1. INTERTANKO Latin American Panel September 13-14, 2010 ENVIRONMENT COMMITTEE UPDATE
Image Courtesy of NORDEN AS

2. Policy Issues
Ballast Water Management
Port Reception Facilities
Garbage Management
Ship Recycling
Greenhouse Gas Emissions
Anti-fouling
Biofouling
Reporting Items
Ship Strikes with Cetaceans
Marine Noise Pollution
Liaison with Environmental Organisations

3. Method of work - using Objectives
the development of Objectives would allow the Committee to focus on each of its agenda items and consider how the Committee would work on each item to meet the objective. This would allow the Committee to remain focused and ensure that the agenda was relevant to the Committee’s aims.
the Objectives are currently in draft but will be tabled for the Council’s consideration in October
The following presentation focuses on the current work of the Environmental Committee based on issues that are on going and have been considered at its previous meeting.

4. BALLAST WATER
International Convention for the Control and Management of Ship’s Ballast Water adopted in 2004
- Entry in Force – 30 countries representing 35% of the world’s gross tonnage
- Current ratifications – 25 countries representing 24.28% of world’s gross tonnage

5. BALLAST WATER TREATY REQUIREMENTS Ballast Water Management Plan
Ballast Water Record Book
Ballast Water Management Certificate and surveys to verify compliance
Mandates ships to conduct ballast water exchange until equipment is approved to meet ballast water standard

6. BALLAST WATER BALLAST WATER STANDARD (D-2)
Less than 10 viable organism greater than 50 microns is size per cubic meter of water
Less than 10 viable organism smaller than 50 microns and greater than 10 micron is size per cubic meter of water
Human health standards for cholerae, coli and cocci

7. BALLAST WATER STATUS OF EQUIPMENT APPROVALS Basic Approval 24
Final Approval 12
Type Approval
Active substances 5
Non-active substances 2
Under Development 6
(Systems using “active substances” require IMO “basic” and then “final” approval)

8. BALLAST WATER DATES
Ship constructed in 2009 with a ballast water capacity below 5000m3 must meet the D-2 standard by its 2nd Annual Survey, but not later than 31 December 2011.
2010/ Ships constructed in 2010 or 2011 with a ballast water capacity below 5000m3 must meet the D-2 standard when built.
Ships constructed in or after 2012 must meet the D-2 standard.
Ships constructed before 2009 with a ballast water capacity between 1500m3 and 5000m3 must meet the D-2 standard at first drydocking after January 1, 2014.
Ships constructed in or after 2009 with a ballast water capacity of 5000m3 or above must meet the D-2 standard when built. Ships constructed before 2009 with a ballast water capacity below 1500m3 and above 5000m3) must meet the D-2 standard at first drydocking after January 1, 2016.

9. Concern over treatment systems to meet 2012 deadline
BALLAST WATER
Concern over treatment systems to meet 2012 deadline
Treatment type
Generation of chemicals
Capital Cost ($USD)
Operating costs over 10-years
Other Costs: consumables, spares, maintenance
Power Consumption
Size (m3)
Weight (kg)
Pressure Drop
# installations/contracts
Tried and tested on large scale

10. BALLAST WATER
States implementing and enforcing IMO Convention, although not in force, Norway
Other States seek to go beyond IMO Convention, USA
Implementation issues arising - Ballast Water Record Book format
IMO list of Guidelines continues to be important but overlooked by operators:

11. BALLAST WATER
FIVE KEY IMO GUIDELINES (out of 16) that are aimed at assisting the ship operator
Ballast water sampling
Ballast water management and the development of ballast water mangement plans
Ballast water exchange
Ballast water exchange design and construction standards
Sediment control on ships

12. Countries that have taken national action
BALLAST WATER
Countries that have taken national action
Australia Argentina
Brazil Canada
Chile Georgia
Israel Lithuania
New Zealand Panama
Peru Russia
Ukraine USA
To see the details of their requirements, go to – Environment – Ballast Water – Ballast Water Legislation

13. BALLAST WATER
Objective: Encourage the sharing of information on ballast water treatment systems and the results of on-board test installations
Objective: Encourage the establishment of uniform industry best practice based on the principles of the IMO Convention
Current work...
State of the Membership Survey
Facilitate INTERTANKO policy making in respect of the IMO Convention
Information sharing on technology under consideration by the tanker industry
Global Industry Alliance (GIA) – sharing of information
State of the Industry Survey
Membership questionnaire/survey on ballast water treatment systems to be circulated with a view to using the circular as a survey to gauge the current state of the industry and INTERTANKO members in relation to their implementation of the BWM Convention and the installation of ballast treatment systems. The survey will also gather information on types of systems being considered and technical data direct from owners as opposed to vendors. The information can then be used to form future policy on the subject as well as information sharing, much like that which was gathered to develop the TEEMP.
Global Industry Alliance (GIA) – sharing of information
The Committee has agreed to become more involved in the work of the GIA and share information with the GIA on ballast treatment technologies.
The Global Industry Alliance (GIA) is a public-private partnership between the GloBallast Partnership Programme and maritime companies including BP Shipping, Daewoo Ship Building and Marine Engineering Co Ltd, APL and Vela Marine International. The GIA will assist in creating solutions for addressing ballast water issues, including new technologies, along-with training and capacity-building activities.

14. RECEPTION FACILITIES Current work...
Objective: Encourage and cooperate with stakeholders in improving the adequacy and availability of reception facilities at all oil and chemical ports and terminals
Current work...
Proposal to adopt a Compulsory Discharge policy
Advantages:
Establishment of a level playing field
Minimise waste on board
Lower emissions as incinerator would not need to be used as frequently
Lower maintenance costs due to less use of incinerator
Fewer options for facilitation payment demands
An effective way to attain the zero pollution and clean seas objectives.
Further consideration of this requirement would need to take into account the fee mechanism and possible abuse of the scheme by port states.
The issue of no-special fee was considered at the committee’s last meeting. While INTERTANKO had been an advocate of this concept in the late 1990’s, only a hand full of ports had taken the idea on. These were generally the Baltic Sea ports which are currently considered the best practice model in terms of adequate facilities.
The Committee supported the view that a compulsory discharge requirement at all ports and terminals could force action to have facilities in every port and terminal. This position however was discussed with a clear understanding that for such a scheme to work then a transparent fee system would need to be established. It would be preferential if this fee system or mechanism was harmonised across all ports. The Committee felt that the following benefits could be gained from a compulsory discharge regime:
Establishment of a level playing field
Minimise waste on board
Lower emissions as incinerator would not need to be used as frequently
Lower maintenance costs due to less use of incinerator
Fewer options for facilitation payment demands
An effective way to attain the zero pollution and clean seas objectives.
It was reiterated that future consideration of this requirement would need to take into account the fee element and possible abuse of the scheme by port states.
Note that the discussion on this item was largely based on information that the European Commission and EMSA had been considering this type of policy as the basis for a change in the EU Directive on reception facilities.

15. RECEPTION FACILITIES Current work...
Updates on the INTERTANKO website:
List of facilities with alleged inadequacy reports against them in the IMO GISIS (with a clear link to GISIS for further details)
2. List of facilities that members have received positive experience – promoting the good ports/facilities
The Committee has agreed that it would be beneficial to begin listing on the members area of the INTERTANKO website those ports that had alleged inadequate facilities against them in the GISIS database. In balance with this, the Committee supports the establishment of a list of ports and terminals where facilities were deemed to be exceptionally good. This latter recommendation was given to promote those ports that had invested in good facilities and to act as a marketing incentive for those ports that had made the extra effort.

16. GARBAGE MANAGEMENT Current work... Best practice
Objective: Develop industry best practices for the management of garbage
Current work...
Best practice
Reviewed and supported the ISO Standard on waste handling, pending final revision, Committee will recommend use by INTERTANKO members
General guidance
MAPOL Annex V review and interpretations
Soot handling
Trace heavy metals
Regarding the ISO standard, Management and handling of ship board garbage, the Committee also urged the secretariat to ensure that the ISO did not establish a separate set of standards to that within MARPOL annex V. On the latter and as noted in ‘2’ above, the secretariat is requested to maintain its position within the IMO MARPOL Annex V correspondence group to ensure that the review and possible revision of MARPOL Annex V takes into account the need to reduce, reuse and recycle waste while also ensuring a degree or responsibility remains with the port side in term sof adequate facilities to receive segregated waste in readiness for recycling.
1. Soot handling
Some consideration was given to the categorisation of soot with the general consensus being that soot should be classified as ash even when in liquid form.
2. Trace heavy metals
It has been noted that the distinction between ash that contains trace heavy metals and that which does not is very difficult to make. As a consequence the Committee members suggested that this generally leads to two basic policies; 1) to land all ash ashore, and 2) to not burn plastics aboard.

17. SHIP RECYCLING
International Convention for the Safe and Environmentally Sound Recycling of Ships adopted in May 2009 to regulate:
- Design, construction, operation and preparation of ships for environmentally sound recycling
- Operation of recycling facilities in safe, environmentally sound manner
- Appropriate enforcement of both through certification and reporting

18. SHIP RECYCLING MAJOR ELEMENTS OF TREATY (SHIP)
Control of ship’s hazardous material (prohibit or restrict its use)
Ship inventory of hazardous materials
Ship recycling plan
Preparation for ship recycling
Ship survey and certification
Reporting (Notify of intent)

19. SHIP RECYCLING MAJOR ELEMENTS (FACILITY)
Standards for facility design/operations
Document of authorization
Recycling Management Plan
Safe and environmentally sound operational procedures
Emergency preparedness/response plan
Worker safety and training
Reporting (Intent and upon completion)

20. SHIP RECYCLING ENTRY INTO FORCE CONDITIONS 15 countries
Representing 40% of the world’s gross tonnage;
AND
Combined maximum annual recycling volume during the preceding 10 years constitutes not less than 3% of the gross tonnage of these countries

21. SHIP RECYCLING Complicating Factor
Australia proposed to include provisions in treaty that allows ships to be recycled in non-party states (free trade issue)
Conference rejects proposal because it could encourage recycling states not to ratify treaty
Problem is that flag states may not ratify treaty until major recycling states do so

22. SHIP RECYCLING The key issues for ship operator...
Convention is unlikely to enter into force until 2013 at the earliest, but...
Pressure on shipping industry to move towards compliance in the transitional period
Interest from INTERTANKO members to recycle in compliance with the Hong Kong Convention
Recommendation to recycle ships in accordance with the Hong Kong Convention, where possible
Industry Working Group – “Transitional Measures – for Shipowners Selling their Ships for Recycling”

23. SHIP RECYCLING Current work...
Objective: Promote the use of ship recycling facilities which have proven health, safety and environmental protection standards
Objective: Urge recycling states to adopt the standards specified in the Hong Kong Convention and eventual ratification for early entry onto force of the legislation
Current work...
Noted that there was limited scrapping within INTERTANKO membership, however, desire to gather information on ‘better’ facilities
Clearinghouse on recycling facilities striving to meet the HK Convention standards, based on information from ship owners
Watching brief over action in Europe
European Commission continue to consider how to enforce legislation in relation to ship recycling

24. GREENHOUSE GAS EMISSIONS
March 2010 IMO agreed on
Mandatory (MARPOL Annex VI) Energy Efficiency Design Index (EEDI) for new ships
Guidelines for voluntary use of the ship Energy Efficiency Operations Indicator (EEOI)
Guidelines for Ship Energy Efficiency Management Plan (SEEMP) and inclusion in MARPOL Annex VI
Expert Group to assess impacts on shipping and trade of Market Based Instruments (MBIs)
Proposals: Cap and Trade / Compensation scheme / Hybrid
Note: Most propsals based on EEDI as benchmark

25. GREENHOUSE GAS EMISSIONS
Ship Energy Efficiency Management Plan
Developed as a ship-specific plan by the ship owner
Part 1 – What the Plan should look like in four parts
Planning: Package of measures identified & Goal setting
Implementation: Implementation system
Monitoring: Monitoring system (tools and record keeping)
Self-evaluation & Improvement: Voluntary reporting
Part 2 – List of possible options for improving energy efficiency (use of INTERTANKO’s Guide)

26. GREENHOUSE GAS EMISSIONS
INTERTANKO’s Guide for a Tanker Efficiency and Emission Management Plan
Introduction *
Establishing the Company and Ship Management Plans
Voyage Optimisation Programme
Propulsion Resistance Management Programme
Machinery Optimisation Programme
Cargo Handling Optimisation
Energy Conservation Awareness Plan
* Also introduces elements associated with the over-lap between SEEMP and OCIMF TMSA Fuel Management Appendix

27. GREENHOUSE GAS EMISSIONS
Objective: Share information on operational, technical and educational options for reducing GHGs from tankers
Current work...
Assessment of the implementation of the IMO SEEMP
Gather feedback on implementation and consider providing guidance for a harmonized approach by INTERTANKO members and an update of the TEEMP.
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28. a different route for organisms other than ballast water
ANTI-FOULING
Anti-fouling Systems
Entry into force of the AFS Convention
INTERTANKO Environmental Committee
Move towards biocide-free systems
Comparison of silicon systems
Antifouling Problem = Chemical
Biofouling Problem = Biological
Invasive species
a different route for organisms other than ballast water

29. ANTI-FOULING
October 2001 – IMO Conference adopts International Convention on the Control of Harmful Anti-fouling Systems on Ships
September 2007 – With Panama ratification of treaty, entry into force conditions are met
September 17, 2008 – Anti-Fouling Treaty entered into force for all parties

30. ANTI-FOULING
Current ratifications – 40 countries representing 67.83% of world’s gross tonnage
Countries party to Anti-Fouling Treaty
Latin American region – Mexico
Open registries – Bahamas, Liberia, Marshall Islands, Panama
Others – Australia, Japan, most all European countries, South Africa

31. ANTI-FOULING Treaty Requirements
By January 1, 2003 no ship shall apply or re-apply organotin compounds which act as biocides in anti-fouling systems
By January 1, 2008, ships shall either:
1. not bear such compounds on their hulls or external parts or surfaces; or
2. bear a coating that forms a barrier to such compounds leaching from the underlying non-compliant anti-fouling systems
Ships shall carry:
1. an International Anti-Fouling System Certificate
2. a Declaration on Anti-Fouling Systems

32. ANTI-FOULING
MEPC 57 issue – should the treaty requirement dates (Jan 1, 2003 and Jan 1, 2008) be deemed to take effect on entry into force date (Sept 17, 2008) OR should there be retroactive application??
DECISION –
1. No consensus on the date on which these requirements should be applied;
2. Agreement to let each party apply provisions in accordance with its national law; and
3. Invite each party to inform IMO of its decision on implementation and enforcement of provisions
NOTE: EC states that under European regulation, no ship may enter a European port with a tin-based anti-fouling system after January 1, US???

33. BIOFOULING Biofouling Biofouling – going forward
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
Hull resistance management
Air emissions benefits
Invasive species benefits
Biofouling – going forward
IMO Guidelines
National hull management requirements – USA & Australia
Ban on hull management/cleaning !

34. BIOFOULING Current work...
Objective: Develop practical and uniform international guidelines and best practice on the management of ships’ biofouling for the prevention of invasive species
Current work...
IMO Guidelines Assessment, Review and Commentary
Providing input on current IMO Guidelines due to be completed in 2011
Guidelines to regulations... ???
Maintain principle that ports MUST allow hull management operations in their waters
Regarding the second bullet point and ensuring ports allow operators to conduct hull management in their waters, the argument has focused on the need to more frequently manage micro-fouling (slime) which has limited (if any) invasive species threat. This argument has been carried through into our comments on the IMO Guidelines which we aim to ensure a distinction is made between micro and macro fouling.

35. Reporting items Ship strikes with cetaceans International Issue
IMO’s Guidance to States - routing measures and speed restrictions, but initiated/regulated through IMO
Regional Laws
USA – speed restrictions and speeding fines!
Environmental Committee: Watching brief

36. Reporting items Marine noise pollution
Adverse anthropogenic marine/ocean noise impacts on cetaceans and other biota
or...
Noise pollution and its effect on marine mammals
Technical Guidelines for ship-quieting technologies plus potential navigational and operational practices
Environmental Committee: Full review of the IMO work on this issue to be delivered and considered by the Committee at its next meeting
The first two bullet points I use as a joke to explain the divergence in views of the scientists at IMO and those representing the shipping industry. When this issue was first tabled it was proposed to be titled ‘Adverse anthropogenic...’, but no one knew what that meant so it was simplified to ‘Noise pollution...’.

37. Reporting items Environmental organisations
WWF International – conducting a review on the effectiveness of class green notations. The Committee has agreed to peer review this work
World Ocean Council – general support for the principle established by the WOC

38. MUCHAS
GRACIAS!!