mepc 66 - lr summary report

Lloyds Register Briefing Note MEPC 66 Summary Report April 2014

Introduction

The 66th session of the IMO Marine Environment Protection Committee (MEPC 66) was held from 31 March to 4 April 2014, at the IMO headquarters in London. This briefing summarises the subjects discussed which are relevant to the work of Lloyd's Register and our Clients.

Overview

Many of the decisions taken at MEPC 66 have significant impact on the current practices in industry. With regard to Air pollution, after extensive discussion, MEPC 66 decided to keep the implementation date of the NOx Tier III requirements as 1 January 2016 for new ships constructed on or after this date which operate in existing NOx emission control areas (ECAs), while accepting a delay in the application to yachts until 2021. MEPC 66 also decided that for any future new ECA, the Tier III requirement will be made mandatory for ships constructed on or after the announcement of the establishment of the ECA, or any date decided by the party(ies) proposing the ECA but not earlier than the announcement date. Additionally, MEPC agreed to expand the scope of engines subject to NOx controls from the current liquid and dual fuel engines to include gas-fuelled engines from a yet to be set date. MEPC 66, despite of its attempt to develop a base for workable further operational and technical measures for energy efficiency, it only considered the core elements for a data collection system, noting that data is required to do further work on the evaluation of appropriate energy efficiency metrics, if required. MEPC 66 also agreed to start developing a way to conduct the low sulphur fuel availability study. Furthermore, MEPC agreed the expansion of the EEDI requirements to new ship types, i.e.

LNG Carriers (including non-conventional propulsion) Ro-ro cargo ships (pure vehicle carrier) Ro-ro cargo ships Ro-ro passenger ships Cruise passenger ships (having non-conventional propulsion only)

This amendment will enter into force on 1 September 2015. Owing to the various issues raised on the environment requirements for the Polar Code, MEPC66 could not conclude the final draft of the code as well as draft the relevant amendment to the MARPOL convention for making the code mandatory. The matter will be further discussed at MEPC 67 and MEPC 68 with target entry into force date on 1 January 2017. With regard to the Ballast Water Management, MEPC 66 did not conclude on the need of G8 guideline (Guidelines for approval of ballast water management systems (MEPC. 174 (58))

Summary of discussions

The following agenda items are relevant to the work of Lloyds Register:

IMO Ship Design and Construction (SDC 1) IMO Marine Environment Protection Committee (MEPC 66)

Working together

for a safer world

Summary Report

2


Harmful aquatic organisms in ballast water (agenda item 2 and 11)

The following is the summary of the discussion on these agenda items. Readers, who would like to know more about this subject, please note that Guidance on the BWM Convention and available technologies is available on the Lloyds Register website.

Approval of new systems A further 2 final approvals and 4 basic approvals were made for treatment systems using active substances in accordance with the G9 guideline (Procedure for approval of ballast water management systems that make use of active substances (MEPC. 169 (57))). Readers are to note that these approvals by the IMO of the use of an active substance are subject to subsequent type approval by the flag Administration in accordance with the G8 guidelines (Guidelines for approval of ballast water management systems (MEPC. 174 (58)). Systems that do not use an active substance do not require IMO approval; they only require type approval by the flag Administration.

Port-based Mobile Ballast Water Treatment Facility The idea of a ballast water treatment barge was examined, i.e., Port-based Mobile Ballast Water Treatment BwBoat. MEPC 66 noted the opinion of the Ballast Water Review Group (BWRG) established during the session that discharge to a BwBoat is not an alternative method but it actually equals with discharge to a reception facility. Guidelines for reception facilities are already in place.

The Guidelines for approval of ballast water management systems (G8) (MEPC.174(58)) While industry members and some member States expressed their desire to have a more robust and reliable type approval standard, some members expressed concerns that this update may pose difficulties to the entry into force of the convention. In addition, some concerns with regard to systems already installed onboard were expressed. Members response were

completely against the proposal; completely supporting the proposal; and requesting further evidence to support the proposal or suggest an alternative one.

In the review group, an NGO and co-sponsors pressed about the need for a more robust testing methodology. MEPC 66 decided to further examine the need for revising G8 guideline through a study. Issues to be addressed during this study were agreed.

BWM circular on Guidance on entry or re-entry of ships into exclusive operation within waters under the jurisdiction of a single Party Articles 3.2(b) and 3.2(c) of the Convention exclude ships that only operate in waters under the jurisdiction of a single Party. Article 3.2(d) excludes ships that only operate in waters under the jurisdiction of a single Party and on the high seas. The above questions the application of the Convention to MOUs. MEPC 66 approved the circulation of a BWM circular which would clarify the application of the convention in these occasions.

Draft Guidance on stripping operations using eductors MEPC 66 noted that there was a need to further review the outcome of the PPR 1. Being impossible to submit comments between PPR 1 and MEPC 66, MEPC 66 decided to defer the review of the outcome of PPR 1 to MEPC 67.

Recycling of ships (agenda item 3)

No working group/drafting group was allocated for the discussion during MEPC 66. There was an intense discussion on the threshold value of prohibited materials, especially on asbestos. Opinions were divided whether to accept the value of 1% subject to this being recorded in the Material Declaration and the Inventory of Hazardous Material (IHM), or not.

3


It was also suggested that the threshold value for asbestos should not only apply to existing ships but also to new ships, and proposed that all applicable threshold values for hazardous materials listed in tables A and B of appendix 1 of the Inventory Guidelines should be recorded in both the IHM and the Material Declaration. MEPC 66 also noted that SDC 1, having been instructed by MSC 92 to consider the matter following a request by MEPC 65, had endorsed a compromising proposal of 0.1% as the threshold value and a footnote including a reference to the UN recommendation "Globally Harmonized System of Classification and Labelling of Chemicals (GHS)" as the basis for the value and a relaxation clause which allows the 1% threshold to be applied, subject to this being recorded in the Material Declaration and the IHM. Given the limited time available, a resolution on the complex technical issues related to setting a threshold level for asbestos was not possible so it was agreed to refer this issue to the MEPC 67 for further discussion. Readers, who would like to know more about this subject, please note that Guidance on the Ship Recycling Convention and available services is available on Lloyds Register website.

Inventory of Hazardous Materials (IHM) threshold values and exemptions - developed draft amendment to the 2011 Guidelines for the development of the inventory of hazardous material (resolution MEPC.197 (62))

Air pollution and energy efficiency (agenda item 4, 6, 7 and 11)

MEPC 66 discussed various issues in relation to air pollution under this agenda.

Further operational and technical measures for energy efficiency of ships A number of submissions to MEPC 66 proposed further operational and technical measures for the energy efficiency of ships. All of these proposals recognised the value of establishing a data collection system. MEPC 66 agreed to consider the development of a data collection system and its core elements. It was noted that further work is required to evaluate any proposed energy efficiency metric and member states were encouraged to share any data from voluntary programmes.

EEDI related issues Amendment to the MARPOL Convention (agenda item 4)

Amendments to regulations 2, 13, 19, 20 and 21 of MARPOL Annex VI and the Supplement to the IAPP Certificate were adopted under agenda item 6. These amendments will enter into force on 1 September 2015. These amendments expand the requirement for ships meeting the required EEDI to the following ship types:

LNG Carriers (including non-conventional propulsion) Ro-ro cargo ships (vehicle carrier) Ro-ro cargo ships Ro-ro passenger ships Cruise passenger ships (having non-conventional propulsion only)

Various technical guidelines

MEPC 66 adopted the following technical guidelines in relation to EEDI:

2014 Guidelines on the method of calculation of the attained EEDI for new ships

The revision addressed:

Use of DWT to define size threshold for required EEDI for Ro-ro passenger ships DWT replaces GT in table 1 of regulation 21.1 of MARPOL Annex VI.

Ships with dual-fuel engines method for identifying primary fuel in order to determine relevant carbon factor Cf for use in calculating EEDI.

Calculation of the attained EEDI for ships defined in regulations 2.32 to 2.35 of MARPOL Annex VI agreement to calculate the attained EEDI for passenger ships with conventional propulsion using existing calculation methods until such time as specific guidelines for this ship type becomes available.

Calculation of the attained EEDI for LNG carriers new methodology to calculate EEDI for LNG Carriers with direct drive, diesel-electric and steam turbine propulsion. The guidelines also provide for LNG Carriers with re-liquefaction systems or compressors in the calculation of auxiliary power PAE and specific calculation requirements for MPP and SFC for LNG Carriers with diesel-electric propulsion.

Correction factor for power fj extension of the application of the ice correction factor, fj, for refrigerated cargo carriers which are designed to ice-class requirements.

4


Terminology used in the guidelines related to Energy Efficiency Design Index (EEDI) regulations noting work done to provide a comparison of terminology used in the various EEDI guidelines.

2014 Guidelines on survey and certification of the EEDI were revised with a view to further consideration and adoption at the next session (MEPC 67).

Ships with dual-fuel engines Survey and Certification of EEDI for LNG carriers

Unified Interpretation of regulation 2.24 of MARPOL Annex VI (MEPC.1/Circ.795) amendments were adopted noting that some ships temporarily need to increase or decrease their freeboard due to operational requirements. In these cases, these temporary assignments of freeboard will not be considered as a major conversion. Furthermore, the Unified Interpretations contained in MEPC.1/Circ.795 will be reissued in a new consolidated circular incorporating all previous amendments.

EEDI reviews required under regulation 21.6 of MARPOL Annex VI - EEDI data base.

Regulation 21.6 of MARPOL Annex VI states that: At the beginning of phase 1 and at the midpoint of phase 2, the Organization shall review the status of technological developments and, if proven necessary, amend the time periods, the EEDI reference line parameters for relevant ship types and reduction rates set out in this regulation."

MEPC 66 agreed a specific dataset to populate an EEDI Database. The dataset relates to each ship required to have an attained EEDI under Regulation 20 MARPOL Annex VI and takes into issues to do with confidentiality and protection of Intellectual Property Right (IPR). The database will be administered by the IMO Secretariat and collection of data will cease after Phase 2 of the EEDI, with the database existence limited to the end of Phase 3.

NOx control Amendments to MARPOL Annex VI (Agenda item 6)

At the previous MEPC (MEPC 65), there was an agreement to grant an extension of the Tier III date to 2021 from 2016. MEPC 66 considered proposals and accepted a delay in the application to yachts until 2021, but did not accept a change for other ship types sailing in the existing NOx ECAs. However it was decided that for any future ECA, the Tier III requirement will be made mandatory to ships constructed on or after the announcement of the establishment of the ECA, or any date decided by the party(ies) proposing the ECA but not earlier than the announcement date. In other words, Tier III requirements will be made applicable as follows:

Ships that will be operating in ECAs in America (North American and US Caribbean Sea) - ships constructed on or after 1 January 2016.

Ships that will be operating in future ECAs (that might be established) - applies to ships constructed on or after the date that ECA is adopted by MEPC, or a date decided by the parties concerned but not earlier than the date of adoption.

Notwithstanding the above, yachts (ships used solely for recreational purposes) of less than 500 gt constructed before 1 January 2021 do not need to comply with Tier III requirement, and recreational yachts of less than 24m will not need to comply with Tier III even after that date.

NOx Technical Code 2008 (Agenda item 6) MEPC 66 adopted amendments to the NOx Technical Code in respect of dual fuelled vessels (gas / liquid). These amendments clarify that for testing and approval, including calculation values, the requirement for dual fuel engines to be tested at their maximum liquid/gas fuel ratio (i.e., the worst NOx emission case) is retained. It was confirmed that these changes are in no way a means of offering a single certification on gas for engines for which the normal in-service NOx emission values will be higher due to operating with a greater liquid/ gas fuel ratio than that used in the testing process. This amendment will enter into force on 1 September 2015. Draft Amendments to MARPOL Annex VI regarding engines fuelled solely by gaseous fuels (Agenda item 7)

MEPC 65 agreed to the conclusion by the Tier III NOx Review Correspondence Group that engines fuelled solely by gaseous fuels, e.g. pure LNG, should be required to comply with the provisions of regulation 13 of MARPOL Annex VI. MEPC 66 agreed that the scope of the regulation 13 NOx requirements is to be extended to also include gas fuelled engines. It was agreed that this will be done by means of a modification of the definition of marine diesel engine as given by regulation 2.14. The implementation date of this requirement is still to be set. Consequential amendments necessary to the NOx Technical Code in order to cover the certification of these gas fuelled engines are to be submitted to MEPC 67.

5


MEPC resolution on 2014 Guidelines in respect of the information to be submitted by an administration to the Organization covering the certification of an approved method as required under regulation 13.7.1 of MARPOL Annex VI (Outcome of PPR 1)

MEPC resolution on the 2014 Guidelines on the approved method process (Outcome of PPR 1)

These two Approved Method related resolutions were adopted as developed by PPR. It was agreed that existing Approved Methods will not have to be repeated taking into account the guidance now given. The Approved Method Process Guidelines with their process flowchart are expected to significantly clarify the requirements, responsibilities and required action to all involved. These guidelines are aimed to apply for the approval of future engine approvals.

Standard specification for shipboard incinerators Paragraph A1.7 of the Standard specification for shipboard incinerators (MEPC.76(40)) states Passenger/cruise ships with incinerator installations having a total capacity of more than 1,500 kW. A question was raised whether this applies to cargo ships as well. MEPC 66 agreed on an updated version of the existing MEPC 76(40) specification as 2014 Standard specification for shipboard incinerators. Principally this extends the range, as previously agreed, up to 4000kW, consistency with the definitions in revised MARPOL Annex V and the updating of the various SOLAS and IEC cross-references. Beyond those changes there are no amendments to the approval requirements or operational limits. The footnotes to regulation 16 of MARPOL Annex VI are duly amended and the relevant section of the Supplement to the IAPP Cert has been amended to additionally include where the incinerator installed is to this new specification.

Availability study of low sulphur fuel MARPOL Annex IV regulation 14.8 stipulates a review of the fuel availability which shall be completed by 2018. After extensive discussions, MEPC 66 agreed to establish a correspondence group which will consider how to conduct such a study.

Marine fuel quality Concerns are expressed about the quality of bunker fuel currently supplied to ships. However, MEPC 66 could not agree on concrete actions. The matter will be further discussed at MEPC 67.

Reduction of GHG emissions from ships (agenda item 5)

The outcome of the United Nations Framework Convention on Climate Change (UNFCCC) COP 19

MEPC 66 instructed the Secretariat to keep liaising easing with UNFCCC.

The outcome of an update of the 2009 IMO Study of greenhouse gas emissions estimate for international shipping

There was an interim report to MEPC 66. Full report will be submitted to MEPC 67.

Consideration and adoption of amendments to mandatory instruments (agenda item 6 - other than those introduced under Air pollution above)

Amendments to MARPOL Annexes I, II, III, IV V and VI to make the III Code mandatory

In order to make IMO Instruments Implementation Code (III Code) (resolution A.1070 (28) mandatory, a set of amendments were adopted. These amendments will enter into force on 1 January 2016.

Amendments to MARPOL Annex I (Mandatory carriage requirements for stability instrument)

Draft amendments to the BCH Code (Cargo containment and Form of Certificate of Fitness)

Both new and existing tankers will have to be fitted with a stability instrument capable of verifying compliance with the relevant intact and damage stability requirements. It will need to be approved by the Flag Administration. The amendment will enter into force on 1 January 2016. Existing tankers will be given a period of grace for compliance.

Draft amendments to the International Code for the Construction and Equipment of ships Carrying Dangerous Chemicals in Bulk (IBC Code)

The amendments consist of the following contents:

6


Above mentioned damage stability for tankers (Amendment to MARPOL Annex I) for chemical tankers Clarification (definition) of inerting/purging/gas-freeing and operational requirements (see Note below)

(Note) IMO decided to require Fixed Inert Gas Systems on new oil and chemical tankers (8,000 to 20,000 dwt), constructed (keel laid) on or after 1 January 2016. Relevant amendments to SOLAS, FSS Code and the IBC Code are prepared. (SOLAS and the FSS Code are to be adopted at MSC 93). For details, please refer to Lloyds Register FP56 and BLG 16 reports. The amendment will enter into force on 1 January 2016. However, readers are to note that there were some unfinished discussions on chapter 15 of the IBC Code, which will be further addressed at MSC 93 during the final adoption of the code.

Draft Amendments to MARPOL Annex V (Record of Garbage Discharge)

MEPC 66, while agreeing on the need to revise the current format of the garbage record book, agreed to further discuss this matter in depth at MEPC 67, rather than concluding the issue in a hasty manner.

Interpretations of, and amendments to, MARPOL and related instruments (agenda item 7, other than air pollution introduced above)

Electronic record book

MEPC 66 reviewed the work of the correspondence group established by MEPC 65 on the possible introduction of the Electronic Record Books for the records required by the MARPOL convention. The group prepared guidance on the use of such record books. Concerns have been expressed over safe-guarding, certification and verification, verification by Port State Control Officials and surveyors, recording periods, control of overwrite and others. The matter will be further discussed by the correspondence group. It was also agreed to develop a unified interpretation for the MARPOL Convention in order to avoid any possible conflicts during PSC inspections. The group will also consider the need for any consequential amendments to the Procedures for Port State Control, 2011 (resolution A.1052(27)).

Management of boiler/economizer washdown water Following the discussion at MEPC 65, there was a proposal on a draft MEPC circular on best practice for the management of boiler/economizer washdown water, which will allow the discharge of the wash water off 12 nautical miles from the nearest land. While this proposal gained some support, MEPC 66 concluded that it would require a new work programme and Members were encouraged to submit a proposed one at MEPC 67.

Use and carriage of Heavy Grade Oil (HGOs) in the Antarctic area While use (as fuel) and carriage (as cargo) was prohibited in the Antarctic area by MARPOL Annex I regulation 43, there was a case where a ship carried HGO as ballast. MEPC 66 approved amendment to the regulation to clarify that carriage, even as ballast, is prohibited for adoption by MEPC 67. Entry into force is expected on 1 March 2016.

Report of the sub-committees (agenda item 11)

MEPC 66 reviewed the outcome of DSC 18, STW 44, DE 57, SDC 1 and PPR 1. The outcome of these Sub-Committees discussion other than Ballast water management and Air pollution are given hereunder. For details, please refer to Lloyds Registers report on the respective Sub-Committee.

DSC 18 Environment section in the IMSBC Code

MEPC 66 noted the decision of DSC 18 on the need to compile a new section for substances harmful to the marine environment (HME) within the IMSBC Code in relation to the revised MARPOL Annex V by developing an indicative list of solid bulk cargoes and establishing a correspondence group accordingly.

Draft amendments to MARPOL Annex III

7


MEPC 66 approved draft amendments to MARPOL Annex III for adoption at MEPC 67. This relates to the criteria for the identification of harmful substances in packaged form. The amendment now includes an exemption for radioactive material as defined in Class 7 of the IMDG Code.

STW 44 Draft MSC-MEPC circular on Guidelines for the reactivation of the Safety Management Certificate following an

operational interruption of the Safety Management System due to lay-up over a certain period

This document provides guidelines to Companies and Administrations on the actions to be taken following a lay-up, in order to ensure that the Safety Management System (SMS) on board vessels is functional once the ship is taken back into service.

MEPC 66 approved this circular subject to its concurrent approval by MSC 93.

Draft MSC-MEPC circular on Guidance on safety when transferring persons at sea

When performing transfer of personnel at sea there are a number of considerations that should be taken into account and safety measures to be addressed to ensure that the transfer is carried out in a safe manner. The circular lists up items to be considered as a minimum set of work.

MEPC 66 approved this circular subject to its concurrent approval by MSC 93.

Decision of the Sub-Committee not to develop amendments to the ISM Code for the transfer of ship maintenance and failure records

MEPC 66 endorse, subject to endorsement by MSC 93, the view of the STW 44 that transfer of ship maintenance and failure records could pose a number of significant practical difficulties, in particular, related to implementation and agreed not to develop amendments to the ISM Code for the transfer of ship maintenance and failure records.

SDC 1 Polar code relating issues

The following issues were discussed:

Application - MEPC 66 agreed that the relevant chapters of part II-A of the Polar Code would be applicable to those ships to which the associated Annex of MARPOL is applicable.

Goal based approach - MEPC 66 agreed that a goal and functional requirement based approach does not fit to environmental requirements, thus agreed to delete all goals and functional requirements in the draft part II-A.

Prevention of pollution from Oil - MEPC 66 maintained the decision taken at MEPC 65 - any discharge of oil will be prohibited.

Additional carriage (structural) requirement - MEPC 66 agreed that an impact assessment for additional carriage (structural) requirements for the carriage of noxious liquid substances (NLS) is required.

Port reception facility - in principle, MEPC 66 agreed that port reception facilities will be required in the polar region but it also agreed that lack of reception facilities should not delay the entry into force of the code.

Certificates and manuals, plans, record books and other paperwork - To limit the administrative burden, it was agreed that compliance with the Polar Code shall be reflected on the existing certificates under the relevant Annexes to MARPOL. It has also been agreed that the case of a single voyage may be treated differently.

Section 3.3 of Part II-B (lubricants for stern tube etc.) - the draft text was revised to clarify which parts of lubricated systems the use of non-toxic biodegradable lubricants is recommended. Readers are to note that part II-B is not mandatory.

Draft amendment to MARPOL - MEPC 66 agreed to make the Polar Code mandatory via a separate chapter in every relevant Annex to MARPOL and not in the application part of each Annex.

The following revised time table was agreed:

MEPC 66 - establish a correspondence group for further discussion (to produce concrete texts based upon the above agreement)

MEPC 67 - a working group to consider details and approve the final text of the code and MARPOL MEPC 68 - adopt final texts (for entry into force on 1 January 2017)

MEPC 66 requested Council to hold an intersessional meeting the week before MEPC 67.

PPR 1

Chemical related issues

The following were approved:

8


MEPC.2/Circ.20 related issues

The following will be included into the next update of MEPC.2/Circ. Series (MEPC.2/Circ.20) that will take effect on 1 January 2015.

Evaluation of new products (List 1 of the MEPC.2/Circular 20) The evaluation of cleaning additives The evaluation of trade-named mixtures presenting safety hazards and their consequential inclusion in list 3 of

the draft MEPC.2/Circular with validity for all countries and no expiry date (List 3 of the Circular) Clarification on the use of generic cleaning products - status of annex 10 to the MEPC.2 Circulars Draft MEPC-MSC Circular on products requiring oxygen-dependent inhibitors

MEPC 66 approved the circular subject to the concurrence of MSC 93. The circular explains that the existing IBC Code paragraph 15.13.3.2, which requires the Certificate of Protection to state "whether the additive is oxygen-dependent" should be amended by a requirement that states "whether the additive is oxygen-dependent and if so, the minimum level of oxygen required in the vapour space of the tank for the inhibitor to be effective must be specified."

Noise from commercial shipping and its adverse impacts on marine life (agenda item 17)

MEPC 66 approved a MEPC circular on Guidelines for the reduction of underwater noise from commercial shipping. These guidelines will be non-mandatory, however some of the suggested solutions may help to improve ship efficiency so would be worth be considered at the design stage. The suggested solutions could have a large impact on ship design and should be carefully reviewed. Lloyds Register ODS is involved in several underwater noise projects. We are applying the latest technology to analyse noise impact on the underwater environment and are working with clients to reduce the emitted noise generated by the major sources associated with ships (e.g. engine, propeller etc.).

Lloyds Register and variants of it are trading names of Lloyds Register Group Limited, its subsidiaries and affiliates. Copyright Lloyds Register EMEA. 2014. A member of the Lloyds Register group.

Lloyds Register Group Limited, its subsidiaries and affiliates and their respective officers, employees or agents are, individually and collectively, referred to in this clause as Lloyds Register. Lloyds Register assumes no responsibility and shall not be liable to any person

for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that

person has signed a contract with the relevant Lloyds Register entity for the provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

External Affairs Lloyds Register, EMEA 71 Fenchurch Street London EC3M 4BS, UK E [email protected] www.lr.org

IMO Ship Design and Construction (SDC 1)IMO Marine Environment Protection Committee (MEPC 66) - Summary ReportIntroductionOverviewSummary of discussionsHarmful aquatic organisms in ballast water (agenda item 2 and 11)Recycling of ships (agenda item 3)Air pollution and energy efficiency (agenda item 4, 6, 7 and 11)Reduction of GHG emissions from ships (agenda item 5)Consideration and adoption of amendments to mandatory instruments (agenda item 6 - other than those introduced under Air pollution above)Interpretations of, and amendments to, MARPOL and related instruments (agenda item 7, other than air pollution introduced above)Report of the sub-committees (agenda item 11)Noise from commercial shipping and its adverse impacts on marine life (agenda item 17)

mepc 66 - lr summary report

Documents