regulatory developments & their practical … – design load for membrane tanks – accidental...

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Regulatory Developments & their Practical Implementation

Asian Offshore Support Journal Conference 2015

Keith Yeo Principal Engineer

Singapore

8-9 September 2015

Subramani RagunathanSenior Engineer

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IGF Code

� International Code of Safety for Ships Using Gases or Other Low-

Flashpoint Fuels (IGF Code)

� Adopted by IMO Maritime Safety Committee on 11 June 2015

� SOLAS Ch. II-1, Part G added to address low-flashpoint fuels

� Apply to ships using low-flashpoint fuels:

� For which the building contract is placed on or after 1 January 2017;

� In the absence of a building contract, the keels of which are laid or which are at a similar stage of construction on or after 1 July 2017; or

� The delivery of which is on or after 1 January 2021

� An existing ship which converts to using low-flashpoint fuels on or

after 1 January 2017

� Governments to consider the voluntary application of the IGF

Code to cargo ships of less than 500 gross tons

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IGF Code

� Practical Considerations

� Containment system

� Bunkering

� Gas vent exit

� Multi-purpose vessels – increase in risks

� Boil-off gas management

� Single or dual fuel

� Engage flag States early, obtain AIP

� Risk assessments

302ft Offshore Support Vessel

35m ASD type Escort Tug

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IGF Code

� For ships using natural gas as fuel (part A-1 of the IGF Code) and

complying with detailed prescriptive requirements within the

Code, a risk assessment need only be conducted where explicitly

required by the prescriptive parts of the Code

� 5.10.5 – Capacity of Drip Trays

� 5.12.3 – Separation of Spaces by Airlocks

� 6.4.1.1 – Containment System – Integration to Overall Design

� 6.4.15.4.7.2 – Design Load for Membrane Tanks – Accidental Scenarios

� 8.3.1.1 – Closed or Semi-enclosed Bunkering Stations

� 13.4.1 – Alternative Ventilation Capacity for Tank Connection Spaces

� 13.7 – Ventilation System for Bunkering Station not on Open Deck

� 15.8.1.10 – Gas Detectors for Ventilation Inlets

� Annex 4.4 & 6.8 – Novel Containment Systems

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Status of BWM Regulations

� IMO BWM convention – not ratified

� USA BWM regulations – entered into force

� USA does not ratify IMO BWM Convention

� USA enforces own BWM regulations

– BWM discharge standard – same as IMO

– Two regulatory agencies: USCG & EPA

Status of US Regulations on BWM

• USCG – effective 21 June 2012

• EPA – effective 19 Dec. 2013

• 16 States have additional ballast

water management requirements

Status of US Regulations on BWM

• USCG – effective 21 June 2012

• EPA – effective 19 Dec. 2013

• 16 States have additional ballast

water management requirements

Status of IMO BWM Convention

As of end July 2015, ratified by:

• 44 Member States/Parties (needs 30)

• 32.86% of World Tonnage (needs 35%)

Entry into Force – 12 months after

ratification criteria met

Status of IMO BWM Convention

As of end July 2015, ratified by:

• 44 Member States/Parties (needs 30)

• 32.86% of World Tonnage (needs 35%)

Entry into Force – 12 months after

ratification criteria met

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IMO: MEPC 68 Updates

� Revision of the Guidelines (G8)

� Gathering information with regards to 10 items

� A study on the ability for BWMS to achieve D-2 standard or performing as anticipated – ongoing

� Non-Penalization of Early Movers

� Shipowners should not be required to replace BWMS approved by MEPC.174(58) for the life of the ship/ system due to occasional lack of efficacy for reasons beyond the control of the ship-owner and ship's crew if specific criteria are met

10 items under consideration for

the revision of Guidelines (G8)• Effect of temperature in cold and tropical

waters

• Standard test organisms used in BWMS

testing

• Methods for testing of BWMS

• Differences between type approval

protocols in Member States

• Incorporation of control and monitoring

equipment in BWMS

• Documents needed for scaling of BWMS

and how to determine validation of

computer modelling, model assumptions,

etc.

• Minimum storage times for ballast water

during testing

• Comparison of control samples in holding

tank versus real environment in normal

double bottom ballast tanks

• Development of common approach to

achieve the threshold for biological and

physical constituents

• Definition of viability of organisms

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US BWM Regulations

� No USCG type approved BWMS

� 17 BWMS vendors submitted Notices of Intent (NOI) to USCG

� 3 UV BWMS vendors announced submittal of USCG type approval packages through an Independent Lab (IL)

� Trojan Technologies – Trojan Marinex™ BWT

� Alfa Laval – PureBallast 3.0/3.0EX

(3.1/3.1Ex)

� DESMI – RayClean™ BWMS

� Interim measure:

� Alternate Management Systems (AMS)

� Extension of compliance date

Source: https://homeport.uscg.mil

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ILO MLC 2006: First National Reports (FNR)

� Overview

� Focusing on certification of seafarers’ working and living conditions on ships

� Entered into force for 30 members on August 2013

� Ratified by 65 members as of November 2014

� General Observation

� FNR requested from 32 members

� Report lists deficiencies which led to detention of ships

� Significant level of implementation in practice

� Consistency of application

� Implementation and national tripartite consultation

� DMLC Part I – incorrect references, no additional information

� DMLC Part II – reference other documents

� Exemptions are to limited extend where expressly permitted by MLC

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� General Observation

� Recruitment and placement

� Seafarer’s employment agreement

� Technical assistance for implementation

� Moving Forward

� New form for national reporting – electronic

� Recruitment and placement services to comply with convention

� Original employment agreement

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Implementation of SOLAS: Noise Code

� Application to new ships ≥ 1600 gt with

� Contract Date, CD ≥ 1 July 2014;

� Keel Laid, KL > 1 Jan. 2015, if no CD, or

� Delivered > 1 July 2018 (regardless of CD or KL date)

� Ships in port or at sea

� Exceptions

� Limitations for ships on short duration voyages

� High-speed craft

� Pile drivers / dredgers

� MODUs

� Fishing vessels

� War ships

� Crane barges

� Pleasure yachts (non commercial)

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Implementation of SOLAS: Noise Code

� Verification at the time of delivery/sea trial

� Noise measurement by firms approved per IACS UR Z17(final draft under IACS review)

� Noise survey report for that ship

� Hearing protection and warning notices

� Noise levels measured during sea trials at normal service speed (not < 80% MCR)

� Verification after the delivery

� Availability of Noise Survey Report

� Hearing protection

� Warning notices

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