INTERTANKO’s Environmental Committee Driving INTERTANKO’s Environmental Agenda
INTERTANKO’s Environmental Agenda Environmental Agenda / Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other upcoming issues
Governance Structure 14 Committees 4 Regional Panels
INTERTANKO’s Environmental Committee Committee Overview To set INTERTANKO’s environmental policy Driven by member issues and external factors; from IMO’s environmental agenda to the implementation of environmental management systems. Tasked with liaison with environmental organisations; Greenpeace, WWF, IUCN, FOEI, regional organisations such as HELMEPA, Sea Alarm Foundation Liaise directly with ISTEC on technical and operational issues; air emissions, ballast treatment systems etc.
INTERTANKO’s Environmental Committee Committee Overview Company Country First Name Surname Minerva Marine Inc. Greece Dimitris Stamoudis Seaworld Management & Trading Inc. Michael Reppas Teekay Shipping (Canada) Ltd. Canada Howard Seto Vela International Marine Limited Saudi Arabia Mohammad A. Al-Gilani Dampskibsselskabet "NORDEN" A/S Denmark Jørn Andresen Heriot-Watt University United Kingdom Paul F. Kingston Tradewind Tankers S.L. Spain/Venezuela Carlos Juan Madinabeitia Stolt-Nielsen Transportation Group Ltd. Netherlands William D. Millar ITOPF T. H. (Tosh) Moller AET (Singapore) Ltd. Malaysia B. Subarrao OSG Ship Management (GR) Ltd. Panos Hatzikyriakos d'Amico Societá di Navigazione SpA Italy Fabio Tagliavia Euronav Shipmanagement (Hellas) Ltd. Sotiris Shinas Stena Bulk AB Sweden Johan Roos Laurin Maritime AB Marissa Laurin 16 Seats available, 15 members at present
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other upcoming issues
1. Reception Facilities – Issue Development Oil into the sea from Fuel Oil Sludge from All Ship Types 187,990M/T Bilge Oil from All Ship Types 64,400M/T Cargo Discharges from Tankers 19,250M/T (1990 158,600M/T) What to do with the waste oil: Incinerate (air emissions issue) Discharge at sea in legal quantities (15ppm) Discharge ashore Port Reception Facility issue International Law Obligates Availability and Adequacy MARPOL I, II, IV, V & VI Not just oil... 30 years..!
1. Reception Facilities – Issue Development MARPOL Availability “Member States shall ensure the availability of port reception facilities adequate to meet the needs of ships normally using the port” Adequacy “the reception facilities shall be capable of receiving the types and quantities of ship-generated waste and cargo residues from ships normally using the port without causing undue delay to ships” Reporting for the past 18 months has been in line with the two broad categories of problems, availability and adequacy issues.
1. Reception Facilities – Issue Development MARPOL Availability All waste Streams Adequacy Technical Problems Oil and Garbage Wastes Communication General Issues Reporting to Flag Administration Legislation Regional / National / Local European Cost Systems
1. Reception Facilities – Committee Action Internal Policy 1. Case by case basis 2. Feedback forms, data gathering
1. Reception Facilities – Committee Action 2. Feedback forms, data gathering Port or Terminal Summary of Problem Encountered INTERTANKO Comment Follow-up Action Port of Tarragona Compulsory discharge of cargo generated waste Compulsory discharge regardless of ample/adequate storage available on board (105cbm slops, 2280cbm storage) Under the EU Directive, compulsory discharge is only required for ship generated wastes NOT cargo generated and when the ship cannot demonstrate that it has adequate dedicated storage capacity (Reference Article 7 of the EU Directive) Clarity of procedures at Port of Tarragona sought by INTERTANKO (04/12/06) EMSA and European Commission informed regarding INTERTANKO’s position. Coryton BP Terminal, UK No slop reception facility at terminal for vessels discharging cargo. While MARPOL requires ports to provide facilities at loading terminals the EU Directive requires facilities at ports adequate to meet the needs of ships regularly calling. In this case it can be assumed that the terminal will be regularly visited by tankers discharging. Clarity of provision of facilities sought from Coryton refinery operators, BP Oil UK Ltd (13/12/06) Huelva / Algeciras Refinery informed that slop-arm damaged, no discharge possible. Algeciras discharge also not possible. - Wilhelmshaven Refinery jetty will not take slops due to no time / very closed program at jetty. Immingham Slops not accepted due to previous cargoes of orimulsion and crude oil. Member confirms slops ‘chemicals free oil and water only’.
1. Reception Facilities – Committee Action 2. Feedback forms, data gathering Port or Terminal Summary of Problem Encountered INTERTANKO Comment Follow-up Action Lavera Port of Marseille Compulsory discharge was required regardless of evidence of incinerator use in ship records. Record should be maintained in Garbage record Book, including start/stop time of incineration. Ash should be discharged ashore. Further comment noted in fax sent to Port of Marseille (see Follow-up Action). Record books should also be inspected to assess use of waste management systems on board before requiring compulsory discharge. Clarity of procedures at Lavera sought by INTERTANKO (23/05/05). Response from Port of Marseille received (10/06/05). Amsterdam PSC inspector enacted compulsory discharge of 5.3m3 of sludge regardless of short voyage to Gibraltar and 38.8m3 sludge tank capacity (8/12/04) While Article 7 of the Directive gives states the authority to enact compulsory discharge, it also provides ports to use its discretion in such cases. INTERTANKO feels that the compulsory discharge requirement should be more clearly defined within the Directive. EMSA and the Commission informed of INTERTANKO’s point of view on when compulsory discharge can be invoked by a port. New Orleans Terminal did not supply waste facilities for garbage. Alternative discharge options sought, quote received at USD1,600 for 1.15m3 of garbage waste. -
1. Reception Facilities – Committee Action Internal Policy 1. Case by case basis 2. Feedback forms, data gathering 3. Name and shame 4. Industry Cooperation
1. Reception Facilities – Committee Action 4. Industry Cooperation - Industry Port Reception Facilities Forum Aim: The Reception Facilities Forum aims for cleaner seas by the reduction of marine pollution. Objectives: encourage the wider provision of appropriate reception facilities encourage the use of reception facilities increase knowledge of reception facilities and the associated procedures
1. Reception Facilities – Committee Action 4. Industry Cooperation - Industry Port Reception Facilities Forum Objectives will be achieved by: bringing together those parties responsible for the use and provision of port waste reception facilities enhancing communication and cooperation between the facility users and providers identifying technical problems between facility users and providers, and proposing solutions to these problems addressing regulatory issues on local, national, regional and international levels and providing feedback to regulatory bodies on implementation issues collecting relevant data in order to act as a resource on international port reception facilities
1. Reception Facilities – Committee Action 4. Industry Cooperation - Industry Port Reception Facilities Forum Involving: INTERTANKO INTERCARGO ICS BIMCO ESPO EHMA/IHMA IAPH FONASBA Euroshore OCIMF Supported by: IMO secretariat EMSA (European Commission) REMPEC Transport Canada USCG / EPA ROPME HELCOM
1. Reception Facilities – Committee Action Internal Policy 1. Case by case basis 2. Feedback forms, data gathering 3. Name and shame 4. Industry Cooperation External Policy 5. Driving change at IMO
1. Reception Facilities – Committee Action 5. Driving Change at IMO Prior to 2004 INTERTANKO lobbied for greater activity – countless submissions! 2005 INTERTANKO submits Action Plan on behalf of Forum 2005 IMO acknowledges and supports Forum work Fundamental approach of IMO changed: Problem of reporting now a problem of inadequate facilities 2006 IMO Adopts its own Action Plan based on Forum’s 2007 IMO accept ANF and WDR by incorporating into Correspondence Group 2008 Correspondence Group work due to be completed April 2008, extension likely for further work 2007 IMO also endorses implementation of the Gulfs’ Special Area under MARPOL I… In 2007 the IMO also endorsed the application of the Gulfs area as a Special Area…
1. Reception Facilities – Committee Action Internal Policy 1. Case by case basis 2. Feedback forms, data gathering 3. Name and shame 4. Industry Cooperation External Policy 5. Driving change at IMO 6. Regional cooperation
1. Reception Facilities – Committee Action 6. Regional Cooperation HELCOM The Baltic Sea REMPEC The Mediterranean Sea European Commission EU Directive Gulfs Area (ME) ROPME and MEMAC Asia-Pacific Concentrated Reporting Campaign North America USCG Feedback Forms Spot a distinct absence in Asia or even South East Asian initiatives.
1. Reception Facilities – Committee Action Future activity and summing up (1) Waste recycling - Final disposal obligations / responsibilities - Overlap with waste segregation work - Incorporate into MARPOL Annex V garbage management plan - Waste Delivery Receipt will become important Reporting to INTERTANKO and IMO/flag administration - New reporting Form (MEPC Circ.469 Rev1) - IMO momentum sustained: Action Plan and Correspondence Group Use of GISIS - A Tool for the Industry: i. to report inadequate facilities ii. to view inadequate facility follow up iii. to gather facility information
1. Reception Facilities – Committee Action Future activity and summing up (2) Some homework: Download NEW IMO reporting form Log onto GISIS (http://gisis.imo.org/Public/PRF/Default.aspx) Report to flag administration and INTERTANKO on alleged inadequate facilities Contact Tim Wilkins (tim.wilkins@intertanko.com) on repeated problem areas Download ‘Why Report Inadequate Reception Facilities’
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other upcoming issues
2. Ballast Water Management – Issue Development
2. Ballast Water Management – Issue Development Two External Policy Drivers: IMO Convention implementation Local, National and Regional Regulations
2. Ballast Water Management – Committee Action IMO Convention implementation Focus on Guidelines INTERTANKO/ICS Model Ballast Water Management Plan 3rd Edition IMO Guidelines (5 key guidelines out of 16) Guidelines for Ballast Water Sampling Guidelines for Ballast Water Management and Development of Ballast Water Management Plans Guidelines for Ballast Water Exchange Guidelines for Ballast Water Exchange Design and Construction Standards Guidelines for Sediment Control on Ships
2. Ballast Water Management – Committee Action IMO Convention implementation Focus on Technology Originally involved European technology assessment 2000-2002 (MARTOB) Comparison of technologies tried/tested? Lloyd’s Register release ballast water technology overview – available from INTERTANKO All systems should be type approved by the administration – those using active substances will need Basic approval and Final approval by IMO One ballast treatment system now has Final Approval, with 6 systems having acquired Basic Approval Systems to watch... NEI Treatment Systems (Type approved) Alfa Laval OceanSaver
2. Ballast Water Management – Committee Action IMO Convention implementation Focus on Entry into Force Dates Assembly Resolution A.1005(25) Uncertainties raised by industry (INTERTANKO, ICS and OCIMF) in the availability of treatment equipment to meet the standards in the Convention for those ships constructed in 2009 (with ballast capacity <5000m3) So, ships constructed in 2009 will now have to install treatment technology until its second annual survey and no later than 31 December 2011. Review the application of the Convention for ships constructed in 2010 at MEPC 58 (October 2008)
2. Ballast Water Management – Committee Action Two External Policy Drivers: IMO Convention implementation Local, National and Regional Regulations Australia (Victoria) New Zealand Argentina (Buenos Aires) Brazil Panama Canada Peru Chile Russia (Novorossiysk) Georgia Lithuania (Klaipeda) Ukraine Israel USA
2. Ballast Water Management – Committee Action
2. Ballast Water Management – Committee Action
2. Ballast Water Management – Committee Action Two External Policy Drivers: Local, National and Regional Regulations Russia (Novorossiysk), Georgia and Ukraine State Inspectorate for the Protection of the Black Sea (SIPBS) Ballast exchange requested Samples tested for iron, oil and suspended solids Fines imposed or request made to exchange ballast outside of port area is ballast found to be off spec
2. Ballast Water Management – Committee Action Future activity and summing up Some homework Information on treatment technology being considered or tested on board members vessels Report on problems with PSC inspections Advise on any new local, national or regional requirements
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other upcoming issues
3. Ship Recycling – Issue Development Three initial drivers on Ship Recycling Greenpeace European Commission (Parliament and Council) IMO (UN Agencies: ILO and Basel Convention)
3. Ship Recycling – Issue Development IMO and Industry Initiative Industry Code of Practice 2000 ILO & Basel Guidelines Shipping Industry Feedback Workable Practical Objectives Met 2003 IMO Guidelines Consideration of Mandatory Elements 2004 Draft International Ship Recycling Convention 2006 Increasing EU Pressure Interim Measures Adopt International Ship Recycling Convention 2009 2014? Entry into Force
3. Ship Recycling – Issue Development European Commission (Parliament and Council) Green Paper, ‘Better Ship Dismantling’ Global solution through IMO, but… Opens possibility for regulating through European or International waste instruments Suggests standards for global recycling facilities to European environmental and safety levels Port state control of suspected vessels Provides basis for the development of interim measures (voluntary and/or mandatory) Industry voluntary action promoted (Interim period)
3. Ship Recycling – Issue Development IMO (UN Agencies: ILO and Basel Convention) Key Elements of the Mandatory Convention (1) 1. Recycling Facilities Licensed recycling facilities Ship owners to use only licensed/approved facilities Ship owners to remove material the facility cannot Ship owner to gas-free if yard is not capable 2. Mandatory reporting scheme 3. Ship Recycling Plan Prepared by the recycling facility – MEPC Circ.419
3. Ship Recycling – Issue Development IMO (UN Agencies: ILO and Basel Convention) Key Elements of the Mandatory Convention (2) 4. Ship Recycling Contract Ensuring key elements of the Guidelines are included 6. Potentially Hazardous Materials Restrict use of hazardous substances on new ships States to minimize hazardous substances in existing ships Ship owners to mark potentially hazardous materials 7. Inventory Hazardous Materials (aka Green passport) Ship builders to provide IHM to owner (new building) Ship owners to maintain validity of IHM Ship owner to deliver IHM to recycling facility
3. Ship Recycling – Committee Action INTERTANKO – Interim measures Industry Working Group – Interim Measures Dynamic process of guidance and best practice for ship owners. Drawing heavily on and eventually to be a guide on Convention implementation 1. Yard Selection When selling ships for recycling, owners are encouraged to select only those yards which have stated they are willing to undertake operations compatible with the measures recommended in this document. 2. Inventory of Hazardous Materials Owners are encouraged to complete part 1 of the Inventory of Hazardous Materials for all ships in their fleet and to complete parts 2 and 3 during sales and prior to delivery to the ship recycling facility. 3. Gas Freeing As a precaution against explosions during the recycling process owners should ensure that Gas-Free-For-Hot-Work provisions are included in their contract of sale and, to the extent possible, that the recycling facility to which they are selling the ship conducts gas-freeing in its operations.
3. Ship Recycling – Committee Action Industry Working Group – Interim Measures Ship Recycling Plan Owners are encouraged to provide the ship recycling facility with as much information as possible, in particular an inventory of hazardous materials, to facilitate the development of the ship recycling plan. Reporting to Flag State As soon as possible after the delivery of the ship to the recycling yard, owners are encouraged to inform their Flag Administration that they have taken steps in accordance with these recommendations and to request appropriate acknowledgement.
3. Ship Recycling – Committee Action Future activity and summing up IMO Members States need to agree on whether to include bilateral agreements within the Convention Industry to push for definition of Ready for Recycling and its criteria...
3. Ship Recycling – Committee Action Ship owner Decides to recycle vessel 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 Ship owner Submits IHM Part I plus other relevant information (regulation 9.2) to recycling facility to allow facility to develop and complete SRP Recycling facility Deposits SRP with recycling state to gain [authorization/verification] Recycling state either; Authorizes/verifies SRP Tacitly agrees to SRP [14 day rule] Recycling facility Notifies ship owner that SRP has been approved/verified contract between ship owner and recycling facility finalised Ship owner requests final survey from flag administration Flag administration Provides ready for recycling Certificate based on completion of Parts 1-3 of IHM and the approved/verified SRP Ship owner Once receiving RfR Cert delivers vessel to recycling facility sale completed, recycling to commence
3. Ship Recycling – Committee Action Some homework IHM delivery with all new buildings – as per INTERTANKO Council decision Consider implementation of Industry Interim Measures – available from INTERTANKO website Feedback problems in development of IHM Share information on facilities
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other upcoming issues
4. Biofouling and Anti-fouling – Issue Development Hull-mediated transfers of harmful invasives / nuisance foulers, on a range of external and internal hull 'Niches' Antifouling The sub-group of Fouling Control Coatings that contain biocides, and so subject to environmental concerns and regulations. For example: TBT: (2003-2008 phase out) Irgarol: co-biocide (banned by some states) Diuron: co-biocide (now in the spotlight) Copper: (also in the spotlight)
4. Biofouling and Anti-fouling – Issue Development Anti-fouling Systems Entry into force of the AFS Convention Total of 24 states have ratified the Convention representing 16.63% of the world’s tonnage – Panama announced it would ratify the Convention this year (adding the state plus 21.46% in tonnage) Note EU will not allow any ship with tin-based anti-fouling on its hull after 1st January 2008 Environmental Committee Move towards biocide-free systems Comparison of silicon systems
4. Biofouling and Anti-fouling – Issue Development Biofouling as an issue for the IMO Organisms found in the sea chest – hydroids, bryozoans, mussels
4. Biofouling and Anti-fouling – Issue Development Biofouling as an issue for the IMO Organisms found in the sea chest – Part 2
4. Biofouling and Anti-fouling – Issue Development Biofouling as an issue for the IMO Rudder post identified as favoured niche area for many organisms
4. Biofouling and Anti-fouling – Issue Development External and Internal hull 'Niches': External skin / shell plating - typically where the Fouling Control Coating is scratched (bow stem, bulb), missing, mismatched or exhausted (e.g. dry-dock support strips) hi-wear areas (rudder, waterline) anode blocks uncoated areas (prop, rudder pivot) sea chests thruster tunnels, grills, azimuth units, etc Internal - bilge spaces, strainer boxes, seawater pipe work
4. Biofouling and Anti-fouling – Issue Development Biofouling as an issue for the IMO New Zealand, Australia, UK, FOEI and the IUCN proposal for a new work item on Biofouling: Development of international measures for minimizing the translocation of invasive species through biofouling of ships Consideration would be given to: developing Guidelines for the adoption by MEPC linking measures to the AFS Convention linking measures to the BWM Convention developing a new Convention Future direction Continued development of national requirements: Australia, New Zealand, California AB740 Industry pro-activity required
4. Biofouling and Anti-fouling – Committee Action Assess scale of problem: research commissioned by Committee, Heriot-Watt University, Edinburgh Scale of issue defined and indication of severity in relation to ballast water 36% of species introduced into North America attributed to biofouling 77% of species introduced into Port Phillip, Australia attributed to biofouling Seek risk based approach in initial stages Platforms , barges, pontoons, and derelict and laid-up vessels which have been moored for extended periods of time; Recreational and small craft which spend significant periods at moorings or in marinas and which also do not, or cannot use high performance antifouling coatings; Poorly maintained merchant vessels; Vessels near the end of their docking cycles Vessels with long docking cycles which do not undertake in-water cleaning of unprotected or poorly protected areas, such as propellers, and around rudders and seawater intake grates between dockings. Provide information on possible biofouling management options In water hull cleaning options: Stena CleanHull Effective management options: Australian Shipowners’ Association Guide
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other upcoming issues
5. Environmental Awareness and Benchmarking Training Environmental Awareness Training Courses Heriot-Watt University ITOPF Energy Conservation On board awareness campaign Requiring information on on-board energy monitoring and measuring equipment Training guide for companies to train crew on energy conservation on-board Includes standardised presentation for seafarers Guidance document Awareness posters Consider further the establishment of a benchmarking scheme for energy consumption
5. Environmental Awareness and Benchmarking Environmental Benchmarking (1) Environmental Management Systems TMSA Continuous Improvement Experienced gaining in establishment of standard TMSA benchmarking within INTERTANKO membership Experienced gained with Loss Time Frequency benchmarking within membership Requires Agreement on what significant aspects to record and benchmark: GHGs: CO2 and VOCs SOx Sludge and oily bilge water Garbage Sewage
5. Environmental Awareness and Benchmarking Environmental Benchmarking (2) Requires Agreement on which formulas to use: MEPC’s Voluntary Indexing of Ships Guidelines INTERTANKO/Tim Gunner’s GHG Indexing of Ships BP benchmarking formula expanded Discussion and agreement on requirements at next meeting in Istanbul, 17th April Objective to establish system on INTERTANKO website
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other issues
Other issues Whale Strikes Predominantly a National and Regional issue Oman Whale and Dolphin reporting Killer Whale Recovery Plan (NOAA) North Atlantic Right Whale (NOAA) Mandatory reporting (Whalesnorth & Whalesouth) – also IMO Routing proposals Slow steaming proposals International developments IMO (NAV) Traffic Separation Scheme requirements, Bay of Fundy and Port of Boston IWC Proposals Adopt national, regional and local legislation Whale data on radar Crew training
Other issues Whale Strikes Committee Consideration Regionally: Environmental Committee recommended that INTERTANKO members report on a voluntary basis in advance of the mandatory reporting requirements and that members also implement the recommended navigational proposals put forward in the NOAA east coast traffic route circular. Internationally: On the proposed measures to reduce ship strikes, the Committee favoured well considered and practical navigational amendments over the use of slow steaming as a whale-strike mitigation measure.
Environmental Organisation Liaison Other issues Environmental Organisation Liaison WWF Agreement to work together on mutual issues: - Antifouling systems - Port reception facilities - Air emissions from shipping IUCN (World Conservation Union) Agreement to work together on specific issues: - Whale and dolphin conservation (objectives yet to be set) - Biofouing: establishment of an industry/environmental working group to suggest and promote solutions Sea Alarm Foundation - Committee support for work strategy and promotion of the Foundation within the industry
Environmental Organisation Liaison Other issues Environmental Organisation Liaison MEPA’s - HELMEPA, CYMEPA, AUSMEPA, TURMEPA etc. Assist and promote Greenpeace - Communication and meetings relating to ship recycling Friends of the Earth International (FOEI) - Reception facilities and general marine pollution issues
INTERTANKO’s Environmental Agenda Presentation Overview Port reception facilities Ballast water management Ship recycling Biofouling and Anti-fouling Environmental Awareness & Benchmarking Other issues Please contact Tim Wilkins (tim.wilkins@intertanko.com) Thank you...