- Domestic Vessels

8/18/2014: Polar Code workshop after-action: Environmental considerations

This is a part of the Maritime Commons blog-post series on the process forward for adopting a Polar Code for ships operating in Arctic and Antarctic waters. Thursday, the Coast Guard hosted a workshop on the Polar Code in Seattle. For those of you who could not attend, Maritime Commons is providing an after-action blog post for each of the Coast Guard spokespersons that presented at the workshop. You are encouraged to submit your comments to the Federal Docket before it closes on September 1, 2014.

The Polar Code is divided into two parts, safety and environment. In one of the Maritime Commons Polar Code workshop after-action posts, we covered the Coast Guard presentation on the safety part of the Code.

This post provides key-takeaways from Mr. Wayne Lundy, of the Coast Guard Office of Design and Engineering Standards, and his presentation on the environmental part of the code.

“The Code is not a stand alone document, it is a supplement to the SOLAS and MARPOL conventions,” said Lundy

Lundy discussed how there are six annexes under MARPOL 73/78 and that, currently, the Polar Code has supplemental provisions for MARPOL annexes I, II, IV and V.

Lundy went through what each of these draft provisions entail. They are all still in draft and will be considered by the IMO at a committee meeting in October.

Draft provisions for Arctic waters:

Annex I: Prevention of pollution by oil

• In Arctic waters, prohibition of discharges of any oil or oily mixtures
o This would mean that ships would not be able to use oily-water separators
• Oil record books, manuals, shipboard oil pollution emergency plans and shipboard marine pollution emergency plans, to be updated to account for operations in polar waters
• Category A and B ships: additional structural provisions that would require separation from the outer shell for those fuel tanks, cargo tanks on smaller vessels and sludge holding tanks

Annex II: Control of pollution by noxious liquid substance

• In Arctic waters, prohibition of discharges of any NLS or mixtures containing such substances
• Oil record books, manuals and shipboard marine pollution emergency plans for NLS or the SMPEP as required by MARPOL Annex II to be updated to account for operation in polar waters
• Category A and B ships: additional structural provisions that would require separation from the outer shell for all tanks carrying NLS

Annex IV: Prevention of pollution by sewage from ships

• Discharges of sewage prohibited within certain distances of ice shelves and land-fast ice
• Discharges through an approved system allowed for those Category A and B ships that operate in ice for extended periods of time subject to the advance approval of the IMO Administration

Annex V: Prevention of pollution by garbage from ships

• In Arctic waters, discharges of garbage is prohibited, except under limited circumstances
• Discharges of food wastes permitted when ship is enroute and beyond certain distances of land, ice shelves and land-fast ice
• Discharges of food wastes prohibited on ice
• Discharge of animal carcasses prohibited
• Discharges of cargo residues not containing any substances harmful to the marine environment may be permitted when ship is enroute and beyond certain distances of land, ice shelves and land-fast ice
• Similar provisions as above for the Antarctic

The Polar Code contains both non-mandatory and mandatory sections. Lundy also covered the draft non-mandatory sections for the environmental section of the Code:

Draft Part II-B provisions (non-mandatory):
• Encouragement to consider non-toxic lubricants or water-based systems in lubricated components outside the underwater hull with direct seawater interfaces
• Additional guidance for MARPOL Annex V garbage management
• Additional guidance for cold water functionality of systems regarding ballast water management and minimizing the risk of invasive aquatic species

“These are still in draft and have not been approved by the IMO committee. There are still continuing discussions about environmental aspects of the Polar Code. At the committee and subcommittee levels, there’s still work that needs to be done,” said Lundy.

Presentations from Thursday’s workshop will be made available on the Docket. Submit your comments on the Polar Code by September 1, 2024 and subscribe to Maritime Commons for additional after-action blog-posts from the workshop!

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.