29395260 technical and operational for bulk carriers[1]

Technical and Operational Update for

Bulk Carriers

INTERCARGO

International Association of Dry Cargo Shipowners

March 2006 Issue One

Photograph front cover courtesy of Bocimar

INTERCARGO

Technical and Operational Update for Bulk Carriers

March 2006 Issue One

Acknowledgement

INTERCARGO is grateful to the Members of its Safety, Technical and Environ-mental Committee (CASTEC) for contribution in the drafting process of this pub-lication. Appreciation also goes to the INTERTANKO Safety, Technical and Environmental Committee (ISTEC) for the comments and suggestions received. The valuable information from the following source is unique and relevant to many common interest issues:

http://www.intertanko.com

All rights reserved. No part of this publication may be reproduced in any material form (including photocopying or storing it in any medium by electronic means and whether or not transiently or incidentally to some other use of this publica-tion) without the written permission of the copyright owner. Applications for the copyright owner’s written permission to reproduce any part of this publication should be addressed to the publisher.

© INTERCARGO 2006

Whilst every effort has been made to ensure that the information contained in this publication is correct, neither the authors nor INTERCARGO can accept any re-sponsibility for any errors or omissions or any consequences resulting therefrom. No reliance should be placed on the information contained in this publication without independent verification.

www.intercargo.org

INTERCARGO St Clare House, 30-33 Minories,

London EC3N 1DD Tel: + 44 (0) 20 7977 7030 Fax: +44 (0) 20 7977 7031 Email: [email protected]

INTERCARGO


Page

Air Pollution Prevention - MARPOL Annex VI…………. 5

Ballast Water Management……………………………… 12

Bunkers - MARPOL Annex VI and EU Directive ……… 8

Cargoes - Dangerous……………………………………. 30

Cargoes - Direct Reduced Iron………………………….. 32

Cargoes - Petcoke……………………………………….. 19

Cold Ironing……………………………………………….. 10

Emergency Towing………………………………………. 33

Entry into Force …………………………………………. 1

IACS Common Structural Rules………………………... 28

Lifeboats…………………………………………………… 9

MARPOL Special Areas…………………………………. 27

Oily Water Separators …………………………………… 40

Particularly Sensitive Sea Areas……………………….. 9

Pilotage - Denmark ……………………………………… 34

Reception Facilities - Baltic……………………………… 21

Ship Recycling……………………………………………. 37

Index of Abbreviations……………………………………. 42

Contents

INTERCARGO International Association of Dry Cargo Shipowners

FOREWORD It gives me great pleasure to be associated with Intercargo’s initiative to publish a sum-mary of regulatory developments and other useful guidance designed to promote safety in the bulk carrier sector. Many countless hours have been spent in developing Regulations and Conventions, both nationally and in the main international fora of the IMO and IACS. “Best practice” ex-amples are increasingly being communicated to industry through international and na-tional shipping associations. Although the result of this regulation and self-regulation has seen a markedly safer bulk carrier industry, re-emphasising these new developments will undoubtedly increase the knowledge base of the dry bulk supply chain. This document, which will be published regularly after the introduction of significant developments at both IMO and IACS, is equally commended to Technical Departments and those providing commercial and strategic direction in the industry as a means of un-derstanding the interlinking nature of issues. I commend the foresight in producing a published record suitable for the bulk carrier sector and look forward to the issuance of future editions.

March 2006

Tom Allan Former Chairman of the IMO Maritime Safety Committee

The dry bulk cargo residue will be treated as gar-bage. The residue and cargo hold wash water should be treated carefully in accordance with the relevant national, regional and international re-quirements and regulations.

Relevant information:

Intercargo Guide on compliance with MARPOL Annex V. Contact [email protected] for more information.

1 Jan 2006: entry into force 4.1 Amendments to SOLAS chapter II-1 concerning means of access for inspections within spaces in the cargo area of oil tankers and bulk carriers, adopted by Resolution MSC.151(78). Contact [email protected] for the sources of the document. 4.2 Amendments to the Technical Provisions for Means of Access for Inspections, adopted by Resolution MSC.158(78). Contact [email protected] for the source of the document.


IACS Unified Interpretations (UI) SC 191for the application of amended SOLAS regulation II-1/3-6 (Resolution MSC.151(78)) and revised Technical Provisions for Means of Access for Inspections (Resolution MSC.158(78)). Contact [email protected] for the source of the docu-ment.

4.3 Revised NAVTEX Manual. The relevant circular MSC/Circ.1122 on the Revised NAVTEX Manual is available for download from http://www.imo.org/home.asp. 4.4 Early implementation and guidance on safety dur-ing abandon ship drills using lifeboats and the Guide-lines for simulated launching of free-fall lifeboats. MSC 79 urged Member Governments to give effect to the amendment to SOLAS regulation III/19.3.3.3, adopted by Resolution MSC.152(78), prior to 1 July 2006 (which is the amendment’s entry into force date) and approved MSC circular MSC/Circ.1127 on Early Implementation of Amendment to SOLAS Regulation

The index contains currently available requirements and regulations relevant to bulk carriers with entry into force dates from 19 May 2005 to 1 Jan 2009. It will be updated periodically with new items of requirements and regula-tions when they are adopted and their entry into force dates are fixed. 19 May 2005: entry into force 1.1 MARPOL Annex VI: Air Pollution Prevention.


Circular IMO MEPC/Circ.472 on Guidelines for Port State Control under MARPOL Annex VI (Resolution MEPC.129(53)). It is available for download from http://www.imo.org/home.asp.

Intercargo Guide on C125 ompliance with MARPOL Annex VI - Air pollution prevention. Contact [email protected] for the full text of an up to date version.

22 Jul 2005: entry into force 2.1 Resolution MEPC.130(53) - Guidelines for On-Board Exhaust Gas-SOx Cleaning Systems. Contact [email protected] for the source of the document. 1 Aug 2005: entry into force 3.1 Revised MARPOL Annex IV on Regulations for the prevention of pollution by sewage from ships, adopted by Resolution MEPC.115(51). Contact [email protected] for the source of the document.

Annex IV may cause difficulties for ships without a holding tank in certain ports, such as in Korea and the Black Sea region. IMO may develop relevant port State control guidelines for the implementation of An-nex IV in the future.

3.2 MARPOL Annex V: Amendments to MARPOL An-nex V on “cargo residues” to the Form of the Garbage Re-cord Book contained in the Appendix to MARPOL Annex V on Regulations for the prevention of pollution by gar-bage from ships, adopted by Resolution MEPC.116(51). Contact [email protected] for the source of the docu-ment.

INTERCARGO Technical and Operational Update for Bulk Carriers

Entry into Force - Index of New Requirements to be Implemented

March 2006 Issue One ■ 1

Circular MSC/Circ.1145 on Precautionary Advice to Masters When Undertaking Ballast Water Exchange Operations.

5.3 The adopted amendments to SOLAS chapters II-1, by Resolution MSC.170(79). Contact [email protected] for the source of Resolution MSC.170(79) and the amendments. The amendments were made in: • Regulation 2 - Definitions of bulk carrier; • Regulation 18 - Construction and initial tests of wa-tertight doors, sidescuttles, etc., in passenger ships and cargo ships; and • Regulation 45 - Precautions against shock, fire and other hazards of electrical origin 5.4 Amendment to SOLAS Chapter III (Life-Saving Appliances and Arrangements) The following new paragraph 1.8 is added after the exist-ing paragraph 1.7:

“1.8 Notwithstanding the requirements of paragraph 1.1, bulk carriers as defined in regulation IX/1.6 con-structed on or after 1 July 2006 shall comply with the requirements of paragraph 1.2.”.

5.5 Amendments to Chapter V (Safety of Navigation) In paragraph 2.5 of Regulation 19 (Carriage requirements for shipborne navigational systems and equipment), the existing text of subparagraph .1 is replaced by the follow-ing:

“.1 a gyro compass, or other means, to determine and display their heading by shipborne non-magnetic means, being clearly readable by the helmsman at the main steering position. These means shall also transmit heading information for input to the equipment referred in paragraphs 2.3.2, 2.4 and 2.5.5;”

The following new paragraph 2, regulation 20 (Voyage data recorders) is added after existing paragraph 1: “2 To assist in casualty investigations, cargo ships, when engaged on international voyages, shall be fitted with a VDR which may be a simplified voyage data recorder (S-VDR) as follows:

.1 in the case of cargo ships of 20,000 gross tonnage and upwards constructed before 1 July 2002, at the first scheduled dry-docking after 1 July 2006 but not later than 1 July 2009; .2 in the case of cargo ships of 3,000 gross tonnage and upwards but less than 20,000 gross tonnage con-

III/19.3.3.3 adopted by Resolution MSC.152 (78). Contact [email protected] for the source of Resolution MSC.152(78). The relevant circular MSC/Circ.1127 is available for download from http://www.imo.org/home.asp. 1 Jul 2006: entry into force 5.1. Amendments to SOLAS Chapter III, adopted by Resolution MSC.152(78). Refer to 4.4 above. Resolution MSC.152(78) adopted amendments to: - Chapter III Life-Saving Appliances and Arrangements in:

Regulation 19 - Emergency training and drills Regulation 20 - Operational readiness, maintenance and inspections Regulation 32 - Personal life-saving appliances (An immersion suit shall be provided for every person on board the ship).

- CHAPTER IV Radiocommunications in: Regulation 15 - Maintenance requirements.

5.2 Amendments to SOLAS Chapter XII (Additional Safety Measures for Bulk Carriers). Contact [email protected] for the source of the revised Ch XII. In relation to the entry into force of the revised Ch XII, the following Resolutions have the same entry into force date:

Resolution MSC.168(79) - Standards and Criteria for Side Structures of Bulk Carriers of Single-Side Skin Construction; and Resolution MSC.169(79) - Standards for Owners’ In-spection and Maintenance of Bulk Carrier Hatch Cov-ers.

Contact [email protected] for the source of the MSC.169(79) and MSC.168(79). Relevant circulars (effective when issued and available for download from http://www.imo.org/home.asp):

Circular MSC/Circ.1135 on As-Built Construction Drawings to Be Maintained On Board the Ship and Ashore, 15 December 2004; Circular MSC/Circ.1143 on Guidelines on Early As-sessment of Hull Damage and Possible Need for Aban-donment of Bulk Carriers; and

2 ■ March 2006 Issue One


were adopted by Resolution MSC.194(80). Contact [email protected] for the source of annex 1 to Reso-lution MSC.194(80). The amendments are in:

Regulation 3-2: Corrosion prevention of seawater ballast tanks in oil tankers and bulk carriers (This regulation applies to oil tankers and bulk carriers constructed on or after 1 July 1998); Regulation 3-7: The amendment includes Construc-tion drawings maintained on board and ashore; Regulation 3-8: Towing and mooring equipment; and Regulation 23-3: Water level detectors on single hold cargo ships other than bulk carriers.

7.2 Amendments to the Guidelines on the Enhanced Programme of Inspections during Surveys of Bulk Car-riers and Oil Tankers (Resolution A.744(18), as amended) by Resolution MSC.197(80). Contact [email protected] for the source of Resolution MSC.197(80). 7.3 The revised MARPOL Annex II, as adopted by Resolution MEPC.118(52), is expected to enter into force on 1 January 2007. Contact [email protected] for the source of Resolution MEPC.118(52). 1 Jan 2008: amendment of entry into force 8.1 Under the terms of the ASF Convention (International Convention on the Control of Harmful Anti-fouling Systems on Ships ), by 1 January 2008 (effective date), ships shall either:

(a) not bear such compounds on their hulls or external parts or surfaces; or

(b) bear a coating that forms a barrier to such com-pounds leaching from the underlying non-compliant anti-fouling systems.

1 Jan 2009: amendment of entry into force 9.1 Amendments to SOLAS chapter II-1 parts A, B and B-1, II-2, VI, IX, XI-1, XI-2.

The amendments to SOLAS chapter II-1 parts A, B and B-1, II-2, VI, IX, XI-1, XI-2 were adopted by Resolu-tion MSC.194 (80). Contact [email protected] for the source of Resolution MSC.194(80). The reasons for the entry into force date:

As the revised SOLAS chapter II-1 introduces a fundamental change to the way ships are de-signed and would have a significant effect on

structed before 1 July 2002, at the first scheduled dry-docking after 1 July 2007 but not later than 1 July 2010; and .3 Administrations may exempt cargo ships from the application of the requirements of subparagraphs .1 and .2 when such ships will be taken permanently out of service within two years after the implementation date specified in subparagraphs .1 and .2 above.”

5.6. Unified interpretation of SOLAS Chapter XII

MSC 80 agreed to the need to provide ship designers with interpretations of the revised SOLAS chapter XII, before its entry into force. At its twenty-fourth regular session of the IMO Assembly (A24), the unified interpretations of the regulations 6.5.1 & 6.5.3 were adopted. IMO circular SLS.14/Circ.250 with the unified interpretations is avail-able for download from http://www.imo.org/home.asp.

Note: The IACS Common Structural Rules will be imple-mented to tankers and bulk carriers contracted for con-struction on or after 1st April 2006. IACS believe that the objective of removing competition on scantlings for each ship type has been achieved. The IACS Council also en-dorsed a long-term harmonisation plan between the tanker and bulk carrier rule sets at its meeting in Dec 2005.

22 Nov 2006: amendment of entry into force 6.1 Amendments to MARPOL Annex VI and the NOx Technical Code by Resolution MEPC.132(53). Contact [email protected] for the source of the Resolution MEPC.132(53).

Amendments to MARPOL Annex VI are the introduction of the Harmonized System of Survey and Certification (HSSC) and the introduction of the North Sea as a new SOx Emission Control Area (SECA), (Regulation 14(3)(a)).

6.2 Amendments to the revised Survey Guidelines under the Harmonized System of Survey and Certification (Resolution A.948(23)) for the purpose of MARPOL An-nex VI by Resolution MEPC.128(53).

The Resolution MEPC.128(53) was adopted on 22 July 2005. IMO invited Governments to apply the Guidelines, as soon as possible. Contact [email protected] for the source of Resolution MEPC.128(53).

From 1 January 2007: amendment of entry into force 7.1 Amendments to SOLAS chapter II-1 parts A-1 and C. The amendments to SOLAS chapter II-1 parts A-1 and C



10.2 circular MSC/Circ.1142 - MEPC/Circ.425 on Marking the ship’s plans, manuals and other docu-ments with the IMO ship identification number. The circular is available for download from http://www.imo.org/home.asp. 10.3 Resolution MSC.200(80)- Amendments to the revised recommendation on testing of life-saving ap-pliances. Contact [email protected] for the source of Resolution MSC.200(80).

Governments are recommended to apply the amendments to the Revised recommendation on testing of life-saving appliances (Resolution MSC.81(70)), when testing life-saving appliances.

IMO Circulars (available for download from http://www.imo.org/home.asp):

MSC/Circ.1140 - MEPC/Circ.424 on Transfer of ships between States.

Amendments to the FAL/MEPC/MSC circular FAL/Circ.90 - MEPC Circ.368 - MSC Circ.946 on list of certificates and documents to be carried on board ships.

MEPC/Circ.472 on Guidelines for Port State Con-trol under MARPOL Annex VI (Resolution MEPC.129(53)).

MEPC/Circ.469 on Revised consolidated format for reporting alleged inadequacy of port reception facilities - an effort to improve the rate of report-ing of alleged reception facility inadequacies so that the problem can be tackled more effectively.

MSC/Circ.1108 on Guidelines for assessing the longitudinal strength of bulk carriers during load-ing, unloading and ballast water exchange.

MSC/Circ.1114 on Guidelines for periodic test-ing of immersion suit and anti-exposure suit seams and closures.

MSC/Circ.1115 on Prevention of accidents in high free-fall launching of lifeboats.

MSC/Circ.1117 on Guidance for checking the structure of bulk carriers.

STCW.7/Circ.14 on Guidance for masters on keeping a safe anchor watch.

SN/Circ.245 on Amendments to the Guidelines for the installation of a shipborne automatic identification system (AIS) (SN/Circ.227).

MSC/Circ.1145 on Precautionary advice to masters when undertaking ballast water exchange opera-tions.

MSC/Circ.1159 on Guidelines on the provision of stability-related information for bulk carriers.

MSC/Circ.1119 on Ship/Terminal Interface Im-provement for Bulk Carriers.

MSC/Circ.1135 on As-Built Construction Drawings to Be Maintained On Board the Ship and Ashore, 15 December 2004.

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shipbuilders and ship operators, there is a need for suf-ficient time before the revised chapter II-1 enters into force in order that shipbuilders and ship operators can develop and optimize new designs before such entry into force; and The time period between the adoption of amend-ments to SOLAS chapter II-1 and their entry into force should be sufficient for the DE Sub-Committee to deal with consequential amendments to SOLAS chapter III, in particular to SOLAS regulation III/21.1.2, so that the draft amendments to SOLAS chapter II-1 under consideration at this session and proposed amendments to SOLAS chapter III, when developed by the DE Sub-Committee and adopted by MSC, could enter into force simultaneously.

9.2 Annex 2 to Resolution MSC.198(80) - Amendments to the Format and Guidelines for the Maintenance of the Con-tinuous Synopsis Record (CSR). Contact [email protected] for the source of Resolution MSC.198(80).

The amendments require the use of Registered Owner ID Number and Company ID Number.

9.3 Resolution MSC.194(80) - Amendments to SOLAS Ch XI-1include a new regulation 3-1 Company and Regis-tered Owner ID number. Contact [email protected] for the source of Resolution MSC.194(80). 9.4 Resolution MSC.195(80) - Amendments to ISM Code: Company Identification Number to be added in the DOC and SMC Certificates. Contact [email protected] for the source of Resolution MSC.195(80). 9.5 Resolution MSC.196(80)- Amendment to ISPS Code: Company identification number to be added in the Ship Security Certificates. Contact [email protected] for the source of Resolution MSC.196(80). Voluntary requirements 10.1 Resolution MSC.160(78) on “Adoption of the IMO unique company and registered owner identifica-tion number scheme” requires voluntary implementation before the requirements are made mandatory from 1 Jan 2009. Contact [email protected] for the source of Reso-lution MSC.160(78).

MSC 78 adopted the IMO unique company and regis-tered owner identification number scheme for implemen-tation on a voluntary basis. The Resolution recommends Governments concerned to voluntarily implement the scheme as far as is practicable, and to inform IMO of measures taken in this respect.



strate that while the ship is passing through a SOx emission control area (SECA) it is either:

(4) (a) using fuel which has a sulphur content not exceeding 1.5% m/m, or

(4) (b) using an approved exhaust gas cleaning de-vice or any other technological method which en-sures that the total emission of sulphur oxide from the ship does not exceed 6.0 g SOx/kW h;

III. Regulation 14(6) for those ships using separate fuels to comply with Reg14(4)(a) records must be kept on the completion of any fuel change-over procedure when entering and leaving a SECA to verify compli-ance. The records shall include the date, time and position of the ship when the fuel change-over is complete. It shall also record the quantity of the low sulphur fuel in each tank;

IV. Regulation 18(4), which states that the ship is to re-tain the BDN, readily available for inspection, on board the ship for a minimum of 3 years;

V. Regulation 18(6), which states that the Annex VI sample is to be retained under the ship’s control until the fuel is substantially consumed, but in any case for a period of not less than 12 months from the time of delivery; and

VI. Resolution MEPC.96(47), which requires that the ship’s master should develop and maintain a system to keep track of the retained samples.

2.2) Bunker delivery notes and fuel samples. MEPC 53 endorsed that “it was clear that a ship, which has on board only non compliant fuels, would be asked to obtain compliant bunker fuels before leaving port.” As raised at the last Intercargo Safety, Technical and Envi-ronmental Committee (CASTEC) meeting in June 2005 in Hong Kong and the Follow-up Action No. 12 (FUA 12) , members are concerned about what will happen if the ship could not get the required sample and relevant documenta-tion when receiving PSC inspection at ports of the 20 or so signatory States of MARPOL Annex VI. MEPC 53 recognized that Annex VI places requirements on ship owners in respect of bunker delivery notes and representative samples of the fuel delivered. If the country of fuel oil supply is not a Party to the 1997 Protocol, then the required bunker delivery note or the representative sample may not be available. It also noted the concern about problems relating to ships that cannot obtain the appropriate documentation - the bunker delivery note and the representative sample(s) of fuel delivered, when bun-kering in ports and terminals under the jurisdiction of non-

1. Background MARPOL Annex VI was adopted in 1997 and entered into force on 19 May 2005. In the 8 years since the adoption of Annex VI, there have been significant technical advances in the control of harmful emissions from diesel engines, including marine engines. Since 2000, virtually all new ship engines have met or exceeded Annex VI requirements for nitrogen oxides (NOx). There has been an MEPC project on monitoring the worldwide average of sulphur content of residual fuel oil ever since MEPC 45 (2-6 Oct 2000). The information of the project for 2004 as provided by the Netherlands (MEPC 53/4) has the conclusion that the three year (2002-2004) rolling average can be established as 2.67%, which is identical to the previous three years average. Subsequent to the entry into force of MARPOL Annex VI regulating emissions from ships, MEPC 53 agreed to delegate to the IMO Sub-Committee on Bulk Liquid and Gases (BLG) the revision of MARPOL Annex VI by April 2006 with the aim of reducing further the limits. The preliminary indications at MEPC 53 are that all cur-rent emissions limits would be subject to revision and, in addition, it is proposed that elements like Particulate Mat-ters (PM) be added to the convention. The revision proc-ess would also aim to bring greater clarification through amendments to the current provisions, particularly to the NOx Technical Code. 2. Areas of possible difficulties and problems 2.1) What Masters are required to do. Vessels must retain the bunker sample for minimum of 1 year. The BDN (Bunker Delivery Note) must be retained on board for 3 years. If the vessel’s flag is a signatory State of MARPOL Annex VI, the vessel must comply with Annex VI regardless of where they purchase their fuel. Ship’s Master is to comply with: I. Regulation 14(1), which states that the sulphur con-

tent of any fuel used on board shall not exceed 4.5% m/m (mass of sulphur per mass of fuel);

II. Regulation 14(4), which requires ships to demon-

Air Pollution Prevention - Guide on Compliance with MARPOL Annex VI



between the supplier and the receiver, and that according to MARPOL Annex VI, the ship is responsible for docu-mentation of the fuel oil quality on board and used. MEPC 53 agreed to urge countries, which are not Parties to MARPOL Annex VI, to institute relevant measures in order that ships are provided with the necessary bunker delivery note and representative samples of the fuel oil delivered. With regard to ships flying the flags of non signatory States to MARPOL Annex VI, those ships may have ob-tained a certification or document of compliance by a Classification Society, MEPC 53 noted that para 3.3 of the draft PSC Guidelines for MARPOL Annex VI stipu-lates that “……, the PSCO may take such documentation into account in the evaluation of the ship”. Paragraphs relating to the above Bunker Delivery Note issue in the PSC Guidelines are:

Chapter 2: 2.1.1.8 any notification to the ship’s flag Administra-tion issued by the master and the officers in charge of the bunkering operation crew together with any avail-able commercial documentation relevant to non-compliant bunker delivery. 2.1.4bis In the case where the bunker delivery note or the representative sample as required by regulation 18 of this Annex presented to the ship are not in compli-ance with the relevant requirements, the master or the officers in charge of the bunkering operation should have documented that through a Notification to the ship’s Flag Administration with copies to the port au-thority under whose jurisdiction the ship did not re-ceive the required documentation pursuant to the bun-kering operation and to the bunker deliverer. A copy should be retained onboard the ship, together with any available commercial documentation, for the subse-quent scrutiny of port State control. 2.3.2.3 the sulphur content of any fuel oil being used on board exceeds 4.5% m/m.

2.4) Letter of Protest. In event that either the BDN or the statutory sample, or both, have been found to be non-compliant, a Letter of Protest (LOP) should be issued in accordance with the ship’s standing instructions. It is recommended that the ship’s flag administration is consulted as to whether they have any procedural requirements for LOP. If no standing instructions exist then it is recommended that 4 or more copies of the LOP may be issued. One to the supplier, one to the port State Authority overseeing

Party States to MARPOL Annex VI. Suppliers are to comply with:

I. Regulation 18(7) (b), which states that the supplier is to provide a compliant BDN and a representa-tive sample of the fuel oil delieved. This sample is to be used solely for determination of compliance with Annex VI by port state authorities;

II. Resolution MEPC.96 (47) Guidelines for the sam-pling of the fuel oil, which requires that the IMO sample should be taken at the receiving ship’s bunker inlet manifold according to specified pro-cedures; and

III. Regulation 18 (1) (a) & (b), which requires the fuel to be of a specified quality.

Suppliers need to be registered with the appropriate Au-thorities and are required to provide a mandatory sample. This is to be taken by either a:

I. continuous drip sampler, II. time proportional automatic sampler, or III. flow proportional automatic sampler.

The sample should be taken at the receiving vessel’s manifold in accordance with resolution MEPC.96(47). It must be a minimum of 400ml. The sample will be accompanied by a Bunker Deliver Note (BDN). The supplier is required to retain a copy of BDN’s for 3 years. 2.3) PSC Guidelines under Annex VI. MEPC 53 noted that a number of bunker providers oper-ating under the jurisdiction of a MARPOL Annex VI non-Party State are issuing a “Bunker Certificate of Compliance” to receiving ships, in order to provide them with documentation of the fuel oil on board, in case the ship should be subject to port State control in the port of call under the jurisdiction of a MARPOL Annex VI Party. MEPC 53 confirmed that according to the applica-tion of regulations 14 and 18 of MARPOL Annex VI, it is the ship which is responsible for documenting compli-ance. Having considered the issue, MEPC 53 agreed that a Bunker Certificate of Compliance could not replace ap-propriate documentation issued by a bunker provider operating under the jurisdiction of a Party to MARPOL Annex VI. It was also agreed that it was at the discretion of the port State control Authority of a MARPOL Annex VI Party whether to accept the Certificate of Compliance or not and to take appropriate action. The IMO Secretariat has received many enquiries from both receivers and suppliers of bunker fuel oil. In re-sponse to the enquiries, the Secretariat has informed them that the issue is considered as a commercial issue



mittee (CASTEC) is carrying out a project of data col-lection and analysis, in order to report their experiences back to MEPC 58 (October 2008), using the following form:

CO2 Index reporting sheet

Fuel type includes: Diesel/Gasoil, light fuel oil (LFO), Heavy fuel oil (HFO). 4. Guidelines for On-Board Exhaust Gas (SOx) Cleaning Systems MEPC 53 adopted the Guidelines for On-Board Ex-haust Gas (SOx) Cleaning Systems (EGCS-SOx). It also endorsed the view that small engines such as life-boat engines and emergency generators would rarely, if ever, be run on high sulphur fuel and therefore will not be subject to exhaust gas scrubbing. At present it would also be inappropriate to standardize connections for delivering scrubber wash water to shore-based recep-tion facilities due to the variety of dimensions used, differing needs of different ship types and inadequate experience to date in using such a system. MEPC will address the issue of exhaust wash water discharges with more specific recommendations and criteria relevant to EGCS-SOx wash water discharges in the near future as amendments to the Guidelines. 5. References 1). MEPC/Circ 472 - PSC Guidelines under Annex VI. 2). MEPC/Circ 471 - Interim Guidelines for Voluntary Ship CO2 Emission Index for Use in Trial. 3). Resolution MEPC.128(53) Adopted on 22 July 2005 Amend-ments to the Revised Survey Guidelines under the Harmonized Sys-tem of Survey and Certification (Resolution A.948(23)) For The Purpose of MARPOL Annex VI. 4). Resolution MECP.130(53) Guidelines for On-Board Exhaust Gas-Sox Cleaning Systems. 5). Lloyd’s Register “Marine Fuel Sulphur Record Book for the control of sulphur oxide emissions” Contact [email protected] for the sources of the above circulars.

the registration of the suppliers, another for the ship’s re-cord and you may consider sending a further LOP to the ship’s Flag Administration. Issuing of the LOP will demonstrate the ship’s understand-ing of Annex VI requirements putting the onus on the sup-plier in the event that a port State Authority challenges any non-compliance identified. 2.5) Options to comply with Annex VI.

I. The ship is not intending to operate in a SECA. All fuel on board is not to exceed the global sulphur maximum of 4.5% m/m.

II. All heavy fuel oil (HFO) carried on board is to be less than 1.5% sulphur content.

III. Dual fuel operation <1.5% & <4.5% HFO – change-over procedures apply.

IV. Alternative technological method – specify. V. Strategy for handling national boundary emission

regulations, such as those imposed by the EU and USA.

3. CO2 index - MEPC Circular 471 In 1997 IMO adopted a resolution on CO2 emissions from ships, requesting to consider what CO2 reduction strategies would be feasible for ships. Resolution A.963(23) on IMO policies and practices related to the reduction of green-house gas emissions from ships was adopted, which re-quests the MEPC to develop a greenhouse gas emission index for ships, and guidelines for application of that index. As urged by the Assembly, MEPC 53 approved circular MEPC/Circ.471 on Interim Guidelines for Voluntary Ship CO2 Emission Indexing for Use in Trials. The most com-mon equation used, and that which has found its way into the CO2 Guidelines is expressed as:

Index = Fuel consumed x Carbon content / mass cargo x distance

The objective of these guidelines is to provide the users with guidance on achieving the targets set by IMO Assem-bly Resolution A.963 (23). The guidelines present the concept of an index for the en-ergy efficiency of a ship in operation, limited to an expres-sion of efficiency expressed in way of CO2 emitted per unit of transport work. The guidelines are intended to monitor the efficiency of ship operation. They should be used to establish a common approach for trials on the voluntary CO2 emission indexing, which will enable shipowners to evaluate the performance of their fleet with regard to CO2 emissions. As the amount of CO2 emitted from a ship is directly related to the consumption of bunker fuel oil, the CO2 indexing will also provide useful information on a ship’s performance with regard to fuel efficiency. The Intercargo Technical, Safety and Environmental Com-

NAME AND TYPE OF SHIP: Voyage

Fuel consumption (FC) at sea and in port in tonnes

Voyage or time period data

Fuel type ( )

Fuel type ( )

Fuel type ( )

Cargo (tonnes or units)

Distance (NM)

1 2

3

4



oils (MDO) used by ships in intra-European voyages and when in EU ports should have a maximum sulphur content of 0.2%. The lack of supply of these oils has created a number of problems and since the original EU Sulphur Directive did not cover residual fuels, many ships have been forced to use exclusively inter-mediate fuel oil (IFO) and heavy fuel oil (HFO) when in Europe. The amendments have changed the situation and ad-dress all marine fuel oils but with one significant change: from 11 August 2006, the 0.2% sulphur limit will apply ONLY to DMA and DMX grade marine gas oils (MGOs) but no longer to DMB and DMC grade marine diesel oils (MDOs), which are commonly used by sea-going ships. As the ISO specification of grade DMB is close to the specification of grade DMA (the differences being in order to allow for the bunkering of DMA through a contaminated bunkering hose), one could assume that if MGOs are not available, the ship could use grade DMB for a short period of time and avoid the problem of non-compliance due to lack of supply. It should also be aware that from 1 January 2010, when ships are at berth they will be required to use only fuels with a 0.1% sulphur content. 2 EU Sulphur Directive - What do the provi-sions on marine distillate fuels (MDO & MGO) mean in practice? There are different provisions in Article 4 of EU Di-rective 1999/32 and the new Articles 4a and 4b of 2005/33 which relate to marine gas oils (MGO) and marine diesel oils (MDO). Confusion can arise here because the new directive is an amending proposal which has to be read in conjunction with the original directive. The following clarifications are proposed: · Until 10 August 2006, the existing 0.2% sulphur limit continues to apply to all marine distillates used in EU territory waters, including ships in territorial seas and on inland waterways, but excluding ships in the territory waters of Greece, the French DOM-TOM, Madeira, the Azores and the Canary Islands. The term used in the directive is “marine gas oil” but the defini-tion includes all marine distillates under ISO 8217: DMA, DMB, DMC and DMX grades, i.e. also includ-ing marine diesel oils;

1. The differences between IMO MARPOL An-

nex VI and the EU Sulphur Directive In July 2005 the European Union (EU) adopted signifi-cant amendments to the EU Directive 1999/32, now amended by the EU Sulphur Directive (2005/33). These amendments have largely aligned the EU Sulphur Direc-tive with the IMO MARPOL Annex VI requirements. However there are still a few important differences: (1) Differing dates for the commencement of the North Sea/English Channel Sulphur Emissions Control Area (SECA). North Sea/English Channel becoming a SECA. According to IMO, the North Sea/English Channel will become a SECA (i.e. where fuels with a maximum sul-phur content of 1.5% must be used) on 21 November 2007, while the interpretation given by the EU Commis-sion to their own Sulphur Directive is: "In the North Sea and English Channel SECA, operators of all ships other than passenger vessels should comply with the 1.5% sx.ulphur fuel limit from 11 August 2007." (Passenger ships must, however, comply with the 1.5% sulphur fuel limit from 11 August 2006 whilst on regular services in European waters.) We have no doubt that EU Member States will imple-ment this requirement within their 12 nautical mile terri-torial zone, which according to the United Nations Con-vention on the Law of the Sea (UNCLOS) is under their jurisdiction. But while the EU can enforce this require-ment in its own territorial waters (12 miles), we cannot clarify whether they could legally monitor enforcement in international waters. However, bearing in mind that the difference between the IMO and EU enforcement dates for ships (other than passenger ships) is only 3 months and 10 days, we cannot foresee that this discrepancy would create too much of a problem as long as ship op-erators take it into account when trading in the North Sea/English Channel at this time. (2) Requirements that ships use very low sulphur con-tent fuels while "at berth". Use of very low sulphur fuels Before these amendments, the EU Sulphur Directive re-quired that all marine gas oils (MGO) and marine diesel

Bunkers - MARPOL Annex VI and EU Directive



Lifeboats

- Measures to prevent accidents IMO produced the following documents with meas-ures to prevent life-boat accidents: • MSC/Circ 1049 Accidents with Lifeboats MSC/Circ 1093 Guidelines for Periodic Servicing and Maintenance of Lifeboats, Launching Appli-ances and On-Load Release Gear • MSC/Circ.1136 Guidance on Safety During Abandon Ship Drills using Lifeboats • MSC/Circ.1137 Guidelines for Simulated Launching of Free-Fall Lifeboats • Resolution MSC.152(78) Adoption of Amend-ments to the International Convention for the Safety of Life at Sea, 1974, As Amended

****************

Particularly Sensitive Sea Areas The following Particularly Sensitive Sea Areas (PSSA) have been designated: • the Great Barrier Reef, Australia (designated a PSSA in 1990); • the Sabana-Camagüey Archipelago in Cuba (1997); • Malpelo Island, Colombia (2002); • the sea around the Florida Keys, United States (2002); • the Wadden Sea, Denmark, Germany, Nether-lands (2002); • Paracas National Reserve, Peru (2003); • Western European Waters (2004); • Extension of the existing Great Barrier Reef PSSA to include the Torres Strait (proposed by Australia and Papua New Guinea) (2005); • Canary Islands, Spain (2005); • the Galapagos Archipelago, Ecuador (2005); and • the Baltic Sea area, Denmark, Estonia, Finland, Germany, Latvia, Lithuania, Poland and Sweden (2005).

· From 11 August 2006 until 31 December 2007, the 0.2% sulphur limit now applies only to marine gas oils used in EU territory waters with a viscosity or density falling within the ranges of viscosity or density defined for DMX and DMA grades under ISO 8217. The exemp-tion for Greece and the outermost regions continues to apply. For DMB and DMC grade marine diesel oils the 0.2% sulphur limit in EU territory waters is dropped, and a less stringent limit of 1.5% sulphur is introduced with respect to fuels placed on the market in EU Member States’ territory. This is to allow the use of marine diesel oils to comply with the SOx Emission Control Areas, in case supplies of 1.5% S heavy fuel oil are insufficient; · From 1 January 2008 until 31 December 2009, a 0.1% sulphur limit applies to marine gas oils used in EU territory with a viscosity or density falling within the ranges of viscosity or density defined for DMX and DMA grades under ISO 8217. The exemption for Greece and the outermost regions continues to apply; and · From 1 January 2010, the provisions originating from Directive 1999/32 and relating to the use of marine gas oils in EU territory waters (described above) are now deleted. Instead a 0.1% sulphur limit is introduced for marine gas oils placed on the market in EU Member States’ territory, and a 0.1% sulphur limit starts to apply to all types of marine fuel used by ships at berth in EU ports and by inland waterway vessels. This applies to any use of the fuel e.g. in auxiliary engines, main en-gines and boilers. There are the following exemptions: for ships which spend less than 2 hours at berth accord-ing to published timetables, for hybrid sea-river vessels while they are at sea, and for ships which switch off all engines and use shore-side electricity. The outermost regions continue to be exempt from this provision, but Greece does not, apart from a 2-year derogation for 16 named Greek vessels until 2012.

**********



According to Princess Cruise Lines, the cost of pur-chased power of some 100,000 kWh per day some-what exceeds the cost of diesel fuel that would be con-sumed if the ship's generators were operated in port. However, if new legislation further reduces the emis-sion level in ports, ships may be offered an option to use shore power instead of using different types of fuel and related installations to balance the added cost with a contribution to protecting the environment. Modify-ing a ship to accept cold ironing costs more than $500,000 per vessel. Currently, the cruise line is im-plementing cold ironing at its docks in Seattle. A ma-jor Chinese line has also begun implementing cold ironing for its freighters that dock in Long Beach, California, which is known for its concerns about air pollution (source http://www.copper.org/resources/cutopics/Ct98/ports_pollution.html). This approach is especially concerning for the tanker industry. There are obvious safety issues when con-necting to the mains ashore. Other issues cover the availability of large amounts of power needed for tankers. Attention should also be paid to the type of energy plant that will be required to deliver this elec-tricity (quite possibly coal based in U.S.), and the loca-tion of the power plant in relation to densely inhabi-tated areas. Therefore an immediate question is what is the real gain from the introduction of cold ironing by burning more coal. 2. New development At the last meeting of the Inter-Industry Shipping and Ports Contact Group (IISPCG) on 15 Nov 2005, IAPH (International Association of Ports and Harbours) re-ported the progress of cold ironing in the US. Los An-geles and Long Beach ports are considering introduc-ing AMP (alternative marine power) but only for the hotelling operation, i.e. only providing shore electric-ity to ships for crew living on board, not for opera-tional needs. It was also reported at the meeting that the International Standardisation Organisation (ISO) is in the process of developing standards but using differ-ent vocabulary from those used by shipping. 3. Comments from Members Based on current information and initial comments from CASTEC members, we have the following sum-mary: • It is extremely important NOT to underestimate

1. Introduction There are reports on the feasibility studies in the US about cold ironing to meet environmental concerns. Cold-ironing refers to shutting down auxiliary engines on ships while in port and connecting to electrical power supplied at the dock, thus eliminating virtually all emissions from a ship while it is in port. (Cold-ironing is also referred to as “shore power” and alternative maritime power). The term “cold-ironing” comes from the act of dry-docking a vessel, which involves shutting down all on-board combustion, resulting in the vessel going “cold.” Without cold-ironing, auxiliary engines run continuously while a ship is docked, or “hotelled,” at a berth to power lighting, ventilation, pumps, communica-tion, and other onboard equipment. Ships can hotel for several hours or several days. There are no effective standards for electrical connection to shoreside power, and wide variations in the electrical infrastructures of both ships and ports. Ships which can connect in the US cannot easily do so in Europe (and vice versa). Controls are likely to apply primarily to regular visitors. Some examples are: � Cruise Ships in Alaska: Cruise lines now use

shoreside power when alongside. Princess Cruise Lines, based in Santa Clarita, California, has spent over $4.5 million to enable its big cruise ships to accept local power in Juneau, the capital of Alaska.

� New terminal in Los Angeles: The port was sued by a local community who was not adequately con-sulted before a new terminal went ahead. A settle-ment required ships at the terminal to use shoreside power.

� BP in Los Angeles: With the port paying for the shoreside installation, BP has also invested to allow its tankers, bringing oil from Alaska, to use shore-side power while unloading. It makes clear this is voluntary, and it has no legal obligation to do so.

The costs, complications and additional shoreside emis-sions appear to make it unattractive as a general solution without significant change in both ship and shore electri-cal technologies. (Source: The USA & Shipping Emis-sions) In order for a ship to “cold iron”, it must be equipped to do so and the terminal at which it is docked must be equipped to provide power to the ship.

Cold Ironing



Cold ironing is only one of the tools to locally reduce air pollution from ships in ports and can be effective in some special cases, depending on local circumstances and sen-sitivity of the local environment. It is often difficult to adapt the ship to shore connection. The cables are bulky, safety critical, and need special handling, espe-cially for ships of different lengths and sizes and shifting in berth. Intercargo would like to see uniform measures and re-quirements to tackle the emission problem. If the IMO development is directed to low sulphur fuel on board and shipping has purchased expensive fuel with the installa-tion of additional storage tanks and handling systems, another regime following a different approach would undermine the implementation of the IMO requirements. It is noted that the issue is not a high priority for bulk carriers compared to cruise ships, tankers and container ships. However, it is realised that participation in the joint industry initiative may be necessary:

• To monitor closely the progress in the US on cold

ironing; • To provide feedback and comments of the bulk car-

rier sector to the process; • To influence the standard being developed by ISO; • To bring the issue to IMO when necessary to reduce

the negative impact on shipping; • To influence the early practice and protect and bal-

ance ships interests (high cost and long term conse-quences); and

• To exchange views with other industry partners. Intercargo would encourage safety assessments for bulk carriers and feasibility studies for bulk carrier terminals with moving loading/unloading facilities.

**********

what it takes to “shut a ship down” these days and accordingly arrangements should, at all costs, allow for parallel running of the shore supply and ship’s power plant. The relevance of this increases with the decrease in expected stay alongside. Matching of power supplies will be an issue.

• It is difficult to make the changeover between

ship and shore power supplies without power inter-ruptions, however short. This imposes extra costs and safety precautions to a great deal of the sensitive electronic equipment upon which modern ships de-pend

• Heating is a service normally provided by the boiler.

Electric heating is not really practical (the average or typical 30kW~40kW heaters for domestic services found are often inadequate) and the power required for the machinery heating services would be im-practically large.

• What will be a much more significant problem is if

the requirement is also to shut down the boiler. Owners would then be faced with all the problems of keeping the main engine and the fuel at the correct temperature and supplying hot water and heat for the accommodation for which on most ships the boiler is required. If the boiler cannot be used then significant expense will be involved.

• The power demands are large in comparison with

other port uses. The approach of cold ironing is ca-pable of handling the ships normal power require-ments excluding that required for the deck cranes, which would require to be fitted with individual power supply points.

4. Industry position The environmental benefit achieved depends on a number of factors, such as the time the vessel is berthed at the quay, the fuel used, the performance of the engines and so on. The relative benefit of electricity supply from the shore depends on how the electricity is produced. If the shore power is generated by coal other than wind power, analysis may come out with a different view. The total cost for onboard generation of electricity will depend on the design of the ship’s power supply system and the fuel used (the fuel prices vary largely over time and by fuel quality). The total cost will also depend on costs for investments and maintenance (the investment costs will vary with the type of engine (two/four stroke, engine brand, size etc), age and running hours per year).



(53); 3) Guidelines for Ballast Water Exchange (G6),

adopted by Resolution MEPC.124(53); 4) Guidelines for the Approval of Ballast Water

Management Systems (G8), adopted by Reso-lution MEPC.125(53); and

5) Procedure for the Approval of Ballast Water Management Systems that make use of Ac-tive Substances (G9), adopted by Resolution MEPC.126(53).

Substantial work was undertaken on the remaining 9 sets of guidelines, all of which will be completed by the end of 2006. Contact [email protected] for the information of the Programme for Development of the Guidelines for Uniform Implementation of the BWM Convention. 3. Technology available Categories of technology include filtration, ultraviolet radiation (UV), oxidation, ultrasonic, non-oxidizing chemical biocides, heat, and deoxygenation processes, as well as combinations (usually with an initial filtra-tion step) in multi-stage systems. . Some systems pre-sented used more than one technology. On reviewing some 14 different types of systems (detailed in annex II to this document) MEPC 53 agreed that for the time being there was no need to review the implementation dates as set out in the Con-vention. However, not enough information has been provided to firmly conclude on cost effectiveness. It should also be noted that no systems had been fully tested on board before MEPC 53. MEPC 53 agreed that it would undertake a second review at its 55th meeting in October 2006 (MEPC 55) to assess the progress made on the technologies re-viewed at its 53rd session. There is a growing concern that sufficient capability will not be available in time to produce and install the systems on all the vessels mandated to use them. 4. When type approved systems will be available The program for a (G8) type approval (not using active substances) could potentially range from 8 months for land-based and shipboard testing in parallel and to up to 2 years if difficulties are encountered. 1) A G8 process might be achievable within the fol-lowing dates:

1. Background The Ballast Water Management Convention (BWM Con-vention) was adopted in 2004 and is expected to enter into force in 2009 (a summary of BWM Convention is at annex I to this document). Relevant technologies of bal-last water management have been developing since 2004. IMO will use the evaluation methodology to conduct a technology review covering aspects of safety, environ-mental acceptability, practicability, cost-effectiveness and biological effectiveness. By noting that the International Conference on Ballast Water Management for Ships (February 2004) had adopted the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention), MEPC 51 in April 2004 considered the requirements under the BWM Convention and ap-proved a work programme for the development of guide-lines for the uniform implementation of the BWM Con-vention. MEPC 52 in October 2004 finalized the “Guidelines for approval of ballast water management systems” ( also referred to as G8) and approved the “Procedure for ap-proval of active substances” (G9), with a view to adop-tion at MEPC 53 in July 2005. MEPC 52 also agreed on a set of recommendations for the conduct of a review of the ballast water management technologies, as required by regulation D-5 of the BWM Convention, and invited IMO Member States and Non-Governmental Organisa-tions (NGO’s, Intercargo being one of NGO’s) to submit relevant information to MEPC 53 to facilitate the review. MEPC 53 made significant progress on the development of guidelines called for under the BWM Convention and adopted 5 sets of Guidelines. 2. Up-to-date Progress There are 14 sets of Guidelines to be developed by MEPC in order to implement the BWM Convention. At MEPC 53 the following 5 sets of Guidelines have been adopted by MEPC Resolutions. Contact [email protected] for information of the resolutions and the Guidelines. 1) Guidelines for Ballast Water Management

Equivalent Compliance (G3), adopted by Reso-lution MEPC.123(53);

2) Guidelines for Ballast Water Management and the Development of Ballast Water Management Plans (G4), adopted by Resolution MEPC.127

Ballast Water Management



by heating may need to be cooled to less than 10 deg C above ambient to minimize any environmental impact. 5). Systems with filters on up-take and/or discharge should ensure that any residual waste discharged by back-flushing may only be discharged at the point of origin. The capabilities of filters may impose a limit on achievable flow rate. 6). The size range of the systems onboard varies be-tween systems and between flow rates for the same sys-tem. 7). Systems that include an in-tank treatment stage may introduce a minimum voyage time and may not be prac-ticable for voyages of short duration. The minimum voyage time may be of the order of 24 to 48 hours. 8). There was not enough information at MEPC 53 to come to any firm conclusions about likely costs. 6. Annexes Annex I Summary of the Ballast Water Management Convention; and Annex II Summary of the technologies presented at MEPC 53.

***********

• Systems that do not use Active Substances: Land-

based test facilities available: February 2006; • Earliest type approval using parallel ship and land-

based testing: October 2006. However, it is ques-tionable whether any operator would consider the installation of a test system without the confidence given by an extensive land-based test; or

• Type approval assuming difficulties encountered:

February 2008 2) A combined G8 & G9 approval for a system that used active substances would have to follow the (G9) process and assuming that data for an Active Substance was available at the earliest opportunity, then a combined (G8)/(G9) process might be achievable within the fol-lowing dates: • Systems that use Active Substances: Consideration

by the Technical Group December 2005; Basic ap-proval at MEPC 54 March 2006;

• Earliest (G8) completion using parallel land and

ship testing: January 2007. Earliest final approval at MEPC 56: July 2007; or

• (G8) completion assuming difficulties encountered:

May 2008. Final approval assuming difficulties encountered, at MEPC 58: October 2008.

5. Advice to Members 1). No equipment should be permanently installed be-fore it is type approved, during which full consideration should be given to the issues of safety, environmental risks and practicality. 2). The calibration or consistency of manufacture is also an important area of concern. There are uncertainties with regards to maintenance, robustness, design-life and calibration of the system. Owners should consider ex-tending guarantees and/or warranties for maintenance cover since the system may have not been life-cycle tested. 3). Storage facilities should be given appropriate design consideration for systems that use Active Substances, since it is possible for ships to store and carry large quantities of potentially hazardous and toxic chemicals for use in ballast treatment systems. Investigation should be made to check whether some technologies may have other waste products from the Active Substances used on board. Residual chemicals may be produced when using non-active substance treatment systems. 4). The ballast water that has been subject to treatment



Construction Date: keel laying date; 50 tons or 1% of structural material – whichever is less; or major conver-sion. Major Conversion: change of ballast capacity of 15%; change of ship type; projected life is extended by 10 years; or ballast system modification except for replace-ment-in-kind or modifications needed to carry out ballast water exchange. Ballast Water Exchange is to take place as follows: 1. at least 200 nm from the nearest land and in more than 200 m water depth; 2. at least 50 nm from the nearest land and in more than 200 m water depth; or 3. in the event throughout the intended route the sea area does not afford the above characteristics, in a sea area designated by the port State. All ships > 400gt (except floating platforms, FSUs and FPSOs) are to be surveyed (initial, annual, intermediate, and renewal) and certificated (not exceeding 5 years). States may establish additional ballast water manage-ment measures for ships to meet, based on Guidelines which remain to be developed. The MEPC shall undertake a review of the Ballast Water Standards no later than 2006 and is to include an assess-ment of the technologies available that achieve the stan-dard.

Annex I Summary of the Ballast Water Management Conven-tion The new Ballast Water Convention has been adopted and will enter into force when 30 States representing 35% of the world’s gross tonnage become signatories. All ships including submersibles, floating craft/platforms, FSUs and FPSOs) are to manage their ballast water in ac-cordance with an approved Ballast Water Management Plan and record such management in a Ballast Water Re-cord Book in accordance with the provisions of the Con-vention based on the following implementation schedule: • D1 = Ballast Water Exchange (95% volumetric

exchange) or pumping through three times the vol-ume of each tank;

• D2 = Ballast Water Treatment systems approved by

the Administration which treat ballast water to an efficacy of: ∗ not more than 10 viable organisms per m3 >50

micrometers in minimum dimension; and ∗ not more than 10 viable organisms per millilitre

< 50 micrometers in minimum dimension and >10 micrometers in minimum dimension.

Indicator Microbe concentrations shall not exceed: a) toxicogenic vibrio cholerae: 1 colony forming unit (cfu) per 100 millilitres or 1 cfu per gram of zooplankton sam-ples; b) Escherichia coli: 250 cfu per 100 millilitres; and c) Intestinal Enterococci: 100 cfu per 100 millilitres

Ballast Capac-ity (m3) Construction Date

First, Intermediate or Renewal Survey , which ever occurs first after anniversary date of delivery in the year indicated below

2009 - 2014 2015 2016 2017

<1500 <2009 D1 or D2 D2

>2009 D2

> 1500 < 5000

<2009 D1 or D2 D2

>2009 D2

> 5000 <2012 D1 or D2 D2

> 5000 >2012 D2



A

nnex

II

Sum

mar

y of

the

tech

nolo

gies

pre

sent

ed a

t ME

PC53

N

ote:

Tec

hnol

ogie

s 8, 1

0 an

d 13

are

not

incl

uded

as t

hey

are

dupl

icat

es o

f oth

er te

chno

logi

es a

lrea

dy su

bmitt

ed.

Tec

hnol

ogy

Des

crip

tion

Act

ive

subs

tanc

es

used

A

ntic

ipat

ed si

ze

rang

e St

ate

of d

evel

op-

men

t E

xten

t of t

estin

g

Oth

er re

leva

nt

info

rmat

ion

Cos

t inf

orm

atio

n

No.

1 (H

eat

Met

hod

in d

ocu-

men

t ME

PC

53/2

/15)

Hea

t wat

er to

38-

40 d

egre

es C

elsi

us

for a

per

iod

of

time

in o

rder

to b

e ef

fect

ive.

Lim

ited

by le

ngth

of v

oy-

age

and

balla

st

capa

city

.

Doe

s not

use

ac-

tive

subs

tanc

es

Bet

wee

n 50

and

50

00 c

ubic

met

ers

per h

our.

Spac

e re

quire

men

ts

shou

ld n

ot b

e si

g-ni

fican

t.

Test

ed o

n a

dry

bulk

car

rier,

14

1,47

5 dw

t tra

v-el

ling

betw

een

Japa

n an

d A

ustra

-lia

.

Posi

tive

resu

lts fo

r el

imin

atin

g vi

able

or

gani

sms.

has n

ot b

een

un-

derta

ken

in re

la-

tion

to th

e D

-2

stan

dard

or t

he G

8 gu

idel

ines

The

syst

em p

ro-

vide

s a le

vel o

f si

mpl

icity

, whi

ch

for p

ract

ical

pur

-po

ses i

s des

irabl

e in

a sh

ipbo

ard

syst

em.

No.

2 (F

iltra

tion

and

Chl

orin

e D

ioxi

de T

reat

-m

ent M

etho

d in

do

cum

ent M

EPC

53

/2/1

5)

This

syst

em u

ses

filtra

tion

on u

ptak

e w

ith a

seco

ndar

y ch

emic

al tr

eatm

ent

of b

alla

st w

ater

w

ith C

hlor

ine

di-

oxid

e.

An

activ

e su

b-st

ance

(Chl

orin

e di

oxid

e) is

use

d, to

be

gen

erat

ed o

n bo

ard

the

ship

fr

om it

s sub

com

-po

nent

s.

Con

stra

ined

by

a ba

llast

ing

rate

of

2,50

0 cu

bic

met

ers

per h

our d

ue to

fil

tratio

n

Not

und

ergo

ne

ship

boar

d tri

als

The

test

ing

unde

r-ta

ken

has p

rovi

ded

posi

tive

resu

lts;

how

ever

test

ing

has n

ot b

een

un-

derta

ken

in re

la-

tion

to th

e D

-2

stan

dard

or t

he G

8 gu

idel

ines

.

Chl

orin

e di

oxid

e is

wid

ely

used

in

mun

icip

al w

ater

tre

atm

ent.

No.

3

(Mec

hani

cal

Sepa

ratio

n an

d D

isin

fect

ion

in

docu

men

t ME

PC

53/2

/11)

a) m

echa

nica

l se

para

tion

(filt

ratio

n) a

nd

b) g

ener

atio

n of

an

activ

e su

bsta

nce

The

activ

e su

b-st

ance

is g

ener

ated

on

boar

d

Ava

ilabl

e fo

r all

ship

type

s and

all

ship

size

s due

to

the

mod

ular

sys-

tem

des

ign

Will

be

com

mer

-ci

ally

ava

ilabl

e in

th

e ne

ar fu

ture

(e

nd o

f 200

6).

Pilo

t tes

ts h

ave

been

car

ried

out

unde

r wor

st c

ase

cond

ition

s in

river

. St

anda

rd D

-2 c

an

be m

et fo

r org

an-

ism

s >50

µm

and

or

gani

sms <

50 a

nd

>=10

µm

.

Des

igne

d in

a

mod

ular

fash

ion

no u

pper

lim

it in

th

e flo

w ra

te

Ope

ratio

n do

es n

ot

requ

ire c

onsu

m-

able

s. H

owev

er,

clea

ning

che

mi-

cals

and

spar

e pa

rts re

plac

emen

ts

are

need

ed.

INTE

RCAR

GO

Tech

nica

l and

Ope

ratio

nal U

pdat

e for

Bul

k Car

riers


T

echn

olog

y D

escr

iptio

n A

ctiv

e su

bsta

nces

us

ed

Ant

icip

ated

size

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Stat

e of

dev

elop

-m

ent

Ext

ent o

f tes

ting

O

ther

rele

vant

in

form

atio

n C

ost i

nfor

ma-

tion

N

o. 4

(Filt

ratio

n an

d U

V in

doc

umen

t M

EPC

53/

2/11

)

A fi

rst s

tep

filtra

-tio

n, se

cond

step

U

V-r

adia

tion

and

third

step

dis

infe

c-tio

n

The

activ

e su

b-st

ance

nee

ds to

be

dose

d di

rect

ly in

to

the

balla

st w

ater

For s

hips

with

a

balla

st w

ater

flow

ra

te u

p to

250

cu-

bic

met

ers p

er

hour

. It r

equi

res

appr

ox. 5

squa

re

met

ers.

Pi

lot t

ests

hav

e be

en c

arrie

d ou

t an

d di

d no

t mee

t th

e D

-2 S

tand

ard

com

plet

ely.

The

in

suff

icie

nt fi

ltra-

tion

rate

for l

arge

r or

gani

sms n

eeds

th

e us

e of

act

ive

subs

tanc

es to

mee

t th

e D

-2 st

anda

rd

Due

to th

e m

odul

ar d

esig

n sy

stem

, com

po-

nent

s can

be

plac

ed in

diff

er-

ent l

ocat

ions

w

ithin

the

ship

. La

rger

flow

rate

s ca

n be

trea

ted

by

usin

g m

ultip

le

syst

ems i

n pa

ral-

lel.

Con

sum

able

s are

re

quire

d on

a

very

lim

ited

scal

e. C

osts

for

mai

nten

ance

and

co

nsum

able

s are

be

low

10k

US$

an

nual

ly.

No.

5 (P

hysi

cal S

epa-

ratio

n an

d D

isin

fec-

tion

in d

ocum

ent

ME

PC 5

3/2/

11)

A fi

rst s

tep

me-

chan

ical

sepa

ratio

n (h

ydro

cyc

lone

an

d 50

µm fi

ltra-

tion)

and

a se

cond

st

ep tr

eatm

ent w

ith

an o

xidi

zing

age

nt.

The

syst

em m

akes

us

e of

an

activ

e su

bsta

nce

PER

AC

LEA

N®

O

cean

, whi

ch is

a

read

ily b

iode

grad

-ab

le a

nd c

hlor

ine-

free

.

Test

ed o

n la

nd

with

a fl

ow ra

te o

f 20

0 an

d 50

0 cu

bic

met

ers p

er h

our.

Size

4.8

and

14.

8 sq

uare

met

ers.

Fully

dev

elop

ed

and

read

y fo

r sh

ipbo

ard

test

ing

in a

ccor

danc

e w

ith G

8.

Rea

ched

or e

ven

exce

eded

the

D-2

st

anda

rd

No

cons

train

t re

sulti

ng fr

om

the

voya

ge

leng

th. T

he

treat

ed w

ater

sh

ould

be

re-

tain

ed fo

r a

min

imum

of 2

4 ho

urs.

Inst

alla

tion

cost

ca

nnot

be

as-

sess

ed a

t the

pr

esen

t. C

osts

fo

r ope

ratio

n ar

e an

ticip

ated

at

0.30

US$

per

tre

ated

m³ o

f ba

llast

wat

er.

No.

6 (F

iltra

tion

and

Dis

infe

ctio

n in

doc

u-m

ent M

EPC

53/

2/11

)

Firs

t ste

p fil

tratio

n (m

esh

size

50

µm)

and

a se

cond

step

di

sinf

ectio

n ba

sed

on e

lect

ro-

chem

ical

-ac

tivat

ion

The

syst

em u

ses a

n ac

tive

subs

tanc

e.

Prod

uces

no

spe-

cial

risk

s for

the

envi

ronm

ent.

No

spec

ial r

isk

for

heal

th o

r onb

oard

sa

fety

.

5 sq

uare

met

er si

ze

for a

flow

rate

of

300

cubi

c m

eter

s pe

r hou

r.

Inst

alle

d on

a

cont

aine

r ves

sel

(1.1

00 T

EU)

sinc

e M

ay 2

005.

N

o in

fluen

ce to

th

e no

rmal

bal

-la

st w

ater

ope

ra-

tion.

It st

arts

and

st

ops a

utom

ati-

cally

with

the

com

mon

bal

last

op

erat

ion.

Res

ults

in

rela

tion

to D

-2 f

rom

on-

boar

d t

estin

g a

re

not

avai

labl

e

at

pres

ent.

The

syst

em c

an

be d

esig

ned

for a

ba

llast

wat

er

flow

rate

up

to

5000

m³/h

and

sh

ould

be

wor

ld

wid

e co

mm

er-

cial

ly a

vaila

ble

in su

mm

er 2

006.

Estim

ated

ope

ra-

tion

cost

s for

10

00 m

³ of

treat

ed b

alla

st

wat

er a

re b

e-tw

een

4 €

to 1

0 €.

INTE

RCAR

GO

Tech

nica

l and

Ope

ratio

nal U

pdat

e for

Bul

k Car

riers


Tec

hnol

ogy

Des

crip

tion

Act

ive

subs

tanc

es

used

A

ntic

ipat

ed si

ze

rang

e St

ate

of d

evel

op-

men

t E

xten

t of t

estin

g

Oth

er re

leva

nt

info

rmat

ion

Cos

t inf

orm

a-tio

n

No.

7 (F

iltra

tion

and

UV

Rad

iatio

n in

do

cum

ent M

EPC

53

/2/1

6)

The

met

hod

of

treat

ing

balla

st

wat

er w

ith a

low

-pr

essu

re lo

ss se

pa-

rato

r and

UV

.

The

syst

em d

oes

not u

tiliz

e ac

tive

subs

tanc

es. N

o sa

fety

haz

ard

for

the

ship

or t

he

crew

runn

ing

and

oper

atin

g th

e sy

s-te

m.

A 3

00 c

ubic

met

er

syst

em is

app

roxi

-m

atel

y 1.

5 sq

uare

m

eter

s in

size

. Ex-

pect

ed li

fetim

e of

30

00 ru

nnin

g ho

urs

Inst

alle

d on

bo

ard

a to

tal o

f 7

ship

s; 5

retro

fits

and

2 ne

w

build

s. Th

e fir

st

inst

alla

tion

sinc

e M

ay 2

000.

The

re

are

no e

nviro

n-m

enta

l con

cern

s.

The

curr

ent v

er-

sion

has

not

bee

n te

sted

und

er th

e cu

rren

t D-2

stan

-da

rds a

nd G

8 te

st-

ing

guid

elin

es.

No.

9 (F

iltra

tion,

D

ual P

ulse

d Sh

ock

Wav

e/Su

pers

atur

atio

n an

d O

xyge

n D

epri

vatio

n in

doc

umen

t ME

PC

53/2

/16)

Use

s nitr

ogen

in-

ject

ed in

to a

st

eam

-plu

me

es-

tabl

ishe

d in

the

flow

in th

e ba

llast

pi

pe li

ne fo

llow

ing

filtra

tion

thro

ugh

a 50

mic

rom

eter

m

echa

nica

l aut

o-m

atic

ally

bac

k flu

shin

g fil

ter.

Not

usi

ng A

ctiv

e Su

bsta

nces

.

U

nder

gone

labo

ra-

tory

test

s, la

nd-

base

d te

st a

nd is

cu

rren

tly e

valu

ated

in

a sh

ipbo

ard

situ

atio

n.

Com

pris

es a

co

mpr

esso

r and

m

embr

anes

for

nitro

gen

prod

uc-

tion,

onl

y th

e fil

ter,

inje

ctio

n

and

cavi

tatio

n co

mpo

nent

s ne

ed to

be

in-

stal

led.

No.

11

(Ele

ctro

chem

ical

Dis

-in

fect

ion

in d

ocum

ent

ME

PC 5

3/2/

31)

Elec

troch

emic

al

disi

nfec

tion

uses

va

rious

act

ive

sub-

stan

ces p

rodu

ced

from

ele

ctro

lysi

s of

sea

wat

er.

Act

ive

sub

stan

ces

are

not

adde

d t

o th

e

syst

em

but

prod

uced

du

ring

elec

troly

sis

of s

ea

wat

er,

at

tack

ing

sim

ulta

neou

sly

an

orga

nism

or

orga

n-is

ms

for

disi

nfec

-tio

n so

tha

t a

syn-

ergy

eff

ect

can

be

expe

cted

.

Elec

troch

emic

al

reac

tor m

odul

e,

dim

ensi

on (m

m)

840

W x

740

D x

27

00 H

. Rec

tifie

r di

men

sion

(mm

)

1400

W x

130

0 D

x

2350

H.

Land

-bas

ed p

ilot

test

with

bal

last

w

ater

flow

rate

of

60

cubi

c m

e-te

r is b

eing

con

-du

cted

.

Th

ere

are

no

was

te st

ream

s th

at h

ave

to b

e di

spos

ed o

f and

re

quire

spec

ial

conc

ern

durin

g th

e sy

stem

op-

erat

ion.

The

capi

tal c

ost

incl

udin

g in

stal

-la

tion

is e

xpec

ted

to b

e in

the

rang

e of

160

K -

170K

U

S$ fo

r new

ve

ssel

with

150

0 m

3 /hr b

alla

st

pum

p an

d 18

0K

- 200

K U

S$ fo

r an

exi

stin

g ve

s-se

l.

INTE

RCAR

GO

Tech

nica

l and

Ope

ratio

nal U

pdat

e for

Bul

k Car

riers


T

echn

olog

y D

escr

iptio

n A

ctiv

e su

bsta

nces

us

ed

Ant

icip

ated

size

ra

nge

Stat

e of

dev

elop

-m

ent

Ext

ent o

f tes

ting

O

ther

rele

vant

in

form

atio

n C

ost i

nfor

ma-

tion

N

o.12

(Filt

ratio

n an

d A

dvan

ced

Oxi

datio

n in

doc

umen

t ME

PC

53/2

/6)

Aut

omat

ical

ly

blac

k-flu

shin

g fil

ter f

or re

mov

al

of la

rge

parti

cles

an

d th

e A

OT

unit

prod

ucin

g hy

-dr

oxyl

radi

cals

in

brea

king

dow

n m

icro

-org

anis

ms

and

bact

eria

.

No

subs

tanc

es a

re

adde

d an

d no

re-

sidu

als a

re c

reat

ed.

A a

rea

of 3

squa

re

met

ers f

or e

quip

-m

ent i

s req

uire

d to

tre

at 5

00 c

ubic

m

eter

s per

hou

r.

A fu

ll-sc

ale

pro-

toty

pe h

as si

nce

Sept

embe

r 200

3 be

en in

stal

led

on

boar

d a

trans

oce-

anic

car

car

rier.

Com

plia

nce

with

th

e D

-2 st

anda

rd

shou

ld b

e ac

hiev

ed. F

ull-

scal

e la

nd-b

ased

te

sts a

ccor

ding

to

G8

are

yet t

o be

te

sted

.

Pow

er c

onsu

mp-

tion

depe

nds o

n th

e am

ount

of

balla

st w

ater

to

be tr

eate

d, e

.g.

500

cubi

c m

eter

s pe

r hou

r req

uire

s 15

kW

.

Ope

ratio

nal c

osts

in

clud

ing

pow

er

cons

umpt

ion

and

cons

umab

les

abou

t 0.

015U

S$/

m3 tr

eate

d ba

llast

w

ater

.

No.

14 (C

hlor

ine

Di-

oxid

e in

doc

umen

t M

EPC

53/

2/14

Bas

ed o

n a

chlo

-rin

e di

oxid

e (C

lO2)

gen

erat

or

whi

ch p

rodu

ces a

tre

atm

ent s

olut

ion

from

sulp

huric

ac

id a

nd so

dium

ch

lora

te/h

ydro

gen

pero

xide

.

Use

s Act

ive

sub-

stan

ce C

lO2.

Its

stor

age

and

han-

dlin

g ar

e no

t a c

on-

cern

bec

ause

it is

ge

nera

ted

on

boar

d. D

esig

n do

se

is 5

mg/

L C

lO2

with

24-

hour

incu

-ba

tion.

All

equi

pmen

t and

ta

nks h

ouse

d in

a

stan

dard

20

foot

lo

ng sh

ippi

ng c

on-

tain

er. T

arge

t flo

w

rate

cap

abili

ty is

1,

000

-10,

000

cu-

bic

met

ers p

er

hour

.

Cur

rent

ly u

nder

-go

ing

full-

size

d sh

ipbo

ard

test

s on

a 1

1,00

0 cu

-bi

c m

eter

bal

last

w

ater

cap

acity

co

ntai

ner s

hip

with

a b

alla

st

flow

rate

of

2,50

0 cu

bic

me-

ters

per

hou

r.

Ven

dor r

epor

ts th

at

the

de

sign

do

se

achi

eves

tre

atm

ent

mee

ting

IMO

D-2

st

anda

rd

conc

entra

tions

. Sh

ipbo

ard

test

s to

valid

ate

at fu

ll sc

ale

are

unde

r-w

ay.

C

apita

l for

eq

uipm

ent a

nd

inst

alla

tion:

$3

00K

to $

450K

; te

chni

cal s

uppo

rt in

clud

ing

mat

eri-

als:

50K

- 10

0K

US$

per

yea

r.

INTE

RCAR

GO

Tech

nica

l and

Ope

ratio

nal U

pdat

e for

Bul

k Car

riers


with these requirements by completion of log books, oil record books, incinerator logs and records of port discharges. 2. Operational experience 2.1 Experts contacted The following members and organisations were con-tacted for advice: Intercargo membership:

Anglo-Eastern Ship Management (Hong Kong) Ltd. COSCO UK Bocimar, Belgium IMC Singapore Kristen Marine S.A. Greece Oceanbulk Maritime S.A. Greece Pacific Basin UK Thomas Miller Ltd Unisea Shipping Ltd Wallem Shipmanagement Ltd, Hong Kong

Others:

Experts from Intertanko Thenamaris Ships Management Inc. Greece Strømme ASA, Norway

2.2 Advice received MEPC circular MEPC.2/Circ.8 issued in Dec 2002 indicates the restriction on the types of detergents used in washing under Para. 3.4 Cleaning additives as: “1.8.2 When small amounts of detergents are added to water in order to facilitate tank washing, no detergents containing pollution category A components should be used except those components that are readily bio-degradable and present in a total concentration of less than 10%.” No restrictions additional to those already applicable to the tank due to the previous cargo should apply (amendments to the Standards for Procedures and Arrangements for the Discharge of Noxious Liquid Substances, implemented as of 1 July 1996). The IMO BLG Sub-Committee evaluated a list of cleaning additives and found it to meet the require-ments of paragraph 1.8.2. Annex 12 of the MEPC.2/Circ.8 details the consolidated list. Cargo residues: Having a similar property is fuel sludge, petcoke should be collected by a shore facility. Owners’ best proposal is to get the cargo receiver and

1. Background Due to the entry into force of the amendments to MAR-POL Annex V on 1 Aug 2005, cargo residues become “garbage” under the amended Annex V. After carrying green delayed petcoke, subsequent clean-ing will remove both the residues and the residual foot-print (the paint pigment) left behind. The cargo residue has polluting properties which leave a sheen on the sur-face, therefore it needs a port reception facility to collect it. The water cleaning operations may use chemicals/detergents to remove the "footprint". The resultant wash water then needs special attention. The wash water may be contaminated by oil, or hydrocarbons and may trigger application of regulation 3(2), or 5(2) of Annex V which states that "when the garbage is mixed with other dis-charges having different disposal or discharge require-ments the more stringent requirements shall apply". If a bulk carrier is within special areas (as defined within MARPOL Annex V) or within port limits (this definition to be determined by the port authority regarding how far out to sea this goes), the wash water cannot be discharged overboard. Even if the ship is out of the special areas, but the chemicals/detergents of the wash water do not break down the oily deposit and prevent the 'sheen' from occur-ring and/or the chemicals/detergents are not the ones as approved by IMO, the wash water is still not allowed to be discharged overboard. Ships turn to adequate port re-ception facilities for assistance, which are required by MARPOL as statutory obligation of ports. Without proper port reception facilities to receive the cargo resi-dues, a ship may not be able to physically present itself with clean holds to back load at a port or terminal within one of the Special Areas. Intercargo is aware that it is not easy for a ship to clean for loading after a discharge in either North West Europe or the Mediterranean. The PSC inspectors may quickly become aware of the issue. MARPOL Annex I contains limits on the amount of oil which ships can legitimately discharge into the sea. Where discharge from bilge tanks is permitted it is a re-quirement that an Oil Discharge Monitoring and Control System together with Oil Filtering equipment (Oily Wa-ter Separator) be fitted so as to ensure that the oil content of any discharge does not exceed the maximum permitted under Annex I (15ppm). Any residue or sludge should then either be incinerated or discharged into port recep-tion facilities. Owners are required to ensure compliance

Cargoes - Petcoke - Guide on disposal of petcoke residue and cargo hold wash water



is not approved under the above class and its use should be avoided. The disposal has to go through standard discharge and monitoring equipment if available.

6). For dry petcoke EDGE or Enviromate 2000 is usually recommended.

Edge or Enviromate 2000 would be the product of choice if a spray on application is going to be used.

EDGE is recommended when stubborn stains are a

problem. US Practice: A vessel may not discharge wash water of any kind from her bilge tank(s) directly into the sea. Any wash products that may form a sheen (shiny translucent film) in the wa-ter or contain chemicals, oil, hydrocarbons or any other product unfriendly to the aquatic life environment, cannot be disposed overboard in US waters. The procedures call for the secure transfer of the wash water or of any other liquid type to be disposed into spe-cial holding tanks (frac tanks). Once the wash water has been transferred into the holding tanks a tank transporta-tion company would thereafter transport the tank content to an approved (EPA agency) facility for final disposal. All the disposals are governed by federal, state and local environmental control regulation. • 3. References (contact [email protected] for the

information of them):

1. Summary of the amendments to MARPOL Annex V. 2. Introduction of Petcoke. 3. Garbage management plans - MEPC/Circ.317. 4. Provisional categorization of liquid substances, IMO MEPC.2/

Circ.8, Dec 2002. 5. Research project - Precautions when fixed for Green Delayed Pet-

coke, Strømme AS, Nesveien 15, PO Box 31 N-1305 Haslum, Nor-way.

6. Cleaning Manual for bulk carriers, Strømme AS. 7. Solutions to petcoke problems, Strømme AS. 8. Solving hold cleaning problems in vessels transporting petcoke,

Strømme AS. 9. Pollution Prevention Equipment Required By Marpol 73/78.

receiving terminal involved as early as possible for their preparation and arrangement to deal with the cargo resi-dues. Cargo hold washing: It is normal that after discharging of petcoke there are always some dark foot prints left behind on the bulkheads of cargo holds. These are nor-mally cleaned with bridgeable cleaning agents which remove these stains and any oily content or sheen which is then emulsified into a harmless solution and is dis-charged as normal and won’t invoke Marpol Annex I. Procedure to wash cargo holds after discharge: 1) Sweep tank (Very Important to Thoroughly Sweep

Out); 2) High pressure water wash if possible with warm

water (50 to 60 deg C); 3) Manual spray at 100 to 150 liters of cleaner per 1000

cubic meters of tank space or tank cleaning machine; 4) Let soak 45 to 60 minutes maximum; and 5) High pressure water wash.

Chemicals for different types of petcoke 1) Only products listed under IMO MEPC.2/CIRC.8

can be used and disposed of at sea for cargo tank cleaning when cargo residue slops are permitted to be disposed at sea. It is suggested to check with the manufactures for a Certificate of Compliance of the products to meet the requirements of MEPC.2/Circ.8.

2) The cleaning products EDGE, Enviromate 2000 and

DREW TC at Sea have been evaluated by IMO bulk liquid and gases (BLG) working group on the evalua-tion of safety and pollution hazard of chemical (ESPH) and found to meet the requirement of Para-graph 1.8.2 of Procedures and arrangement standards and is listed on IMO MEPC.2/CIRC.8.

3) OSD/LT is an oil spill dispersant used to breakdown

sheen and TYPE 1 approved by the UK environ-mental and food council.

4) Cleaning chemical Aqutuff from Unitor was evalu-

ated through IMO’s BCH Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals and found to meet their requirements of paragraph 1.8.2 of the P&A Standards.

5). For oily petcoke Solvent cleaning is required. Drew TC Sea or TC #4

can be applied or used through a tank cleaning ma-chine, combigun or maxigun.

If De-odoring is required then use Drew EDGE. The product TC#4 is not listed under this category and



ships, in the entire Baltic Sea area. Source: http://www.helcom.fi (GRID Arendal) The HELCOM Recommendation 26/1on “Application of the no-special-fee system to ship-generated wastes in the Baltic Sea area” was adopted on 2 March. It recommends that the Governments of the Contracting Parties to the Helsinki Convention apply the attached Guidelines for the establishment of a harmonised "no-special-fee" system for the operation of reception facilities in their ports as of 1 January 2000 for ship-generated wastes covered by Annex I (oily wastes from machinery spaces) of MARPOL 73/78 and as of 1 January 2006 for wastes covered by Annex IV (sewage) and Annex V (garbage) of MARPOL 73/78. “No-special-fee” for the reception of ship-generated waste means that the ports charge the reception and treatment costs to all ships calling as part of their har-bour fee, irrespective of whether a certain ship delivers any waste or not and irrespective of amounts dis-charged. In addition, they have a mandatory commit-ment for ships to deliver all their wastes to port recep-tion facilities before leaving port. The "no-special-fee" system has the dual purpose of encouraging ships to deliver waste ashore thus avoid-ing undesirable waste streams between ports and en-couraging a sound sharing of the waste burden. This

1. INTRODUCTION of the Baltic Strategy

The Baltic Sea area has been designated as a special area under Annexes I, II and V. Prohibitions and restrictions on any discharge into the sea of oil or oily mixtures, nox-ious liquid substances and garbage have been introduced by the Baltic Sea States. The Baltic Sea area comprises the Baltic Sea proper, plus the Gulf of Bothnia, the Gulf of Finland, and the entrance to the Baltic Sea bounded by the parallel of the Skaw in the Skagerrak at 57°44.43'N, with a total area of about 370,000 km². The Helsinki Commission has approved the Strategy for Port Reception Facilities for Ship-generated Wastes and Associated Issues, also known as the Baltic Strategy, which comprises a set of measures and regulations with the main goals to ensure ships' compliance with global and regional discharge regulations and to eliminate illegal discharges into the sea of all wastes from all ships. In addition, regulations concerning the discharge of sew-age into the sea and the prohibition of incineration of ship-generated wastes in the territorial seas of the Baltic Sea States have been adopted by the Contracting Parties to the HELSINKI CONVENTION (refer to the attached Introduction to the Convention). There is also a general ban on dumping and incineration of other wastes, not incidental to or derived from the normal operation of

Main Components of the Baltic Strategy

• Port reception facilities: Over 210 port reception facilities in the Baltic Area • Notification: 24 hours in advance • Mandatory delivery: obligation to deliver to a port reception facility before leaving • ”No-special-fee”: Ports charge the reception costs as part of their harbour fee, irrespective of de-livery of any waste or not and irrespective of amounts • Promotion of sound waste management on board and on shore • Information and awareness raising • Control and enforcement: aerial surveillance supported by satellite observations

Reception Facilities - Baltic - Introduction of its no-special-fee System



CONVENTION, which was signed in 1974 and came into force in 1980. The 1974 Convention was the first international agreement worldwide to take into account all aspects of marine environment protection. The Con-vention aims to prevent pollution from ships (including dumping), pollution from land-based sources, and pollu-tion resulting from the exploration and exploitation of the seabed and its subsoil. The Convention also regulates the co-operation to respond to marine pollution by oil and other harmful substances. A new Convention was signed in 1992 in order to ex-tend, strengthen and modernize the legal regime for the protection of the marine environment of the Baltic Sea area. The 1992 HELSINKI CONVENTION entered into force on 17 January 2000. The Convention text and HELCOM Recommendations can be found in the inter-net, see www.helcom.fi. The discharge regulations are as follows: Oil Any discharge of oil or oily mixtures into the Baltic Sea area is prohibited. Oil means petroleum in any form in-cluding crude oil, fuel oil, sludge, oil refuse and refined products. The prohibition applies not only to discharges from the cargo tanks of oil tankers but equally to dis-charges from the machinery spaces of any ship. Only if the oil content in the effluent does not exceed 15 parts per million can a discharge be permitted. The oil filtering equipment must be provided with arrangements that en-sure that any discharge of oil or oily mixtures is auto-matically stopped when the oil content in the effluent exceeds 15 parts per million. Since 1 January 2002 ships of less than 400 tons gross tonnage, flying the flag of a Baltic Sea State, should also comply with the adopted guidelines concerning holding tanks/oily water separat-ing or filtering equipment. Finland has prohibited the use of bilge water separators in her inland waterways and in the territorial waters, within an area of 4 nautical miles from the nearest land. Noxious liquid substances carried in bulk Within the Baltic Sea area there is a prohibition on dis-charges from tanks that have contained Category A or B substances, specified by IMO’s International Bulk Chemical Code, which categorizes noxious liquid sub-stances carried in bulk as A, B, C or D according to their magnitude of harm to the marine environment if dis-charged. Tanks having contained Category A or B substances must be pre-washed and the resultant tank washings must be delivered to a reception facility. This is either to ensure a certain concentration of the substance in the

means that fees covering the cost of the reception, han-dling and final disposal of ship-generated wastes are in-cluded in the harbour fee and otherwise charged to the ship, irrespective of whether any wastes are actually de-livered. Over 210 port reception facilities are provided in ports located around the Baltic Sea. Additionally, the Baltic Sea States have agreed that by 1 January 2001 ships bound for or leaving a port of a Baltic Sea State and carrying dangerous or polluting goods, must report on the substances to the competent authority of that Baltic Sea State. Some Baltic Sea States have al-ready made this reporting requirement obligatory under their national law. CHAIN of responsibility The responsibility for avoiding discharges of oil or other harmful substances rests not only with the master and his crew but also with the charterer, the ship-owner and the ports. The charterer should include in the Charter Party a clause stating his policy on pollution prevention compliance. The ship-owner should ensure sound management in safety and pollution prevention, as required by the Inter-national Safety Management Code for certain categories of ships. Ports should be prepared to accept tank cleaning slops, or cargo that has been mixed with retained residues. Notes: 10 Contracting Parties (9 Baltic Sea coastal States and the European Community) HELCOM: the Helsinki Commission, Governing body of the Convention . HELCOM MARITIME: the Maritime Group of the Hel-sinki Commission

Attachments:

1. Introduction to the Helsinki Convention. 2. Application of the “No-Special-Fee System” to Ship- Generated Wastes in the Baltic Sea Area.

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Attachment 1

Introduction to the Helsinki Convention (source: http://www.helcom.fi/)

Growing awareness that national measures alone are not sufficient to protect this highly sensitive marine environ-ment led the Baltic Sea States to adopt the HELSINKI



cause no harm to the marine environment, may be used. The Baltic Sea States have also agreed to take actions to reduce and finally prohibit the use of ozone-depleting substances on board ships flying the flag of a Baltic Sea State. When Annex VI of MARPOL 73/78 on “Regulations for the Prevention of Air Pollution from Ships” enters into force on 20 May 2005 the Baltic Sea area will obtain the status of a SOx emission control area requiring that on and after 20 May 2006 all ships navigating in the area use fuel oil with a sulphur content not exceeding 1.5% m/m or an exhaust gas cleaning system or any other technical method reducing the total emissions of sulphur oxides from ships. In accordance with Annex VI deliberate emissions of ozone-depleting substances will be prohib-ited. Prohibition of incineration Incineration means the deliberate combustion of wastes or other matter at sea for the purpose of their thermal destruction, excluding activities incidental to the normal operation of ships or other man-made structures. Incineration, except for incineration of ship-generated wastes, is prohibited throughout the Baltic Sea area. However, incineration of wastes deriving from the nor-mal operation of the ship is also prohibited in the territo-rial seas of the Baltic Sea States. Prohibition of dumping Dumping means any deliberate disposal at sea of wastes or other matter from ships, or any deliberate disposal from ships at sea. The prohibition of dumping does not apply to the disposal of dredged materials at sea, pro-vided specific provisions are complied with. Dumping is prohibited throughout the Baltic Sea area. Mandatory delivery of wastes at port reception facili-ties All ships, with some exceptions, are under an obligation to deliver to a port reception facility, before leaving the port, their ship-generated wastes and cargo residues that cannot be legally discharged under the global Interna-tional Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78), or under the HELSINKI CONVENTION. Availability of port reception facilities To enable ships to deliver their ship-generated wastes and cargo residues, over 210 port reception facilities are pro-

effluent or a certain concentration of the substance in the wake astern of the ship. The same applies to tanks that have contained high-viscosity or solidifying Category C substances. The eventual discharge into the sea must com-ply with provisions on the speed of the ship, discharge below the waterline, distance from the nearest land and depth of water. For discharges from tanks that have contained other Cate-gory C substances there are provisions on the concentra-tion of the substance in the wake astern of the ship, maxi-mum quantity of cargo to be discharged, speed of the ship, distance from the nearest land, discharge below the water-line and depth of water. Likewise provisions on concentration of the mixtures to be discharged, speed of the ship and distance from the nearest land apply to discharges from tanks that have con-tained Category D substances. The discharge into the sea of noxious liquid substances, which have not been categorized, provisionally assessed or evaluated, or of ballast water, tank washings, or other residues or mixtures containing such substances, is pro-hibited. Sewage For ships flying the flag of a Baltic Sea State it is prohib-ited to discharge sewage within 12 nautical miles of the nearest land. This prohibition also applies to all other ships in the territorial seas of the Baltic Sea States. How-ever, sewage that has been comminuted and disinfected using an approved system may be discharged at distances greater than 3 nautical miles from the nearest land. In any case, when discharging from a sewage holding tank, the discharge must be at a moderate rate and the ship must be proceeding en route at a minimum speed of 4 knots. Only if an approved sewage treatment plant is used onboard can discharge take place at any distance from the nearest land. For ships, flying the flag of a Baltic Sea State, certified to carry more than 50 persons and engaged in international voyages in the Baltic Sea area, regulations on Surveys and Sewage Pollution Prevention Certificates also apply. Garbage Discharge of garbage in the Baltic Sea area is prohibited. However, food wastes may be discharged, but in any case not less than 12 nautical miles from the nearest land. Fuel oil quality In the Baltic Sea area ship-owners are encouraged to use marine fuel oils with as low sulphur content as possible, but not exceeding 1.5% m/m (mass/mass) by weight. Al-ternatively, exhaust gas treatment systems, proven to



Co-operation in investigation The Baltic Sea States are co-operating to investigate violations of anti-pollution regulations. This is particularly important when a ship violates the discharge regulations in the waters of one State, with-out calling at a port in that State, and proceeds to a port in another State. Thus, a Baltic Sea State can request another State to conduct a Port State Control inspection upon the ship's arrival at the next port of call, to obtain the necessary information and evidence of the sus-pected violation. To enhance this co-operation, the Baltic Sea States have elaborated a Baltic Legal Manual specifying the requirements for obtaining a conviction in each Baltic Sea State and Guidelines on ensuring successful con-victions of offenders of anti-pollution regulations at sea. Fines The Baltic Sea States have agreed to harmonize admin-istrative fines by deciding on a minimum level, which is intended to be preventive - discouraging the master or other person in charge of a ship from violating the anti-pollution regulations. The minimum level will prevent fines varying greatly between the Baltic Sea States, and will also avoid a situation in which it is cheaper to discharge illegally than to use port reception facilities.

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Attachment 2

Application of the “No-Special-Fee” System to Ship- Generated Wastes in the Baltic Sea Area

(source: http://www.helcom.fi/) THE COMMISSION, RECALLING Article 8 of the Convention on the Pro-tection of the Marine Environment of the Baltic Sea Area, 1992 (the Convention) which calls for develop-ment and application of uniform requirements for the provision of reception facilities, RECALLING ALSO Article 9 of the Convention stipulating a need for special measures in relation to pleasure craft, which includes the establishment of ade-quate reception facilities for wastes from pleasure craft,

vided in ports located around the Baltic Sea area. Notification of the intended use of port reception fa-cilities To ensure the use and efficiency of the port reception facilities, an information sheet must be forwarded to the next port of call 24 hours in advance of the intended use of a port reception facility. The sheet must include the following information: the capacity of the waste storage tanks/bins on board; the amounts of wastes delivered at the last port of call and the estimated amounts of wastes to be delivered at the next port of call. The notification can also be accomplished electronically via the Baltic Ports Waste Information System. The “no-special-fee” system According to the “no-special-fee” system, a fee covering the cost of reception, handling and final disposal of ship-generated wastes is levied on the ship irrespective of whether or not ship-generated wastes are actually deliv-ered. The fee is included in the harbour fee or otherwise charged to the ship.

Detection and prosecution of offenders of anti-pollution regulations The Baltic Sea States place high priority on the elimina-tion of violations of anti-pollution regulations, and on the conviction of any offenders. Various actions have been taken to this end. Cargo, Oil and Garbage Record Books MARPOL 73/78 and the HELSINKI CONVENTION lay down a duty to keep Cargo, Oil and Garbage Record Books, and specify the operations requiring entries in the appropriate Record Books. Accurate and timely entries in Cargo, Oil and Garbage Record Books are of utmost im-portance to ensure compliance with the special discharge regulations. A copy of the relevant Record Book may be used in judicial proceedings as evidence of facts stated in the entry. Aerial surveillance In order to prevent and detect any violation of discharge regulations, the Baltic Sea States regularly conduct aerial surveillance supported by satellite observations of their response regions and jointly survey specific parts of the Baltic Sea area. During the joint surveys a chosen traffic route is surveyed for a minimum of 24 hours by a number of aircraft from the Baltic Sea States. A joint command post manages the surveillance in close co-operation with patrol vessels, ready to take proper measures when offenders are de-tected.



age and Garbage to Port Reception Facilities 1 Definition of the "no-special-fee" system 1.1 In this context the "no-special-fee" system is defined as a charging system where the cost of reception, han-dling and disposal of ship-generated wastes, originating from the normal operation of the ship, is included in the harbour fee or otherwise charged to the ship irrespective of whether wastes are delivered or not. 1.2 The "no-special-fee" system is not restricted to any specific type of ship-generated waste. 2 Obligation to pay 2.1 Every sea-going ship's obligation to pay for recep-tion, handling and disposal of oil residues, sewage and garbage is deemed to arise with the arrival of a ship in any port of the participating countries, irrespective of whether or not that particular ship will actually make use of the reception facilities, which are available there. 2.2 The above fee covers the waste collecting, handling and processing including infrastructure and shall be dis-tributed among ships and collected as part of or in addi-tion to the port dues. 3 Exemptions 3.1 A ship may be exempted by the competent authority from the obligation to pay, when engaged in scheduled traffic with regular and frequent port calls and it is en-sured that the disposal requirements will be met on the ship’s own account. 3.2 For the purpose of these Guidelines "scheduled traf-fic with regular and frequent port calls" means the traffic meeting the following criteria:

3.2.1 scheduled: the ship must have a published or planned list of times of departures and arrivals, between nominated ports or terminals;

3.2.2 regular: for being exempted, the ship must make repeated journeys between those nominated ports or terminals; or

3.2.3 frequent: the ship must visit the port for which the

exemption applies at least once a week. 3.3. When a ship applies for an exemption, the compe-tent authority of the Port State should require evidence of the ship’s scheduled traffic as well as evidence of waste management practice (contract, receipts, copy of garbage record book, oil record book etc.). The ship has to organise its waste management according to a contract and deliver its waste regularly under this arrangement in a certain port/ports. If it chooses to deliver elsewhere, a port can charge the ship according to the real costs (direct fee). 3.4. The Contracting Parties should also advise on ex-

CONSCIOUS that the "no-special-fee" system consti-tutes a system with the dual purpose of encouraging ships to deliver waste ashore and to avoid undesirable waste streams between ports, thereby encouraging a sound sharing of the waste burden, CONSCIOUS ALSO that the “no-special-fee” system constitutes one of the prerequisites for a substantial de-crease in the number of operational and illegal dis-charges and thus for the prevention of pollution of the marine environment from ships, NOTING that the port authorities are responsible for providing reception facilities for wastes covered by An-nex I (oil), Annex II (noxious liquid substances), Annex IV (sewage) and Annex V (garbage) of the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto (MARPOL 73/78), NOTING ALSO that the consignor in the loading port is responsible for reception arrangements for cargo re-lated wastes covered by Annex I (oil residues from cargo tanks) of MARPOL 73/78, NOTING FURTHER that the consignee in the unload-ing port is responsible for reception arrangements for wastes covered by Annex II (residues of noxious liquid substances) of MARPOL 73/78, RECOMMENDS that the Governments of the Contract-ing Parties apply the attached Guidelines for the estab-lishment of a harmonised "no-special-fee" system for the operation of reception facilities in their ports as of 1 January 2000 for ship-generated wastes covered by An-nex I (oily wastes from machinery spaces) of MARPOL 73/78 and as of 1 January 2006 for wastes covered by Annex IV (sewage) and Annex V (garbage) of MAR-POL 73/78, TAKING NOTE of the adoption within the European Union of Directive 2000/59/EC on port reception facili-ties for ship-generated waste and cargo residues, REQUESTS the Governments of the Contracting Parties to support or seek active co-operation with the North Sea States for the purpose of establishing a similar "no-special-fee" system also in the North Sea Region, REQUESTS ALSO the Governments of the Contracting Parties to report on the implementation of this Recom-mendation and attached Guidelines in accordance with Article 16(1) of the Convention.

Guidelines for the Establishment of a Harmonised "No-Special-Fee"

System for the Delivery of Ship-Generated Oily Wastes Originating

From Machinery Spaces and for the Delivery of Sew-



ing and operation of reception facilities, and evaluate such reports at the meetings of the Maritime Group of the Helsinki Commission.

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emptions issued to other Port States along the scheduled route. The Contracting Parties will inform the HELCOM Secretariat of their competent authority responsible for granting exemptions from the mandatory delivery and notification requirements. 4 Basis of calculation of the no-special-fee 4.1 The waste management fee imposed on a ship should be independent of the volume of the wastes delivered to the port reception facilities. To obtain the maximum fair-ness in specifying the ship’s contribution to the “no-special-fee” system the gross tonnage, as indicated in the vessel's Data Sheet, could be taken as the basis of calcu-lation by the port. The basis of the quantity calculation of oil, garbage and sewage may depend on the type and size of the ship as well as the number of crew and passengers. 4.2 A high quality standard of the applied waste manage-ment procedures and waste processing equipment on board can also be taken into account in scaling the waste management fee, having in mind the general aim of mini-misation of waste production, and the benefit of waste separation. 4.3 The waste management fee shall be fair, transparent and non-discriminatory to all ships, i.e. the size of the waste management fee shall be visible to every ship even if it is included in the harbour fee. 4.4 The waste management fees received from ships shall be used for no other purposes than:

- investments in reception facilities, stationary and mobile; - operation of reception facilities; - repair and maintenance costs of such facilities; and - costs of handling, treatment and final disposal of the received wastes.

5 Avoidance of competitive distortion 5.1 To avoid competitive distortions between ports lo-cated in different sea areas, all possible efforts shall be made to achieve as soon as possible a harmonised waste management fee system for the ports in the Baltic Sea and in the North Sea Regions. 5.2 The Contracting Parties involved shall make the nec-essary efforts in order to implement a harmonised fee system simultaneously in the ports of the Baltic Sea as well as in the North Sea Regions. 5.3 Provisions should be made to preclude any subsidis-ing of the waste management fee through public funds for the operation of reception facilities. 5.4 The Governments of the Contracting Parties shall exchange periodic reports on the implementation of these Guidelines in their ports, including reports on the financ-



der amendments to Annex VI adopted by the MEPC in July 2005, with expected entry into force in November 2006.

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Special areas under MARPOL 73/78 are as follows: 1) Annex I: Regulations for the prevention of pollu-tion by oil Regulation 10 identifies the following special areas with strict controls on discharge of oily wastes: • Mediterranean Sea area • Baltic Sea area • Black Sea area • Red Sea area • “Gulfs” area • Gulf of Aden area • Antarctic area • North West European Waters • Oman Sea area of the Arabian Seas (from 1 January 2007) 2) Annex II: Regulations for the prevention of pollu-tion by Noxious Liquid substances Regulation 1 identifies the following special areas with strict controls on tank washing and residue discharge procedures: • Baltic Sea area • Black Sea area • Antarctic area 3) Annex V: Regulations for the prevention of

pollution by Garbage Regulation 5 identifies the following special areas, in which there are strict controls on disposal of garbage: • Mediterranean Sea area • Baltic Sea area • Black Sea area • Red Sea area • “Gulfs” area • North Sea • Antarctic area (south of latitude 60 degrees south) • Wider Caribbean region including the Gulf of Mex-ico and the Caribbean Sea 4) Annex VI: Prevention of air pollution by ships This annex enters into force on 19 May 2005 and estab-lishes the Baltic Sea area as a "SOx Emission Control Areas" (SECA) with more stringent controls on sulphur emissions from ships. The North Sea was adopted as a SECA in July 2005, un-

MARPOL Special Areas



ment in newbuildings and who are not interested in a ship’s life longer than 20 years. These are entirely le-gitimate concerns and interests, which will need to be accommodated within the CSR development process. There are still areas of ship design and building issues waiting for new technology to come up with new solu-tions or clarification. The advance of new technology will leave the CSR under continuous pressure for re-view and evaluation. Information flow between key stakeholders of the CSR can either promote or restrict the understanding and appreciation of the CSR. Lack of transparency or shortage of information flow will delay the process of CSR development and the review process. Shipyards and marine products manufacturers have to respond to the CSR positively. New designs under the CSR will therefore impact on their standards. The cost of absorption will be passed down to the end user, shipowners, with commercial uncertainty. The principle of CSR is to reduce the competition level between IACS Members but internal conflicts have been evidenced in the review and harmonisation of the CSR between tanker and bulk carrier and the ramification study, although recent perceived unanim-ity within IACS Members has been greatly welcomed by the wider shipping industry. There is always a question as to what extent the CSR incorporates the industry comments and feedback. Overall impact on shipping CSR, covering both single and double side skin bulk carriers, will come into force for ships contracted for construction on or after the 1st of April 2006, as de-cided by IACS Council in December 2005. From April 1, 2006, ships contracted will be subject to the new rules. According to the IACS assessment, bulk carriers, built to the new common rules, could be expected to require “5%-6%” more steel on average than ships either built or under construction that did not already comply with the Unified Requirements issued by IACS for ships contracted after July 1, 2003. This equals to a 3% rise in scantlings over a ship built to UR S25. Apart from the opportunity cost of ship new buildings between the first draft CSR available in 2004 and final

General industry position INTERCARGO, together with the other three Round Table International Shipping Associations (BIMCO, ICS and INTERTANKO), lends its full support to IACS and its commendable work on developing Common Structural Rules (CSR) for Bulk Carriers. We believe that the broad application of the Rules by all IACS members is funda-mental to the future of Class and is in the best interests of maintaining the highest standards of ship safety and qual-ity. INTERCARGO has shown and will continue to show its commitment to work together with IACS in the har-monisation and future reviews process. As to the history, the 2nd draft of Common Structural Rules for Bulk Carriers was published on the JBP Web-site on 8th April, 2005. Large number of comments from the Industry have already reached IACS and led to the revision of the 2nd draft CSR. It shows that the IACS harmonisation process has difficulties. It is the request of the shipping industry that the IACS members should en-deavour to maximise those elements of harmonisation which can be achieved before the implementation of the CSR. Both IACS and the industry have covered much ground, however the industry still has areas of concern and has requested IACS to consider them during the harmonisa-tion process and future revisions in the review process. Uncertainties at present with the impact on the CSR The IMO is also busy with the development of Goal-based New Construction Standards (GBS), which are indirectly linked to the CSR development. Such a link will have a significant impact on the future review of the CSR. This leaves CSR with a level of uncertainty for its user. Maritime safety and environmental issues are increas-ingly attracting the attention of the public, who together with their governments, are demanding increasingly ro-bust ships. These pressures alone are enough to push the development of CSR to the fullest extent of its safety margins. Shipping is driven by commercial interest. Shipowners who put more attention on the long term benefit, will respond positively to the increase of safety margins, but there are also groups of shipowners positioning them-selves with the intention of relatively short term invest-

IACS Common Structural Rules



implement the CSR from 1 Apr 2006, the following sug-gestion is offered to those owners who are planning new-buildings: 1. The CSR for bulk carriers are completely new to all yards. There will be more certainty in terms of cost, de-sign, planning approval, and delivery date if the new-building contract follows existing rules prior to the intro-duction of CSR on 1 Apr 2006, because normal yards have years of experience using them. This will make for a cheaper newbuild vessel price. However, those with the perception to use the CSR may have a more robust, ‘forward-proofed’ ship offering the long-term benefits such as a sound second hand resale security and compli-ant with future IMO strengthening requirements; and 2. Owners will need to check the up-to-date development in the areas of uncertainty, for an overall appreciation and understanding of the situation. Only then will they be in a position to take the decisions necessary for a satisfactory outcome.

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implementation in 2006, same uncertainties remain and may leave a long term impact on new ships during their 25 years of commercial life. On the positive side, the CSR is expected to raise the overall safety bar for new ships. It is also expected to reduce market forces on ship design and building and avoid compromise on the safety level of ships. The same set of rules across the whole design and construction sec-tor is expected to provide the same design in term of main scantling and strength elements, which will reduce the opportunity to optimize design and new building stan-dards. On the commercial side, heavier ships will incur higher cost of building and a burden on the original owner but will give more certainty to the second hand owners. On the negative side, all new ships with IACS member societies’ class will follow the new CSR and bear the possible cost of all uncertainties. A tiny proportion of ships of non IACS Member societies may compete with the CSR ships with the advantage of an initial low invest-ment on newbuildings, although it is not widely antici-pated that owners will overturn the many years of experi-ence with IACS Members in favour of untried non tech-nically competent non IACS members. The CSR may result in a higher cost for new orders. Those owners who have newbuildings shortly after 1 July 2006 may have to bear the cost of change or re-arrangement of production lines with ship yards. New rules will also improve the design and drawing ap-proval process. Extra resources from shipowners may need to be allocated to digest the new rules, especially to those who have new building contracts with yards around 1 July 2006. Conclusion Industry welcomes the development of the CSR with the expectation that there will be improvement on the safety level of ships. However, the influences from different interest groups internally and externally may push the CSR development into a compromise situation. In addi-tion, there are a number of areas of uncertainty from dif-ferent parts of the whole safety chain, which will load significant and different long term cost impacts on indi-vidual shipowners. CSR ships may have material differ-ences regarding loading capacity, maintenance and opera-tion, and ship/terminal regimes. They will need to be tested against the real sea and cargo conditions, which goes some of the way to explaining why the development process has been as time-consuming as it has been to the INTERCARGO working group and others who have con-tributed so extensively to the debate. With the perception that IACS will move forward and



Board Ships, adopted by the IMO by resolution MSC.88(71), as subsequently amended;

(11) Cargo Securing Manual: a manual for the secur-ing of cargo, as required by SOLAS, prepared pursuant to IMO guidelines, MSC/Circ.745, as subsequently amended;

(12) MARPOL 73/78: the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978, as subse-quently amended;

(13) MFAG: the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, MSC/Circ. 857, as subsequently amended;

(14) Resolution A.673 (16): the IMO Guidelines for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels. The resolution ap-plies to all combustible substances, irrespective of whether or not they are listed in Appendix 1 of the resolution;

(15) SOLAS (Chapter VII): the International Conven-tion for the Safety of Life at Sea 1974, as subse-quently amended; and

(16) STCW: the International Convention for Stan-dards, Training, Certificates and Watchkeeping 1978, as subsequently amended.

Normally there are entry-into-force dates clearly indi-cating its implementation. In absence of an entry into force date, the adoption date should be complied with. Ships carrying cargoes covered by the above provisions should, to the extent they are covered by the body of legislation, keep the following documentation on board:

SOLAS, Chapter VII; SOLAS, Regulation II-2/19 / Regulation II-2/54; MARPOL, Annex III; BC Code; IMDG Code; EmS; MFAG; and Directive 2002/59/EC.

Packages containing dangerous goods offered for sea transport should be marked and packaged in compliance with applicable regulations, and accompanied by the necessary transport documents. Goods which do not comply with this should be refused for transport. Goods in damaged packaging should always be refused.

The following IMO Conventions, Resolutions, Codes, Circulars, Manuals as well as EU Directives are relevant for a ship carrying dangerous cargoes. The ships should comply with their provisions according to which type of dangerous cargoes are on board. It is also prudent for those ships to make sure whether there are additional requirements from their flag States and the visiting port States: (1) BC Code: the Code of Safe Practice for Solid Bulk

Cargoes, adopted by the IMO by resolution A.434(XI), as subsequently amended;

(2) BCH Code: the Code for the Construction and Equipment of Ships Carrying Dangerous Chemi-cals in Bulk, adopted by the IMO by resolution A.212 (VII), as subsequently amended;

(3) Directive 2002/59/EC: the EU Directive 2002/59/EC establishing a Community vessel traffic and monitoring and information system and repealing Directive 93/75/EEC, as subsequently amended;

(4) MSC Circular EmS: Emergency Response Proce-dures for Ships Carrying Dangerous Goods, MSC/Circ.1025, as subsequently amended;

(5) GC Code: the Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk, adopted by the IMO by resolution A.328(IX), as subsequently amended;

(6) Gas Code for existing gas carriers: the Code for Existing Ships Carrying Liquefied Gases in Bulk, adopted by the IMO by resolution A.329 (IX), as subsequently amended;

(7) IBC Code: the International Code for the Con-struction and Equipment of Ships Carrying Dan-gerous Chemicals in Bulk, adopted by the IMO by resolution MSC.4(48), as subsequently amended;

(8) IGC Code: the International Code for the Con-struction and Equipment of Ships Carrying Lique-fied Gases in Bulk, adopted by the IMO by resolu-tion MSC.5(48), as subsequently amended;

(9) IMDG Code: the International Maritime Danger-ous Goods Code, adopted by the IMO by resolu-tion A.716(17), as subsequently amended;

(10) INF Code: the International Code for the Safe Car-riage of Packaged Irradiated Nuclear Fuel, Pluto-nium and High-Level Radioactive Wastes on

Cargoes - Dangerous - Requirements on Ships Carrying Dangerous Cargoes



All ships carrying dangerous goods should have a spe-cial list, manifest or detailed stowage plan which sets out the dangerous goods on board and the location thereof. The relevant training to the ships’ crew should be made according to the requirements of the IMDG Code and STCW, and must be documented, as referred to in the IMDG Code, Volume 1, Chapter 1.3 and STCW 1995, Chapter II, Section A-II/2 including Tables, and Section B-V/c of the STCW Convention. Safety measures for dangerous packaged goods should also be in place.

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• IMO Circular DSC.1/Circ.36 on Accidents involv-ing transport of direct reduced iron (DRI) fines;

• IMO Circular MSC/Circ.1149 on Accidents In-

volving Bulk Cargoes Not Specifically Listed In the Code of Safe Practice for Solid Bulk Cargoes (BC Code);

• IMO MSC79 meeting paper on report of the ex-

plosion and subsequent sinking of M.V. Ythan carrying DRI (MSC79 12-1);

• DSC.1/Circ.26 on Incident involving transport of

zinc ingots; • DSC.1/Circ.27 on Explosion in a Cargo Hold

Loaded With Recycled Aluminium; and • MSC/Circ.1146 on Lists of Solid Bulk Cargoes for

Which a Fixed Gas Fire-Extinguishing System May Be Exempted or for which a Fixed Gas Fire-Extinguishing System Is Ineffective.

Contact [email protected] for details of the above in-formation.

********

The cargo DRI or direct reduced iron is one of the raw materials used in the production of steel by certain method. When moist, hydrogen is released. It also cre-ates heat, which can be so extreme that the DRI glows white hot. It has been known to melt through steel plate. The hydrogen it produces in an enclosed space like the cargo holds could be ignited and causes an explosion. Before its loading, following cautions should be taken: • Prior to shipment the DRI has to be aged for at

least 72 hours or treated with an air-passivation technique, or some other equivalent method that reduces the reactivity of the material to at least the same level as the aged product would have (72 hours);

• It should not be loaded when it is either hot or

damp; • Its condition should be monitored during loading.

Cargo with a temperature in excess of 65 ºC should never be loaded;

• During loading the DRI must be protected from

exposure to rain or other respiration; • As far as is reasonably practical, DRI should not

be dropped from a height into the hold; • DRI, which has been exposed to wetting on an

open-conveyor or elsewhere, should be rejected; • During loading or discharging no smoking, burn-

ing, cutting, chipping or other source of ignition should be allowed in the vicinity of the holds; and

• Movable cargo lights, if used, must be not less

than 3m from the coaming in a position where they are not likely to be broken during operations, and not over the square of the hatch.

Relevant information with requirements and reports of incidents: • IMO BC Code (the Code of Safe Practice for

Solid Bulk Cargoes), as adopted by Resolution MSC.193(79);

• IMO Circular DSC/Circ.8 on Incident reports in-

volving dangerous cargoes;


Cargoes - Direct Reduced Iron


2. Emergency towing procedures on ships 2.1 Ships shall be provided with an emergency

towing procedure. Such a procedure shall be carried aboard the ship for use in emergency situations and shall be based on existing ar-rangements and equipment available on board the ship.

2.2 The procedure shall include: .1 drawings of fore and aft deck showing pos-

sible emergency towing arrangements; .2 inventory of equipment on board that can

be used for emergency towing; .3 means and methods of communication; and .4 sample procedures to facilitate the prepa-

ration for and conducting of emergency towing operations.

2.3 This regulation applies to ships, regardless of the date of construction, as follows: .1 all new ships constructed after [1 July

2008]; .2 cargo ships constructed before [1 July

2008] and above 20,000 dwt and all pas-senger ships not later than [1 July 2008]; and

.3 cargo ships constructed before [1 July 2008] and below 20,000 dwt not later than [1 July 2010].

An intersessional correspondence group will be estab-lished to finalise the guidelines for owners/operators on the development of emergency towing procedures, and submit a report to DE50. The Co-ordinator is Dipl.-Ing Stephan P. Assheuer, [email protected]. Clarification at DE 49 1) Certificates and document required to be carried on board ships. This should be considered as a verification that such pro-cedures are available on board, rather than an approval or verification of the content. Such availability on board could sufficiently be granted by inclusion of the emer-gency towing procedures in FAL.2/Circ.87 - MEPC/Circ.426 - MSC/Circ.1151. 2). The emergency towing procedures should be added to the list of documents to be carried on board ships and that circular FAL.2/Circ.87 - MEPC/Circ.426 - MSC/Circ.1151 should be amended accordingly.

********

Background The DE Sub-Committee, at its forty-eighth session in Feb 2005, established an intersessional correspondence group (CG) on Mandatory emergency towing systems in ships other than tankers greater than 20,000 dwt (DE 48/25 paragraph 14.4) coordinated by Germany. The CG was instructed to prepare a revised proposal for draft SOLAS amendments to SOLAS chapter II-1, Regu-lation 3-4 and related guidelines as per Annex 1 and 2 of DE 48/14 for the assessment of deck equipment to be used in emergency towing, taking into account comments and proposals made in plenary, and to submit a report to DE 49 in Feb 2006. Intercargo is one member of the CG, together with Ger-many, Australia, Cyprus, Italy, Japan, the Netherlands, the United Kingdom, the United States, ICS, IMCA, In-tertanko and ISU. Work of the DE 48 CG The Correspondence Group did not make any progress but, Germany still insists on developing new regulations. The only concern so far is their suggestion that the emer-gency towing can be arranged without assistance by crew members. From the limited input received, it can be summarised that there is a need: • for a common understanding of certain terms used in

the context of the guidelines (towing, emergency, redundant propulsion systems …), and

• that there be a re-emphasis on developing and meeting

functional requirements for procedures and arrange-ments for emergency towing.

Outcome of DE 49

Intercargo agrees to the development of emergency pro-cedures but not mandatory requirements for equipment and supports the application to new ships only. Intercargo accepts the comments: At DE 49 in Feb 2006, it has been agreed that there will not be requirements for equipment installation but only procedure requirements for new and exiting ships. The following draft amendments to regulation 3-4 of SO-LAS Chapter II-1 were agreed at DE 49:


Emergency Towing - Progress report of New Requirements


However, in urging our members to comply with this resolution and, as we propose in other pilotage situa-tions, we advocate the mutual sharing of responsibility by the respective parties. It is therefore our contention that the pilotage service provider, when contracting to provide such services, should accept liability for loss or damage caused by the vessel under pilotage, where such loss and/or damage is attributable to the deliberate and/or negligent actions of the pilot and/or the service provider, and that the national authority responsible for licensing and regulating the pilots and pilotage service providers ensures that the pilotage service provider maintains ade-quate insurance protection to discharge this liability. We believe that this approach highlights that our primary concern is about damage caused by the ship, and ad-dresses both the duties of the pilotage service provider, with regards to such matters as training, ensuring pilots are competent both physically and professionally, provi-sion of appropriate equipment and backup etc. By drawing this distinction between the pilotage service provider and the national regulatory authority, Intercargo believes this highlights that the pilot is not the employee of the regulatory authority but the service provider – by doing so, and if the regulatory authority chooses to also be a service provider, it should be subject to the same responsibilities as all service providers in regard to its activities. 3. Issues of further consideration 3.1) Reaction of the adjacent States It is noted that the issue is highly sensitive due to the recent boom in Russian oil exports that move through the straits. Baltic Sea States have declined to agree to make pilotage compulsory, with Russia in particular arguing that the international law of the sea should be respected. 3.2) Commercial aspects One relevant issue as raised some time ago by a member was the unwillingness of a time charterer to pay for non-mandatory pilotage expenses in the English Channel where a Master of a deep draughted bulk carrier chose to take a pilot but was not required to do so. The Charterer argued that Masters of such ships which they had previ-ously chartered had sufficient experience not to require a pilot. Therefore, they took the view that they should not have to pay. We agree that the bottom line should be safety and nothing else. However we have to be aware that our members are moving in a commercial world and usually do not like to see mandatory conditions applied to their operation.

1. Background The Danish Maritime Authority (DMA) wrote to Inter-cargo on 10 Oct 2005 urging all ships (other than tankers) with a draught of 11m or more or with Irradiated Nuclear Fuel (INF) cargoes to take on a pilot when they enter or leave the Baltic Sea, as recommended by the IMO under Resolution MSC.138(76). The DMA backs up this asser-tion with a report that from 1 January 2002 to 30 June 2005, 22 ships grounded on the Great Belt – none of which had a pilot onboard. Intercargo recognises all IMO Recommendations. Careful review was taken of the recommendations con-tained within the letter and the “Groundings and collision reports in the Great Belt 1997-2005”. Intercargo reacted to the letter through a clear statement in the INTER-CARGO Bulletin No. 202, October 2005 with a recom-mendation from the DMA that the IMO recommenda-tions should be followed and that members should in-clude the INTERTANKO Clause in their Charter Parties, as follows: Where the vessel is to pass through the entrances to the Baltic Sea the vessel shall comply with the recommenda-tions set out in the IMO Resolution MSC.138(76) adopted on 5 December 2002 as amended from time to time in-cluding the use of pilots for the passage. Charterers shall reimburse owners for any pilotage expenses incurred by compliance with these recommendations on any ballast passage to a port of loading or on the laden passage unless such expenses have already been taken into ac-count in the freight payable [in accordance with the terms and conditions of Worldscale]. 2. Intercargo Position Intercargo responded to DMA’s letter with a position that the IMO recommendations should be followed but, as intended by IMO, there is a distinction between Recom-mendations and Mandatory Resolutions. However, in this particular instance, Intercargo is fully prepared to go fur-ther and urge its members to comply with the recommendation contained in Resolution MSC.138(76) regarding pilotage in the Danish Straits and include the INTERTANKO Clause in their Charter Parties. The DMA was also informed that Intercargo is in the process of establishing an Ad Hoc Correspondence Group to review the issue of Pilotage as it relates to dry bulk carriers. Intercargo welcomes and promotes the creation of a 'User Group' where industry and pilot inter-ests can be debated openly, issues can be discussed and problems solved.


Pilotage - Denmark


4. Safety measures in the Baltic Sea area: The Baltic Sea States have agreed on certain safety meas-ures in the Baltic Sea area, like ship routing, ship report-ing, traffic separation schemes, pilotage, safety of winter navigation etc.

Route T

A transit route (Route T) through the Kattegat, the Great Belt and the Western Baltic has been established for deep draught ships.

SHIPPOS

IMO recommends that large ships navigating Route T participate in the radio reporting service SHIPPOS. The system, which is free of charge, provides beneficial infor-mation to ships.

Ship reporting systems

IMO has adopted a mandatory ship reporting system in the Great Belt Traffic Area. Ships with a gross tonnage equal to or exceeding 50 GT, and all ships with an air draught of 15 metres or more, are required to submit a ship report to the VTS Centre. Participation is free of charge. Mandatory ship reporting systems have also been estab-lished nationally by the Baltic Sea States in approaches to oil terminals.

Automatic Identification System (AIS)

The Baltic Sea area within A1 sea area will be covered by land-based monitoring systems for ships, based on AIS signals (by 1 July 2005). The AIS information will improve the safety of naviga-tion via real time information as well as statistical infor-mation on shipping in the Baltic Sea. The AIS informa-tion will also be used to identify offenders of anti-pollution regulations.

Pilotage

Pilotage services are established locally by the coastal states. IMO recommends that, when navigating the Sound, local pilotage services should be used by: - loaded oil tankers with a draught of 7 metres or more; - loaded chemical tankers and gas carriers irrespective of size; and

3.3) Liability and human element of the service pro-vider Liability:- With regard to the pilotage provider, when providing such services, there is an issue of liability for causing loss or damage to the vessel under pilotage, where such loss and/or damage may be attributable to the deliberate and/or negligent actions of the pilot and/or the service provider (and also the national authority responsi-ble for licensing and regulating pilots?). Do the pilotage service providers maintain adequate insurance protection to discharge this liability? By drawing a distinction between the pilotage service provider and the national regulatory authority that the pilot is not the employee of the regulatory authority but the service provider –then if the regulatory authority chooses to also be a service provider, then it should be subject to the same responsibilities as all service provid-ers in regard to its activities. Human element:- Concerns about the quality, qualifica-tions of pilotage and the efficiency of the whole system in the area, including the number of appropriately qualified pilots, training, professional competency both physically and professionally, provision of appropriate equipment and backup, etc. need to be addressed. Procedures:- to manage their areas of responsibility, including measures to deal with pilot fatigue. 3.4) Common practice of members What is the common practice of the membership when their vessels pass through the Danish Straits? 3.5) The regulatory regime of DMA Review of the system:- Are there any independent re-views of the pilotage regulatory system and regular re-views of the pilotage operations? Information on support and fair treatment of every vessel with or without a pilot onboard is needed. Code of practice to cover: * Clarification of the responsibility of provider organi-

sations and individual pilots; * Effective and comprehensive fatigue management

arrangements; * Effective and safe boarding arrangements; * Emergency management arrangements; * Maintenance of effective training programs; and * Introduction of a "check" pilot system. 3.6) Price Is the $7,500 a reasonable charge for the pilotage service? Is the price referred to review by a Surveillance Authority in the EU system?



- ships carrying a shipment of irradiated nuclear fuel, plutonium and high-level radioactive wastes (INFcargoes). IMO also recommends that, when navigating Route T, established pilotage services should be used by: - large ships with a draught of 11 metres or more; and - ships carrying a shipment of irradiated nuclear fuel, plutonium and high-level radioactive wastes (INFcargoes).

Traffic separation schemes

Traffic separation schemes are established and adopted by IMO in the following parts of the Baltic Sea area:

Deep sea pilotage

Certified Baltic deep sea pilots are available in all Baltic Sea States.

Safety of winter navigation Adequate ice strengthening is required for ships sailing in ice. Information about ice conditions in the Baltic Sea area can be obtained from the national ice services. Contact information of the national ice services and basic infor-mation about ice conditions in the Baltic Sea area can be obtained from the common website of the national ice services of the Baltic Sea States www.bsis-ice.de.

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Area Number of schemes

In Samsø Belt/Great Belt 2

In the Sound 2

Off Kiel lighthouse 1

South of Gedser 1

South of Öland Island 1

South of Gotland Island 1

Entrance to the Gulf of Finland 2

In the Gulf of Finland 5


1. Background MEPC 52 (11-15 October 2004) approved an MEPC cir-cular on the Guidelines for the development of a ship recy-cling plan. MEPC 53 (18 to 22 July 2005) approved an MEPC circu-lar MEPC/Circ.419 on the Implementation of the IMO Guidelines on ship recycling, providing specific recom-mendations and guidance to Administrations in recycling States, shipowners and recycling facilities. Another circu-lar MEPC/Circ.466 on “Gas- free- for- hot-work” certifi-cation in connection with recycling operations was also approved. The circulars are available for download from http://www.imo.org/home.asp. The 24th IMO Assembly (A24) (21 November to 2 De-cember 2005) adopted a resolution to develop the above-mentioned instrument and agreed to complete the new legally binding instrument on ship recycling in time for consideration and adoption by a diplomatic conference in the 2008-2009 biennium. The instrument would cover the design, construction and operation of ships as well as preparation for the delivery of a ship prior to recycling. A24 adopted amendments to resolution A.962(23). Con-tact [email protected] for the sources of the amend-ments. It was also agreed that the development of a new legally binding instrument on ship recycling should not shift the attention of stakeholders away from implementa-tion of the current IMO Guidelines on ship recycling adopted by Resolution A.962(23). Contact [email protected] for the source of A.962(23). 2. Draft structure for the new instrument on ship recy-cling MEPC 53 developed a preliminary draft structure for the new instrument on ship recycling and had an initial con-sideration on a number of issues related to the develop-ment of the appropriate mandatory requirements on ship recycling, including items as outlined in the table at the end of the article. 3. Green passport The outcome of MEPC 53 indicated that the Green Pass-port should contain, at least, the following information on the ship details: .1 the name of the State whose flag the ship is entitled

to fly; .2 the date on which the ship was registered with that

State;

.3 the date on which the ship ceased to be regis-tered with that State;

.4 the ship’ identification number (IMO number);

.5 hull number on new-building delivery;

.6 the name and type of the ship;

.7 the port at which the ship is registered;

.8 the name of the shipowner and its address;

.9 the name of all classification society(ies) with which the ship is classed;

.10 the ship’ main particulars (Length over-all (LOA), Breadth (Moulded), Depth (Moulded), Lightweight); and

.11 shipbuilder’ name and address. 4. Hazardous Materials Inventory Inventory of the materials known to be potentially hazardours, containing the location and the approxi-mate quantity/volume of each identified material on board the ship, split into the following parts:

Part 1 - Potentially hazardous materials in the ship’ structure and equipment;

Part 2 - Operationally generated wastes; and Part 3 - Stores.

Any changes relating to Part 1 of the inventory should be recorded so as to provide updated and cur-rent information together with a history of the changes. Inventories of operationally generated wastes (Part 2 of the inventory) and potentially hazardous items carried as stores (Part 3 of the inventory) should be prepared by the shipowner prior to or dur-ing the final voyage to the recycling facility and handed to the recycling facility on delivery of the ship, as part of the Green Passport. It is a less confusing issue regarding requirement for a Green Passport on a newbuilding, on a voluntary basis, than for the purchase of second hand ship when its issue of a Green Passport could be confusing no matter how long an owner intends to keep the ship. On existing ships, there is still nor firm conclusion as to when the mandatory requirement will be in place or to what extent retrospective application will apply. A cautious approach for existing ship owners is to prepare for application as soon as possible. 5. Gas Free Certification At MEPC 53, it was decided that ship owners, ship recycling facilities and member states will be urged to consider the matter of gas-freeing vessels in prepa-ration for recycling by circular MEPC/Circ.466 on

Ship Recycling



******** the Implementation of the IMO Guidelines on Ship Recy-cling - “Gas-free-for-hot-work” certification, 6. Responsibility delineation between yard and last operating owner Although it encourages ship owners to deliver vessels with a “gas-free-for-hot-work” certificate, it recognises that it is the main responsibility of the ship recycling fa-cility to ensure that those tanks which have been certified are maintained in the gas-free state. Shipowners are urged to enter into contract only with those recycling facilities with the ability to maintain and monitor ships in “gas-free-for-hot-work” condition during the whole process of ship recycling. 7. Licensed/Approved recycling Facilities In the framework of the legal instrument, ship recycling facilities will also be regulated to ensure safe and envi-ronmentally sound recycling. Under the proposed regime, recycling yards and facilities are required to be licensed/approved to conduct the recycling business. 8. Intercargo position Intercargo has the following position on the IMO Con-vention: Continue to support the development of an IMO Convention on Ship Recycling, and to underline that the IMO is the key UN agency on this issue. Intercargo will: • invite members to provide feedback on the imple-

mentation of various aspects of the IMO Guide-lines so that this may be presented during the IMO mandatory process;

• ensure an active participation in both the Working Group and Correspondence Group during MEPC meetings; and

• provide members with continuous feedback on the development of the Convention

9. References (contact [email protected] for the sources of information) 1). Resolution A.962(23) IMO Guidelines on ship recy-

cling, adopted on 5 December 2003 2). Amendments to the IMO Guidelines on Ship Recy-

cling (Resolution A.962(23)) 3). MEPC/Circ.466 on Implementation of the IMO

Guidelines on Ship Recycling (Assembly resolution A.962(23))

4). MEPC/Circ.419 on Guidelines for the Development of the Ship Recycling Plan



Items of the preliminary draft structure for the new instrument on ship recycling


Mandatory Requirement Guidelines Refer-ence

Recycling Facilities

Recycling State to require operational waste reception facilities at recycling facilities 9.4.2.3

Ship Recyclers to be "licensed" 9.4.4.1

Shipowners required to use “approved/licensed” recycling facilities 8.1.6

Shipowners to arrange for removal of materials the recycling facility cannot handle 8.1.5

Reporting

Ship Recycling Plan

Recycling facility to prepare a ship recycling plan in consultation with the shipowner 8.3.2.2

Ship Recycling Contract

Shipowners/Recycling facilities to include elements of the Guidelines such as the Ship Recycling Plan, etc. in recycling contracts

8.3.2.5, 9.2.2, 9.4.3.3, 9.8.2

Potentially Hazardous Materials

States to prohibit/restrict/minimize the use of potentially hazardous materials in new ships 6.1.1, 6.1.4, 6.1.2

Shipbuilders to provide the first shipowner with Part 1 of the inventory 5.5

States to prohibit/restrict/minimize the use of potentially hazardous materials in existing ships 7.2.1

Shipowners to provide an updated inventory of potentially hazardous materials on board on arrival at the recy-cling facility

5.6

Shipowners to mark assumed and identified potentially hazardous materials included in the inventory and any potentially hazardous spaces in accordance with the Ship Recycling Plan

8.3.1.1, 8.3.1.2.2, 8.3.3.2.8, 8.3.4.1.2-4

Shipbuilders to seek advice on limiting the use of identified potentially hazardous materials in ships 6.1.6 Green Passport

Shipbuilders to provide new ships with a “Green Passport” 5.5, 5.5.1, 5.8

Shipowners to maintain Ship Details and Part 1 of Inventory sections of the “Green Passport” 5.1, 5.3

Shipowners to prepare Parts 2 and 3 of the Green Passport prior to the final voyage to the recycling facility 5.6

Shipowner to develop “Green Passport, Part 1” for existing ships as far as is reasonable and practicable 5.5.2

Shipowners to deliver “Green Passport” to recycling facility 5.1

Gas Free for Hot Work Certificate

Shipowners to arrange with recycling yard for a "gas-free-for-hot-work" certificate covering enclosed cargo and other spaces and empty fuel spaces at handover or in accordance with the Ship Recycling Plan

8.3.4.1, 9.4.3.2, 8.1.3.3

Ship Details

Shipowners to hand over the Continuous Synopsis Record to the recycling facility 5.2.1 (Pending development of the “Green Passport”)


tion MEPC No.108(49), cargo monitors originally in-stalled on vessels built before January 1, 2005, may meet either the new or previous standards when replaced. Oily water separating equipment and bilge alarms, however, installed on existing vessels to replace existing equip-ment must meet the new standards. In addition, the NPRM would remove existing requirements for bilge monitors. The NPRM would require the use of pollution preven-tion equipment that is more technologically advanced than that found on most oceangoing vessels now operat-ing. With respect to cargo monitors, the new regulations would include updated standards for monitors used with category C and D oil-like noxious liquid substances. Under the new regulations, oily water separators would be required to effectively process emulsified oils, surfac-tants, and contaminants. In addition, the proposed rule would impose stricter standards for bilge alarms, includ-ing requirements that every bilge alarm: • Pass new tests using emulsified oil and contami-nants; • Has a ppm display that would display each change in oil content of the mixture being measured within 5 seconds after the change occurs instead of 20 seconds; • Limit access to the bilge alarm beyond checking instrument drift, and require the breaking of a seal to repeat the instrument reading and re-zero the instrument; • Activate the alarm whenever clean water is used for cleaning or zeroing purposes; • Record date, time, alarm status, and operating status of the 15 ppm bilge separator; • Store data for at least 18 months; and • Have the ability to display or print a protocol. Furthermore, in the event that the 15 ppm bilge alarm is replaced, means must be provided to ensure that the data recorded remains available on board for 18 months. Impact of Proposed Rule Owners and operators should consider the lack of speci-ficity associated with the replacement of PPE in the NPRM with respect to the applicability to existing ves-sels. For example, the NPRM provides only that existing oceangoing vessels subject to the new regulations would be required to install oily water separating equipment and bilge alarms that meet the new standards whenever the owners or operators "replace" the equipment. The NPRM, however, does not clarify the extent to which components must be replaced in order to trigger the new requirements. For example, applicability is unclear when only parts of an oil-water separator are replaced. This

New Development On November 3, 2005, the U.S. Coast Guard published a Notice of Proposed Rulemaking (NPRM) proposing to change pollution prevention equipment (PPE) performance standards to make them consistent with the new Interna-tional Maritime Organization (IMO) guidelines and speci-fications issued under Annex I of the International Con-vention on the Prevention of Pollution from Ships (MARPOL). In short, the NPRM would: (1) require newly constructed oil tankers to install

cargo monitors meeting new PPE standards; and (2) require newly constructed vessels and existing

oceangoing vessels (only when an existing vessel is replacing the exiting PPE) to install oily water sepa-rating equipment and bilge alarms to meet new PPE standards. Comments are due February 1, 2006.

Background Many in the maritime community have expressed concerns that existing pollution prevention equipment, especially technology related to oily water separator systems, does not work properly. Of particular concern is the processing of oily bilge waste and the methods by which the oil con-tent of the effluent is measured. In response to those concerns, the IMO issued Resolution MEPC.107(49) "Revised Guidelines and Specifications for Pollution Prevention Equipment for Machinery Space Bilges of Ships." Subsequently, the Coast Guard issued MOC Policy Letter No. 04-13, which provides guidance on implementation of Resolution MEPC.107(49). Please see http://www.blankrome.com/publications/maritime/update0405_06.asp dated April 2005 for a discussion of the IMO guidelines and Coast Guard policy. The Coast Guard noted that the policy will remain in effect until regu-lations are promulgated. In addition, IMO issued Resolu-tion MEPC No.108(49), Revised Guidelines and Specifica-tions for Oil Discharge Monitoring and Control Systems for Oil Tankers, which upgrades cargo monitor PPE stan-dards. The IMO standards become effective internationally as an amendment to MARPOL on April 1, 2007. The Proposed Rule The NPRM would not change the type or class of vessel that requires a cargo monitor, oily water separator, or bilge alarm, but would require that such equipment meets the new IMO PPE standards. The new IMO standards are ap-plicable to vessels newly built on or after January 1, 2005. Although not clearly stated in the NPRM, under Resolu-


Oily Water Separators - New Requirements of the US Coast Guard


poses several questions: Can owners/operators continually replace components piecemeal, even when a complete re-placement is needed, in order to prevent the expense of a whole new system? If not, which components can be re-placed without requiring a complete replacement? Owners and operators should take into account the fact that these new standards apply to PPE equipment placed on new and existing vessels after January 1, 2005, and will become enforceable either when made effective by the Coast Guard, or January 1, 2007, when the MARPOL amendment becomes effective, whichever comes first. Ac-cordingly, owners and operators should ensure that PPE equipment installed after January 1, 2005, meets the stan-dards as discussed above in order to avoid possible en-forcement action. In addition, the NPRM provides inade-quate guidance with regard to the replacement of cargo monitors on existing vessels. These issues should be care-fully considered and commented upon in response to the NPRM. Conclusions and Recommendations Owners, operators, manufacturers, and other interested parties should review the NPRM carefully to determine the impact on their operations, comment on the proposed rule and continue to monitor the development in the US.

********




A

A24 the twenty-fourth regular session of the IMO Assembly AIS Automatic Identification System AMP alternative marine power, also referred to as “cold ironing” Anti-fouling Convention The International Convention on the Control of Harmful Anti- fouling Systems on Ships, 2001 ASF Convention The International Convention on the Control of Harmful Anti-fouling Systems on Ships B

BC Code the Code of Safe Practice for Solid Bulk Cargoes BCH Code the Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk BDN Bunker Delivery Note BLG Sub-Committee The IMO Sub-Committee on Bulk Liquid and Gases BLU Code the Code of Safe Practice for the Safe Loading and Unloading of Bulk Carriers BLU Manual the Manual on Loading and Unloading of Solid Bulk Cargoes for Terminal Representatives BWM Convention The International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004 C

CASTEC The Intercargo Safety, Technical and Environmental Committee cfu colony forming unit Circ circular COLREG The Convention on the International Regulations for Preventing Collisions at Sea, 1972 CSR: IACS common structural rules D

D1 or D-1 Ballast Water Exchange (95% volumetric exchange) or pumping through three time the volume of each tank D2 or D-2. Ballast Water Treatment systems approved by the Administration which treat ballast water to an efficacy of:

not more than 10 viable organisms per m3 >50 micrometers in minimum dimension; and not more than 10 viable organisms per millilitre < 50 micrometers in minimum dimension and >10 micrometers in minimum dimension

DE Sub-Committee The IMO Sub-Committee on Ship Design and Equipment Directive 2002/59/EC Establishing a Community vessel traffic and monitoring and information system DMA Danish Maritime Authority DOC: Document of Compliance DRI direct reduced iron. When moist, it releases hydrogen as well as creates heat. DSC Sub-Committee The IMO Sub-Committee on Dangerous Goods, Solid Cargoes and Containers E

EGCS-SOx On-Board Exhaust Gas (SOx) Cleaning Systems EU Directive (2005/33) The amendments to the EU Directive 1999/32 EU Directive 2000/59/EC Port reception facilities for ship-generated waste and cargo residues, 27 November 200 EU Sulphur Directive EU Directive (2005/33) F

FSI Sub-Committee The IMO Sub-Committee on Flag State Implementation FUA 12 Follow-up Action No. 12 H

HFO heavy fuel oil I

IACS International Association of Classification Societies IAPH International Association of Ports and Harbours ICS International Chamber of Shipping IFO intermediate fuel oil IISPCG Inter-Industry Shipping and Ports Contact Group IMDG The Code the International Maritime Dangerous Goods Code IMO International Maritime Organisation INMARSAT The Convention on the International Maritime Satellite Organization, 1976 Intercargo International Association of Dry Cargo Shipowners INTERTANKO the International Association of Independent Tanker Owners

INDEX OF ABBREVIATIONS



ISM Code the International Management Code for the Safe Operation of Ships and for Pollution Prevention ISO International Standardisation Organisation ISPS Code the International Code for the Security of Ships and of Port Facilities L

LFO light fuel oil LL The International Convention on Load Lines, 1966 LOP Letter of Protest M

m/m mass of sulphur per mass of fuel in weight MARPOL 73/78 the International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 MARPOL Annex I Regulations for the Prevention of Pollution by Oil MARPOL Annex IV Regulations for the Prevention of Pollution by Sewage from Ships MARPOL Annex V Regulations for the Prevention of Pollution by Garbage from Ships MARPOL Annex VI Regulations for the Prevention of Air Pollution from Ships MDO marine diesel oil MEPC IMO Marine Environment Protection Committee MEPC 49 the 49th session of IMO MEPC on 14 to 18 July 2003 MEPC 50 the 50th session of IMO MEPC on 1 and 4 December 2003 MEPC 51 the 51st session of IMO MEPC on 29 March to 2 April 2004 MEPC 52 the 52nd session of IMO MEPC on from 11 to 15 October 2004 MEPC 53 the 53rd session of IMO MEPC on 18 to 22 July 2005 MEPC 54 the 54th session of IMO MEPC on 20 -24 Mar 2006 MGO marine gas oils MSC IMO Maritime Safety Committee MSC 78 the 78th session of IMO MSC on 12 to 21 May 2004 MSC 79 the 79th session of IMO MSC on 1 to 10 December 2004 MSC 79/4/1 the submitted paper No.1 under agenda item 4 to MSC 79 MSC 80 the 80th session of IMO MSC on 11 to 20 May 2005 MSC 81 the 81st session of IMO MSC on 10 – 19 May 2006 N

NAVTEX transmission of maritime safety information, including navigational and weather information and forecast NGO Non-Governmental Organisation NOx nitrogen oxides NOx Technical Code the Technical Code on Control of Emission of Nitrogen Oxides from Marine Diesel Engines P

ppm one part of oil per million parts of water by volume S

SAR The International Convention on Maritime Search and Rescue, 1979 SECA SOx Emission Control Area SMC: Safety Management Certificate (ISM Code) SN/Circ.227 Circular N0.227 issued by IMO Sub-Committee on Safety of Navigation SO2 sulphur dioxide SOLAS the International Convention of the Safety of Life at Sea SOLAS Ch XII Chapter XII of SOLAS “Additional safety measures for bulk carriers” SOx sulphur oxides STCW The International Convention for Standards, Training, Certificates and Watchkeeping for Seafarers, 1978 U

UNCLOS The United Nations Convention on the Law of the Sea UR S25: No.25 of the IACS Unified Requirements concerning Strength of Ships UV ultraviolet radiation


INTERCARGO


INTERCARGO

Intercargo’s vision is for a safe, efficient and environmentally friendly dry cargo maritime industry where its member’s ships serve world trade - operating competitively, safely and profitably. Intercargo, the International Association of Dry Cargo Shipowners, represents the interests of 62 Full and 59 Associates members who between them own and operate about 800 dry cargo ships. Promoting the interests of our member companies in regulatory fora such as IMO and IACS, Intercargo works closely with the other members of the Round Table of in-ternational maritime associations (BIMCO, ICS Intercargo and Intertanko) to promote a safe, high quality, efficient and profitable industry. On 1st June 1998, the Intercargo Executive Committee decided to set up a bulk carrier Tech-nical, Safety and Environmental Committee (CASTEC) comprising of selected technical/operational managers from Intercargo member companies. Leo Cappoen was elected as CASTEC Chairman in June 2005. CASTEC is one of Intercargo’s key Committees. It was established to promote and protect the interests of the INTERCARGO membership in relation to International, National and Local Legislation and Regulation as it affects Ship Design, Safe Bulk Carrier Operations and the Protection of the Environment. It will also foster co-operation with IMO, IACS, Round Table international shipping associations (BIMCO, ICS, Intercargo and Intertanko) and other recognised bodies involved with bulk carrier safety and the protection of the environment. To ensure members views are represented effectively CASTEC meets twice a year, one be-ing the forum for Asian based members the other for those in the Western hemisphere. The statutory and classification matters debated by IACS and at IMO provide the main areas of discussion for CASTEC members at these meetings. CASTEC also oversees technical pub-lications such as the annual Bulk Carrier Casualty Report, a new guide on Port State Control and analysis of ship-terminals interface experiences. For further information on joining Intercargo, please contact [email protected].

INTERCARGO


INTERCARGO Ninth Floor, St Clare House,30/33 Minories, London EC3N 1DD Tel: 020 7977 7030 (Switchboard) Fax: 020 7977 7031 Email: [email protected] Web Site: www.intercargo.org

29395260 technical and operational for bulk carriers[1]

Documents

acknowledgement intercargo

technical departments

dry bulk supply chain

intercargo st clare

bulk carrier sector

safer bulk carrier industry

main international fora

bunkers marpol annex