BIMCO attended the 72nd session of the IMO’s Marine Environment Protection Committee (MEPC 72), which was held in London from 9 to 13 April 2018.

This report gives a brief overview of most important items, which were debated:

Amendments to mandatory instruments

MEPC adopted the following amendments to MARPOL:

• Amendments of the Ballast Water Management (BWM) Convention concerning the implementation schedule of ballast water management for ships
• Amendments to the regulation D-3 of the BWM Convention to make the 2016 Guidelines for Approval of BWM systems (G8) mandatory
• Amendments of the BWM Convention concerning endorsements of additional surveys on the BWM Certificate

These amendments will enter into force by 13 October 2019 (16 months after adoption).

• Amendments on the required EEDI for ro-ro cargo and ro-ro passenger ships. These ship types have previously not formed part of the EEDI framework

The amendments will enter into force on 1 September 2019.

• Amendments to the International Bulk Chemical Code (IBC Code) and the Code for the Construction Equipment of Ships Carrying Dangerous Chemicals in Bulk (BCH Code) to confirm that any specific loading condition complies with damage stability requirements. These amendments highlight the necessity of an approved stability manual.

Note, the BCH code is applicable to the chemical tankers built before 1 July 1986. The IBC code is applicable to the chemical tankers built after 1 July 1986.

The amendments will enter into force on 1 January 2020.

Adoption of the initial IMO GHG Reduction Strategy

The IMO adopted the initial strategy with a vision to decarbonize international shipping as soon as possible. The strategy contains a reduction objective of at least 50% GHG emissions reduction by 2050 compared with 2008, while pursuing efforts to phase them out. This objective is a very ambitious one, but still in our view not impossible.

How the industry is going to achieve the objective is not fully understood and it is likely to require substantial R&D into zero-carbon fuels and technology to propel ships.

The initial strategy is the first step in a process that eventually shall result in zero GHG emission ships. IMO member states will now embark on measures, and the work starts already this summer.

BIMCO will engage in the work with a view to ensure a level playing field and measures which a practical and workable in the industry.

Paving the way to a prohibition on the carriage of fuel oil exceeding 0.50% sulphur

BIMCO and other industry organizations, proposed a prohibition on the carriage of fuel oil exceeding 0.50% m/m sulphur, which is intended for use as bunker. It should be noted that the proposed prohibition on the carriage of non-compliant fuel oil will not affect the carriage of high sulphur oil as cargoes.

Thus, MEPC 72 agreed to a prohibition on the carriage of non-compliant fuel oil and sent it to the Maritime Safety Committee (MSC) for consideration of safety issues that might occur when using low-sulphur fuel oil. MSC will meet next month. The prohibition may be adopted at MEPC 73 later this year.

Ballast water management (BWM)

MEPC 72 re-established Ballast Water Review Group to address a number of pending matters prior to the date where the BWM Convention will take effect (8 September 2018):

• Review of the Procedure for Approval of Ballast Water Management (BWM) Systems that make use of Active Substances (G9) and making it mandatory, as a consequence of the revision of Guidelines (G8)
• Data Gathering and analysis plan for the BWM Experience Building Phase - which is expected to be running until 2024
• Validation of the compliance or individual BWM Systems with regulation D-2 of the BWM Convention in conjunction with their commissioning - this is for ensuring that an installed BWMS are in compliance after installation
• Revised Guidance on scaling of BWM Systems in connection with the type approval process –  BWMS manufacturers can use mathematical modelling and/or calculations to limit the shore and ship board testing process in connection with type approval to a single BWMS model of a given capacity to document compliance for BWMS models of less or higher capacity
• Contingency measure in the BWM Plan – there are currently no mandatory requirements for such contingency measures to be included in the BWM Plan. A recommendation could be that ships should have a BWM contingency plan annexed to the approved BWM Plan on a voluntary basis

The above issues will be further communicated to members as soon the IMO Secretariat issues the respective resolutions and circulars.

Measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters

A range of proposals will be considered when developing measures to reduce risks of use and carriage of Heavy Fuel Oil (HFO) as fuel by ships in the Arctic as defined in the Polar Code. During the extensive discussion at MEPC, a majority of member states were in favor of a ban of the use and carriage of heavy fuel oil (HFO) as fuel on ships in Arctic waters.

BIMCO intervened that the original intent the working item was to consider a range of options in developing measures to reduce risks of use and carriage of HFO as fuel by ships not only banning carriage of HFO. We also called for a definition of what HFO meant, and that it remained unclear what the impact of the proposed ban will be related to the availability of fuels and the acceptability of fuel oil blends that may become available to meet the 0.50 % global sulphur cap.

The item will now be sent to PPR (in January 2019) for further discussion and a ban on HFO will be based on an impact assessment of the economic consequences for the people living in the Arctic.

Review of the existing Energy Efficiency Design Index (EEDI) regulations

MEPC discussed the review of the EEDI and may propose a strengthening of the EEDI reference line parameters and/or new reduction rates for phase 2 and phase 3, which enter into force in 2020 and 2025 respectively, for certain ship types.

This work is ongoing and although the matter was discussed at the meeting, the schedule is, that the conclusions will be taken at the MEPC meeting in Spring 2019.