Key items at MEPC 73, 22-26 October 2018
The 73rd session of the IMO’s Marine Environment Protection Committee (MEPC 73) took place on 22-26 October 2018 in London, presided over by Hideaki Saito (Japan) as chair and Harry Conway (Liberia) as vice-chair.
Below is a summary of the key outcomes of the session.
Implementation of the new sulphur rules
MEPC 73 adopted an amendment to MARPOL Annex VI, thereby prohibiting, as of 1 March 2020, the carriage of fuel oil with a sulphur content exceeding 0.50% on board a ship, unless the ship is fitted with a scrubber or equivalent cleaning technology. The amendment is an important element of the efforts to ensure effective implementation and enforcement of the 0.50% sulphur limit, which will come into effect on 1 January 2020. The new sulphur rules will be applicable globally with the exception of the existing regional sulphur emission control areas (SECAs).
A proposal for a “pragmatic approach” to enforcement of the 0.50% sulphur limit for a period after the entry into force on 1 January 2020 was rejected by the Committee. A pragmatic approach would create uncertainty in the industry as to when the rules would be enforced and could potentially delay the environmental benefits of the regulation.
Furthermore, a number of countries had proposed the introduction of an experience-building phase (EBP) after 1 January 2020 to enable ships to gain experience with the new types of fuel, and taking a pragmatic approach to enforcement during this phase as well. The proposers emphasised that the proposal was not intended to delay the implementation. Several countries backed the proposal, while others – including Denmark – opposed it, because such a phase would cause uncertainty in the industry and, in effect, delay the implementation of the 0,50% sulphur limit. Against this background, the Committee rejected the proposed experience-building phase; however, a data gathering phase was approved to accommodate fuel quality concerns. Accordingly, the IMO’s Secretariat will gather and analyse data on the availability and quality of compliant fuel oil with a view to ensuring effective implementation of regulation 18 of MARPOL Annex VI. It should be noted in this respect that the data collection will be based on the reporting already mandatory for member states under the above-mentioned regulation. The starting date and duration of the data gathering will be decided at the Committee’s next session (MEPC 74).
Fuel oil quality
In continuation of the ongoing preparations for implementation of the new sulphur rules in 2020, the Committee approved “Guidance on best practice” for fuel oil suppliers. Among other things, the document contains recommendations for suppliers to establish a quality assurance system and ensure traceability throughout the supply chain. Denmark supported the document, which may contribute to ensuring the quality of fuel oil delivered to ships.
A similar document aimed at member states regarding their responsibilities towards fuel oil suppliers was also discussed. The subject had been examined by a correspondence group, but the document from the correspondence group contained a number of unresolved issues, particularly in respect of how member states should assure the quality of fuel oil. Therefore, the working group was unable to finalise the work, and it was decided to set up a new correspondence group charged with developing the document.
Use of heavy fuel oil (HFO) by ships in the Arctic
Heavy fuel oil (HFO) spills in Arctic waters pose a risk to the marine environment and coastal ecosystems. Rising Arctic shipping traffic as a result of ice melting, new raw material projects and tourism is expected to increase the risk of HFO spills in Arctic waters. The use of HFO also contributes to black carbon (soot) emissions, one result of which is increased ice melting in polar areas. The Committee had previously decided that the Sub-Committee on Pollution Prevention and Response (PPR) should prepare a proposal for a possible ban on the use and carriage of HFO as fuel on ships in the Arctic and that the proposal should be based on an impact assessment of a ban on Arctic communities.
On that basis, a number of proposals for the scope and methodology of the impact assessment, as well as for the data to be included, had been submitted prior to this session. Common to several proposals was the notion that an impact assessment should consider economic, environmental and social impacts and that it should be based on existing data to the widest possible extent.
Denmark supported the IMO’s work to develop a possible ban and emphasised the need for the impact assessment to take particular account of Arctic communities and economies.
It was decided that the impact assessment is to be conducted by the PPR Sub-Committee at its next meeting in early 2019, and interested parties were invited to submit impact assessments already made prior to this meeting to enable specific discussions of the impacts on the Arctic communities.
Greenhouse gas reductions
In April 2018, the IMO adopted an initial strategy on the reduction of greenhouse gas (GHG) emissions. As a follow-up on this strategy, the Committee adopted an action plan for the work up to 2023. The action plan is a time schedule, i.a. for the technical work of implementing reduction measures in the short, medium and long term as well as a plan for the preparation of impact assessments of the reduction measures. One aim of the time schedule is to prioritise reduction measures that may have an impact before 2023. At this session, the Committee also had an initial discussion of proposals for specific reduction measures such as strengthening of the Ship Energy Efficiency Management Plan (SEEMP).
Moreover, the Committee had an initial discussion of the preparations for the Fourth IMO GHG Study, which is to be initiated at the next session in the first half of 2019. The study is intended to reduce uncertainties as regards estimates and scenarios for GHG emissions from shipping and will be important in relation to the level of ambition of the revised GHG strategy set for approval in 2023.
As the next step in this field, a fifth meeting of the Intersessional Working Group is expected to be held in the week just prior to MEPC 74. At this meeting, the concrete work of the short, medium and long-term reduction measures will be initiated. In addition, procedures for impact assessments of measures will be discussed.
The Committee discussed the outcome of the work of a correspondence group set up at MEPC 71 in 2017. The correspondence group had examined the current status of the technological development of ships and thereby the possibilities for strengthening the Energy Efficiency Design Index (EEDI), which, in three phases so far, gradually tightens the requirements for the energy efficiency of new ships.
The correspondence group had prepared an interim report for this session on the possibility of shortening phase 2, bringing forward phase 3 from 2025 to 2022 and introducing new reduction rates in phase 3. The Committee could not reach agreement on these matters, and the decision was deferred to MEPC 74. The correspondence group will continue this work and will also discuss a possible introduction of a new phase 4.
The requirements of the IMO’s data collection system for fuel oil consumption of ships were introduced in MARPOL Annex VI on 1 March 2018. The system is mandatory for ships of 5,000 gross tonnage and above. As from 2019, the ships will be required to submit data annually to the IMO through their flag state/recognised organisation on total fuel consumption, distance travelled and time at sea. The ships will therefore need to update their existing Ship Energy Efficiency Management Plan (SEEMP). To avoid a situation where all ships submit their revised plans for approval immediately before the system enters into force, the MEPC adopted at its last session in April 2018 a circular on timely submission of the SEEMP. This request was reiterated at this session as a large number of ships worldwide have still not submitted their plans. The data for the data collection system is submitted through the IMO’s GISIS module, where user guidance on the module is also available. The data will be included in the IMO’s continued work regarding reduction of GHG emissions from ships. The system is the first step of a three-step plan, the second step being an analysis of the data submitted, followed by a decision on what further measures to take to reduce carbon emissions from shipping, which will also be included in the work on a revision of the IMO’s initial strategy on the reduction of GHG emissions.
Amendments to MARPOL Annex II (paraffin)
Under the current regulations set in MARPOL Annex II, ships are permitted to clean paraffin from their tanks and then discharge the tank washings directly into the sea. The paraffin may subsequently wash ashore to the detriment of the environment and tourism. Furthermore, the subsequent clean-up of the beaches poses a financial burden.
Since 2013 the IMO has been working to amend these rules so that tank cleaning involving highviscosity substances, including paraffin, is required to take place at the port and that the tank washings must subsequently be discharged to a reception facility at the port. This will prevent discharges into the sea and thus also paraffin from washing up on the shores.
The Committee approved the draft amendments to MARPOL Annex II. The proposal will be submitted for adoption at MEPC 74.
Marine plastic litter from ships
At its previous session, the Committee agreed that an action plan on marine plastic litter from ships should be developed at this session. The proposals submitted were wide in scope, covering issues such as waste management on board ships, port reception facilities, waste related to fishing and loss of containers. Denmark is interested in an ambitious action plan and finds that this work may contribute to achieving compliance with UN resolutions on marine litter and micro plastics as well as Target 14.1 related to Life below Water. This is the first time the issue of marine plastic litter is addressed in an IMO setting.
The Committee discussed the many proposed actions and prepared on that basis an initial action plan containing a total of 30 actions. They are grouped in the plan according to focus areas and include reduction of marine plastic litter from fishing vessels, reduction of marine plastic litter from merchant vessels, improvement and efficiency enhancement of port reception facilities as well as improved education and training and increased awareness of the issue among future seafarers. The individual actions will now be prepared in detail by the relevant technical bodies of the IMO.
In connection with type approval, issue of certificates and self-monitoring of ballast water management systems, the Committee adopted the new Guidance on System Design Limitations (SDL) (BWM.2 circular).
Also, a draft guidance regarding commissioning of ballast water management systems for ships was adopted, which contains a simple indicative test of ballast water management systems (BWM.2 circular).
The existing Guidelines (G4) concerning ships’ ballast water management plans were amended so that any contingency measures, for instance in case of failure of a ballast water management system, may be incorporated in the plan.
Denmark contributed to keeping ballast water on the agenda of the MEPC in the period 2019-2023 as part of the experience-building phase (EBP) adopted.
The next session of the Committee, MEPC 74, will be held in the first half of 2019.