The 6th session of the Sub-Committee on Pollution Prevention and Response (PPR) took place from 18 to 22 February 2019 at the International Maritime Organization (IMO). Key outcomes of relevance to marine insurance can be summarised as follows:
- Low sulphur fuels: Strong focus was placed on the progress made towards the IMO’s final preparations for the new global sulphur regulation which comes into effect 1 January 2020. The following key points were discussed and agreed:
- Draft guidelines on consistent implementation of 2020 sulphur limit finalised: The Sub-Committee agreed draft guidelines for consistent implementation of the 0.50% sulphur limit under the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI, together with other relevant guidelines, forming a comprehensive package of new and updated instruments that shall assist industry and administrations to effectively and uniformly implement the 0.50% sulphur limit. The IMO has already issued ship implementation planning guidance to help shipowners prepare. The draft guidelines on consistent implementation of the 0.50% sulphur limit include sections on the impact on fuel and machinery systems resulting from new fuel blends or fuel types; verification issues and control mechanism and actions, including Port State Control and samples of fuel oil used on board; a standard reporting format for fuel oil non-availability (fuel oil non-availability report (FONAR)); and possible safety implications relating to fuel oils meeting the 0.50% sulphur limit. The Marine Environment Protection Committee (MEPC) 74 (May 2019) is expected to adopt these guidelines.
- Draft circular on delivery of compliant fuel oil by suppliers: The Sub-Committee agreed a draft joint Maritime Safety Committee (MSC)-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 and at the MSC 101. The draft circular says that Members States should urge fuel oil suppliers to take into account, as relevant: MEPC.1/Circ.875 guidance on best practice for fuel oil purchasers and users for assuring the quality of fuel oil used on board ships; and MEPC.1/Circ.875/Add.1 guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.
- Draft amendments to MARPOL Annex VI on sulphur content definition and sampling: The Sub-Committee agreed draft amendments to MARPOL Annex VI for approval by MEPC 74 and subsequent adoption by MEPC 75 (Spring 2020), with an expected entry force date of mid-2021.
- Draft amendments to on board sampling guidance: The Sub-Committee agreed draft 2019 guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships, updating the previous version. MEPC 74 (May 2019) is expected to approve these guidelines.
- Draft interim guidance for Port State Control on contingency measures for addressing non-compliant fuel oil: The Sub-Committee developed draft interim guidance for Port State Control on contingency measures for addressing non-compliant fuel oil and invited concrete proposals to MEPC 74. The draft interim guidance covers possible actions to be taken, following discussions between ship, Flag State and Port State, when a ship is found to have on board non-compliant fuel oil either as a consequence of compliant fuel oil being not available when the ship bunkered fuel oil or the ship identifying through post bunkering testing that the fuel oil on board is non-compliant. MEPC 74 (May 2019) is expected to consider these draft interim guidelines further.
- Review of the 2015 guidelines on exhaust gas cleaning systems: SSE 6 was undertaking a review of the 2015 Guidelines on exhaust gas cleaning systems (EGCS). The Sub-Committee noted the progress made by the Correspondence Group on review of the 2015 EGCS guidelines. It agreed to request an extension of the target completion year to 2020 with a view to continuing the work on the review at PPR 7.
- Controls on the biocide cybutryne in anti-fouling systems agreed: A second compound/active ingredient used in biocides in anti-fouling systems on ships is set to be prohibited under the IMO Convention for the control of harmful anti-fouling systems on ships (AFS Convention). The AFS Convention currently has controls on only one active compound - it prohibits the use of biocides using organotin compounds (TBT). The Sub-Committee agreed that new controls on the biocide cybutryne (also known under its industry name Irgarol-1051) should be included in the AFS Convention. MEPC may also consider the need for revisions of the revised guidance on best management practices for removal of anti-fouling coatings from ships, including TBT hull paints and the inventory of hazardous materials under the Hong Kong Convention, in light of the introduction of controls of cybutryne under the AFS Convention.
- Reducing risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters: The Sub-Committee began its work to develop measures to reduce the risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters. A working definition for heavy fuel oil was noted, which says that “heavy fuel oil means fuel oils having a density at 15ºC higher than 900 kg/m3 or a kinematic viscosity at 50ºC higher than 180 mm2/s”. A draft methodology for analysing impacts of a ban on heavy fuel oil for the use and carriage as fuel by ships in Arctic waters was agreed. The Sub-Committee invited submissions to PPR 7, especially those by Arctic States, containing impact assessments guided by but not limited to the methodology. Moreover, a correspondence group was instructed to develop guidelines on measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters. The guidance could include sections on navigational measures; ship operations; infrastructure (onshore and offshore) and communications; enhanced preparedness for emergencies of oil spills, early spill detection and response; drills and training; and economic assessment of potential measures.