1. Environmental Notation & Green Passport
Duration; one hour incl questions
Environmental Notation & Green Passport
LRNA, Inc. – Intertanko North American Panel Meeting 3/20/06

2. Introduction Background EP Notation Brief History IMO Guidelines
Green Passport
Granatina
Conclusion
Intertanko North Ameican Committee Meeting, 20 March 2006

3. EP Rules why and what? Why: What are they:
Increasing environmental awareness
IMO response to specific environmental issues
Commercial concerns
ISM environmental policy requirements
Public accountability of operations through environmental audits eg : ISO
What are they:
Independently derived environmental standards, whose effective implementation is verified by means of survey and audit processes.
An environmental benchmark - for what could reasonably be expected from environmentally conscious ship owner.
Goes beyond ISM and MARPOL
Examples, Australian, Canadian and USA concerns regarding the transfer of unwanted marine organisms in ships’ ballast water (Introduction of the national Invasive Species Act 1986 NISA) - Japanese total ban on TriButylTin in anti-fouling paints due to fears of bioaccumulative effects on local seafood. - Oil pollution incidents Sea Empress, Braer - Baltic sea states with exhaust emissions - recent introduction by Sweden of reduced fairway fees for vessel with reduced NOx and SOx (graduated fee-scale)
These are reflected in amendments and new Annexes to MARPOL - in particular Annex VI dealing with Air Pollution from Ships, with future potential Annexes covering TBT and Ballast Water
Any delay to shipping operation or restriction on trading service will have direct impact on trading income to owner or charterer
Contained in Clause 2 which requires an environmental policy to be established and must describe how the objectives will be achieved. There is also a need to audit and review the policy periodically
Social - usually produced as an environmental report or impact assessment to demonstrate a responsible attitude to the public or client base
Economic - used as a means to generate business or operate in restricted areas
Regulatory - the introduction of company controls in order to offset statutory controls
Simple definition - in line with the ideology of both ISM and ISO 14001
Anticipating future legislation and/ or Flag/Port State Requirements
A descriptive note is shorthand entry into column 6 of the LR Register of Ships which denotes that a vessel has achieved a certain standard as stipulated within an LR Rule or Requirement (Once Rules are no longer provisional an EP Notation will be issued)

4. Operating Ship Sources
The core technical requirements cover all major ship-generated pollution sources and can broadly be grouped into three classes:
pollutants covered by the traditional MARPOL provisions - garbage, oil and sewage;
pollutants covered by the recently adopted Annex VI to MARPOL on the prevention of Air Pollution from Ships - exhaust gases (NOx and SOx), refrigerants and fire-fighting agents;
pollutants - such as ballast water which has been under discussion at the International Maritime Organization (IMO) for some time, but which is not yet regulated and antifouling paints, covered by the newly adopted (2001) IMO International Convention on the Control of Harmful Antifouling Systems .
In all cases, however, the Rules have tried to look beyond the existing, forthcoming or potential MARPOL requirements at what could reasonably be expected from a ship owner wishing to demonstrate a commitment to the environment.
NB Substitute slide showing tanker located in supplementary slides if more appropriate.

5. Structure of EP Rule RequirementsB N
Supplementary characters A P S R G V
Refrigerants
Anti-fouling paints
Sewage
Garbage
Core requirements
NOX
SOX
Fire-fighting agents
Ballast water
Oil
The Rules consist of a number of prerequisite requirements
compliance with all relevant annexes of MARPOL (including sewage - Annex VI - not mandatory at present);
possession of valid ISM certificate;
membership of SERS (LR’s Ship Emergency Response Service) or an equivalent IACS member scheme.
as well as the core requirements covering the major operational pollutants (covered in next slide).
In addition there are a number of more stringent ‘supplementary’ requirements which can also be adopted on an individual basis according to the owner’s requirements. These cover:
Antifouling coatings (A)
Ballast water management (B)
Grey water treatment (G)
Oxides of nitrogen (N)
Protected oil tanks (P)
Refrigeration systems (R)
Oxides of sulphur (S)
Vapour emission control systems (V)
Adoption of one or more of these supplementary requirements is signified in the Register Book by additional characters alongside the basic notation ‘EP’ in the Register Book.
This system enables owners to highlight substantial investment in particular aspects of pollution control (eg. selective catalytic reduction (SCR) for NOx control or grey water treatment), whilst demonstrating a high all-round level of environmental performance.
Additional information for Supplementary Characters:
B: Ballast water management
• Ballast water management plan;
• Ballast Water Management Plan approval certificate;
• Schematic piping plans of the ballast system and plans of the ballast treatment system
G: Grey water
• Details of grey water treatment plant & effluent quality (measured in terms of faecal coliforms, suspended solids & BOD5).
• Statement indicating whether grey water treatment plant effluent is to be re-used or recycled for any purpose.
N: Oxides of nitrogen
• Manufacturer’s specification(s) for NOx emission control equipment or systems, if fitted, & evidence of NOx emission reduction efficiency;
• Schematic showing NOx emissions control equipment or system/ engine(s) layout, as applicable.
P: Protected oil tanks
• Arrangements of oil tanks, including distance from side or bottom plating.
R: Refrigeration systems
• Details of intended refrigerant(s) including manufacturer’s supporting statements in respect of the ODP (Ozone Depleting Potential) and GWP (Global Warming Potential).
ISM
MARPOL
SERS
Prerequisites

6. design build scrap operate
Through-life solutions
design
build
scrap
operate
The very nature of scrapping uniquely applies first to the oldest ships! There is no point in the IMO producing legislation that only applies to newbuilds. The legislation must be retrospective to be effective, and thus newbuilds cannot squeeze past any new legislation since it will apply to them sooner or later.
A ship built today, especially a long lived, high added value ship, such as a gas tanker, will be scrapped in a very different future situation. The Green Passport, and inventory of hazardous materials will enable the owner to identify his liability for changing legislation.
Present examples are TBT and asbestos. A properly structured, verifiable and maintained Green Passport issued at newbuild will enable the owner to prove his ship is free of chosen hazards such as TBT and asbestos. Since this will have to be done before scrapping anyhow, it is cheaper and more effective to do it at newbuild. If his Green Passport is properly supported and maintained, he will not have to spend this money again.
Maybe the biggest advantage is safety onboard. A proper summary of hazards on the ship brings this to the awareness of everyone involved and proper attention to whether sufficient hazard and safety management systems are in place. It also enables new crew members and visitors to see if they are properly trained and aware of the hazards onboard. This is a very powerful tool for safety onboard and safeguarding the owners liability.
Ship recycling is a visibly environmental subject and adds to the Owners environmental portfolio. A policy of implementing Green Passports is quantifiable, qualifiable and measurable within the required goals of an ISO company.
At present there is excellent scope for companies to be seen in the forefront of developing technology and demonstrating a proactive stance on safety and the environment.

7. Brief History Traditional scrapping 1980’s the beaches take over
1995 Brent Spar
1999 First Global Ship Scrapping Conference
Industry Guidelines – ILO, BC, ICS.
MEPC and the IMO Guidelines. (IMO Res A.962(23))
1st Tripartite meeting – Feb 2005
MEPC agreed legally binding Instrument on Ship Recycling to be adopted in
2nd Tripartite Meeting – Dec 2005
Inverkeithing, the RInA presentation
Alang
Brent Spar
De Jongs paper – natural extension of their mandate to enforce any future international regulations relating to the disposal of ships
MEPC Circular Covering “Gas Free for Hot Work” Certificates adopted since lack of proper control in this area has long been recognised as a principal cause of deaths during ship recycling.
Committee agreed – new legally binding document required
Design, Construction, Operation
Operation of recycling facilities
Establish an appropriate enforcement mechanism
Completed draft in 2007 – adoption

8. IMO Guidelines on Ship Recycling
Promulgated in IMO Res A.962(23)
Ship Design
Minimize use of hazardous materials
Design for Recycling
Through life-inventory of potentially hazardous materials: Green Passport
Hazardous materials in ship’s structure and equipment
Operationally generated wastes
Stores
Preparation for scrapping
Selection of ‘approved’ recycling facilities.
Preparation for recycling.

9. Green Passport – What is it??
A document that complies with IMO Res A962(23) para 5.
Consists of: basic details pertaining to the ship, and an inventory of hazardous materials.
But!
What materials should be in the Green Passport?
How much detail is required?
How is it produced?
Who will approve it?
What materials should be on the Green Passport?; as in the LR guidance – maintenance is essential for shifting perspective
How much detail is required?; see above
How is it produced?
Who will approve it?
1)New technology
Refrigerant developments
Lead, cadmium pvc
Flexible to recognise inevitable changes, recognise lack of certainty and developing requirements
Responsibility; LR will verify the Green Passport against the IMO guidelines, and against the LR guidelines
Reasonable
3) LR will publish a set of guidelines not only explaining all the hazards, but advising how an Owner can best complete his Inventory and how he can best use it to maximise its potential to improve safety onboard and to finally discharge his responsibility properly at disposal.

10. The Green Passport inventory:
Asbestos
Paint
Plastic and Rubber materials
Materials containing PCBs, PCTs, PBBb at levels of >50 mg/kg
Refrigerants, fire-fighting media, blowing agents and other gases
Chemicals in ship’s equipment/ machinery
Electrical & electronic equipment
Constructional materials
Working with our collaborative partners (Teekay-Shell- BP, etc…)
The LR Green Passport contains
Executive Summary – one page on Principal Hazards
It may sound like a simple thing but the format is landscape vice portrait which permits more details of the systems and standards.
Added new items like Rubber, Electrical & electronic eq. and Construction Material
Changed focus from Ozone Depleting substances to Refrigerants, Fire Fighting and Insulation Material

11. Priorities & Role Industry Priorities Green Passport
Licensed dismantling facilities
Lloyd’s Register Role
Developing Green Passport template, industry guidance, procedures to permit implementation.
Approve, Verify and maintain Green Passports

12. Implementation EXISTING SHIP NEW CONSTRUCTION
OPERATION
Compile Data w/owners
& Manufacturers
Examine and Approve
Verification
Issue Green Passport
Maintain
Periodic Audits
EXISTING SHIP
DESIGN
Pre-Contract Review
Specification Review/Developed
Design for Recycling
CONSTRUCTION
Compile Data w/Shipyard
& Manufacturers
Examine and approve
Verification
Issue Green Passport
OPERATION
Maintain
Periodic Audits
SCRAPPING
Scrapping Plan
Ship Inventory
NEW CONSTRUCTION
The OBJECTIVE is to keep this ‘GREEN PASSPORT’ issu

13. Newbuilding Procedure
Pre contract discussion
Contract for LR Green Passport with excluded material (request for services)
Survey / audit of suppliers, materials and yard
Review of documentation and appraisal of Green Passport
Issue Green Passport on Delivery
Maintain by annual audit/survey
Title; Following the IMO guidelines, the newbuilding procedures will provide for the following;
Pre contract discussion; Where the Owners, yard and LR will discuss Green Passport issues, such as excluded materials, replacement materials and recycling design. At this time the list of excluded materials and it’s management is the most important. Specifying out TBT’s, asbestos, pcb,s etc will save money in the future.
This will be in the contracts of all parties. For LR the Green Passport information will be included in the Request for Services.
During the newbuild process, as a simple extension of the surveyors normal duties, he will audit / survey the subcontractors supply and the yard, both in terms of his normal site visits and his normal document review.
The yard will compile all this information at the end of the newbuild and present it with the other documentation of the vessel for review by the site surveyor.
The site surveyor will issue the Green Passport with the other essential documents LR is responsible for.
During the normal class Annual Survey, the continued accuracy and maintenance of the Green Passport will be verified.

14. Existing Ship Procedure
Owner compiles and submits Green Passport
Green passport appraised with comments as necessary
Onboard survey and verification
Issue Green Passport
Maintain by annual audit/survey
Title; The procedure is similar for existing ships.
The Owner, or responsible crew member(s) will compile and submit the Green Passport three months before the next major class survey (preferably ITSS/DS or SS/DS).
This will be appraised and comments made for resolution.
When satisfactory, and at the scheduled survey, the surveyor will verify the Green Passport whilst carrying out his normal survey duties.
On completion the Green Passport will be issued.
This will be maintained as part of the normal annual surveys, as before.

15. Granatina, First Green Passport
The Shell LNG Tanker, Granatina
So, what does a Green Passport look like.
Well, the first Green Passport to be publicly issued and maintained by an IACS member Classification society was;
Photo courtesy of STASCo.

16. The Green Passport
This is the Interim Certificate for the survey held on Granatina.
At present the Green Passport survey is a miscellaneous hull survey. On completion a document of compliance with IMO guidelines is issued and a memo placed on the ship for information, and annual maintenance.
The annual Green Passport survey will be held seamlessly at the same time as the other annual surveys, and will simply consist of the surveyor making his normal surveys, but with his attention also on Green Passport issues.
This system may be developed into Rules and a class notation if that is the direction wanted by the industry, although since it is likely to become a Statutory requirement, a class notation may not be appropriate.
LR may develop lists of materials recommended to be excluded during newbuild. This info may be included in column 6 of the register book.

17. The Green Passport
Statement of Fact that LR have verified contents to be in accordance with the provisions of the IMO guidelines.
Harmonised with other statutory/class certificates.
This is a sample of the Green Passport that LR is developing.
At present it is, in essence, a statement of fact that LR have verified the contents to be in accordance with the relevant provisions of the IMO guidelines: A Document of Compliance.
The first page, as shown, states the relevant resolution with which compliance is verified. It lists the required ship information, as recorded in the Continual Synopsis Record, and it give an expiry date. At present this is the harmonisation date. Further pages would give annual endorsement spaces in the familiar form.

18. Through Life Benefits
Provision of structured System to Properly Control hazardous Materials at new build & through life
Promotes better hazard management & long term liability planning.
Proper certification and reporting ability to manage liability for hazardous materials
By identifying hazards, enhances onboard safety.
Awareness to changing price structure re: end of life asset.
Promotes better environmental awareness & planning.
Enhanced reputation
ISO – measurable and achievable objectives.
The LR Green Passport in the first attempt to produce rational, pragmatic procedures to identify and certify hazardous materials onboard vessels. In some ways it is surprising that such a high level definitive tool has not existed before.
Issued by an internationally recognised company such as Lloyds Register, this has global credibility for the statutory guidelines it follows, and should thus be recognised in any port and by any authority, that generally operates with Recognised Organisations within its statutory framework. The Green Passport is designed to fit naturally into the expected IMO mandatory reporting system.
The proper identification of hazards has obvious safety benefits to all working on board, or visiting the vessel. It allows Owners to properly manage hazards onboard and to be able to demonstrate proper safety management documentation in case of incident. (procurement procedures should specifiy asbestos free components, etc…)
Owners are liable for the hazards their vessels pose to the crew, other people onboard the vessel, the ports, seas and environment the vessel operates in. How can an Owner be confident in this liability unless he knows what hazards are onboard? The Green Passport also allows him to calculate his liability for the inevitable changes in the definitions of hazardous materials. It allows him to sensibly target materials and plan for their replacement, relevant crew training, or disposal.
Changing price structure: an end-of-life ship, which was previously an asset, may now be of little net value or may even be a financial liability.
Implementation of non-mandatory Guidelines will help enhance reputation.
Compilation and independent verification of the hazardous materials inventory provides measurable and achievable objective.
All these measures benefit the environment.

19. Key Points The Green Passport:
Is not difficult to compile; it records hazards rather than prohibits them.
Approval is a simple extension of surveyors normal duties.
Issued at new building is inherently more accurate than that issued for an existing ship.
Is designed to aid scrapping & help protect workers and the environment with significant through life benefits:
Safety
Environmental Management
Management of Liability

20. Recycling Facility Standards
ILO; ‘Safety and Health in Ship Breaking, Guidelines for Asian Countries and Turkey’
Basel Convention; ‘Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships’.
Any other Internationally Recognised standards
Familiarity to Shipowner = IMO / ILO
List of materials in Green Passport = List of materials Recycling Facility Licensed to handle

21. The Future Tripartite IMO / ILO / BC Meetings (2nd in DEC 2005)
Mandatory Timetable (IMO circa )
Green Passport
Licensed Scrapping Facilities – and associated guidance
Four stakeholders
Ready for scrap agreement
Inevitable price structure shift
The three main UN bodies, IMO, ILO and the Basel Convention are to have a 2nd meeting in December 2005.
This meeting has been planned for some time and the three bodies have each been preparing their agenda’s and proposals for discussion. This is why the October MEPC 52 was so important because it laid out IMO’s proposals.
This is also why the IMO proposal has such a long list of mandatory items. The IMO needs to prove its competence, and show that its proposals are equivalent to items in the Basel Convention. When (if) this is agreed in February then the IMO will be able to take its (proper) primacy and implement the necessary legislation at MEPC 53 later in the year.
This legislation is anticipated to be;
A long list of mandatory items, as set out in the MEPC 52 proposal, including;
Green Passport for all ships
Licensing of scrapping facilities.
The identification of the four main stakeholders and their relative responsibilities and relationships. The four are; Ship owner and the flag state, Recycling facility and national authority. This is a difficult area and includes contentious lines of communication and agreement (eg directly between flag state and national authority – impractical in reality) as well as a four party agreed ‘consent to scrap’ or;
The ‘ready for scrap agreement’. This has several names, but in essence is a document that shows that all four parties agree to all stages of the scrapping. This may seem simple and sensible, but at present there are many post contract hurdles which are difficult to quantify, the Owner’s sole responsibility, and easy for any of the other three parties to disagree. An obvious example is that there is a full detailed contract, the Owner arrives at the recycling facility gas free, there is a delay and the gas free certificate is challenged. Suddenly the whole contract is null and void, the owner has almost unlimited liability, and the recycling facility has a captive customer to renegotiate the contract.
The inevitable price structure shift has already happened. The MOD sold the ‘Olwen’ to India for scrap last year, presumably for a profit for the UK taxpayer. The MOD now needs to scrap HMS Intrepid and is already spending money on preparation. The American ghost fleet ships which went to Able UK were sent to the UK with the american government paying Able to dispose of them.
A picture of Sandrien. This what we are all trying to avoid. A ship that failed port state surveys and was essentially abandoned by its Owner, at a cost to the taxpayer of up to 3 million euros

22. design build scrap operate
Through-life solutions
design
build
scrap
operate
We all have a duty of care to our employees, families and the environment.
Environmental Notation coupled with the Green Passport are most certainly good forward steps.