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IMO update: Marine Environment Protection Committee – MEPC 77

The 77th session of the IMO’s Marine Environment Protection Committee (MEPC 77) was held remotely from 22 to 26 November 2021. Highlights include recognition of the need to strengthen the ambitions in the IMO GHG Strategy, adoption of a resolution urging for the use of distillates or other cleaner fuels or technologies to reduce emission of black carbon in or near the Arctic, and revised guidelines on exhaust gas cleaning systems.

Relevant for ship owners and managers and exhaust gas cleaning system manufacturers.

Meeting highlights

  • Agreed to initiate the revision of the Initial IMO Strategy on Reduction of GHG Emissions, to be finalized in 2023
  • Resolution urging the use of distillates or other cleaner fuels or technologies to reduce emission of black carbon in or near the Arctic
  • Agreed to make the Garbage Record Book mandatory also for ships between 100 and 400 GT
  • Revised guidelines on exhaust gas cleaning systems
  • Analysis of data from the experience building phase on ballast water management underway

Harmful aquatic organisms in ballast water 

Experience building phase
The proposal to extend the experience building phase (EBP) by two years was not considered. Data currently submitted from 15,000 ships will be analysed by the World Maritime University (WMU) and presented in a submission to MEPC 78 in June 2022, with a view to considering a package of amendments to the convention at MEPC 79 in December 2022. 

Port with challenging waters
MEPC 77 agreed to progress the work on a guidance for ships that need to conduct ballast water management (BWM) in ports with challenging water quality, with a view to finalization at MEPC 78.

Unified interpretation on commissioning testing
MEPC 77 approved unified interpretations clarifying the dates related to mandatory commissioning testing in accordance with MEPC.325(75). Commissioning testing should be conducted if the initial or additional survey is completed on or after 1 June 2022.

Air pollution and energy efficiency  

Exhaust gas cleaning systems (EGCS)
MEPC 77 finalized its review of the 2021 Guidelines for Exhaust Gas Cleaning Systems. New definitions of “Phenanthrene equivalent” in the wash water have been introduced. It was agreed that the revised guidelines should be applied to ships which are keel-laid six months after adoption of the guideline and also to EGCSs to which amendments to the ETM-A or ETM-B are undertaken on or after the date of adoption.

Furthermore, MEPC 77 revised a circular on Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and agreed that only the flag and port state’s administration should be notified in such cases of failure.

Wind-assisted propulsion
MEPC 77 revised the 2021 Guidance on treatment of innovative energy efficiency technologies for calculation and verification of the attained EEDI and EEXI. Regarding wind-assisted propulsion, more details are described for the procedure to determine the wind system force matrix. The calculation of the wind matrix was updated to gain more realistic results, meaning that the new calculation gives a higher benefit in the EEDI/EEXI calculation for wind-assisted propulsion systems.

Data collection on fuel oil quality
MEPC 77 did not prepare draft amendments to MARPOL Annex VI to include flashpoint as a required item on the Bunker Delivery Note (BDN) and delegated the task to MSC to develop further measures to enhance the safety of ships relating to the use of fuel oil.

Reduction of GHG emissions

Mid- and long-term measures and revision of the GHG Strategy
MEPC recognized the need to strengthen the ambitions in the IMO Strategy on Reduction of GHG Emissions and agreed to initiate the revision of the strategy with the intent to have a revised IMO GHG Strategy adopted at MEPC 80 in spring 2023. This is in keeping with the schedule agreed at the adoption of the IMO GHG Strategy in 2018. Discussions were also held on mid- and long-term measures as a step towards decisions also to be made at MEPC 80. The proposed measures will be considered within an intersessional working group in spring 2022.

There were divergent views on the industry proposal for a levy-based R&D fund (International Maritime Research Fund – IMRF). No decision was made at this session, and it is expected to be folded into the broader discussion of future regulations, with overall decisions to be made at MEPC 80.

Revision of the IMO Data Collection System
Proposals for the revision of the IMO Data Collection System, facilitating greater transparency and potentially the reporting of additional voluntary Carbon Intensity Indicators, were also deferred to MEPC 78, including consideration within an intersessional working group in spring 2022.

Technical guidelines for the EEXI, CII and SEEMP
The few remaining open points for the Energy Efficiency Existing Ship Index (EEXI) guidelines concerning in-service trials and consideration of power limitation in case of PTO (power take-out), the ongoing discussion on correction factors and other adjustments for the Carbon Intensity Indicator (CII), and the guidelines for the Ship Energy Efficiency Management Plan (SEEMP) were forwarded to the Correspondence Group on Carbon Intensity Reduction reporting to MEPC 78.

Marine plastic litter

A resolution on the strategy to address marine plastic litter from ships was adopted at the meeting. This confirms the commitment to reducing plastic litter entering the marine environment from all ships, including fishing vessels. The aim is to strengthen the international framework and compliance with the relevant IMO instruments, endeavouring to achieve zero plastic waste discharges to sea from ships by 2025. The strategy will guide the action plan to address plastic litter from ships, adopted at MEPC 73, by setting a time frame and methods of work. A comprehensive review of the strategy is planned in 2025.

MEPC 78 supported a proposal to make the requirement in MARPOL Annex V to have a Garbage Record Book mandatory also for ships between 100 and 400 GT. The PPR sub-committee was instructed to prepare draft amendments to MARPOL accordingly.

Consensus could not be reached on whether to make marking of fishing gear mandatory under MARPOL or if it should be done based on voluntary guidelines. It was decided to defer the matter to PPR 9 to further consider the potential regulatory options for promoting the marking of fishing gear.

Pollution prevention and response

Black carbon (BC)
A resolution on protecting the Arctic from BC emissions from shipping was adopted. It encourages member states to commence addressing the threat to the Arctic from BC and urges ship operators to voluntary use distillates or other cleaner alternative fuels or methods of propulsion that are safe and could contribute to the reduction of BC emissions from ships when operating in or near the Arctic.

Work programme

A new output to revise the 2014 Standard specification for shipboard incinerators (MEPC.244(66)), in order to align it with SOLAS Chapter II-2 with respect to fire protection requirements, was agreed, with a target completion year of 2022.

A new output was approved to revise Regulation 13.2.2 of MARPOL Annex VI to clarify that a marine diesel engine replacing a boiler shall be considered a replacement engine, including consequential amendments to the guidelines on non-identical replacement engines not required to meet the Tier III limit (MEPC.230(65)).

Recommendations

DNV recommends to note and start applying the revised guidelines on exhaust gas cleaning systems (EGCS) and recommended actions in case of malfunction of EGCSs. DNV recommends that our customers evaluate possible technical and operational modifications to comply with the upcoming GHG requirements and prepare for the development of an EEXI Technical File and an SEEMP.

For more information about decarbonizing shipping and about the relevant DNV services relating to GHG, visit:

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Provisional list of resolutions and circulars

Please note that the list and document references are provisional.

  • Resolution MEPC.340(77)
    2021 Guidelines for Exhaust Gas Cleaning System
  • Resolution MEPC.341(77)
    Strategy to address marine plastic litter from ships
  • Resolution MEPC.342(77)
    Protecting the Arctic from shipping Black Carbon emissions
  • Circular BWM.2/Circ.76
    Unified interpretation of regulations E-1.1.1 and E-1.1.5 of the BWM Convention
  • Circular MEPC.1/Circ.883/Rev.1
    Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the exhaust gas cleaning system (EGCS) fails to meet the provisions of the EGCS Guidelines
  • Circular MEPC.1/Circ.896
    2021 Guidance on treatment of innovative energy efficiency technologies for calculation and verification of the attained EEDI and EEXI
  • Circular MEPC.1/Circ.897
    Cross-referencing tables between the 2021 revised MARPOL Annex VI and the previous MARPOL Annex VI
  • Circular MEPC.1/Circ.898
    Model agreement for the authorization of recognized organization acting on behalf of the Administration
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