The 9th session of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 9) was held remotely from 4 to 8 April 2022. A wide range of topics was on the agenda, including biofouling, ballast water management, black carbon, sewage treatment and marine plastic litter. PPR agreed on draft guidelines on risk and impact assessments of the discharge water from exhaust gas cleaning systems when considering local or regional regulations.
Relevant for ship owners and managers as well as manufacturers of ballast water and sewage treatment systems.
Meeting highlights
- Draft guidelines supporting the implementation of control of cybutryne in the Anti-Fouling System Convention
- Draft guidelines on risk and impact assessments of the discharge water from exhaust gas cleaning systems (EGCSs) when considering local or regional regulations
- Draft amendments to MARPOL Annex V making the garbage record book mandatory also for ships between 100 and 400 GT
- Unified interpretations on biofuels, Selective Catalytic Reduction (SCR) systems and issuing certificates for ships using other approaches to ballast water management
Amendments to the IBC Code
There was no working group on this topic at PPR 9. The agenda for the next intersessional ESPH (Evaluation of Safety and Pollution Hazards) meeting was approved (ESPH 28). This includes the ongoing review of existing trade-named mixtures and consideration of the implication that the lack of toxic vapour detection will have on the daily operations of chemical tankers.
Anti-fouling Systems (AFSs)
To support the implementation of the controls on cybutryne in the AFS Convention, PPR 9 agreed on three drafts of updated guidelines:
- 2022 Guidelines for brief sampling of anti-fouling systems on ships
- 2022 Guidelines for inspection of anti-fouling systems on ships
- 2022 Guidelines for survey and certification of anti-fouling systems on ships
Biofouling
PPR 9 discussed inspection frequencies and proactive versus reactive cleaning as recommended actions of the drafts of revised Biofouling Guidelines. The correspondence group was re-established to further discuss these topics, as well as the biofouling rating, the outcome of reactive cleaning activities, including appropriate capture rates, and how to increase uptake and effectiveness of the guidelines. The revised guidelines should be finalized at PPR 10 and adopted at MEPC 80 in June 2023.
Black carbon
PPR 9 agreed to continue the work aimed at reducing the impact of black carbon emissions on the Arctic through the correspondence group on air pollution. The correspondence group was given the following specific terms of reference:
- Develop draft guidelines for recommendatory goal-based control measures
- Review existing data on the recommended measurement methods to be used in conjunction with the draft of the recommendatory guidelines
- Further consider regulating or otherwise directly controlling black carbon emissions
Use of multiple engine operational profiles for a marine diesel engine
The use of multiple engine operational profiles (EOPs) in the context of NOx certification and a possible extension of the NOx Technical Code to better reflect new applications, for instance hybrid propulsion, was delegated to a correspondence group for further discussion. The correspondence group will consider regulatory controls on the use of multiple EOPs and clarify the need for definitions of terminology and application related to engine test cycles.
Sewage treatment
PPR 9 recommended to expand the existing output on confirming the lifetime performance of sewage treatment plants to also include a prohibition of fitting comminuting and disinfecting systems (CDSs) on new ships. The correspondence group was re-established and instructed to further progress the work. One important issue to address is the potential retroactive requirements to existing vessels.
Standards for shipboard gasification of waste systems
PPR 9 discussed standards for shipboard gasification of waste systems and the associated amendments to regulation 16 of MARPOL Annex VI. It tasked a correspondence group with developing a draft of standard specifications/guidelines for thermal waste treatment devices.
Evaluation and harmonization of rules and guidance on discharge water from exhaust gas cleaning systems (EGCSs)
PPR 9 agreed on draft guidelines on risk and impact assessments of the discharge water from EGCSs. This will ensure a uniform approach for member states when considering local or regional regulations with respect to restrictions on or the conditions of discharge water. The guideline also includes assessments of the risks in a long-term perspective.
Furthermore, an MEPC Circular on guidance regarding the delivery of EGCS residues and stored discharge water to port reception facilities was drafted for approval at MEPC 78 in June 2022.
Marine plastic litter
PPR 9 agreed on draft amendments to MARPOL V to make the garbage record book mandatory also for ships between 100 and 400 GT. Subject to adoption by MEPC 79 in December 2022, entry into force of the amendments is expected to be in May 2024. The following additional topics were discussed:
- The transport of plastic pellets
- The reporting of lost or discharged fishing gear
- The marking of fishing gear
PPR 9 supported the need for measures reducing the environmental risk of marine transport of plastic pellets. Concrete proposals included amendments to MARPOL Annex III and the IMDG Code to strengthen stowage requirements for containers containing plastic pellets and to develop guidance for handling pellets. A correspondence group was tasked to consider the options further.
The correspondence group was also instructed to further progress the work on reporting mechanisms for lost fishing gear. In order to progress on the topic of the marking of fishing gear, the MEPC was invited to provide further advice on possible regulatory options to seek clarity as there was a divergent view on potential options.
Unified interpretations
PPR 9 agreed on draft amendments to unified interpretations (UI) to MARPOL Annex VI regarding the usage of biofuels. The amendment clarifies that fuels with a biofuel content up to 30% in principle fall under the definition of marine fuel oil derived from petroleum refining (Regulation 18.3.1) and no further NOx testing is required. For fuels with a biofuel content of more than 30%, it needs to be verified that the engine is not altered beyond the approved parts and settings of the NOx Technical File (Regulation 18.3.2) in order not to require NOx testing.
PPR 9 agreed on unified interpretations of the NOx Technical Code, clarifying the process for on-board testing, definitions of the engine family concept for engines with Selective Catalytic Reduction (SCR) systems and interpreting requirements for parent engine NOx tests.
PPR 9 agreed on unified interpretations of Appendix I of the Ballast Water Management (BWM) Convention, which is the international BWM certificate. It was clarified how to issue certificates for other approaches to BWM, especially with respect to ships occasionally engaged in an international voyage, ships exempted due to voyages between specific ports or locations, and for ships with “other approach” in accordance with Regulation A-5, B-3.6 or B-3.7.
PPR 9 did not come to a consensus for unified interpretations of Regulation B-3 of the BWM Convention regarding the loophole identified by IACS for ships constructed before 8 September 2017 but with a compliance date that falls after 8 September 2024. Unless an UI is agreed to at a later stage, the application of Regulation B-3 for the relevant ships needs to be decided on a case-by-case basis by the flag state.
Any other business
Volatile Organic Compounds
Due to time constraints, PPR 9 was unable to consider the submissions on reduction of emissions of Volatile Organic Compounds (VOC) and agreed to have these sent to a correspondence group tasked with identifying the outline of a scope of work on VOC emissions reduction.Protocol for verification of ballast water compliance monitoring devices
PPR 9 made good progress on finalizing the protocol for verification of ballast water compliance monitoring devices. A correspondence group will continue the work on the outstanding issue of laboratory testing using treated water and the development of a standard reporting format.Pollution prevention equipment for machinery space bilges of ships
Interested member states and international organizations were invited to submit a proposal for a new output on the development of amendments to Res. MEPC.107(49) to ensure that no discharge of water with oil content exceeding 15 ppm occurs in the event that access of sample water to the oil content meter is inadvertently or deliberately blocked.Correspondence groups established
The following correspondence groups were established and will report back to PPR 10 in April 2023:- Correspondence Group on review of the biofouling guidelines
- Correspondence Group on prevention of air pollution from ships (addressing black carbon, thermal waste treatment, multiple engine operating profiles, and volatile organic compounds)
- Correspondence Group on amendments to MARPOL Annex IV and associated guidelines (addressing sewage treatments)
- Correspondence Group on marine plastic litter from ships (addressing plastic pellets and reporting mechanisms for lost fishing gear)
- Correspondence Group on development of a protocol for verification of ballast water compliance monitoring devices
Recommendations
As PPR is a sub-committee, all decisions concerning rules, regulations and dates are subject to further consideration and approval by the Marine Environment Protection Committee (MEPC). DNV recommends that our customers monitor the outcome of MEPC 78 in June 2022 and of the correspondence groups established.
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