LR IMO PPR 2 Agenda Preview This document

Working together
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IMO Pollution Prevention & Response
(PPR 2)
Agenda Preview
Introduction
The 2nd session of the IMO Sub-Committee on Pollution Prevention and Response (PPR) will be held from the 19 to 23
January 2015, at the IMO headquarters in London. This briefing summarises subjects under discussion which are
relevant to the work of Lloyd's Register out of documents submitted by 24 December 2014.
Overview of agenda items
The following agenda items are relevant to the work of Lloyd’s Register.
Decision of other IMO Bodies (Agenda item 2)
PPR 2 will consider the following that are instructed by MEPC 67. These may be dealt with by a working group:
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Amendments to the 2009 Guidelines for exhaust gas cleaning systems (Resolution MEPC.184(59)), taking into
account documents MEPC 66/INF.31 (IMarEST) and MEPC 67/4/22 (Austria et al.)
Consider and prepare draft amendments to appendix V (Information to be included in the bunker delivery note
(BDN)) of MARPOL Annex VI, taking into account document MEPC 67/12/7 (Austria et al.)
Application of calculation-based methodology for verification of the washwater discharge criteria for pH in section
10.1.2.1(ii) of the 2009 Guidelines for exhaust gas cleaning systems (Resolution MEPC.184(59) )
Draft amendments to the 2009 Guidelines for exhaust gas cleaning systems - measurement of the CO2
concentration on wet basis using Non-Dispersive Infra-Red (NDIR)
Prepare draft amendments to the NOx Technical Code 2008 to facilitate the testing of gas-fuelled engines, using
document MEPC 67/7/5 (Norway et al.) as a basis
Prepare draft amendments to MARPOL Annex VI and the NOx Technical Code 2008 concerning the use of dual
fuel engines as a Tier III NOx control strategy, using document MEPC 67/7/6 (United States)
Lloyd’s Register’s view
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Proposed amendments to MARPOL Annex VI and the NOx Technical Code 2008 concerning the use of dual fuel MEPC 67/7/6 (United States) - Lloyd’s Register considers that these are already covered by the existing NOx
Technical Code thus the proposal is redundant.
Bunker delivery note - current wording given in MARPOL Annex VI, Appendix V is “A declaration signed and
certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with the applicable
paragraph of regulation 14.1 or 14.4 and regulation 18.3 of this Annex.” A proposal is to delete reference to
regulation “14.1 or 14.4” which is supported by Lloyd’s Register as the bunker supplier is not in the position to
declare that (e.g. use of scrubber, onboard mixture, etc.)
Application of calculation-based methodology for verification of the washwater discharge criteria for pH - Lloyd’s
Register supports the proposal in principle as it will help practical application of the guidelines but recognizes that
further discussion is required to refine the proposal.
Safety and pollution hazards of chemicals and preparation of consequential amendments to the IBC Code,
taking into account recommendations of GESAMP-EHS (Agenda item 3)
PPR 2 will consider the outcome of the Evaluation of Safety and Pollution Hazards of Chemicals (ESPH) Working Group
and the various issues submitted to this session.
The following are the expected primary discussion points:
Lloyd’s Register Briefing Note – PPR 2 Agenda Preview
January 2015
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Lloyd’s Register Briefing Note – PPR 2 Agenda Preview
January 2015
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The outcome of the twentieth session of the Working Group on the Evaluation of the Safety and Pollution Hazards
of Chemicals (ESPH 20), including
– Evaluation of new products
– Evaluation of cleaning additives
– Review of MEPC.2/Circular – Provisional classification of liquid substances transported in bulk and other related
matters (to be included in tripartite agreements), including evaluation of trade-named mixtures
– Products requiring oxygen-dependent inhibitors
– Proposed revision to the Guidelines for the provisional assessment of liquid substances transported in bulk
(MEPC.1/Circ.512)
– Draft amendment to the IBC Code (chapters 17 and 21)
Carriage of used cooking oil
Safe carriage of contaminated bulk liquids
inconsistencies and ambiguities in the revised chapter 21
Reclassification of Urea/Ammonium nitrate solution
High-viscosity products
This is a continuous agenda item.
Lloyd’s Register’s view
In general, Lloyd’s Register supports the outcome of the ESPH 20.
Code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk
on offshore support vessels (OSVs) (Agenda item 4)
OSVs supply a number of cargoes to offshore installations. Sometimes these cargoes can be liquids which are noxious,
hazardous or both. Recognising that only limited quantities are carried, the IMO had developed requirements for these
vessels (Resolution A.673(16)). The maximum quantity permitted to be carried on any single voyage in this document is
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800 m . As offshore installations have moved further away from shore and it is no longer possible to provide supplies
on a daily basis, there is a need for the quantities carried to increase beyond this limit.
The new Code will be extensive and will cover the following aspects:
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General requirements
Ship survival and location of cargo tanks
Ship design
Cargo containment
Cargo transfer
Cargo tank venting
Electrical installations
Fire-fighting requirements
Acid spill protection
Ventilation of spaces in the cargo area
Instrumentation
Special requirements
Pollution requirements
Personnel protection
Operational requirements
Transport of liquid chemical waste – referred to as “back-loading” of bulk cargo
Applicability of the guidelines to existing offshore support vessels
Carriage of liquefied gasses
Portable tanks
The majority of the text has been agreed by the correspondence group however the following elements of the code
will be discussed:
– Ship design and special requirements
– Back Loading of liquids used in drilling operations.
It should be noted that three chapters have been sent to other Sub-Committees for comment:
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Chapter 2 (old and new numbering) on ship survival capability and the location of cargo tanks has been sent to
SDC
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January 2015
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Chapter 5 (old numbering, chapter 6 under the new numbering) on cargo transfer has been sent to SDC
Chapter 8 (old numbering, chapter 9 under the new numbering) on fire-fighting requirements has been sent to
SSE
Lloyd’s Register’s view
Lloyd’s Register welcomes the developments so far and has participated in the correspondence group. The need for this
work to be completed is recognised as ships providing supplies to offshore rigs are getting bigger and as the rigs are
further offshore and require larger quantities of supplies due to the increased time between deliveries. There are safety
and pollution aspects to be considered with the back-loaded cargoes. This aspect needs further careful and detailed
consideration.
Ballast Water Management issues (Agenda item 5 and 6)
PPR 2 will discuss various matters relating to Ballast Water Management under separate agenda items (5, 6 and 7).
Discussions will revolve around issues relating to:
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Information provided in document MEPC 66/INF.27 (Germany) on ballast water sampling methods for assessing
compliance with the standards of the BWM Convention
MEPC 67/2/12 and MEPC 67/INF.23 (Denmark and INTERFERRY) addressing issues on regulations A-3 and A-4 of
the Convention (exceptions and exemptions) and the associated Guidelines for risk assessment under regulation A4 of the BWM Convention (G7)
Draft guidance on self-monitoring for ballast water management systems
Sampling issues
Guidance document - Ballast Water Management: “How to do it"
The target completion date for this item is 2015.
Lloyd’s Register’s view
Lloyds Register, noting that entry into force of the convention could be in the very near future, welcomes discussions
providing clarification of the requirements of the convention, such as discussion on exemption (regulation A-3 and A-4
based on submission on MEPC 67 and PPR 2).
Improved and new technologies approved for ballast water management systems and reduction of
atmospheric pollution (Agenda item 7)
Various new technologies and approaches will be discussed.
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Battery technology
Technology Qualification
NOx reduction technologies
The target for the completion of this task will be reviewed annually.
Lloyd’s Register’s view
There is a submission paper on Technology Qualification, however, Lloyd’s Register considers that the issue has already
been addressed in the recent development on the FSA application discussion, e.g. MSC- MEPC.2/Circ.12.
Consideration of the impact on the Arctic of emissions of black carbon from international shipping (Agenda
item 8)
As instructed by MEPC 67, PPR 2 will continue its work on the item, taking into account documents MEPC 67/12/4,
MEPC 67/12/6, MEPC 67/12/8 and MEPC 67/INF.31, with a view to making a clear recommendation for a single
definition of black carbon and identifying as part of that recommendation why the recommended definition should be
considered, as opposed to any other.
At PPR there is another proposed definition of black carbon for further discussion.
The target completion date for this item is 2015.
Lloyd’s Register’s view
A policy decision is required as to how IMO sees the black carbon, i.e. climate impact or health impact.
Lloyd’s Register Briefing Note – PPR 2 Agenda Preview
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Revised guidelines for the Inventory of Hazardous Materials (Agenda item 9)
As instructed by MEPC 67, PPR 2 will prepare amendments to the 2011 Guidelines for the development of the
Inventory of Hazardous Materials (Resolution MEPC.197(62)), on the basis of the report of the correspondence group
established by MEPC 66 (MEPC 67/3 and MEPC 67/INF.8) and taking into account documents MEPC 67/3/1, MEPC
67/3/2, MEPC 67/3/3 and MEPC 67/3/4.
There will be a working group with a view to finalize the work on the matter at this session.
The target completion date for this item is 2015.
Lloyd’s Register’s view
In general Lloyd’s Register supports the outcome of the correspondence group to MEPC 67, with the following
comments:
– Asbestos threshold level – Regarding the ‘0.1/1 per cent compromise’, Lloyd’s Register is of the view that further
clarification is required. The outcome of the discussion may need to be clarified in the 2012 Guidelines for the
inspection of ships under the Hong Kong Convention - Resolution MEPC.223(64). Lloyd’s Register is of the view
that single agreed value throughout the supply chain of any material/component would be desirable.
Unified interpretation to provisions of IMO environment-related Conventions (Agenda item 15)
PPR 2 will consider the following:
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Gaseous emissions calculation of marine diesel engines fitted with selective catalytic reduction (SCR) systems (IACS
UI MPC105)
Disposal of cooking oil
Questions contained in paragraph 8 of document MSC 93/20/8 (Liberia et al.) on the proposal to develop guidance
on the application of new SOLAS regulation VI/5-2 related to the prohibition of blending of bulk liquid cargoes.
Clarification on Resolution MEPC.240(65) on 2013 Amendments to the Revised Guidelines and Specifications for
oil discharge monitoring and control systems for oil tankers (Resolution MEPC.108(49))
This is a continuous agenda item.
Guidelines pertaining to equivalent methods set forth in regulation 4 of MARPOL Annex VI and not covered
by other guidelines (Agenda item 16)
MEPC 67 did not conclude the consideration of matters related to the draft Guidelines pertaining to equivalent
methods set forth in regulation 4 of MARPOL Annex VI and not covered by other guidelines including issues that BLG
17 had sought advice from the Committee, and deferred further consideration to MEPC 68. PPR 2 is expected to
postpone the work under this item until its next session, when the outcome of MEPC 68 will be available.
The target completion date for this item is 2015 but may be extended.
Guidelines as called for under paragraph 2.2.5.6 of the revised NOx Technical Code 2008 (NOx-reducing
devices) (Agenda item 17)
PPR 1 decided that guidelines as called for under paragraph 2.2.5.6 of the revised NOx Technical Code 2008 (NOxreducing devices) do not need to be developed at this stage (PPR 1, paragraphs 9.7 and 9.8), PPR 2 is expect to defer
the work under this agenda item to a future session.
The target completion date for this item is 2015 but may be extended.
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