Commercial Vessel Compliance

Recap of the 7th Session of IMO Sub-Committee on Pollution Prevention and Response

Submitted by Melissa Perera, Office of Operating and Environmental Standards, Environmental Standards Division

The IMO Sub-Committee on Pollution Prevention and Response (PPR) held its 7th session at IMO headquarters in London, Feb. 17-21, 2020. Capt. Sean Brady, Chief of the Coast Guard’s Office of Operating and Environmental Standards, led the U.S. delegation, comprised of members from the Coast Guard, Department of State, Environmental Protection Agency, National Oceanic and Atmospheric Administration, Department of Transportation, and technical advisors from State and private sectors. 

Key topics discussed at PPR 7 were:

  • Reducing the risk of use and carriage for use as fuel of heavy fuel oil by ships in Arctic waters;
  • Implementation of the IMO 2020 sulphur limit;
  • Revised guidelines on exhaust gas cleaning systems (scrubbers) and evaluating and harmonizing rules and guidance regarding discharges from exhaust gas cleaning systems;
  • Reducing the impact on the Arctic of Black Carbon emissions from international shipping;
  • Prohibiting cybutryne in anti-fouling systems;
  • Revised guidance on commissioning testing of ballast water management systems;
  • Review of the Biofouling Guidelines; and,
  • Marine plastic litter.

Heavy fuel oil use in Arctic waters

The Sub-Committee agreed on draft amendments to MARPOL Annex I to introduce a phased-in prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters starting July 1, 2024, with full compliance required by July 1, 2029 for all ships, other than those involved in search and rescue or directly involved in pollution response. The draft amendments will be submitted to the Marine Environment Protection Committee (MEPC 76) (Oct. 19-23, 2020) with a view to approval and circulation for adoption at MEPC 77 (spring 2021).

Implementation of the IMO 2020 sulphur limit

IMO 2020, the 0.50 percent limit for sulphur in ships’ fuel oil, has been in effect since Jan. 1, 2020, cutting sulphur oxide emissions from ships operating worldwide. 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, helping to support implementation of the global sulphur limit.

To support the safe and consistent sampling of fuel oil being carried for use, and the enforcement of the carriage ban, the Sub-Committee finalized draft guidelines that provide a recommended method for the sampling of liquid fuel oil intended to be used or carried for use on board a ship. These draft guidelines will be forwarded to the next session of the Marine Environment Protection Committee (MEPC 75) with a view to adoption.

Exhaust gas cleaning systems (scrubbers)

The Sub-Committee completed revisions of the 2015 Guidelines for exhaust gas cleaning systems (EGCS, also known as “scrubbers”), to be submitted to MEPC 75 for adoption. Revisions focused upon the uniform application of the guidelines, in light of recent technical developments and experience gathered from approvals and operation of such alternative compliance systems.

With respect to evaluating and harmonizing rules and guidance on the discharge of liquid effluents from EGCS, the Sub-Committee agreed to recommend the following scope of work to the MEPC:

  • risk assessment (development of risk assessment guidelines for the evaluation of possible harmful effects of the discharge water from EGCS, taking into account existing methods and mathematical models);
  • impact assessment (to consider developing impact assessment guidelines);
  • delivery of EGCS residues (developing guidance on delivery of EGCS residues to port reception facilities, regarding volumes and composition of residues);
  • regulatory matters (including assessing state of technology for EGCS discharge water treatment and control, identifying possible regulatory measures, developing a database of local/regional restrictions/conditions on the discharge water from EGCS;
  • database of substances (establishing a database of substances identified in EGCS discharge water, covering physico-chemical data, ecotoxicological data and toxicological data, leading to relevant endpoints for risk assessment purposes).   

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.

Revised guidance on commissioning testing of ballast water management systems

An amendment to regulation E-1 of IMO’s Ballast Water Management Convention, which is expected to be adopted by MEPC 75, mandates the commissioning testing of BWMS. The Sub-Committee completed its revision of guidance on this testing, which is intended to validate the installation of a BWMS by demonstrating that its mechanical, physical, chemical and biological processes are working properly.  

Review of the Biofouling Guidelines

The Sub-Committee began its review of the IMO Biofouling Guidelines, which provide a globally consistent approach to the management of biofouling – the accumulation of various aquatic organisms on ships’ hulls. The Sub-Committee identified key elements that require further attention and discussion, considered areas for potential revision of the Guidelines. In addition, IMO is executing the GEF-UNDP-IMO GloFouling Partnerships project, which aims to drive actions to implement the Biofouling Guidelines. The project will also spur the development of best practices and standards for improved biofouling management in other ocean industries.

Marine plastic litter

In the context of the IMO Action Plan to address marine plastic litter from ships, which was adopted by the MEPC in 2018, 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 and encouraging studies to better understand microplastics from ships;

Correspondence groups established

  • Correspondence Group on Review of the Biofouling Guidelines;
  • Correspondence Group on Development of Guidelines on Measures to Reduce Risks of Use and Carriage of Heavy Fuel Oil as Fuel by Ships in Arctic Waters;
  • Correspondence Group on Sewage Treatment Plants;
  • Correspondence Group on Marine Plastic Litter from Ships; and
  • Correspondence Group on Black Carbon Emissions.

Finally, the Sub-Committee re-elected Dr. Flavio da Costa Fernandes of Brazil as Chair and Dr. Anita Makinen of Finland as Vice-Chair. The next session of the PPR Sub-committee (PPR 8) is tentatively scheduled for Jan. 11-15, 2021.

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.