Class and Statutory News

Summary report - IMO PPR 4

02.06.17

Convention : BWM Ballast Water Management, IBC Code , MARPOL Annex VI Air Pollution, OSV Chemical Code , Greenhouse Gases

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Ship type :ALL TYPES

PPR 4 – 16/20 january 2017 
insight of the major outcomes of the fourth session of the Sub-Committee on pollution prevention and response

The 4th session of the PPR sub-committee was held at the IMO Headquarters from 16 to 20 January 2017. 


PPR4 has agreed on the following decisions :

  • to the final draft of the revised chapter 21 of the IBC Code, for approval in principle by MEPC 71 and MSC 98 ; 
  • to the draft OSV Chemical Code and the associated draft Assembly resolution for its adoption, for approval by MSC 98 and MEPC 71, with a view to adoption by A 30 ; 
  • to the draft Guidance on methodologies that may be used for enumerating viable organisms, for approval by MEPC 71 and subsequent dissemination as a BWM circular ; 
  • to the updated version of the manual entitled "Ballast Water Management – How to do it", with a view to its finalization and approval by MEPC 71 ; 
  • to the draft Guidelines for the discharge of exhaust gas recirculation (EGR) bleed-off water, and requested the Secretariat to prepare the associated draft resolution, with a view to submission to MEPC 71 with a view to adoption ; 
  • to the draft 2017 Guidelines addressing additional aspects to the NOX Technical Code 2008 with regard to particular requirements related to marine diesel engines fitted with Selective Catalytic Reduction (SCR) Systems, and requested the Secretariat to prepare the associated draft MEPC resolution with a view to submission to MEPC 71, with a view to adoption.

Many topics, which have not been finalized both for questions of time and technical matters, will be again addressed at PPR5 :

  • guidelines for sampling of ballast water ; 
  • impact on the Arctic of emissions of Black Carbon ; 
  • standards for shipboard gasification waste to energy systems and associated amendments to regulation 16 of MARPOL Annex VI.

The coming Working Group on the Evaluation of Safety and Pollution Hazards (ESPH 23) will also have to handle many important issues on the request of PPR4 :

  • finalization of the revision of chapters 17 and 18 of the IBC Code ; 
  • procedures for the assessing of products classified under Annex I or Annex II of MARPOL; 
  • Review of MARPOL Annex II requirements that have an impact on cargo residues and tank washing of high viscosity and persistent floating products.

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

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

PPR customarily considers any issues related to the MEPC.2/Circular. 

PPR 4 concurred with the evaluation prepared by the Working Group on the Evaluation of Safety and Pollution Hazards (ESPH 22) and released as MEPC.2/Circ.22 on Provisional classification of liquid substances transported in bulk and other related matters, published in December 2016. 

41 tripartite agreements will expire in December 2017 and would be deleted from the MEPC.2/Circular. PPR4 has invited delegations to advise their industry counterparts to take action accordingly, to avoid any delay in the carriage of these products beyond their expiry dates 

If new GESAMP Hazard Profiles were required for any of these products or their components, they would need to be submitted to GESAMP/EHS 54 which is scheduled to take place from 22 to 26 May 2017. 

Revision of the IBC Code – Chapters 17, 18 and 21 

PPR4 has agreed to the final draft of the revised chapter 21 of the IBC Code, approval in principle by MEPC 71 and MSC 98, pending finalization of the revision of chapters 17 and 18 of the Code, at the same time recognizing future amendments may be needed to other areas of the IBC Code, notably to special requirement 15.12. 

Revised chapter 21 is expected to enter into force on 1 July 2020. ESPH 23 will continue work on Chapters 17 and 18 to reflect the revised Chapter 21 requirements. 

Draft changes to toxicity ratings and how to deal with products that produce low concentrations of, or no vapour raised great concern. The problem of any undue administrative burden related to an anticipated high number of exemptions required for toxic vapour detection equipment being not available was addressed and PPR 4 invited proposals to ESPH 23 on this issue. 

Requirements for products toxic by inhalation, rather than by oral or dermal routes (methyl alcohol for instance) was discussed. 

Chapter 21 sets out the criteria for assigning carriage requirements for products subject to the IBC Code. A point was raised about section 21.5.5 of the criteria (special requirement 15.12 – Toxic Products) and its applicability to the product Methyl alcohol. 

The Group considered other options for considering modified carriage requirements for methyl alcohol, having generally agreed that the assignment of special requirement 15.12, based on the scientific evidence cited by some delegations, may be too stringent Although the Group agreed in principle to a revision of the carriage requirements for methyl alcohol, it nonetheless requested delegations to submit documents providing an appropriate justification 

PPR4 invited more documentation to be submitted to ESPH 23. 


Development of minimum carriage requirements for contaminated bulk liquids carried on OSVs 

PPR4 agreed to two new entries in list 1 of the MEPC.2/Circular for eventual inclusion in chapter 17 of the IBC Code and associated carriage requirements for contaminated bulk liquids from offshore installations 

A draft guidance have been also refined for selecting the appropriate chapter 17, for inclusion directly in the OSV Code. 

The text for inclusion in chapter 15 of the OSV Code is included at annex 3 and the new entries for inclusion in chapter 17 of the IBC Code and consequential amendments to the special requirements as a new section 15.15 in the Code are set out in annex 4. 


Revision of the guidelines for the provisional assessment of liquid substances transported in bulk (MEPC.1/Circ.512) 

PPR 4 discussed extensively the assignment of ship types based on the mixture calculation for mixtures with a safety hazard. It has noted the progress made on the revision of the Guidelines for the provisional assessment of liquid substances transported in bulk (MEPC.1/Circ.512). 

It agreed to work intersessionally on further revising the circular, with a view to arriving at a clearer description of the process for assigning ship type, in the view to be in a position to finalize and reach agreement on the draft revised circular at ESPH 23, for endorsement by PPR 5 and approval by MEPC 73. 


Guidance/procedures for the assessing of products classified under Annex I or Annex II of MARPOL 

PPR4 considered a proposal for the development of guidance for the assessment of Annex II products that could be considered as Annex I complex petroleum/hydrocarbon or petroleum-like mixtures, to ensure that products were shipped under the correct Annex of MARPOL. 

It agreed on a number of issues at that session that should be addressed in the guidance, notably, to incorporate additional criteria related to "reproducibility" to be used to differentiate between the mixtures covered by MARPOL Annexes I and II. 

It concurred that any criteria developed should only be applied to new products and that existing products would not be reviewed against any of the new agreed criteria, unless a formal submission was made to IMO for these products to be re-assessed. 

PPR 4 agreed for ESPH 23 to proceed with assessing the process that would be followed by the ESPH Working Group for determining whether products should be covered by MARPOL Annex I or II. This process should be addressed in a PPR circular, whilst the more general information on the rationale and assessment for the purposes of establishing tripartite agreements under MARPOL Annex II for such products could be addressed in a MEPC circular. 


Item 4 – Review of MARPOL Annex II requirements that have an impact on cargo residues and tank washing of high viscosity and persistent floating products 

MEPC 68 instructed PPR 3 to review Annex II of MARPOL and the IBC Code with regards to the discharge requirements relating to the cleaning and discharging of tank washings containing high viscosity, solidifying and persistent floating products to reduce the impact to the environment. 

Discussions at PPR 3 included the revision of the definition of high-viscosity cargoes to widen its application, increased tank pre-washing and use of shore reception facilities. 

PPR 4 has continued its work on this agenda item. The target completion date of this item is 2018. 

PPR4 noted the progress in developing amendments to MARPOL Annex II and consequential amendments to the IBC Code. 

The lack of port reception facilities for the discharge of tank washings for the groups of products under review remains an ongoing concern, with many delegations emphasizing that this issue would need to be carefully considered and addressed in the development of any new amendments to regulation 13 of MARPOL Annex II. 

Thus, the most practical way forward would be the identification of a geographical region of application, based on the known area of impact, and the establishment of a provisional list of products, or groupings of products, based on those substances that were known to have been discharged and had resulted in the impacts on beaches in the North Sea and Baltic Sea coastal States, as well as in the North Atlantic and in Ireland. 

PPR4 concurred with the following draft amendments :

  • the inclusion of a definition for persistent floaters in MARPOL Annex II ; 
  • the principle of an amendment of regulation 13.7 with regard to the requirements for the discharge of residues of category Y ; 
  • a means of identifying a group of persistent floaters for which a prewash would be required in the IBC Code, agreeing in principle to the development of a new special requirement in chapter 16 of the Code.

PPR 4 prepared draft amendments for further work at the ESPH 23. ESPH 23 is also tasked to consider various options for the phasing in of the requirement based on geographical and product specific criteria. 


Item 5 - Code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk on offshore support vessels 

PPR has been working to update resolution A.673(16) to take into account the need for larger quantities of hazardous and noxious liquid substances to be carried on board OSVs. PPR 3 re-established the Correspondence Group on the development of the OSV Chemical Code, under the coordination of Denmark, and instructed it to finalize the text of the draft OSV Chemical Code. PPR4 was invited to continue its work. 

PPR4 agreed to the draft OSV Chemical Code and the associated draft Assembly resolution for its adoption, for approval by MSC 98 and MEPC 71, with a view to adoption by A 30. 

It noted the view of a majority of delegations that the OSV Chemical Code should be made mandatory in the future, and encourage interested Member States to submit proposals for a relevant new output to the Committees after the adoption of the Code by the Assembly. 

For the time being, all mandatory language used in the draft OSV Chemical Code have been replaced with non-mandatory terms unless there was a direct quotation of the Convention or mandatory code. 

Scope 

This code should apply to OSVs engaged in the carriage of the products subject to the Code, regardless of size or voyage. 

This new code has been developed to meet the growing needs of the OSV industry in terms of transported quantity as well as type of cargoes. To follow the evolution of this industry, the new code has removed any limitation of the amount or type of product to be transported. The tentative date of entry into force is 1 July 2018 

Existing OSVs may be permitted to carry products identified as requiring Ship Type 2 carriage requirements in the IBC Code, provided that they comply with the requirements of the OSV Chemical Code except for the stability requirements (chapter 2), and subject to the satisfaction of the Administration. 

Products 

Products which may be carried subject to the Code are:

  • only those offshore related products which are listed in chapters 17 or 18 of the IBC Code and the latest edition of the MEPC.2/Circular and their related references to chapters 15 and 19 of the IBC Code; 
  • oil-based/water-based mud containing mixtures of products listed in chapters 17 and 18 of the IBC Code and the MEPC.2/Circular; 
  • liquid carbon dioxide (high purity and reclaimed quality) and liquid nitrogen; 
  • contaminated backloads.


Life-saving appliance 

The life-saving requirements for chemical tankers of SOLAS chapter III should apply to vessels carrying more than 1,200 m3 of cargoes with a flashpoint not exceeding 60°C or carrying cargoes emitting toxic vapours or gasses. 

Backloading of contaminated bulk liquids 

Two generic entries for contaminated bulk liquids from oil rigs for use with the new OSV Chemical Code have been generated (cf.item 3 above). Requirements for existing OSV have been included in Chapter 15. 

Portable tanks on board 

These tanks should be secured to the deck. Chemicals, including blending additives, transported in portable deck tanks outside the scope of the Code may be carried in limited amounts on OSVs in accordance with requirements acceptable to the Administration, taking into account of the requirement contained in paragraph 1.2.3 of resolution A.673(16). 


Item 6 - Guidelines for sampling of ballast water (G2) 

IMarEST proposed amendments to the Guidelines on ballast water sampling (G2) (resolution MEPC.173(58)) to incorporate a standard sample port. 

Whilst this proposal was supported in principle by some delegations, concerns were expressed regarding the consequences of introducing prescriptive shipboard arrangements, the suitability of standardized sampling ports for all ships and ballast water management systems (BWMS) and other details of the proposal. 

Some delegations expressed the view that there was no need to revise the Guidelines (G2) and that an ISO standard might be more appropriate to address the issue (ISO informed PPR4 of its ongoing work in revising the Ballast Water Sampling Standard ISO 11711-1). 

PPR4 invited IMarEST to work with interested delegations to refine its proposal and submit a new proposal to PPR 5. 


Extension of target completion date 

PPR4 called for proposals related to ballast water sampling, analysis and contingency measures to future sessions. 

In view of the forthcoming entry into force of the BWM Convention, PPR4 agreed to invite MEPC 71 to extend the target completion date for this output to 2019. 


Unified Interpretation for implementing regulation B-4 (Ballast water exchange) 

Noting imminent entry into force of the BWM convention, two member States expressed their intent to submit an Unified Interpretation on this issue to MEPC 71 


Item 7 - Review of the guidelines for approval of ballast water management systems (G8) 

Determination of viability of organisms 

The text of the 2016 Guidelines for approval of ballast water management systems (G8), adopted by MEPC 70, contains the following statement relevant to the consideration of viability assessment methods :

  • "4.6 The viability of organisms should be determined using a method that has been accepted by the Organization as appropriate to the ballast water treatment technology being tested. (…) Viability may be established by assessing the presence of one or more essential characteristics of life, such as structural integrity, metabolism, reproduction, motility, or response to stimuli."


PPR4 agreed to the draft Guidance on methodologies that may be used for enumerating viable organisms, for approval by MEPC 71 and subsequent dissemination as a BWM circular. 

The purpose of this guidance is to provide information on methodologies used for enumerating viable organisms during the type approval of ballast water management systems, in order to verify that they meet the ballast water performance standard described in regulation D-2 of the BWM Convention. 

This guidance encompasses a list of methodologies that may be used to enumerate viable organisms. 

guidance


This guidance remains open for addition of new methodologies as new or revised methodologies become available. 


Item 8 - Production of a manual entitled "Ballast Water Management – How to do it" 

PPR4 agreed to the updated version of the manual entitled "Ballast Water Management – How to do it", with a view to its finalization and approval by MEPC 71. 

The parts of the Manual corresponding to exceptions, exemptions and the review of Guidelines (G8), regulation B-3 (Ballast water management for ships) have been finalized. 

However, with regard to the experience building phase and trial period for sampling and analysis, and contingency measures, respectively, MEPC 71 is expected to consider the report of the coming Correspondence Group, as well as submissions on contingency measures. Hence, it would be more efficient to finalize these sections at MEPC 71. 


Item 9 - Consideration of the impact on the Arctic of emissions of Black Carbon from international shipping 

MEPC 62 agreed to a work plan to consider the impact on the Arctic of Black Carbon (BC) emissions from international shipping. Consecutive sessions of the Sub-Committee carried out this work by developing a definition of BC under consideration of applicable measurement methods as a first step. 


PPR3, having discussed this matter in the working group, agreed on a proposed measurement/reporting template and protocol for testing. MEPC 70 noted also the need for voluntary measurement studies to collect data and to gain in this way experiences with the application of the definition and the related measurement methods. 

The majority of delegations at PPR4 supported the continuation of measurement studies in order to collect more data on marine BC that would allow PPR5 to take decisions on measurement methods. 

Considering that the measurement method has not yet been finalized, a correspondence group will be established with a view to finalization of the draft measurement reporting protocol at PPR 5. 

Some delegations were in favor of initiating without delay the consideration of control measures, i.e. the final step in the MEPC 62 plan for consideration of BC emissions. It was considered as premature at this stage, but PPR4 Invited members to submit information on potential control measures to reduce the impact of BC to PPR 5. 

As the BC issue is pending from MEPC62, PPR4 agreed to recommend to the MEPC a revised target completion date of 2019. 


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

PPR 4 was invited to continue its work, with a view to finalizing the draft Standards for shipboard gasification waste to energy systems and associated amendments to regulation 16 of MARPOL Annex VI, taking into account the report of the correspondence group, as well as the outcome of MEPC 70. 

PPR4 considered that the draft Standards needed to be restructured and both the draft Standards and regulation 16 of MARPOL Annex VI needed to be technology neutral. Furthermore, consequential amendments may be required to other provisions under MARPOL Annex VI, for example, the IAPP Certificate.

Owing to time constraints, the Working Group could not finalize draft Standards. 

With a view to further development of these standards, PPR4 has decided to establish a correspondence group which should report to PPR5. 

Consequently, PPR will recommend to the MEPC a revised target completion date of 2019. 


Item 11 - Guidelines for the discharge of exhaust gas recirculation bleed-off water 

MEPC 68 briefly discussed the possible discharge guideline of such bleed-off water. The proposal put forward was to use MARPOL Annex I (for oil) until the 2009 Guidelines for exhaust gas cleaning systems-EGCS (Resolution MEPC.184(59)) for acidity. 

The main discussion points at PPR 3 wer the following ones :

  • EGR could be used for a Tier II engine, in addition to Tier III. 
  • EGR bleed-off water should be considered depending on the use of fuel oil complying or not complying with the sulphur limit value in regulation 14.4


PPR 4 had to review the outcome of the correspondence group which prepared draft guidelines. It considered that bleed-off water should be treated as MARPOL Annex VI wastes. 

Finally, PPR4 agreed to the draft Guidelines for the discharge of exhaust gas recirculation (EGR) bleed-off water, and requested the Secretariat to prepare the associated draft resolution, with a view to submission to MEPC 71 with a view to adoption. 

The guidelines address the following :

  • Purpose - Application - Definitions 
  • Discharge of EGR bleed-off water to the sea
    • Bleed-off water when using fuel oil not complying with the relevant limit value in regulation 14 of MARPOL Annex VI 
    • Bleed-off water when using fuel oil complying with the relevant limit value in regulation 14 of Marpol Annex VI
  • Residues from EGR water treatment systems 
  • Bleed-off water additives 
  • Survey and certification


Item 17 – Revision of the 2011 SCR Guidelines 

A set of IACS Unified Interpretations were submitted to PPR 3 with regard to the “scheme B” certification of marine engine (testing engines and SCRs separately). PPR 3 and subsequently MEPC 70 agreed that the work on this topic should be done as a revision to the 2011 Guidelines addressing additional aspects to the NOX Technical Code 2008 with regard to particular provisions related to marine diesel engines fitted with Selective Catalytic Reduction (SCR) Systems (resolution MEPC.198(62), as amended by resolution MEPC.260(68)), rather than developing a set of Unified Interpretations. 

PPR4 agreed to the draft 2017 Guidelines addressing additional aspects to the NOX Technical Code 2008, and requested the Secretariat to prepare the associated draft MEPC resolution with a view to submission to MEPC 71, with a view to adoption. 

According to some delegations, there currently exist a number of problems related to engine + SCR certification, including testing requirements that hamper a level playing field in the market, and raise the costs of SCR installations. Scheme B of the Guidelines contains unnecessary complications and that some modifications to the Guidelines are needed. 

PPR4 estimated that Scheme A and Scheme B should be made equally applicable and that amendments to the NOx Technical Code 2008 are required. It agreed to the justification to revise the output, including the output title to "Revision of certification requirements for SCR systems under the NOx Technical Code 2008", and has recommended approval of the revised output by MEPC 71. 

In addition, various clarifications were made to the content of the NOx technical file, selection of parent engines was clarified and onboard confirmation testing was also revised. 


Item 20 - Development of guidelines for the use of more than one Engine Operational Profile (Map) 

Since the application of electronic engine management systems, engine designers have been significantly freed from the traditional physical constraints imposed by a mechanical systems whereby, in terms of fuel injection, the profile of the fuel cam and the fuel pump control edges principally defined performance. 

At MEPC 69, Norway proposed a new output to develop guidelines to allow the use of more than one engine operational profile (Map) for the purpose of engine certification. EUROMOT noted that the use of more than one Map is a prohibited "irrational emission control strategy" pursuant to the NOX Technical Code (NTC) and the United States similarly considered that such a revision should not be allowed. 

But some delegations expressed the view that some engines are already using more than one Map and the matter should be discussed further. 

PPR4 recommends to the MEPC that the use of multiple engine operational profiles (maps) for marine diesel engines certified under MARPOL Annex VI and NOx Technical Code should be taken forward as a new output. 

The output should address whether multiple maps are allowed under the provisions of MARPOL Annex VI and the NOx Technical Code including questions on switching, and the frequency of switching, of maps, and that consideration needed to be given as to whether, in addition to the development of guidelines, amendments to MARPOL Annex VI and the NOx Technical Code are required. 

PPR4 invite the MEPC to develop a plan for the work to be carried out with a view to completion by 2019 and consider that intersessional work is required to complete the work in a timely and expeditious manner. 


Item 20 - Consistent implementation of the 0.50% sulphur limit under regulation 14.1.3 of MARPOL Annex VI 

MEPC 70 decided that the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI shall become effective on 1 January 2020. In addition, MEPC 70, in recognizing the concerns expressed regarding implementation, agreed to forward relevant comments made in plenary to PPR 4, for further consideration and to draft a justification and scope for a new output on what additional measures may be developed to promote consistent implementation of the 0.50% global sulphur limit, for consideration at MEPC 71. 

PPR 4 prepared the justification for a new output on consistent implementation of the 0.50% global sulphur limit and the scope for the new output to be added to the biennal agenda of the sub-committee.