Sie sind auf Seite 1von 133





MARPOL Annex VI-Regulations for the Prevention of Air Pollution The 1999 EC Directive on Fuel Sulphur and amendments. Refrigerants and fire fighting agents current EU and MARPOL legislation. Antifouling paint certification and future regulations. The International Convention for the Control Management of Ships Ballast Water and Sediments. Recycling of Ships, the IMO Guidelines and the Green Passport scheme. Environmental Protection Notation.


January 2005


ANANGEL/KRISTEN/MARAN GAS Training Dept. has been certified by DNV under the provisions of DNV Rules for Maritime Training Centers with a certificate No: 113443.

Marine Environmental Protection Legislation

Control of air pollution ISO 14001 Anti-fouling systems Ballast water management Ship recycling and IMO guidelines Environmental protection notation

Control Of Marine Pollution MARPOL

Annex I Prevention of pollution by oil Annex II Control of pollution by noxious liquid substances Annex III Prevention of pollution by substances in packaged form Annex IV Prevention of pollution by sewage Annex V Prevention of pollution by garbage Annex VI Prevention of air pollution from ships

MARPOL Annex VI Prevention of Air Pollution From Ships

Entered into force on 19 May 2005 Which ships does it apply to? What does it cover? How do you comply? Future developments

MARPOL Annex VI & EC Fuel Sulphur Directive

Aim of Annex VI-MARPOL 73/78 Annex VI-Brief Historical Overview Annex VI-Regulation 13-NOx Annex VI-Regulation 14-SOx Annex VI-Regulation 18 Fuel Quality & Sampling/Bunkering Requirements European Council Directive 1999/32/EC Low Sulphur-Technical Implications Liner Lacquering Alternatives Conclusions

Aim of Annex VI-MARPOL 73/78

To deliver a significant reduction in ship (harmful)

emissions contribution to acidification and consequently improve air quality.

Annex VI- Brief Historical Overview

Between 1972-1977 studies confirmed the hypothesis that air pollutants could travel thousand kilometers before deposition (&damage) occurred.

The 1972 UN Conference on the Human Environment in Stockholm initiated the beginning of active international cooperation in tackling acidification/acid rain. In 1979 the Convention on Long-range Trans-boundary air pollution was signed by 34 Governments and the EU. Protocols to the 1979 Convention were later signed on: Reducing Sulphur emission (1985) Controlling emissions of nitrogen oxides (1988) Controlling emissions on VOC (1991) Further reducing sulphur emissions (1994) The protocol of 1997 (the new Annex VI of MARPOL 73/78)

Annex VI-MARPOL 73/78 (1997)

Main Focus on the following points: Applicable to ships of 400gt and above. Nitrogen Oxides Reduction (NOx) Sulphur Oxides Reduction (SOx) Volatile Organic Compounds (VOCs) Chlorofluorocarbons (CFCs)

Pressure on Shipping Emissions

There is strong political pressure for Emissions Reductions

Health impacts becoming more important & easily measured. Contribution of Shipping to SOx emissions becoming a significant proportion of overall emissions Cost of Sea reductions is less than other options Annex VI is one step to the right direction, however will not resolve the issue of shipping emissions.

Environmental Impact
According to research conducted by IMO sulphur emission from ships exhaust is estimated at 4.5-6.5 Million tones/year=4% of total global sulphur emissions.

European Council Directive 1999/32/EC

In 1979 the Convention on Long-range Trans-boundary air pollution was signed by 34 Governments and the EU. In 1993 established Directive 93/12/EEC In 1999 amendment of directive 93/12/EEC and a new Directive 1999/32/EC established. Amended 1999/32/EC [com(2002)595] expected?

Existing EU Regulation 1999/32/EC

Initial directive 1999/32/EC applies only to distillate fuels (DMX,DMA,DMB,DMC grades). Specifies that ships in the European community area (territorial waters, including 12 nautical miles from shore and inland waterways) should use distillate fuels with sulphur content 0.20% m/m maximum. Distillate fuels with Sulphur content Lower than 0.1%m/m max.should be used by January 2008 onwards.

Amendments on 1999/32/EC[COM(2002)595)
Designed to be inline with Annex VI-MARPOL 73/78. Maximum 1.5% sulphur limit for fuels used by all ships in the Baltic Sea, North Sea & Channel. Todays political agreement incorporates this provision, and sets implementation dates starting in 19 May 2006 for the Baltic Sea. Maximum 1.5% sulphur limit for fuels used by passenger vessels on regular services between EU ports, from 1 July 2007. EU Ministers also rubber stamped this and brought the deadline forward to 19 May 2006. Maximum 0.2% sulphur limit on fuel used by inland vessels and by seagoing ships at berth in EU ports. The Council agreed a tighter 0.1% limit delayed until 1 January 2010, to allow single-fuel ships time to adapt their fuel tanks. A further two year delay was offered to 16 unifuel ferries serving the Greek islands.

Factors to Consider

Impact on the shipping industry (commercial).

Impact on the Bunker Industry (&what this implies??). Impact of the Expansion of EU member states. Availability of Low sulphur fuels. Impact on storage on the ship (for both Fuels & Lubricants) Technical impact, assessment of the impact on the Machinery plant.

MARPOL Annex VI-Application

All Ships 400 gross tonnage and above, fixed/floating drilling rigs & other platforms-subject to survey New ships-from 19 May 2005 Existing ships-no later than first dry dock & within 3 years (ie by 19 May 2008) Does not apply when: Securing safety of ship Saving life at sea Suffering damage to ship or equipment

MARPOL Annex VI-requirements

Ozone depleting substances (ODS) Nitrogen oxides (NOX) Sulphur oxides (SOX) Volatile Organic Compounds (VOC) Shipboard incineration Fuel oil quality

Ozone Depleting Substances

Prohibits new installations containing ozone depleting substances eg CFC refrigerant gases & halon fire fighting agents (except HCFC until 1 Jan 2020-but banned by other legislation!) Existing ships can retain halons & other ODS until replaced or required to be moved by international, national or other requirements. Prohibits deliberate emissions eg during maintenance, service or repair. Requires ODS removed to be delivered to reception facilities.

Volatile Organic Compounds (VOC)

Controls volatile emissions from tanker cargo tanks during loading/unloading. Requires Vapour Emissions Control System (VECS) compliant with MSC/Circ. 585 on Standards for VECS systems. Applicable in designated ports and terminals with appropriate systems only.

Shipboard incineration of waste

Applicable to incinerators installed on/after 1 January 2000. Requires compliance with IMO specification for shipboard incinerators MEPC 76 (40) Minimum flue gas temperatures Prohibits incineration of: MARPOL Annex I, II & III cargoes Polychlorinated biphenyls (PCB) Garbage containing heavy metals Refined petroleum products containing halogens

Engine NOx emission regulation Regulation 13

Covers all diesel engines with power output>130 Kw (except

emergency or lifeboat engines). Applies from 1 January 2000 delivered ships Variable NOx emission limits dependent upon engine speed. (From 17 gNO2/kWh to 9.8 gNO2/kWh depending on rated engine speed)

Engine NOx emission-certification

Test bed exhaust emission measurement and setting of parameters NOx Technical File (info on components, settings, operating values & allowable adjustments to maintain NOx emissions within acceptable limits) Engine International Air Pollution Prevention (EIAPP) Certificate/ Statement of compliance & approved NOx Technical File issued. New ships this done during sea trials Ships build since 2000 TF available - Statement of compliance converted to EIAPP certificate at first drydock or latest on 19/5/08

Engine NOx emission-onboard survey

On-board verification survey after installation as part of initial IAPP survey. Various methods: Engine parameter (MAN B&W SL03-428) Simplified measurement (Measure emissions onboard with suitable instruments for old engines) Direct measurement & monitoring (Continuous onboard monitoring) Annual, (intermediate) & renewal surveys as part of overall MARPOL Annex VI survey.

Parent Engine Parent engine Measure emissions & establish tolerances on performance data Establish NOx components Measure performance data (Pmax, Pcomp, Tscav, Turbo back pressure) on testbed and establish sensitivity of changes to these parameters to level of NOx emissions

Member Engine Do performance check to ensure all measurements are within the limits established on the Parent testbed results Check and ensure all NOx components are correct and marked as such No need to measure emissions

NOx Components
MAN B&W slow speed engines 11-12 standard engine components selected and marked with their IMO number (usually part no) Fuel nozzle (most influence and easier to check) Fuel pump plunger and barrel Cylinder liner, cylinder cover, piston crown Fuel cam and exhaust cam Scavenge air cooler Auxiliary Blower Turbocharger Governor (as applicable)

Examples of Nox components

Examples of Nox components

IMO NOX Technical file

Class approved document Changes need approval Specifies actual engine performance data Specifies IMO components relevant to NOx Includes instructions on how to check the engine (from manual) Keep Engine Record book of engine parameters for all changes E/R Log

NOx survey requirements

Any replacement of IMO components should be done by maker authorized parts properly marked. Record of maintenance/ replacement should be made (E/R log book). Sensors and gauges used to verify parameters of the engine must be reliable and calibrated. Tolerances of performance parameters to be kept after correction to ISO ambient conditions (Pmax, Pcomp, Tscav, Turbo back pressure)

Implications of NOx emissions

Substantial modifications need approval to ensure NOx emissions are not increased. Maker amendments need to be typeapproved (eg. Slide fuel valves) Reconditioning of IMO parts by authorized repair shops Maintenance as per makers manual

Annex VI-MARPOL 73/78 (1997) Fuel Quality - Regulation 18

Fuel quality to meet requirements in ISO 8217 International Marine fuel standard. The fuel shall be blends of hydrocarbons derived from petroleum refining. This shall not preclude small amounts of additives intended to improve performance. The fuel shall be free from inorganic acid. The fuel shall not include any added substance or chemical waste which either: jeopardizes ship safety or impacts engines harmful to personnel contributes to air pollution

Annex VI-MARPOL 73/78 (1997) Regulation 18 (cont)

Bunker receipts should include Vessels IMO number, name, port, bunkering date, quantity, grade, density and sulphur content.

A declaration that the fuel oil supplied is in conformity with regulation 14(1) or (4)(a) and 18(1) of Annex VI should be signed by the fuel supplier. The bunker delivery note should be accompanied by a representative fuel oil sample of the fuel delivered to the ship. Guidelines as to how a representative drip sample is obtained are defined in MEPC 96(47). Both the vessel and the fuel oil supplier should retain the bunker receipts for a period of three years after the fuel oil has been delivered to the vessel.

Annex VI-MARPOL 73/78 (1997) Regulation 18 (cont.)

Bunker delivery notes should be available for inspection at any time.

Samples should be retained on board ship for at least 12 months since the day/time of delivery. When operated in SECA zone ships should allow sufficient time prior to change over to low sulphur (<or=1.5%m/m) fuels. The volume of low sulphur fuel in the tank as well as the date, time and position of the ship when any fuel change operation is completed should be recorded in a log book.

Annex VI-MARPOL 73/78 (1997) SOx Regulation 14

Annex VI (SOx) will be enforced on 19/05/2005 Applicable to all fuel oil on board ships 4.5% M/M (Max) Sulphur Global Cap

1.5% M/M (Max) Sulphur @ SOx Emissions Control Areas (Known as SECA zone) SECA zone includes (Baltic Sea, North Sea & English Channel) Currently the only SECA Zone is Baltic Sea Baltic Sea-12 months grace period after Annex VI enforcement (19/06/2006)

Alternatively ships must fit an Exhaust Gas cleaning system (which can restrict sulphur emissions to 6.0 g/KWh)

Low Sulphur-Technical Implications

Specifically for Uni-fuel HFO ships designed for one fuel type.

Difficult to maintain seal integrity (H.P. Fuel oil P.P) Very low sulphur-Lubricity vulnerable. compounds reduced-Fuel pumps/injectors

Steam plants-Difficulty to adopt to high load boiler operational requirements when operate boilers on Gas Oil (i.e. Discharging conditions) Cylinder Oil Base Number (BN)-to Sulphur content. Implications on change procedures Liner Lacquering-Increased cylinder deposits-bore polishing-loss of oil control.

Effects of Lacquering
Lacquering and polishing may result to increased cylinder lubricating oil consumption.

Higher operational cost. Lubrication may be ineffective resulting to high temperatures and damage of piston rings, liners etc. he problems are more apparent to modern engines operating at high pressures (especially modern medium speed engines with high BMEP (Brake Mean Effective Pressure) Lacquering is more favorable when the engine is operated above MCR (Maximum Continuous Rating) for extended periods with the duty cycle changing from high to low loads.

Alternatives for SOx reduction

Sea Water Exhaust Gas Scrubbers.

HFO Blending. Increase Import volumes of Low sulphur crude oil. (Brazil, South America etc). Desulphurisation through the refining process. Fuel Oil/Gas oil tank segregation on board ships. Use low sulphur fuel (e.g. 1.5% M/M max. limit) worldwide. Emission Credit Exchange System.

Alternatives-Sea Water Exhaust Gas Scrubbers

Sea Water Scrubbers Effectively reduce SOx of Exhaust Gases. Pilot program between P&O cruises and BP. Systems Efficiency at the moment is around 90% Capital Investment is required as well as viability study for existing/old ships. More consideration on Sea water pollution & monitoring should be given. Complexity of the system. Operation and maintenance (due to corrosive nature of both sea water & Exhaust Gases) Exhaust Gas monitoring/Recording system should be in place. Class/Port authorities inspection will be required. Economic evaluation is required.

Sea Water Scrubber System Efficiency

Efficient gas/water mixing in a compact space.

Cleaning of scrubbing water before discharge Further reductions of NOx & Particulates

SOx 90% NOx 15% Particulates 80%



Blending requires specific consideration and calculations.

The fuels blended should be compatible. Can easily result to incompatibility and consequently operational problems on board. May encourage in-line blending during delivery (depending on suppliers policy). Poses increased risk with respect to compatibility and homogeneity compared to non blended fuels. Fuel & Cylinder Lubricating oil segregation.

Increase Import volumes of Low sulphur crude oil

Increase Import volumes of Low sulphur crude oil may have the following Implications: May affect availability. Increased cost-May Have a spiral effect on the bunker pricing consequently affecting ship owners/operators. Increased number of ships entering EU waters. Highly dependent on OPECs Production Plan. Limitations with regards to local legislation. (highly dependant on the geographical area) i.e. Brazil-Petrobras Fuel & Cylinder Lubricating oil segregation. It is likely to have a spiral effect on the F.O price

Desulphurisation through the refining process

Quality Assurance requirement.

Time consuming Process. Fuel & Cylinder Lubricating oil segregation. Estimated additional cost will be around 40 $ to 60 USD/MT Increased cost will be due to high cost of Hydro treatment and the high capital cost requirements for hydrogen gas. Increased cost. It is estimated that fuel oil desulphurisation will cost the industry approximately 1 billion $ USD. Who is finally covering the additional cost?

Fuel Oil/Gas oil tank segregation

Consideration at the design stage (concept stage). Position of the tanks. Increased risk since crew will have to manage possibly 4 different grades of fuels and 2 different grades of Cylinder Lubricating Oil on board. Less Engine room/Cargo Space. Increased system complexity.

Use low sulphur fuel (1.5 %) worldwide

Will affect availability. Increased cost. Highly dependent on OPECs Production Plan. Consideration of Technical issues required.

Emission Credit Exchange System

The scope of the trading system: To create the same or greater emissions reduction than the one proposed in EU policies and regulations by including shipping within EU and transit traffic. To create the reductions of the lowest economic cost for all parties involved, directly or indirectly. To create financial incentives for the shipping sector to reduce SOx emissions. Possible in theory but difficult in application. Needs a lot of investment and effort Will need an operational base accepted by everybody. Requires good co-operation between Port State Controls (and ship owners) to monitor the trading routes of ships.

Both Annex VI-MARPOL 73/78 and the amended 1999/32/EC will have a huge impact on the fuel quality delivered to ships. Fuel suppliers will be forced to supply a better quality fuel. Storage requirements for both fuel oil and cylinder lubricating oil will be affected. Fuel oil cost is likely to increase (Desulphurisation at an extra US$ 40 US$ 60/MT). Additional requirements for both ships crew and shore based personnel. Independent Testing Services may be required for quality assurance.

MARPOL Annex VI-compliance summary

New ships (from 19 May 2005) Non-ozone depleting refrigerant gases & fire fighting agents; include operational requirements to prevent emissions during maintenance etc and disposal requirements in company procedures. Incinerator certificate or statement of compliance with IMO/MEPC 76(40) design requirements (if fitted); incorporate operational requirements in company procedures. Vapour Emissions Control System certificate or statement of compliance with MSC/Circ.585 (if fitted). Engine International Air Pollution Prevention (EIAPP) certificate or statement of compliance with NOx emissions limits in Annex VI & NOx Technical File-applicable diesel engines. Formulate strategy for compliance with SOx emissions requirements. Specify design requirements consistent with strategy. Specify fuel quality requirements in operational procedures for SOx emissions control & maintenance of fuel quality.

MARPOL Annex VI-compliance summary

Existing ships (first dry dock & latest 19 May 2008) Continued use of ozone depleting refrigerant gases & fire fighting agents not prohibited, but check other international and national legislation. Include operational requirements to prevent emissions during maintenance etc and disposal requirements in company procedures. Incinerator certificate or statement of compliance with IMO/MEPC 76(40) design requirements for incinerators installed on/after 01/01/2000; Incorporate operational requirements in company procedures.(Usually exists). Vapour Emissions Control Systems certificate or statement of compliance with MSC/Circ.585 (if fitted). Individual ports/terminals may waive requirement for up to 3 years. (Usually exists in our fleet). NOx emissions requirements not applicable to engines built or installed pre 01/01/2000. Relevant engines built or installed as from 01/01/2000 need statement of compliance or EIAPP certificate & NOx Technical File (difficult retrospectively). (Most of our ships already have this file). Formulate strategy for compliance with SOx emissions requirements. Implement design modifications consistent with strategy. Specify fuel quality requirements in operational procedures for SOx emissions control & maintenance of fuel quality.

MARPOL Annex VI-certification

All ships>400gross tones, fixed & floating drilling rigs & other platforms require survey & International Air Pollution Prevention (IAPP) certificate. Flag administration may establish alternative requirements for ships<400 gross tones. IAPP valid 5 years from initial survey Annual, (intermediate) & renewal surveys

MARPOL Annex VI-surveys

Initial survey onboard

New ships- ensure Builders working drawings consistent with approved plans. Existing ships-determine applicable requirements. Ensure equipment, system, fittings, arrangements & materials fully comply (with applicable requirements) Survey checklist completed & IAPP Certificate or Certificate of Compliance issued.

MARPOL Annex VI-surveys

Annual survey Verify certificate in order Examine & test selected equipment-establish adequate condition &standard of maintenance Endorse IAPP certificate Renewal survey Ensure equipment, system, fittings, arrangements and materials fully comply with requirements New IAPP certificate issued. Valid 5 years Intermediate survey?

Control air pollution-future developments

MARPOL Annex VI More SECAs? Decreased fuel Sulphur limit globally & in SECAs? Lower engine NOx limits. Additional emission components-particulates? Greenhouse gas (GHG) emissions

Main focus CO2 - directly linked to fuel consumption, international shipping emissions excluded from international agreements. CO2 emissions/tones/mile Ten years time frame

Control air pollution-future developments

European Community Fuel sulphur directive and amendments

No additional measures at present for NOx-but if no definite measures for further NOx reduction at IMO, EC likely to act. Push to include international shipping in CO2 emissions trading from 2012. VOC emissions considered relatively low than other sources & currently no proposals to regulate.


Refrigerants & Fire Fighting Agents

Refrigerants overview Legislation Why? Terminology and definitions. Refrigerants Family Tree. Refrigerants where used in marine applications Legislatory bodies IMO, Flag Sates, Montreal Protocol and European Union. What should we do? existing and new tonnage.


Atmospheric Life/Ozone Depletion Potential (ODP):

This is the time taken before the released refrigerant decomposes down to its constituent elements. Natural compounds with short atmospheric lifetimes will degrade near their point of release, such as hydrocarbons and ammonia. With CFCs and HCFCs it is only once they reach the stratosphere and the chlorine content is subject to the suns high energy ultraviolet radiation will they start to decompose. This process can last many if not hundreds of years.

Global Warming Potential (GWP)

This is another relative figure and is the term given to the upward climatic change attributed to CO2, methane, nitrous oxide, CFCs etc. being released into the atmosphere and absorbing infrared radiation which would otherwise escape into space.

The figures are based on the total calculated global warming due to the emission of a kilogram of the refrigerant divided by the total calculated global warming due to the emission of a kilogram of CFC R11.

Montreal Protocol Ozone depletion

Montreal Protocol initiated 16 September 1987

Ozone Depletion

Kyoto Protocol Global warming

Kyoto Agreement adopted 09 May 1992

Not yet fully ratified stalled by United States. Russia has decided to ratify the protocol by this year

Refrigerants Family Tree

CFC Chlorofluorocarbon Production Ban 1996 Article 5 countries 2010 HCFC Hydrochlorofluorocarbon Traditional Substance Banned in new plant HFC Hydrofluorocarbon Ozone Friendly Under Question Environmentally inert Natural Substances

R11 ODP =1.0 GWP = 4000

R22 ODP = 0.055 GWP = 1700

R410A ODP = 0 GWP = 1890 (High Pressure)

Ammonia ODP = 0 GWP = <1

R12 ODP = 10 GWP = 8500

R141b (Foam blow) ODP = 0.11 GWP = 630

R404A ODP = 0 GWP = 3748 (High GWP)

Carbon Dioxide ODP = 0 GWP = 1.0

R115 (R502) ODP = 0.283 GWP = 5591

R507 ODP = 0 GWP = 3800 (High GWP)

Propane/ Isobutane ODP = 0 GWP = 3.0

R407C ODP = 0 GWP = 1610 Flammability?

Current Montreal Protocol covers all ozone depleting substances and their production phase out. Regulation (EC) No.2037/2000 covers ozone depleting substances their use and also emission control (recovery) within EU. EN 378 Refrigeration systems and heat pumps Safety and environmental requirements. Flag State requirements such as Cyprus totally prohibiting the use of ozone depleting substances, such as HCFC R22, on existing ships as from 2008


IMO MARPOL Annex VI, Annex VI has been ratified and came into force on 19 May 2005

Regulation 12 specifically targets ozone depleting substances, their deliberate emissions and removal from the ship. Flag State requirements

Proposed Legislation

Kyoto Protocol covers global warming potential from a basket of greenhouse gases. European Climate Change Programme covers emissions and use restrictions of Fluorinated gases, CFCs, HCFCs and HFCs (F-gas Regs)

IMO MEPC 46/INF.29 Prevention of Air Pollution from Ships Recommendations submitted by Friends of the Earth International. Release of hydrocarbons (VOCs) to the atmosphere.


Definition of Use as per regulation (EC) 2037/2000:

The charging, topping up and removal of refrigerant from the system or equipment. What is not construed as Use: The circulation of the refrigerant within the system is not considered as use Thus the continued use of CFCs and HCFCs refrigerants in existing systems after their final ban date will not, as of today, be legislated against.

Existing ships Continue to use HCFC R-22 The use of HCFC R-22 in existing systems will continue to be allowed. Virgin R-22 will continue to be available up to 2010. Recycled R-22 will be available up to 2015. HFCs are, as of today, not legislated against- their use should be restricted when possible.

New construction


Unfortunately HFCs, which were original introduced as substitutes for ozone depleting CFCs are extremely powerful greenhouse gases, with a global warming potential many thousand times larger than carbon dioxide. Natural substances Natural substances can not be legislated against Ammonia, apart from being toxic, would be the refrigerant of choice in the majority of industrial applications. Carbon dioxide and hydrocarbons are both good refrigerants.

CFCs are history no refrigerants allowed to be sold, supplied or used.

HCFCs are banned from being supplied in new refrigeration equipment. Still allowed to be used fore servicing existing equipment until 2010, this date will be reviewed not later than 2008. HFCs still promoted as best alternatives when a natural substance can not be readily used. Natural substances carbon dioxide, ammonia, propane and cyclopentane, Free of legislation but possible safety considerations, toxicity, flammability. Alternative technologies.

Halons and Halon replacements overview

Halon family of gases.

Replacements for Halons marine applications. Legislation. Decommissioning requirements. IMO, Flag State, Montreal Protocol and European Union involvement.

Halon 1211 (BFC) used in portable extinguishers & aircraft. Halon 1301 (BTM) used in bulk or flooded marine systems and petrochemical applications. Halons 2402 1011 part of the same Halon group used for feedstock and for fire control. Critical use exception by (EC) regulation 2037 IMO MSC 77/11/1 and especially Flag State involvement regarding continued critical use.

Replacements/Alternatives for Halon 1301

Traditional Detection and manual intervention Water sprinkler systems water mist high fog system Carbon dioxide, dry powder and foam

Man-made gaseous agents Inert gases nitrogen, argon, carbon dioxide or mixtures Halocarbon gases Inert gas generation aircraft only at present Fine solid particle technology Still to be refined

Replacements for Halocarbon gases

Both HFC and PFC gases had been developed FE13 FE-125 FM-200 FE-36 CEA-308 CEA-410 HFC 23 HFC 125 HFC 227ea HFC 236fa PFC-2-1-8 PFC-3-1-10 Triflouromethane Pentafluoromethane Heptafluoropropane Hexafluoropropane Perfluoropropane Perfluorobutane

Subsequently PFC gases have now been banned by IMO/SOLAS Chapter II-2, Reg. 10, 4.1.3. New alternatives such as Fluorinated Ketone are being developed and marketed under various Trade Names such as NOVEC 1230.

Legislation effects
The HFC alternatives have high global warming potential, from 2,900 to a staggering 11,700.

The Kyoto Protocol will affect gases which have a high GWP. Within the EC the proposed F-gas regulations may require any emissions from the whole family of halocarbon gases to be strictly regulated. Some Flag State have individually restricted the continued use of Halon and they may also has some involvement with the Halon replacements.

Halon is still available on a worldwide basis to allow the continued safe operation of cargo ships.

IMO FP/Circ.27 Halon banking and reception facilities lists the sites and limitations when Halon will be provided. The decommissioning date for EC Flag State countries was 31 December 2003. However recycled Halon is still available in a number of Member States for critical use systems.

Regulation and Certification

Anti Fouling Coatings, Regulation and Certification

Background Antifouling coatings Restriction of the use of antifoulants

IMO AFS Convention and EU Regulation IMO Convention Current status of the Convention EC Regulation on antifouling systems. Survey, certification and inspection IMO Guidelines Survey, certification and inspection

Anti-fouling coatings
Antifouling paints are applied to the underwater parts of ships or structures to keep the surfaces free of fouling in order to keep surfaces smooth and, consequently, reduce fuel consumption and increase speed.


International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention) was adopted by an IMO Diplomatic Conference, held in London in October 2001.

AFS Convention Entry Into Force

Entry into force 12 months after 25 countries with not less than 25% of the worlds GT to ratify the convention. To date there are 8 countries with 9.36% of the worlds GT

AFS Convention
The Convention: Bans application of antifouling coatings containing organotin compounds from being applied as biocides from 1 January 2003, and the active presence of organotin compounds on ships hull surfaces from 1 January 2008.

EC AFS Regulation (EC 782/2003)

Same requirements as the AFS convention. Effective from 1 July 2003 for new ships and from 1 July 2008 for existing ships. Vessels changing to an EU flag must remove or seal TBT coating if the TBT coating was/is applied after 1/7/2003

Surveys and Certification

Surveys and certification are required for: Ships of 400 gt and above on international voyages. Does apply to fixed and floating platforms, FSUs and FPSOs

MEPC Resolution 102(48): Guidelines for survey and certification of anti-fouling systems on ships adopted on 11 October 2002. MEPC Resolution 104(49): Guidelines for brief sampling of anti-fouling systems on ships adopted on 18 July 2003 MEPC Resolution 105(49): Guidelines for inspection of anti-fouling systems on ships adopted on 18 July 2003.

Document review
Ships details Details of antifouling paints and coating specification (including sealer coat) Previous antifouling coat if not removed.

On-site inspection to verify compliance of the paint including. Product identification and application witness If necessary, sampling and testing of antifouling paints or coatings.


Record of Antifouling System/Statement of Compliance.

EU antifouling certificates. IMO antifouling certificates to be issued after the Convention comes into force. Certificates remain valid until AFS changed.

Inspection by Port State Control

1. Initial inspection Document checking AFS certificate/Declaration of AFS Record of AFS Brief sampling

2. More thorough inspection on documents and AFS if there is any doubt.


Ballast Water Management

Why manage ballast water and sediments and why have a convention? The new Convention Ballast water management plans

What is the problem?

Every 9 weeks a new species is introduced somewhere in the world Every day, 7000+species of plants and animals are transported in ballast. Every year the worlds fleet moves 3-5 billion tones of ballast around the world.

Why manage ballast water? Why have a ballast water convention?

The introduction of unwanted aquatic organisms via ships ballast water is an internationally recognized problem.

This introduction can have an effect on human health, cause damage to local marine life and local economies. The effects cost millions of dollars to deal with each year. The effects of unwanted organisms has been known for a considerable time. The United Nations Conference on Environment and Development (UNCED) in 1992, in Agenda 21 called on the IMO to take action to address the transfer of harmful organisms by ships. The IMO have been discussing the issues involved and working towards a convention for more than 10 years.

The Convention When will the Convention enter into force?

The convention will enter into force 12 months after at least 30 States, the combined merchant fleets of which constitute at least 30% of the gross tonnage of the worlds merchant shipping.

Which ships does the convention apply to?

The Convention will apply to all ships including submersibles, floating craft, floating platforms, FSUs and FPSOs The convention will not apply to: Ships not designed to carry ballast water Warship, naval auxiliary or other ship owned or operated by a State, only on non-commercial service Permanent ballast water in sealed tanks.

What does the convention require?

All ships will be required to: Carry out ballast water and sediment management on all voyages. Have on board an approved ballast water management plan and a ballast water record book. Ships of 400 gt and above are subject to surveys and certification.

Ballast water managements options

All ships will be required to: Carry out Ballast Water Exchange (BWE) to the standard required by the convention (sequential or flow through method) or

Use an approved ballast water treatment system that meets the standards of the convention.

Ballast water exchange standards

BWE to result to at least 95% volumetric exchange of Ballast Water or Pumping through three times the volume of each Ballast Water tank is considered to meet the standard described above. (Pumping through less than three times the volume may be accepted, provided the ship can demonstrate that at least 95% volumetric exchange is met.)

Treatment Systems standards

Discharge less than 10 viable organisms per cubic metre greater than or equal to 50 micrometers in minimum dimension and less than 10 viable organisms per mililitre less than 50 micrometers in minimum dimension and greater than or equal to 10 micrometers in minimum dimension. And discharge of the indicator microbes shall not exceed the specified concentrations. Indicator microbes, as a human health standard, shall include: Toxicogenic Vibrio cholerae (01 and 0139) with less than 1 colony forming unit (cfu) per 100 mililitres or less than 1 gram (wet weight) zooplankton samples;

b. Escherichia coli less than 250 cfu per 100 mililitres; c. Intestinal Enterococci less than 100 cfu per 100 mililitres.

Where can ballast water exchange be carried out?

At least 200 nm from the nearest land and in water at least 200 m in depth; if this is not possible. As far from the nearest land as possible, and in all cases at least 50 nm from the nearest land and in water at least 200 m in depth. Countries may designate areas where ballast water exchange may be undertaken inside these limits.

A ship is not required to deviate from its intended voyage, or delay the voyage to comply. The master may decide not to carry out exchange: If it would threaten the safety of the ship crew or passengers; Because of adverse weather, ship design or stress, equipment failure; Any other extraordinary condition. If not undertaken the reasons to be entered in the Ballast Water record book.

What to do and when Vessels constructed before 2009:

Ballast water capacity 1,500m3 to 5,500m3, Exchange or Treatment until 2014;Treatment after 2014 Ballast water capacity less than 1,500m3 or more than 5,000m3, Exchange or Treatment until 2016;Treatment after 2016. Vessels to comply by the first intermediate or renewal survey, which ever comes first, after the anniversary date of delivery.

Vessels constructed in or after 2009 Ballast water capacity less than 5,000m3; Treatment

Vessels constructed between 2009 and 2012: Ballast water capacity more than 5,000m3; Exchange until 2016; Treatment after 2016

Vessels constructed in or after 2012; Ballast water capacity more than 5,000m3; Treatment

Do I have to do anything now?

For compliance with the Convention NO (except to plan ahead) For compliance with national regulations YES For example Australia, New Zealand, Israel (Red Sea), Canada, Chile, US (federal and individual state).

Ballast water management practices

Take precautions when ballasting Exchange Ballast Treat Ballast Control sediment built up Retain ballast on board. Discharge to shore reception facilities.

Precautions when ballasting

Minimizing the uptake of organisms by avoiding: Areas where organisms occur Algae blooms Shallow or sediment laden water Ballasting in darkness Avoiding unnecessary ballasting

Control Sediments

Wash tanks regularly Remove sediments regularly Prevent sediment build up

Ballast Exchange Three IMO recognized methods

Sequential method Flow through method Dilution method

Water Ballast Exchange Safety Issues

Sloshing loads Bending moments Sheer forces Stability margins Weather Window Torsional stresses Tank venting Draft Propeller immersion Crew safety

Design Considerations
Light and heavy ballast conditions Departure and arrival conditions Propeller immersion Pumping capability Intact stability Bridge visibility Tank design Longitudinal strength Forward draught Dynamic Loads Ballast Sampling Arrangements

Ballast Treatment Systems


Ballast Water Treatment

Must be safe (For ship and crew) Must be environmentally acceptable Must be cost-effective Must work Must be approved

Approval Requirements
Treatment systems will be required to be approved in accordance with IMO agreed guidelines. The approval guidelines will be adopted in July 2005.

Ballast Water Treatment

There are advantages and disadvantages to each type treatment method.

Current research seems to indicate that a combination of two or perhaps more methods may be the solution.
APPROXIMATE OPERATING COSTS Per tonne of ballast (US cents)

Sequential Exchange = 1 Flow through = 2 Heat = 2.5 Filter = 0.5 Cyclone = 0.3 UV = 0.04

Ballast Water Management Plans

A Ballast water Management Plan is to:

Assist in the ship in complying with international regulations to minimize the risk of the transfer of harmful aquatic organisms and pathogens in ships ballast water and associated sediments. Consider ship safety elements. Provide information to PSC/quarantine officers on the ships ballast handling system and to confirm that ballast management can be effectively planned. Include training on BWM operational practices.


An early decision should be made on what BWM method(s) are to be used for new buildings. Ship design should take into account BWM A BWM plan should be produced for ballast exchange operations to safeguard the ship


History of environmentalist involvement

1995 Dumping of Brent Spar Greenpeace turn attention to ships. Identify attention to ships. Identify & use Basle Convention to prevent export of ships for scrap (toxic waste) 1999 P&O Nedlloyd targeted by Greenpeace for exporting 19 ships to China for scrap. Friends of the Earth stop the US ghost ships being dismantled at Able UK.

Traditional ship scrapping techniques

Scuttling or abandonment. Primitive conditions. Little regard health & safety of workers Massive environmental pollution Low cost

Recent history
Industry initiated development of guidelines for inventory of hazardous materials onboard ships.

Fed into IMO discussions and resulting IMO Guidelines on Ship Recycling adopted Dec 2003. The International Labour Organization (ILO) also developed Guidelines which apply to the safety & health of workers in recycling facilities May 2003. The Basel Convention has published, Technical Guidelines for the Environmentally Sound Management of the Full or Partial Dismantling of Ships December 2002. Difficulties of disposing of unwanted tonnage, exacerbated by EU regulations for accelerated phasing out single hull tankers.

IMO guidelines on Ship Recycling A.962(23)

To give best practice, adopted 05 December 2003. Voluntary guidelines at present. Implications throughout ship lifecycle existing ships & new builds. Preparation of ship for recycling ship recycling plan.

Scope of IMO Guidelines

Ship design Minimise use of hazardous materials Design for recycling

Through life inventory of potentially hazardous materials Green Passport provided by shipyard. Hazardous materials in ships structure and equipment Operationally generated wastes Stores Preparation for scrapping Selection of recycling facilities Preparation for recycling plan Minimise all residual oils and chemicals onboard

Major elements for owners newbuildings

Pre-newbuilding; contract review

Design out hazards minimize the use of potential hazardous materials Finalized prior to final voyage. Newbuilding Audit yard and sub contractor supply Compile inventory and produce Green Passport Promote waste reduction and/or regeneration

Major elements for owners existing ships

Green passport concept It should contain ship details and an inventory of the potential hazardous materials by type, location and quantity Finalized prior to final voyage Disposal Preparation for scrapping Selection of suitable licensed facility shipowner Owners allowed to deliver ship with hazardous materials provided the facility selected for recycling can deal with them.

Benefits of a Green Passport

Provides a structured system to properly control hazardous materials at newbuild and through life. Allows certification and reporting ability thus managing for hazardous materials. By identification of hazards it provides associated safety benefits to those onboard. Invaluable tool to assess hazard management and hazard management and hazard liability. Enhanced protection for environment.

Shipowners actions
Newbuilding program Specify Green Passport for all newbuild contracts Reduce or exclude hazardous materials in contract Audit during construction Existing fleet Compile inventory of hazardous material Submit documentation for approval Verification by survey and issue Green Passport Ships laid waiting to be scrapped Green Passport Preparation for scrapping

Advantages of early compliance with and verification of Green Passports

Future proofing against mandatory legislation Price structure Early identification of liability For example tributyltin (TBT), polychlorinated biphenyls (PCBs) and asbestos. Safety onboard Enhanced environmental profile Proactive stance Saleability

In conclusion Future developments

Tripartite IMO/ILO/BC meeting, February 2005 Mandatory timetable Green Passport Licensed scrapping facilities Ready for scrap agreement Inevitable price structure shift


Environmental Protection notation

Class society environmental rules Cover major operational pollutants Include design, equipment and operational aspects Goes beyond current environmental legislation Applies to new & existing ships

Structure of rule requirements

Core requirements mandatory Supplementary requirements optional Fundamental requirements mandatory ISM, MARPOL & SERS

Core requirements
Exhaust emissions (NOx SOx) Oil pollution Sewage Garbage Ballast water Antifouling paints Fire-fighting agents Refrigerants

Supplementary modules
Hull anti-fouling (A) Ballast water management (B) Grey water (G) NOx emissions (N) Oily bilge water (O) Protected oil tanks (P) Refrigeration systems (R) SOx emissions (S) Vapour emission control systems (V)

Sample requirements: Oxides of suphur (SOx) exhaust emissions

Core Maximum sulphur (S) content 4.5% S 1.5% in IMO SOx Emission Control Areas Supplementary Maximum allowable fuel S content: Maximum allowable fuel S content: Gas oil = 0.2% m/m Fuel oil = 1.5% m/m

Sample requirements: Refrigeration systems

Core: System design, operation and maintenance to minimize refrigerant gas leakage; Maximum allowable leakage = 10% total charge Supplementary:

Refrigerant gases restricted to those having Ozone Depleting Potential (ODP) = 0 Global Warming Potential (GWP)<1950

Summary of design/equipment requirements I

General compliance with all MARPOL annexes NOx Interim Engine Air Pollution Prevention 9EIAPP certificate or Statement of Compliance diesel engines above 130Kw Refrigeration systems leak detection system Fire-fighting systems halons or halocarbons

Summary of design/equipment requirements II

Oil pollution prevention sludge & waste oil tanks sufficient capacity to store oily wastes between ports. Oily water separator to reduce oil-in-water content of bilge water to 15 ppm or less. Sewage treatment system or holding tanks. Capacity sufficient for maximum number onboard. Various design features (eg. Independent ventilation pipes). Statement of compliance with the requirements of USCG 33 CFR 159 or MARPOL 73/78 Annex IV.

Summary of design/equipment requirements III

Incinerators where fitted, certificate of compliance with requirements of IMO resolution MEPC 76(40) Hull antifouling hull coatings must not contain tributyl tin (TBT) Ballast water incorporate features to help reduce need to take up ballast water & help cleaning of ballast tanks to remove sediments (eg. IMO Design suggestions for ballast water & sediment management options in new ships)

Summary of operational procedures

Oil fuel management for SOx emissions control Refrigerant management Oil pollution prevention measures Garbage management Sewage treatment & discharge control Operational measures to minimize transfer of non-native organism in ballast water NOx emission control, if applicable

Approval process

Plan & document review Initial survey (and audit) Assignment of EP notation Annual and renewal surveys

Which ships?
Mainly new builds, some existing ships Changing profile of owners and ships seeking EP notation Approx 170-180 appropriate completed or in hand

Statistics: Ships with EP notation (or undergoing approval)

Tankers 48% Container ships 24% LNG ships 8% Naval vessels 7% Cruise/passenger ro-ro 6% Bulk carriers 2% Private yachts 1% Other 3%

How can Environmental Protection notation benefit owners?

Improves public relations Provides evidence of environmentally responsibility to public, customers and government Reduces likelihood of environmental incident Design for improved environmental performance Operating procedures help maintain high environmental standards Helps future proof your investment Rules in line with international legislative developments