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ClassNK: Preliminary report of MEPC 73

30 Oct 2018

The 73rd session of the IMO Marine Environment Protection Committee (MEPC 73) was held at the headquarters of the IMO in London from 22 to 26 October. A summary of the outcome provided by ClassNK is given hereunder for your information:

1. Greenhouse Gases (GHG) emission reduction measures

Measures to reduce GHG emissions from international shipping have been deliberated at IMO, and so far, the Energy Efficiency Design Index (EEDI), the Ship Energy Efficiency Management Plan (SEEMP) and the Data Collection System for fuel oil consumption of ships (DCS) was introduced. Further, at MEPC 72, Initial IMO Strategy on reduction of GHG emissions from ships, which included emission objectives and their candidate measures, was adopted.

1.1 Review of technological developments for EEDI

Regulation 21.6 of MARPOL Annex VI sets out that a review of the status of technological developments which may contribute to the improvement of EEDI should be conducted at the beginning of phase 1 and at the midpoint of phase 2,. It also requires, if proved necessary, to amend the subsequent requirements, i.e. “when to start the phase 3,” “the EEDI reference line parameters” and “the reduction rate”. At MEPC 71, it was agreed to establish a correspondence group (CG), coordinated by Japan, to consider an early implementation of phase 3 and possible introduction of phase 4 and the group to report to MEPC 74.

At this session, an interim report of the CG was considered and the followings were agreed.

1) Phase 3 requirements:

  • Retain the current requirements of starting year in 2025 and 30% reduction for bulk carrier, tanker, roro cargo and ro-ro passenger ship.
  • For container ship, advance starting year from 2025 to 2022 and strengthen the reduction rate of large container ship from 30% to 40%. For reduction rate of small container ship, decision will be deferred to MEPC 74 and continue consideration by the CG.
  • For general cargo ship, advance starting year from 2025 to 2022 and retain 30 % reduction.
  • For ship types other than the above (gas carrier, LNG carrier, refrigerated cargo carrier, combination carrier, cruise passenger ship), due to the lack of sufficient data, decision will be differed to MEPC 74 and continue consideration by the CG.

Further consideration of the phase 3 requirements will be made by the CG and amendments to MARPOL Annex VI will be approved at MEPC 74.

2) Requirements for ice class ships:

  • For category A ships in Polar Code, amend MARPOL Annex VI to exempt them from EEDI regulation.
  • Revise a correction factor for ice class ships by amending EEDI Calculation Guidelines.
  • To set a 5% margin of the reduction rate for ice class ships of IA Super and IA, continue consideration by the CG.

1.2 Requirements of minimum propulsion power and EEDI

Guidelines for determining minimum propulsion power to maintain the maneuverability of ships in adverse conditions were developed in order to avoid construction of extremely under-powered ships along with implementation of EEDI requirements. At MEPC 71, it was agreed to extend the application period of the current guidelines towards phase 2 of EEDI regulation, assuming by such time any amendments to the guidelines would have been agreed.

On the other hand, concerns were raised at IMO that the requirements of minimum propulsion power in the guidelines might become a barrier for meeting the phase 3 requirements.

At this session, to address the conflict between EEDI and minimum propulsion power requirements, a proposal to allow limitations of a ship's shaft power under normal ships’ operation was discussed. As a result of the discussion, to improve the idea, it was agreed to keep consideration of the proposal at next session.

1.3 Amendments to guidelines on survey and certification of the EEDI

To calculate the EEDI value, ship speed measured at sea trial needs to be calibrated for calm whether condition. In the current guidelines, it is specified that ship speed measured at sea trial should be calibrated, by taking into account the effects of wind, current, waves, shallow water, displacement, water temperature and water density in accordance with ITTC Recommended Procedure 2014 or ISO 15016:2015.

At this session, the Committee considered the fact that ITTC Recommended Procedure was revised in 2017. As a result of the discussion, amendments to guidelines on survey and certification guidelines of the EEDI were adopted to refer the ITTC Recommended Procedure 2017.

1.4 Implementation of Data collection system

Amendments to MARPOL Annex VI to introduce the data collection system (DCS) for fuel oil consumption of ships entered into force on 1 March 2018, and carrying out of the data collection will be mandated to each ship of 5,000GT and above, from 1 January 2019. A review of the revised SEEMP which added the Ship Fuel Oil Consumption Data Collection Plan (DCP), where a description of the methodology for data collecting is provided, should be completed on and before 31 December 2018.

At this session, three unified interpretations to clarify the requirements of DCS are approved as follows.

  • Ships that are delivered on or after 1 January 2019 should keep on board both a SEEMP Part II and confirmation of compliance.
  • Data relating to Boil-off Gas (BOG) consumed on board the ship for propulsion or operation is required to be collected and reported as fuel as part of the Data Collection System for fuel oil consumption of ships.
  • The disaggregated data is not required to be kept onboard the ship provided that the disaggregated data can be made available by the Company.

1.5 IMO strategy on reduction of GHG

The Paris Agreement specifies the ambitious target to limit the increase in the global average temperature to well below 2°C above pre-industrial levels. To address this issue, MEPC 72 adopted Initial IMO Strategy on reduction of GHG emissions from ships.

At this session, following an intersessional meeting held from 15 to 19 October, program of follow-up actions of the Initial IMO Strategy on reduction of GHG emissions from ships up to 2023 was developed. The program indicates followings:

  • Invite member States to propose candidate short-term measures at MEPC 74.
  • Hold an intersessional meeting before MEP 74 and consider all the items described in the program of follow-up actions.
  • Consider short term measures by categorizing: Group A that can be considered and addressed under existing IMO instruments, such as EEDI; Group B that are not work in progress and are subject to data analysis on DCS; Group C that are not work in progress and are not subject to data analysis.
  • Invite member States to propose candidate mid-/long-term measures at MEPC 74 and MEPC 75.

2. Air pollution

2.1 Plan for 2020 global cap of sulphur content in fuel oils

At MEPC 70, it was agreed to set a global sulphur limit in fuel oil of 0.5% from 1 January 2020.

At this session, amendments to MARPOL Annex VI and supplement to IAPP certificate for a prohibition on the carriage of non-compliant fuel oil for combustion purpose with a sulphur content exceeding 0.50% were adopted. Further, a MEPC circular recommending to develop ship implementation plan for 2020 was also approved.

2.2 Experience-Building Phase (EBP) under 2020 global cap

It has been the concerns among the industry that alternative fuels such as low-sulphur residual fuel blend will come into the maritime market to meet the 0.50% limit of sulphur content, which may bring unforeseen negative impacts.

At this session, to address the above concerns, a proposal to establish an experience-building phase (EBP) associated with worldwide availability of safe compliant fuel was considered. The proponents explained that EBP was not an attempt to neither amend the 0.5% sulphur limit nor delay the effective date, but were seeking greater transparency to ensure a consistent manner to implement 0.5% sulphur limit. Following the discussions, it was not agreed to establish EBP, but invite further concrete proposals on how to enhance the implementation of regulation 18 of MARPOL Annex VI, in particular on sharing information for the smooth implementation of the provisions concerning the fuel oil quality and fuel oil supply.

2.3 Guidelines for discharge of exhaust gas recirculation (EGR) bleed-off water

To comply with the NOx Tier III emission limit, Exhaust Gas Recirculation (EGR) System, which recirculates the exhaust gas to engine intake air to lower the combustion temperature inside cylinders has been developed. Since EGR system is equipped with a scrubber to clean the recirculated exhaust gas and the system needs to bleed off its wash water. Since no regulation was in place regarding overboard discharge of bleed-off water, PPR Sub-Committee developed draft guidelines for discharge of EGR bleed-off water.

Following discussions, the guidelines was approved as MEPC Circular, with an application that the guidelines should apply to a marine diesel engine fitted with an EGR device having a bleed-off water discharge arrangement, for which the EIAPP Certificate is first issued on or after 1 June 2019. It was also emphasized that any discharge of oil or oily mixtures into polar waters is prohibited by the Polar Code.

3. BWM Convention

3.1 Commissioning of Ballast Water Management Systems (BWMS)

IMO Assembly 30 (A 30), held in last year, adopted resolution A.1120(30) on Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2017. The new survey provision related to sampling and analysis of treated ballast water at initial survey for the BWM Convention was included. In light of the above, it was pointed out that the sampling and analysis are not required in accordance with the BWM Convention or in the mandatory BWMS Code and no procedures for such sampling and analysis method had been developed yet. At MEPC 72, the Committee invited interested delegations to submit draft Guidance on the validation of the compliance of individual BWMS with regulation D-2 of the BWM Convention in conjunction with their commissioning.

As a result of the discussion at this session, guidance for the commissioning testing of BWMS was approved as BWM.2 Circular.

3.2 Permanent ballast water in sealed tanks

BWM Convention is not applied to permanent ballast water in sealed tanks on ships, which is not subject to discharge, in accordance with article 3 of the convention.

At this session, it was pointed out that a clarification is needed for ballast water in ballast tanks which are sealed with blank flanges or removable spool pieces, to be transferred internally between the tanks during the voyages and loading/unloading of cargos in ports, and overboard discharge will not occur. As a result of the discussion, the Committee agreed to consider unified interpretation on the issue at PPR Sub-Committee.

3.3 System Design Limitations (SDL) of BWMS

Ballast Water Management Systems which are installed on or after 28 October 2020 should be approved in accordance with Code for approval of Ballast Water Management systems (BWMS Code). According to the BWMS Code, SDL should clearly be identified and the parameters should be monitored and recorded.
At this session, Guidance on System Design Limitations of ballast water management systems and their monitoring for dissemination was approved as a BWM.2 circular.

3.4 Contingency measures (C/M)

At MEPC 71, Guidance on contingency measures under the BWM Convention (BWM.2/Circ.62) was approved for implementation of C/M in case that a ship is unable to manage ballast water in accordance with its approved Ballast Water Management plan.

At this session, amendments to Guidelines for the development of Ballast Water Management Plans (G4) to mandate inclusion of C/M into ships’ Ballast Water Management Plan, were adopted.

4. Others

4.1 Electronic record books under MARPOL

MARPOL Convention requires that ships are to be provided with several record books for the purpose of management of pollution prevention, such as oil record book specified in MARPOL Annex I. Today, electrification of record books spreads for ease of access, and standards for implement and use of electronic record books are requested.

At this session, Guidelines for the use of electronic record books under MARPOL and amendments to MARPOL and NOx Technical Code was approved. The Guidelines will be adopted at MEPC 74, by which an approval for electronic record books will be mandatory.

4.2 Marine plastic litter

With a view to tackling the problem of plastics in the oceans, MARPOL Annex V prohibits discharge of plastics from vessels. However, it was often pointed out that this prohibition regulation was not effective and that some additional actions were needed at IMO level to reduce plastic pollution in the marine environment.

At this session, the Committee developed an action plan to address marine plastic litter from ships. In the action plan, it is specified to conduct IMO Study on marine plastic litter from ships and establish a Correspondence Group to consider the appropriate mechanism to undertake the study.

5. Amendments to mandatory instruments

MEPC 73 adopted amendments to mandatory instruments as follows:

5.1 Sulphur content of fuel oils

Amendments to MARPOL Annex VI and supplement to IAPP certificate for a prohibition on the carriage of non-compliant fuel oil for combustion purpose with a sulphur content exceeding 0.50% were adopted.

Entry into force: 1 March 2020

Photo credit: International Maritime Organization
Published: 30 October, 2018


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