IMO may approve prohibition on the carriage of non-compliant fuel oil in 2020

Overview

The International Maritime Organization (IMO) Marine Environment Protection Committee (MEPC 72) will meet next week, where a prohibition on the carriage of non-compliant fuel oil with a sulphur content exceeding 0.50% is on the agenda.

BIMCO’s Maritime Technology and Regulation department will attend the 72nd session of the IMO’s Marine Environment Protection Committee (MEPC 72), which will be held from 9 to 13 April 2018 in London.

The agenda for MEPC 72 is comprehensive and the following important items should be highlighted:

Amendments to mandatory instruments

At this session, MEPC will be asked to adopt the following amendments to MARPOL

  • Proposed amendments of the Ballast Water Management (BWM) Convention concerning the implementation schedule of ballast water management for ships
  • Proposed amendments to the regulation D-3 of the BWM Convention to make the 2016 Guidelines for Approval of BWM systems (G8) mandatory
  • Proposed amendments of the BWM Convention concerning endorsements of additional surveys on the BWM Certificate
  • Proposed amendments on the required EEDI for ro-ro cargo and ro-ro passenger ships. These ship types have previously not formed part of the EEDI framework
  • The International Bulk Chemical Code (IBC Code) and the Code for the Construction Equipment of Ships Carrying Dangerous Chemicals in Bulk (BCH Code) have to be amended to confirm that any specific loading condition complies with damage stability requirements. These amendments highlight the necessity of an approved stability manual.

Note, the BCH code is applicable to the chemical tankers built before 1 July 1986. The IBC code is applicable to the chemical tankers built after 1 July 1986.

If adopted by MEPC 72, the amendments are expected to enter into force on 1 January 2020.

Ballast water management (BWM)

MEPC 72 will discuss and possibly adopt the draft amendments to the BWM Convention in order to be ready before the convention enters into force on 8 September 2018. 

The scope of application is still an issue. Also, the surveys and certificates as well as matters related to retrofitting deadlines are up for discussion during the meeting.

Another issue to be discussed is the guidance on the BWM Convention’s measures related to contingency planning for ballast water management in ports, ballast water exchange using water treated by various BWM systems, as well as contingency measures related to reception facilities. There is also the question as to when the BWM Plan should be revised and approved to address potential contingency plan issues.

Reduction of GHG emissions from ships

At MEPC 70 the decision was taken to establish an Intersessional Working Group on Reduction on Green House Gases (ISWG-GHG) emissions from ships, with the aim of developing a comprehensive IMO strategy for the reduction of CO2 emissions by the international shipping. According to the workplan, the initial strategy will be finalised at MEPC 72 in 2018.

During the meeting, the Committee will consider the reports of the second and third meetings of the ISWG-GHG as well as the relevant outcome of the United Nations Framework Convention on Climate Change (UNFCCC) meetings in order to finalize the initial strategy.

The third ISWG-GHG takes place during this week (the week before MECP 72). The outcome is currently still unknown as the report from the working group only will be available on Friday 6 April 2018.

MEPC 72 will focus on the short-, mid- and long-term measures as proposed during the ISWG-GHG meetings.

Prohibition on the carriage of fuel oil exceeding 0.50% sulphur

At the fifth meeting of the Sub-Committee on Pollution Prevention and Response (PPR 5) in February 2018, one of the most important tasks was to discuss the issue of consistent implementation of regulation 14.1.3 of MARPOL Annex VI dealing with the 0,50% m/m global sulphur limit, as previously decided by IMO.

BIMCO and other industry organisations, proposed a prohibition on the carriage of fuel oil exceeding 0.50% m/m sulphur, which is intended for use as bunker. It was at the same time recognised and made explicit that the proposed prohibition on the carriage of non-compliant fuel oil should not affect the carriage of high sulphur oil as cargoes.

The issue of timing is of great concern as ship operators need sufficient time to prepare prior to 1 January 2020, which is the effective implementation date of the global 0.50% m/m sulphur cap. For this reason, BIMCO and the other industry organisations proposed to speed up the process by allowing an intersessional working group to report directly to MEPC 73 and in doing so, gain 7 months to prepare for the new regulation.

Thus, MEPC 72 will consider the draft amendments to MARPOL Annex VI for a prohibition on the carriage of non-compliant fuel oil for combustion purpose with a sulphur content exceeding 0.50%, with a view to adoption at MEPC 73.

Measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters

A range of proposals will be considered when developing measures to reduce risks of use and carriage of Heavy Fuel Oil (HFO) as fuel by ships in the Arctic as defined in the Polar Code. A ban on HFO is already in place in the Antarctic.

The papers submitted to MEPC 72 propose a number of different measurers including ship design and equipment for both new and existing ships, operating constraints, and restricting or phasing out the use of particular types of fuels in all or parts of Arctic waters. The latter includes a possible ban on use of HFO in the Arctic. Some or all of these measurers will be sent to the next session of PPR (January 2019) for further consideration.

Review of the existing Energy Efficiency Design Index (EEDI) regulations

Furthermore, MEPC 72 will discuss the review of the EEDI and may propose a strengthening of the EEDI reference line parameters and/or new reduction rates for phase 2 and phase 3, which enter into force in 2020 and 2025 respectively, for certain ship types.

BIMCO is concerned by some of the proposed amendments to the EEDI regulations and the effect it will have on ship owners. We do, however, agree that it may be reasonable to discuss a possible add-on to the current phase 3 eg for container ships. This new phase 4 would enter then into force in 2030.

Marine plastic pollution

Marine plastic litter from shipping in the context of 2030 Sustainable Development Goal 14 (SDG 14) is also an important matter at MEPC 72.

The revised MARPOL Annex V that entered into force on 1 January 2013 prohibits the discharge of garbage including plastic from all ships of every type operating in the marine environment.

MEPC 72 will initiate the discussion and consider assessing levels and sources for marine plastic litter and microplastics from ships. This may end up in identifying and developing measures to further prevent and reduce marine plastic litter and microplastics from ships. This includes strengthening the implementation of the MARPOL Annex V prohibition discharge of plastics from ships.

 

Jeppe Skovbakke Juhl
in Copenhagen, DK
 

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