered by the Administration in a manner similar to MARPOL Annex I UI4. 

 

Unified Interpretations to facilitate the implementation of regulation 16.9 of MARPOL Annex VI

 

PPR 6 agreed to the draft revised unified interpretation of regulation 16.9 of MARPOL Annex VI, , with a view to replacing  section 9 of MEPC.1/Circ.795/Rev.3, subject to  the interpretation being approved by MEPC 74.

 

This UI seeks to :

·    clarify an inconsistency between regulation 16.9 of MARPOL Annex VI, which  requires  batch  loaded  incinerators  to   be   designed   so   that  the combustion chamber gas outlet temperature  reaches  600°C  within five minutes after start-up, and the corresponding provision in section 4.2 of the 2014 Standard specification for shipboard incinerators (resolution MEPC.244(66)) which refers to the temperature in the actual combustion space reaching 600°C within five minutes after start; and

·    provide a clear distinction between waste and sludge oil that is fed into continuous-feed type incinerators, unlike the existing corresponding unified interpretation in MEPC.1/Circ.795/Rev.3 which, according to Norway, inadvertently implies that waste also includes sludge oil and should also not specify a time limit of five minutes for reaching 850°C.

 

"Regulation 16.9 of MARPOL Annex VI reads:

 

For incinerators installed in accordance with the requirements of paragraph 6.1 of this regulation the combustion chamber gas outlet temperature shall be monitored at all times the unit is in operation. Where that incinerator is of the continuous-feed type, waste shall not be fed into the unit when the combustion chamber gas outlet temperature is below 850°C. Where that incinerator is of the batch loaded type, the unit shall be designed so that the combustion chamber gas outlet temperature shall reach 600°C within five minutes after start-up and will thereafter stabilize at a temperature not less than 850°C.

 

Interpretation

 

For the application of this regulation, the term "waste shall not be fed into the unit" should be interpreted as follows:

For continuous-feed incinerators solid waste shall not be fed into the unit when the combustion chamber flue gas outlet temperature is below 850°C. Sludge oil generated during normal operation of a ship should not be regarded as waste in connection with this regulation, and can be fed into the unit when the required preheat temperature of 650°C in the combustion chamber is achieved.

 

For the application of this regulation, the term "the unit shall be designed so that the combustion chamber gas outlet temperature shall reach 600°C within five minutes after start-up" should be interpreted as follows:

Batch loaded incinerator should be designed so that the temperature in the actual combustion space where the solid waste are combusted should reach 600°C within five minutes after start-up."

 

 

Unified Interpretations to facilitate the implementation of regulation 13.5.3 of MARPOL Annex VI - Clarification on engine changeover/on-off recording requirements

 

PPR 6 agreed a draft unified interpretation to regulation 13.5.3 of MARPOL Annex VI, for inclusion in a revision of MEPC.1/Circ.795/Rev.3, subject to the interpretation being approved by MEPC 74.

 

Amendments to regulation 13.5.3 of MARPOL Annex VI were adopted by resolution MEPC.271 (69), which entered into force on 1 September 2017. This regulation now states:

 

"The tier and on/off status of marine diesel engines installed on board a ship to which paragraph 5.1 of this regulation applies which are certified to both Tier II and Tier III or which are certified to Tier II only shall be recorded in such logbook as prescribed by the Administration at entry into and exit from an emission control area designated under paragraph 6 of this regulation, or when the on/off status changes within such an area, together with the date, time and position of the ship."

 

MEPC 68 discussed the following possible cases on the status of an engine at the time of a ship's entry into a NOX Emission Control Area (NECA) i.e.:

.1           Tier III compliant engines running or in stand-by mode (all engines necessary for safe ship operation, including all engines required  by  SOLAS regulation II-1/41; and all engines intended to be used for operational purposes inside the NECA);

.2           Tier II/Tier III compliant engines: Recording of switch over to the Tier III mode prior to entry into the NECA; and

.3           Tier II compliant engines stopped prior to entry into the NECA (e.g. Tier III non-compliant additional main or auxiliary engines not necessarily needed for safe ship operation and not needed whilst the ship operates in the NECA).

 

The following draft unified interpretation with respect to regulation 13.5.3 of MARPOL Annex VI was agreed :

 

Regulation 13.5.3 of MARPOL Annex VI reads:

 

The tier and on/off status of marine diesel engines installed on board a ship to which paragraph 5.1 of this regulation applies which are certified to both Tier II and Tier III or which are certified to Tier II only shall be recorded in such logbook as prescribed by the Administration at entry into and exit from an emission control area designated under paragraph 6 of this regulation, or when the on/off status changes within such an area, together with the date, time and position of the ship.

 

Interpretation

 

.1            "marine diesel engines installed on board a ship to which paragraph 5.1 of this regulation applies" includes additional or replaced engine* installed on or after the relevant emission control area takes effect;

 

*additional or replaced      engine:  refer to  section 7.1 of MEPC.1/Circ.795/Rev.3

 

.2            "certified to Tier II only" means a Tier II engine that is installed onboard a ship w ich is constructed on or after the emission control area where the ship is   operating   takes   effect   [or   replaced   engines   subject    to resolution MEPC.230(65)];

 

 

• Tier II engines stipulated under the Tier II requirement of regulation 13.4,i.e. Tier II engines installed onboard a ship constructed before the entry into force of the emission control area where the ship is operating, are not considered to be a "Tier II only" engine in the context of record keeping. Such exclusion is extended to Tier II engines replaced after the entry into force of the relevant emission control areas onboard ships of this category, if the replacement engines meet resolution MEPC.230(65);

 

.3 if an engine installed on a ship constructed before the entry into force of the emission control area where the ship is operating has undergone a major conversion as described in regulation 13.2.1, those engines are to be Tier III engines; thus the above interpretation in .1 above applies; and

 

.4 recording is required for the Tier II engine operation in a NECA under the exemption according to regulation 13.5.4.

 

 

 

 

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