26th Meeting of INTERTANKO’s
Environmental Committee
0900hrs-1800hrs
Montreux Room
Swissôtel The Bosphorus
Bayildim Caddesi, 2 Macka – Besiktas
Istanbul 34357, Turkey
Tel: +902123261100
Fax: +90 212 326 1122
INTERTANKO’s Anti-Trust/Competition law Compliance Statement INTERTANKO is firmly committed to maintaining a fair and competitive environment in the world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in this market. These laws include the anti-trust and competition laws, which theUS, the European Union and many nations of the world have adopted to preserve the free enterprise system, promote competition and protect the public from monopolistic and other restrictive trade practices. This meeting will be conducted in compliance with these laws and in accordance with INTERTANKO’s anti-trust/competition law guidelines.
1. Minutes
2. Membership
Policy Issues
3. Port Reception Facilities
4. Ship Recycling
5. Ballast Water Management
6. Biofouling
7. Greenhouse Gas Emissions
Reporting Items
8. Anti-fouling Systems
9. Training and Awareness
10. Liaison with Environmental Organisations
11. Marine Noise Pollution
12. Whale Strikes
13. TMSA Related Matters
14. Date and Place of next Meeting
15. Any Other Business
Workshop Session
1. Environmental Benchmarking
2. Energy Conservation Programme
Presentation – ‘Recoverit’; Environmentally Friendly Solutions to Hydrocarbon Pollution
1. Minutes
The draft minutes from the previous meeting held in Barcelona on 2nd and 3rd October were circulated on 28th October together with the Work Programme.
The Committee will be invited to approve the draft minutes.
2. Membership
The enclosed document reflects the Committee members as at 28th March 2008. Members should note the changes to the Committee membership since the last meeting:
Capt. Prabhat Sharma, V.Ships (Geneva)
Left company, not replaced
Capr. Sudhir Soman, AET Shipmanagement (Singapore) Pte. Ltd.
replaced by
Capt. B. Subarrao AET Shipmanagement (Malaysia) Sdn. Bdh.
Mrs. Maria Sotiriou, OSG Shipmanagement (GR) Ltd.
replaced by
Capt. Panos Hatzikyriakos, OSG Shipmanagement (GR) Ltd.
The Committee currently has one vacancy.
The Committee is invited to review the membership details and advise of any changes or amendments.
Policy Issues
3. Port Reception Facilities
3.1 IMO Correspondence Group Work
IMO’s Correspondence Group on Port Waste Reception Facilities has now completed its work. The final version of the Advanced Notification Form (ANF) and Waste Delivery Receipt (WDR) can be found below.
The Committee will be invited to consider INTERTANKO’s future activity relating the promotion and possible mandatory application of the two harmonised forms.
In addition to the harmonized forms, INTERTANKO has also been responsible for submitting the Guide to Good Practice to the IMO’s Correspondence Group as instructed by the Committee at its last meeting.
The Committee will be invited to comment and further develop the Guide as presented. Note that the Guide will also be considered by ISTEC for the addition of technical elements.
While there has been some considerable work achieved within the IMO’s Correspondence Group on Port Waste Reception Facilities, it should be noted that there are still several outstanding points to be completed. It is therefore likely that the Correspondence Group will be asked to continue its work into 2009.
3.2 Fee Mechanisms
It has been noted that most of the reports sent to the secretariat with additional information, i.e. over and above that forwarded within the feedback form, have related to the fees being encountered when using reception facilities. This is compounded in EU ports when masters are required to deliver all wastes as per the European Directive.
In 2005 the Commission tasked the European Maritime Safety Agency (EMSA) to study and evaluate the various fee systems used in European ports. EMSA gathered information from 51 ports but was unable to compare and analyse the information owing to the diversity and complexity of the various fee systems in place.
INTERTANKO has traditionally supported the no-special-fee system. The no-special-fee concept was raised by WWF at IMO’s MEPC 57 meeting with a view to the IMO ‘imposing’ such a scheme as mandatory. INTERTANKO intervened to support the idea of the IMO’s consideration of standardised fee mechanisms in general. There was further support for this work at the meeting and the FSI sub-Committee will now take this into account when considering further the PRF Action Plan. The possibility for a robust discussion on standardised fee mechanisms has now presented itself at the IMO.
So that INTERTANKO can fully engage on the in this debate and recognising that the IMO will only be able to develop principals associated with fee mechanisms, the Committee is invited to consider which key elements would be beneficial in a model fee system and which should therefore be established as basic principals for a global fee mechanism developed by the IMO.
4. Ship Recycling
At MEPC 57 agreement was reached adopt the Convention in May 2009 at a Diplomatic Conference in Hong Kong. There are two meetings of the Working Group between now and then. There are now only two significant issues to resolve before the draft Convention is completed.
One of the significant issues relates to how the Convention will enter into force. Unlike many other IMO Conventions that have a certain number of countries and a certain number of ships before the legislation enters into force, the Ship Recycling Convention requires an additional entry into force criteria; ship recycling capacity. This is an important element in this legislation which should ensure that when the Convention enters into force there are sufficient countries that are party to the Convention which have adequate capacity to recycle the ships of those other state parties. This however is seen as a State issue and will require the combined efforts of flag, port and recycling states during the next Working Group meeting scheduled immediately prior to MEPC 58 in September 2008.
The second element relates to the sequence of authorisation and certification when a ship goes for recycling at the end of its operational life. Discussion revolves around the authorisation of a ship as Ready for Recycling by the flag administration and the subsequent approval that the ship can be recycled in the intended state by the recycling state authority. There is some support for a second approval from the recycling state after approval has been given by the flag administration. At present INTERTANKO, together with its industry partners, is working on a system based on Table ‘1’ below.
The Committee will be invited to note the development of the draft Convention and comment as appropriate on the sequence of events as currently envisaged within the Convention.
Once the Convention has been adopted in 2009 work will commence on completing the various Guidelines which will be needed to assist in harmonising the implementation of the convention requirements. Guidelines for developing the Inventory of Hazardous Materials will be important for the industry in ensuring that there is uniformity in the standard IHM’s and the level of detailed required in the documents. Threshold values for the materials will need to be considered as well as the methodology for visual and sampling checks when drawing up the IHM for existing ships.
Following the last Committee meeting, email correspondence continued on the subject of the intermediate and/or periodical surveys as outlined in the Convention. An agreement was reached at the last Working Group meeting that a renewal survey would be included in the Convention rather than a periodical or intermediate survey. This will be conducted at intervals specified by the flag administration but not exceeding 5 years. This will simply verify the status of the Inventory of Hazardous Materials (IHM). An additional survey, partial or general, may be made at the request of the ship owner after a change, replacement, or significant repair of the structure.
The Committee will be invited to note these further developments in relation to the Convention.
Table 1: Ready for Recycling and sequence of events at the end of a vessels life
1. Ship owner Decides to recycle vessel
2. Ship owner Approaches yard ‘authorised’ to recycle that particular vessel
contract established conditional to authorization of SRP by recycling state and final survey of vessel
3. Ship owner Submits IHM Part I* plus other relevant information to recycling facility
to allow facility to develop and complete SRP
4. Recycling facility Deposits SRP with recycling state to gain [authorization/verification]
5. Recycling state either; Authorizes/verifies SRP
Tacitly agrees to SRP [14 day rule]
6. Recycling facility Notifies ship owner that SRP has been approved/verified
contract between ship owner and recycling facility finalised
7. Ship owner Requests final survey from flag administration
8. Flag administration Provides Ready for Recycling Certificate** based on completion of Parts
1, 2 and 3 of IHM** and the approved/verified SRP
9. Ship owner Having received the Ready for Recycling Certificate, delivers vessel to recycling facility
sale completed, recycling to commence
* There is currently some disagreement within the IMO WG as to whether Parts 2 and 3 should also be forwarded to the recycling facility
** The issuance of the Ready for Recycling Certificate will not mean the withdrawal of the International Certificate on the Inventory of Hazardous Materials (IHM) – this allows the vessel to continue trading if required by the owner. There is disagreement on the duration for the validity of the Ready for Recycling Certificate although it is likely to be 3 months with the possibility for an extension
5. Ballast Water Management
At its last meeting, the Committee requested the secretariat to ensure a delay in the Convention implementation dates. Such a delay was under consideration by the industry as well as the IMO’s Secretary General when the Committee last met. However, since its last meeting the issue was debated and agreed upon at the 25th session of the IMO Assembly where member states adopted by consensus anAssembly Resolution regarding the enforcement of the Ballast Water Management Convention. Although the Convention has only been ratified by 11 Member States andhas not yet entered into force, the Assembly was informed by INTERTANKO, ICS and OCIMF of the lack of suitable ballast water treatment systemswhich might cause severe difficulties for compliance within the industry.
After extensive negotiations between Member States and the industry, including INTERTANKO, the Assemblyagreed on the following compromise:
"A ship subject to regulation B-3.3* constructed in 2009 will not be required to comply with regulation D-2** until its second annual survey, but no later than 31 December 2011."
* B-3.3 – Ships with less than 5000M3 Ballast Water Capacity
** 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.
Under Regulation B-3.1, a ship constructed before 2009 should undertake ballast water exchange as per the requirement in Regulation D-1until 2014 or 2016, depending upon its ballast water capacity, after which date, equipment will have to be installed in order to comply with the ballast water treatment standard contained in regulation D-2.
The Assembly also instructed the Marine Environmental Protection Committee (MEPC) to keep the Resolution under review and to further discuss the issue for ships constructed in 2010, which are subject to regulation B-3.3, and the availability of technology for these ships.
The Committee is invited to note the developments relating to the Convention and comment as appropriate.
As requested by the Committee at its last meeting, a table displaying the latest treatment technology together with details relating to their approval status has been placed on the INTERTANKO website: http://www.intertanko.com/templates/intertanko/issue.aspx?id=43797
Links to the company websites have been created where available. The Committee may consider how best to improve on this and include information from members experiences relating to ballast treatment technology.
The Committee will be invited to take note and comment on any further action required.
6. Biofouling
The Biofouling issue is now in the hands of the IMO’s BLG, a sub-Committee of MEPC. At its last meeting in February 2008, the sub-Committee considered documents from Australia, New Zealand and the UK. The submission from Australia and New Zealand provided some basic principles on which any future guidance to the industry should be based and used the Australian Shipowners’ Association Guidelines. These are given in the enclosed document.
A Correspondence Group, led by New Zealand, has now been established by the BLG sub-Committee which requires the further consideration of these management options with a view to developing a Guideline document similar to that which was originally developed for ballast water management, i.e. Resolution A.868(20). Industry has been invited to comment on the principles and the development of the Guideline in general.
The Committee will be invited to consider a general position relating to this issue and provide comments on the development of the Guidelines using the management options as provided by the Australian submission.
In its consideration of the issue, the Committee should note that recent communication with INTERTANKO members on the subject of hull management has suggested that the subject of slime in connection with biofouling accumulation and antifouling system performance continues to raise questions over management options. In particular, there appears to be no single guiding principle relating to the management of slime or the breakdown of management options in relation to the particular type of fouling and the associated methodology or option for management. For example, slime build-up will require a very different type of management technique than hard biological accumulation on the hull. In addition, some have suggested it is still difficult for divers to assess slime build-up with a visual inspection only and that guidance to owners may be required in this area.
7. Greenhouse Gas Emissions