July 30, 2003

LR reports on MEPC meeting
The 49th session of the IMO's Marine Environment Committee (MEPC 49) was held from July 14 to 18, 2003. Lloyd's Register has just issued a "Classification News" summary of what went on at this important meeting.

It's a little less opaque than IMO's report on the meeting.


Amendments to Regulation 13G of Annex I of MARPOL 73/78. Following the introduction of the EU proposals to accelerate the phase-out of single-hull tankers, to expand the Condition Assessment Scheme to single-hull tankers at 15 years of age, and to restrict the carriage of heavy oils to double-hull tankers, MEPC established a working group to review the proposals from EU and counterproposals from Japan and other members.

Category 1 (pre-MARPOL tankers)

The Committee agreed to support the acceleration of the overall phase-out deadline, according to the proposed (EU) amendments, from 2007 to 2005, having understood that this would not create major problems for the shipping industry. This would mean that the current MARPOL 13G regulations would apply until 2005 and that tankers delivered in 1973 or earlier would be phased out in 2003, those delivered in 1974 in 2004, and all other Category 1 single-hull tankers would be phased out in 2005.

Category 2 (MARPOL with SBT/PL) and Category 3 (5,000-19,999 dwt crude and 5,000-29,999 dwt products)

The proposed (EU) amendments to phase out all Category 2 and 3 tankers by 2010 encountered considerable opposition from Japan, Brazil, India, Saudia Arabia and others, particularly over the premature withdrawal of the so-called 'teenage' tankers in 2010.

Concerns highlighted the destabilizing of investment schedules and company balance sheets as well as market distortions.

The EU states noted these concerns and have tabled a revision for these younger tankers to be allowed to trade past 2010, up to 20, 23 or 25 years of age (to be finalised), but in any event not beyond 2015.

This is, however, dependent on compliance with CAS (see below) and on compliance with EU insistence on the retention of the 13G paragraph 8(b) text which would permit a state to deny entry of Category 2/3 oil tankers into its ports and offshore terminals after 2010.

Industry representatives observed that a tanker that has cleared CAS should be allowed to trade internationally without potential denial of port entry.

Condition Assessment Scheme (CAS)

The proposed (EU) amendments introduced the concept of CAS from 2005 for all Category 2 and 3 (single-hull) tankers older than 15 years. The Committee supported using CAS towards a compromise solution on a phase out of Category 2 and 3 tankers, which would contribute to the acceptance of 'teenage' single-hull tankers to trade internationally after 2010.

In a related development, a new study group to be hosted by the U.K. will be established, including representatives from IACS and the industry, to review the applicability of CAS for ships 15 years and older, including Category 3 ships, and to develop any other necessary revisions such as the need to consider cargo histories in the survey planning process.

This group is also considering the development of a CAS or equivalent for double-hull tankers. In this respect IACS has cautioned that direct application of CAS to double-hull tankers (and single-hull tankers) on a regular basis, creates two systems of survey of ship's hull and certification: one under SOLAS and IMO resolution A.744(18) and the other under MARPOL Annex I and CAS.

The very real practical problems in all tankers over 15 years complying with CAS requirements by 2005 (anticipated to be between 800 and 1000 in number), were highlighted. This was accepted and more appropriate introductory phase-in requirements which will give a smoother and more practical implementation of CAS will be looked at. This might end up with the first CAS for such ships being carried out at the first major survey after the vessel's anniversary in 2005 but not later than 2008.

Heavy oils
Particular resistance to proposed (EU) amendments covering the barring of single-hull tankers from carrying heavy oils came from U.S. and Latin-American interests. Some 70% of the total production and trade of heavy crude oils which may fall within the scope of this proposed regulation is concentrated in this one region and would have to be shipped in double-hull tankers.

While the EU countries are apparently adhering to their position, Japan and Russia also expressed their concerns over the impact of the proposals on the large number of small tankers involved in the coastal trade of heavy oils, the vast majority of which are single-hulled. According to the original EU proposals, single-hull vessels below 5,000 dwt would be banned from heavy oil trades from 2008.

The Committee could not reach any decision on this issue. It is deferred to the next session of MEPC.

Extra session – MEPC 50

The Committee has agreed that an extra session will be held in early December 2003 in conjunction with the IMO 23rd Assembly to further discuss and adopt the amendments to MARPOL Annex I regulation 13G only. The Committee has also recommended the reactivation of the Expert Group to review and update the impact study in the light of the revisions now under discussion.

If amendments are adopted at MEPC 50, they will enter into force in April 2005.


Lloyd's Register says much progress on the development of the International Convention for the Control and Management of Ship's Ballast Water and Sediments was made by IMO. It was recommended that the Conference to adopt the Convention should be held in early 2004.

The Convention is framed such that the development of the ballast water treatment technology is encouraged whilst leaving ballast water exchange as the principle means of ballast water management at least for the immediate future.

There are issues that remain to be resolved, in particular, the standard of treated ballast water, the phase-in for existing ships and the concept of local and regional ballast water discharge areas. Standards on the table vary between one viable organism per tonne, up to 100. The size of permitted organisms is also in dispute, with the smallest organisms requiring multiple filters to remove them (resulting in very slow ballast discharge) or chemical treatment (resulting in further pollution and safety problems for operators).

The need to phase in ballast water treatment depending on the size of the ship was accepted. Bigger ships have more ballast water and are therefore more dependent on improved technology
to achieve viable ballast discharge rates. The text of the Convention now reflects this reality in ballast treatment advances and is based on a phase-in of treatment standard according to the size of the ballast capacity, leaving ballast water exchange as the management method for the foreseeable future.

The entry-into-force provisions for the Convention will be decided at the Conference in 2004.

A number of important guidelines will need to be finalised, in particular, the 'Guidelines for Ballast Water Management Plans', safety aspects of ballast water exchange and the approval of ballast water treatment system.


The Committee adopted the 'Guidelines for Brief Sampling of Anti-fouling Systems on Ships' and the 'Guidelines for Inspection of Anti-fouling Systems on Ships'.

On the status of ratification of the AFS Convention it was noted that Antigua and Barbuda, Denmark and Nigeria had ratified the Convention. Japan ratified the Convention on July 8, 2003, Norway was expected to ratify in the coming weeks, Greece and Spain were both in the process of ratifying and were expected to do so by the end of 2003.


The Committee recognising the previous decision that certificates issued under the HSSC should be endorsed with the words "Completion date of survey on which the certificate is based: dd/mm/yy" has agreed that wherever a date is requested in a form or a certificate, the format "dd/mm/yyyy" should be used, noting that this specifies four digits for the year. This would avoid any potential confusion.


The Committee approved guidelines for the application of MARPOL Annex I requirements to FPSOs and FSUs. The United States reserved its position on the application of requirements for double side construction to FPSOs and FSUs.


Norway proposed to the Committee that it should establish the guiding principles for an amendment of MARPOL Annex I with regard to the protection of fuel tanks. In Norway's opinion the proposed measures should:

  • not be less stringent than those set up for cargo oil
  • relate to double-hull protection
  • require the level of protection outlined in Regulation 13F(7) of MARPOL Annex I or Regulation 13F(3)(a), (b), (c) depending on the fuel oil capacity of ships
  • apply to new ships only.

The Committee referred this issue to the 47th session of the Sub-Committee on Design and Equipment of Ships with a target completion date of 2005.

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