Mapping the Polar Code

The idea of linking the operational envelope of different types of vessels to maps of suitable polar regions was considered, and abandoned, by the IMO member states debating the content of the Polar Code. 

“The variation, both geographically and annually, is so big that you have to consider the actual operation of a vessel case-by-case,” says Morten Mejlænder-Larsen, Discipline Leader for Arctic Operation and Technology at DNV GL. “It is very dangerous to make a map because an area could be totally ice-free one year and then the next it could have heavy ice. So you have to be conservative and have a ship designed for the actual conditions.”

Ships operating in the Arctic and Antarctic are exposed to a number of unique risks. Poor weather conditions and the relative lack of good charts, communication systems and other navigational aids pose challenges for mariners. The remoteness of the areas makes rescue or clean-up operations difficult and costly. Cold temperatures may reduce the effectiveness of numerous components of the ship, ranging from deck machinery and emergency equipment to sea suctions. When ice is present, it can impose additional loads on the hull, propulsion system and appendages.

Risk-Based Approach

A risk-based approach to regulation is well-established now at IMO and has been incorporated into the Polar Code. “It is a good way of identifying the risks you have for a particular operation compared to just using proscriptive general rules,” says Mejlænder-Larsen. “However, when you take a risk-based approach you need to have data about the actual area where you plan to operate, and you need to involve people with experience.”

A lack of people with relevant cold climate experience has been identified as a challenge when introducing the Polar Code, and Mejlænder-Larsen agrees that a hazard analysis is only as good as the people participating in it. “After a while the industry will get more experience with how to carry out the risk analysis. Success will depend on bringing in experts.” It is very important to bring in people who have experience on the actual vessel and know about the equipment on board, he says. 

In identifying the hazards, the shipping industry can draw from the experience of the offshore drilling industry, and shipping itself has gradually moved into colder areas. Only a few, such as FedNav and Royal Arctic Line, are already operating regularly in polar regions, but it is anticipated that the Arctic will open up gradually, and this will allow for valuable experience to be gained before activity expands into more heavily iced areas.

“For those experienced in Arctic operations, adhering to the Polar Code will not be a big step. They will have already implemented most of the requirements into their daily operations. For newcomers, it will definitely be a big step.” Mejlænder-Larsen has mapped DNV GL’s Winterization Notations against the Polar Code, and there are some minor gaps that will need to be filled, but a lot of the requirements are already in the Notations. Some requirements, such as the Polar Certificate for the vessel and the Polar Water Operations Manual, will remain Polar Code-specific.

A Positive Start

“The Polar Code as it stands now is a very positive start to protecting assets, people and the environment,” says Mejlænder-Larsen. “The minimum requirements set out in it will definitely exclude those operators that don’t have the experience.” Over time more detailed specifications of the requirements will be clarified, and guidelines will be added. 

One of the potential enhancements to the Polar Code is a ban on the use of heavy fuel oil. “It would be best to ban heavy fuel oil in polar regions from a risk perspective, but it is not practical to do that today,” says Mejlænder-Larsen. “One of the reasons for that is that Russia, for example, said an absolute ‘no’ to the idea. This would have prevented further progress on the development of the code. Russia has a lot of local shipping, so if suddenly, in 2017, the use of heavy fuel oil was stopped, all those vessels would stop. That would be a huge problem.”

Instead, a longer transition period is expected to be considered in the future as environmental organizations maintain pressure on the subject. “I think it is more important to get the code into force now in 2017 than to try to make it perfect because this work in IMO is very time-consuming,” adds Mejlænder-Larsen. “To achieve a consensus, you really have to be patient.”

IMO Secretary-General Koji Sekimizu has pushed the work forward, and he is determined to have it ready by 2016. The Polar Code was adopted during the 94th session of IMO’s Maritime Safety Committee (MSC) last November. Because it contains both safety and environment-related provisions, the Polar Code will be an add-on code mandatory under both SOLAS and MARPOL. 

Entry-Into-Force Dates

In October 2014, IMO’s Marine Environment Protection Committee (MEPC) approved the necessary draft amendments to make the environmental provisions in the Polar Code mandatory under MARPOL. The MEPC is expected to adopt the code and associated MARPOL amendments at its next session in May with an entry-into-force date to be aligned with the SOLAS amendments.   

The expected date of entry into force of the SOLAS amendments is January 1, 2017, and they will apply to new ships constructed after that date. Ships constructed before that date will be required to meet the relevant requirements of the Polar Code by the first intermediate or renewal survey, whichever occurs first, after January 1, 2018.