IMO updated information on the treatment of ODS used by ships

The International Maritime Organization on 9 October 2023 published a document presenting updated information on the treatment of ozone-depleting substances (ODS) used by ships.

Introduction

MEPC 74, having noted updated information on recent decisions by the Parties to the Montreal Protocol on Substances that Deplete the Ozone Layer (or 'ozone-depleting substances' (ODS)) provided in document MEPC 74/5/1 (Secretariat), requested the Secretariat to continue liaising with the Ozone Secretariat with a view to providing future updates on the work of the Montreal Protocol to the Committee (MEPC 74/18, paragraph 5.75).

In this context, it is recalled that the Kigali Amendment to the Montreal Protocol was adopted at the twenty-eighth Meeting of the Parties to the Montreal Protocol (MOP 28) on 15 October 2016, which also includes hydrofluorocarbons (HFCs) as part of its ambit, and entered into force on 1 January 2019.

As of October 2023, 152 Parties have ratified the Kigali Amendment. Although HFCs have an ozone depletion potential of essentially zero as they do not contain chlorine; nonetheless, they are powerful greenhouse gases and short-lived climate pollutants.

Regulation 12 of MARPOL Annex VI on ozone-depleting substances (ODS) contains a prohibition of systems or equipment that contain ODS, other than hydrochlorofluorocarbons (HCFCs), such as CFC or halon, to be installed on ships constructed on or after 19 May 2005, and no new installation of the same is permitted on or after that date on existing ships.

In accordance with regulation 12, no HCFC-containing system or equipment is permitted to be installed on ships constructed on or after 1 January 2020, and no new installation of the same is permitted on or after that date on existing ships.

Regulation 12.5 of MARPOL Annex VI further requires each ship subject to having an International Air Pollution Prevention (IAPP) Certificate (in accordance with regulation 6.1 of MARPOL Annex VI) to maintain a list of equipment containing ODS.

Regulation 12 further prescribes that the substances referred to in regulation 12, and equipment containing such substances, shall be delivered to appropriate reception facilities when removed from ships.

Consideration by the Montreal Protocol of the treatment of ODS used by ships:
MEPC 74, having noted Decision XXX/7 on Future availability of halons and their alternatives adopted by the thirtieth Meeting of the Parties to the Montreal Protocol, reiterated its request to Member States to collect data on halons from the maritime sector, in particular to collect information on the number of ships equipped with halon systems (e.g. the total number of halons installed for their merchant fleets) and to convey this information directly to the Ozone Secretariat.

The full text of Decision XXX/7 was set out in the annex to document MEPC 74/5/1.

Decision XXX/7 also requested the Halons Technical Options Committee of the Ozone Secretariat to identify pathways for enhancing the recovery of halons from the breaking of ships. Information with respect to halon 1301 usage by merchant ships is set out in the 2018 Assessment report of the Halons Technical Options Committee (TEAP) from the Ozone Secretariat.

It emphasized the importance of effective and complete recovery of halon 1301 to countries with shipbreaking activities to minimize halon losses.

Furthermore, the 2022 TEAP Assessment report emphasized the cautious approach employed whilst handling recovered halon 1301 during shipbreaking.

In this regard, it is recalled that the 2023 Guidelines for the Development of the Inventory of Hazardous Materials (resolution MEPC.379(80)) under the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (Hong Kong Convention) contain guidance concerning the cataloguing of halons and other ODS for developing the Inventory of Hazardous Materials, thereby facilitating the compliance with regulation 5 of the Hong Kong Convention.

Ship recycling facilities can utilize this information in managing the types and amounts of halons for recovery and other ODS.

The Committee may further note that in accordance with MSC-MEPC.1/Circ.3 on Decreasing availability of halons for marine uses, Member Governments are requested to collect data on halons from the maritime sector, in particular to collect information on the number of ships equipped with halon systems (e.g. the total number of halons installed for their merchant fleets) and to convey this information directly to the Ozone Secretariat.

In this regard, it is recalled that on 1 October 2020 a set of amendments to the MARPOL Convention to allow for the use of electronic record books, including the Ozone-depleting Substances Record Book, entered into force.

Accordingly, regulation 12.6 of MARPOL Annex VI requires each ship subject to regulation 6.1 that has rechargeable systems that contain ODS to maintain an ODS record book.

This record book may form part of an existing logbook or electronic record book as approved by the Administration (see also resolution MEPC.312(74) on Guidelines for the use of electronic record books under MARPOL).

Such an electronic recording system shall be considered an electronic record book, provided the electronic recording system is approved by the Administration on or before the first IAPP Certificate renewal survey carried out on or after 1 October 2020, but not later than 1 October 2025.