IMO agrees on new guidance on key environmental issues

IMO’s Sub-Committee on Pollution Prevention and Response (PPR 11) made progress on key environmental issues to be submitted to the Marine Environment Protection Committee for approval this March (MEPC 81) and October (MEPC 82).

The International Maritime Organization (IMO) has agreed new guidance on several key environmental issues. Last week at IMO Headquarters in London, IMO’s Sub-Committee on Pollution Prevention and Response (PPR 11) made progress in the following areas, to be submitted to the Marine Environment Protection Committee for approval this March (MEPC 81) and October (MEPC 82):

• the safe transport of plastic pellets by sea
• best practices for cutting Black Carbon emissions from ships operating in or near the Arctic
• reducing risks of use and carriage for use of heavy fuel oil (HFO) as fuel by ships in Arctic waters
• developing local contingency plans for spills or pollution involving oil or hazardous and noxious substances
• controlling nitrogen oxide emissions.

Transport of plastic pellets by sea

The Sub-Committee further discussed the issue of the transport by ship of plastic pellets, which can cause environmental damage if released into the sea.

The Sub-Committee agreed on draft recommendations for the carriage of plastic pellets by sea in freight containers and draft guidelines for the clean-up of plastic pellets from ship source spills.

The draft recommendations for the carriage of plastic pellets by sea in freight containers outline the following actions: 

• Plastic pellets should be packed in good quality packaging which should be strong enough to withstand the shocks and loadings normally encountered during transport. Packaging should be constructed and closed to prevent any loss of contents which may be caused under normal conditions of transport, by vibration or acceleration forces.  
• Transport information should clearly identify those freight containers containing plastic pellets. The shipper should supplement the cargo information with a special stowage request for proper stowage. 
• Freight containers containing plastic pellets should be properly stowed and secured to minimize the hazards to the marine environment without impairing the safety of the ship and persons on board. Specifically, they should be stowed under deck wherever reasonably practicable, or inboard in sheltered areas of exposed decks. 

These recommendations will be submitted for urgent consideration by the Marine Environment Protection Committee at its next session in March 2024 (MEPC 81). 

The draft guidelines on clean-up of plastic pellets from ship-source spills provide practical guidance for government authorities to ensure clean up actions are appropriate and effective. The guidelines cover contingency planning, response, post-spill monitoring and analysis, and intervention and cost recovery. 

The draft guidelines will be submitted to the 82nd session of MEPC (MEPC 82) in October 2024 following an editorial review by the Secretariat. In the meantime, Member States were invited to apply the guidelines early, if needed.

The Sub-Committee held extensive discussions on possible amendments to IMO mandatory instruments related to the transport by ship of plastic pellets. These discussions will continue at future sessions.

Black Carbon emissions in the Arctic

The Sub-Committee agreed on draft guidance on best practices to assist ship operators/companies in their efforts to reduce Black Carbon emissions from their ships operating in or near the Arctic. Black Carbon is a distinct type of carbonaceous material, formed only in flames during combustion of carbon-based fuels.

Several goal‑based control measures have been recommended for all ships, including the following guidance for ship operators or companies:

• As an initial step, to conduct an initial inventory of Black Carbon sources and undertake Black Carbon emission measurements from those sources (marine diesel engines);
• Consider setting a voluntary Black Carbon emission reduction target threshold;
• Identify and consider what practices and/or control measures are available to the ship which could be implemented to achieve the set reduction target threshold;
• Develop a Black Carbon management plan, including periodic monitoring for managing and ensuring success in reduction efforts.

In addition, the Sub-Committee agreed on draft guidelines for measuring, monitoring and reporting Black Carbon emissions, which will help with collecting data to support the development of recommendations and regulations to reduce the impact of Black Carbon emissions on the Arctic environment. 

The guidance on best practices and guidelines for measuring, monitoring and reporting will be submitted for adoption at MEPC 82. 

Use and carriage of heavy fuel oil in Arctic waters

The Sub-Committee agreed on draft guidelines on mitigation measures to reduce risks of use and carriage for use of heavy fuel oil (HFO) as fuel by ships in Arctic waters. These will be submitted to MEPC 82 for approval.

The guidelines cover navigational measures; ship operation; HFO bunkering; communication; enhancement of HFO spill preparedness, early detection and response; and familiarization, training and drills. 

Regulation 43A of MARPOL Annex I, which introduces a prohibition on the use and carriage for use as fuel of HFO by ships in Arctic waters, takes effect on July 1, 2024. Ships which meet certain construction standards with regard to oil fuel tank protection will need to comply on and after July 1, 2029. A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that party’s sovereignty or jurisdiction, up to July 1, 2029.

The guidelines contain recommendations that can be applied to ships not covered by the prohibition in regulation 43A of MARPOL Annex I.  

Local oil and hazardous and noxious substances marine pollution 

The Sub-Committee agreed to draft guidelines for developing a local contingency plan for spills or pollution involving oil or hazardous and noxious substances.

The guidelines outline emergency organization, procedures, and response capability for accidental spills, whatever the source. They are aimed primarily at key local governmental institutions which have emergency planning responsibilities for communities and areas affected by marine pollution, to assist them in developing a marine pollution contingency plan covering their responsibilities. 

The guidelines will be submitted to MEPC 82 in October 2024 for approval and subsequent publication.

Controlling Nitrogen Oxide emissions

The NOx Technical Code aims to control the emission of nitrogen oxides (NOx) from marine diesel engines, which contributes to smog and air pollution. The Code specifies the requirements for the testing, survey and certification of marine diesel engines to ensure they comply with the NOx emission limits set out by Regulation 13 of MARPOL Annex VI.

The Sub-Committee finalized draft amendments to the NOx Technical Code 2008 and MARPOL Annex VI on the use of multiple engine operational profiles for a marine diesel engine, including clarifications of engine test cycles, as well as draft amendments to the NOx Technical Code 2008 on certification of an engine subject to substantial modification.

Both sets of amendments will be submitted to MEPC 82 for approval, with a view to subsequent adoption. 

Guidance related to in-water cleaning

The Sub-Committee continued its work to develop guidance on matters relating to in-water cleaning – an important step for minimizing the transfer of invasive aquatic species which involves the removal of biofouling from a ship’s hull, propeller or other underwater structures and niche areas, with additional benefits also for ship energy efficiency.

The guidance may cover various elements including:

• planning, conducting and reporting on in-water cleaning operations, 
• verification and testing of in-water cleaning systems;
• conducting pre-cleaning and post-cleaning inspections; and 
• expectations for in-water cleaning service providers.

A Correspondence Group will work intersessionally on preparing draft guidance and will submit a report to the next session of the Sub-Committee (PPR 12).

Discharge of sewage from ships

The Sub-Committee continued its work on the revision of MARPOL Annex IV and the associated guidelines, regarding the discharge of sewage from ships into the sea. 

Raw sewage from ships can create a health hazard as well as impact the environment. The revision of MARPOL Annex IV has been primarily focused on sewage treatment plants and on measures that will ensure that the systems have a satisfactory performance throughout their lifetime.  

The Sub-Committee agreed on a preliminary timeline for the revision exercise, aiming for adoption of the whole package in 2028/2029.

A Correspondence Group will continue the work intersessionally to further develop: draft amendments to MARPOL Annex IV, including provisions for record of discharges, record of maintenance, and management plan concerning discharge and maintenance; draft amendments to the type approval guidelines for sewage treatment plants; and draft guidelines for the implementation of MARPOL Annex IV.

Reporting lost fishing gear

The Sub-Committee progressed its work on the reporting of accidental or other exceptional discharges or losses of fishing gear from ships – a significant contributor to plastic pollution in the ocean. Members discussed what type of data needs to be reported by ships when fishing gear is lost or abandoned, and how to collect, transmit, access and manage this data.

The Sub-Committee requested the Secretariat to compile an initial comparative summary of the fishing gear reporting obligations in MARPOL Annex V, regional fisheries management organizations (RFMOs), and other relevant international regulatory frameworks, in consultation with the FAO Secretariat.

This could be then used as the basis for an analytical overview to be undertaken by the Correspondence Group on marine plastic litter from ships and to develop recommendations on what data should be reported to IMO, including which data should be voluntary or mandatory, and the issue of data aggregation and anonymization.  

The Correspondence Group will report back to PPR 12 for further action.

Discharge of discharge water from exhaust gas cleaning systems

The Sub-Committee discussed the evaluation and harmonization of rules and guidance on the discharge of discharge water from exhaust gas cleaning systems into the aquatic environment, including conditions and areas.

These discussions will continue at future sessions.