IMO PPR7 Moves on Arctic, Black Carbon and Washwater
The IMO Sub-Committee on Pollution Prevention and Response (PPR 7) met February 17-21 and moved a range of environmental protections forward including draft MARPOL amendments prohibiting the use and carriage for use as fuel of heavy fuel oil by ships in Arctic waters.
The draft amendments will be submitted to the Marine Environment Protection Committee (MEPC 76) (October 19-23, 2020) with a view to approval and circulation for adoption at MEPC 77 (spring 2021).
The prohibition would cover the use and carriage for use as fuel of oils having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s from July 1, 2024.
Ships engaged in securing the safety of ships, or in search and rescue operations, and ships dedicated to oil spill preparedness and response would be exempted. Ships which meet certain construction standards with regard to oil fuel tank protection would need to comply on and after July 1, 2029.
A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that Party's sovereignty or jurisdiction, up to July 1, 2029.
Currently, a MARPOL regulation prohibits the use or carriage of heavy grade oils on ships in the Antarctic, and under the Polar Code, ships are encouraged not to use or carry such oil in the Arctic.
PPR7 also moved forward on a range of other measures:
Implementation of the IMO 2020 sulfur limit - verifying sulfur content of fuel on board – guidelines agreed
IMO 2020, the 0.50 percent limit for sulfur in ships' fuel oil, has been in effect since January 1, 2020, and from March 1, 2020, the carriage ban on non-compliant fuel oil (except for ships with exhaust gas cleaning systems installed) will enter into force under MARPOL Annex VI.
To support enforcement, the Sub-Committee finalized draft guidelines which provide a recommended method for the sampling of liquid fuel oil. They will be forwarded to the next session of the Marine Environment Protection Committee (MEPC 75), which meets March 30 to April 3, 2020, with a view to adoption.
Revised guidelines on exhaust gas cleaning systems (scrubbers) agreed
The Sub-Committee finalized its work on revising the 2015 Guidelines for exhaust gas cleaning systems. The revision is aimed at enhancing the uniform application of the guidelines in light of recent technical developments and experience gathered from approvals and operation of the systems.
The Guidelines specify the criteria for the testing, survey, certification and verification of scrubbers under regulation 4 of MARPOL Annex VI to ensure that they provide effective equivalence to the sulfur oxide emission requirements of regulations 14.1 or 14.4 of MARPOL Annex VI. They cover continuous monitoring requirements and discharge water quality criteria, including minimum pH, maximum Polycyclic Aromatic Hydrocarbons (PAHs) concentration; provisions to minimize suspended particulate matter, including heavy metals and ash and to prevent discharge of nitrates beyond specified levels.
The Guidelines note that discharge water quality criteria should be reviewed in the future as more data becomes available. Guidance for voluntary discharge water data collection is included.
The Guidelines are expected to be applied to new scrubbers installed after a date to be decided. They will be submitted to MEPC 75 for adoption.
Discharges from scrubbers
The May 2019 session of the Marine Environment Protection Committee (MEPC) asked the PPR Sub-Committee to look into evaluating and harmonizing rules and guidance on the discharge of liquid effluents from scrubbers. To assist the discussions, a report from a task team established by the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) was submitted. The Sub-Committee agreed to recommend to the MEPC that should start a scope of work including risk assessment, impact assessment, guidance on delivery of scrubber residues to port reception facilities and the establishment of a database of substances.
Reducing the impact on the Arctic of Black Carbon emissions from international shipping
The IMO has been looking at how to measure and report on Black Carbon emissions, as part of its work to consider its impact on the Arctic. Black Carbon in the context of international shipping is the product of incomplete combustion of carbon-based fuels. A reporting protocol for voluntary measurement studies to collect Black Carbon data and Black Carbon measurement methods for data collection have already been agreed.
The Sub-Committee noted a number of submissions, including proposals to look at the aromatic content of blends of fuel oil. A high aromatic content, among other factors, could increase Black Carbon emissions from ships.
The International Standardization Organization (ISO) advised that it was already in the process of monitoring properties of very low sulfur fuel oil and high sulfur fuel oil and would provide feedback on their performance. ISO also advised that it would consider whether it was possible to add a further measure to provide an approximate indication as to whether a fuel is more paraffinic or aromatic, based on the characteristics already included in the ISO 8217 standard.
The Sub-Committee established a correspondence group to advance the development of a standardized sampling, conditioning and measurement protocol, including a traceable reference method and an uncertainty analysis, taking into account the three most appropriate Black Carbon measurement methods (light absorption filter smoke number (FSN); photo-acoustic spectroscopy (PAS); and laser induced incandescence (LII)), to make accurate and traceable (comparable) measurements of Black Carbon emissions.
Prohibiting cybutryne in anti-fouling systems
The Sub-Committee finalized a proposed amendment to the IMO Convention for the Control of Harmful Anti-fouling Systems on Ships (AFS Convention), to include controls on the biocide cybutryne. The draft amendment will be forwarded to MEPC 75 for approval, with a view to adoption at MEPC 76. The AFS Convention already prohibits the use of biocides using organotin compounds.
Review of the Biofouling Guidelines
The Sub-Committee began its review of the IMO Biofouling Guidelines. It identified key elements that require further attention and discussion, considered areas for potential revision of the Guidelines and established a correspondence group to progress the work ready for discussion at PPR 8.
Marine plastic litter – draft circulars agreed
The Sub-Committee prepared a draft MEPC circular on Provision of adequate facilities at ports and terminals for the reception of plastic waste from ships and a draft MEPC circular on Sharing of results from research on marine litter.
A correspondence group was established to consider how to amend MARPOL Annex V to enhance reporting of the accidental loss or discharge of fishing gear. This work is in the context of the IMO Action Plan to enhance existing regulations and introduce new supporting measures to reduce marine plastic litter from ships. The action plan was adopted by the MEPC in 2018.