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The decision to recommend a ban on ships’ burning heavy fuel oil in the Arctic was the headline story for much of the coverage of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR) deliberations in London last week, but the meeting also produced important agreements on guidelines for fuel oil sampling and scrubbers.

Arctic rules

In a statement posted on its website, the IMO clarified that the PPR Sub-Committee agreed draft amendments to MARPOL Annex I (addition of a new regulation 43A) which are recommending a prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters on and after 1 July 2024.

As Bunkerspot reported yesterday (25 February), the Sub-Committee's recommendations did allow for some exemptions. The IMO summary explained: ‘The prohibition would cover the use and carriage for use as fuel of oils having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s.

‘Ships engaged in securing the safety of ships, or in search and rescue operations, and ships dedicated to oil spill preparedness and response would be exempted. 

‘Ships which meet certain construction standards with regard to oil fuel tank protection would need to comply on and after 1 July 2029.

‘A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that Party's sovereignty or jurisdiction, up to 1 July 2029.’

The draft amendments will be submitted to the 76th meeting of the Marine Environment Protection Committee (MEPC 76), which will take place on 19-23 October, with a view to approval and circulation for adoption at MEPC 77 in the spring of 2021.

The PPR Sub-Committee has also established a correspondence group to ‘further develop draft guidelines on measures to reduce risks of use and carriage of HFO as fuel by ships in Arctic waters’.

Sampling guidelines agreed

To support the IMO 2020 0.50% sulphur cap – and the ban on the carriage of non-compliant fuel which comes into effect on 1 March - the PPR Sub-Committee finalised draft guidelines ‘which provide a recommended method for the sampling of liquid fuel oil intended to be used or carried for use on board a ship’.

The IMO statement said that the draft guidelines will now go forward to MEPC 75, which meets from 30 March to 3 April 2020, with a view to adoption.

Revised scrubber guidelines agreed

The IMO confirmed that the PPR Sub-Committee finalised the work on revising the 2015 guidelines for scrubbers – and these revisions will also be submitted to MEPC 75 for adoption.

According to IMO: ‘The Guidelines specify the criteria for the testing, survey, certification and verification of exhaust gas cleaning systems (EGCS) under regulation 4 of MARPOL Annex VI to ensure that they provide effective equivalence to the sulphur oxide emission requirements of regulations 14.1 or 14.4 of MARPOL Annex VI, as applicable. They cover continuous monitoring requirements and discharge water quality criteria, including minimum pH, maximum PAHs (Polycyclic Aromatic Hydrocarbons) concentration; provisions to minimize suspended particulate matter, including heavy metals and ash, and to prevent discharge of nitrates beyond specified levels.’

A key area of controversy with scrubbers has been the discharge of wash-water from open-loop systems – and this issue was addressed at last week’s meeting. According to the IMO: ‘The Guidelines note that discharge water quality criteria should be reviewed in the future as more data becomes available. Guidance for voluntary discharge water data collection, by means of a recommended procedure for sampling, is included. 

‘The Guidelines are expected to be applied to new exhaust gas cleaning systems installed after a date to be decided by the Committee.’

The IMO statement noted that the MEPC in its last session in May 2019 asked the PPR Sub-Committee to look into evaluating and harmonizing rules and guidance on the discharge of liquid effluents from scrubbers.

The IMO summarised the current status:-

‘To assist the discussions, a report from a task team established by the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) was submitted. This report contains the conclusions of the task team in relation to the available evidence on the environmental effects of discharge water from EGCS, as well as recommendations on the data, tools and approaches that could be used as basis for conducting a risk assessment of the possible effects of discharges.

‘Following discussion in a working group, the Sub-Committee agreed to recommend to the MEPC that its future work should look at evaluation and harmonization of rules and guidance on the discharge of discharge water from EGCS into the aquatic environment, including conditions and areas.

‘The scope of the work should include:

  • 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). 

‘The MEPC was invited to approve the planned scope of work and to consider involving GESAMP for scientific advice.’  

Black Carbon emissions

The IMO and the PPR Sub-Committee have studied in impact of ‘black carbon’ – which in the context of shipping is the ‘product of incomplete combustion of carbon-based fuels’ – and  a reporting protocol for voluntary measurement studies to collect Black Carbon data and Black Carbon measurement methods for data collection have already been agreed.

Summarising where we are now after PPR7, the IMO said: ‘The Sub-Committee noted a number of submissions, including proposals to look at the aromatic content of blends of fuel oil. A high aromatic content, among other factors, could increase Black Carbon emissions from ships.

‘The International Standardization Organization (ISO) advised the Sub-Committee that it was already in the process of monitoring properties of very low sulphur fuel oil and high sulphur fuel oil and would provide feedback on their performance. ISO also advised the Sub-Committee that it would also consider whether it was possible to add a further measure to provide an approximate indication as to whether a fuel is more paraffinic or aromatic, based on the characteristics already included in the ISO 8217 standard, which specifies the requirements for fuels for use in marine diesel engines and boilers.

‘The Sub-Committee established a correspondence group to advance the development of a standardized sampling, conditioning, and measurement protocol, including a traceable reference method and an uncertainty analysis, taking into account the three most appropriate Black Carbon measurement methods (light absorption filter smoke number (FSN);  photo-acoustic spectroscopy (PAS); and laser induced incandescence (LII)), to make accurate and traceable (comparable) measurements of Black Carbon emissions; and investigate the linkages between the measurement systems and policy options.’

Anti-fouling and BWS

The Sub-Committee also finalised 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, and agreed revised guidance on the commissioning testing of ballast water management systems.




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