IMO's report from PPR 10

The Sub-Committee on Pollution Prevention and Response of the International Maritime Organization (PPR 10) was held on 24-28 April 2023.

The Sub-Committee on Pollution Prevention and Response (PPR) deals with all matters relating to pollution prevention and response which falls within IMO’s remit.

This ranges from all annexes of the MARPOL Convention through to the control and management of harmful aquatic organisms in ships' ballast water and sediments; biofouling; anti-fouling system; pollution preparedness, response, and cooperation for oil and hazardous and noxious substances; and the safe and environmentally sound recycling of ships.

The Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals works under the auspices of the PPR Sub-Committee.

Here is the report from PPR 10 published on IMO's website:

Draft revised Biofouling Guidelines approved

The Sub-Committee approved the revised Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species, following a comprehensive review of the Guidelines.

Biofouling is the accumulation of aquatic organisms on wetted or immersed surfaces such as ships and other offshore structures. Good biofouling management can help protect marine biodiversity by preventing the transfer of invasive aquatic species. Keeping a ship’s hull clean can also reduce the ship’s greenhouse gas emissions by improving fuel efficiency.

The 2023 Guidelines, which expand on and update the previous version, with a view to strengthening it and increasing its uptake, will be submitted to the Marine Environment Protection Committee (MEPC 80) for adoption.

The Sub-Committee also agreed to develop guidance on in-water cleaning at a future session. In this regard, the Sub-Committee recommended to MEPC 80 that the target completion year for the guidance should be extended to 2025, and that it should be renamed as "Development of guidance on matters relating to in-water cleaning". The Sub-Committee invited concrete proposals on the separate guidance.

The Sub-Committee also invited Member States and international organizations to submit relevant information on best practices for biofouling inspections and cleaning actions to the Organization as it may become available in the future.

The Biofouling Guidelines were first adopted in 2011. The MEPC 72 session (2018) decided to initiate a review, to take into account best practices and experience as well as the latest research. In implementing this review, PPR 8 (2021) agreed that the Guidelines should be revised.

A separate guidance document provides advice relevant to owners and/or operators of recreational craft less than 24 meters in length. (Guidance for minimizing the transfer of invasive aquatic species as biofouling (hull fouling) for recreational craft - MEPC.1/Circ.792).

The GEF-UNDP-IMO GloFouling Partnerships Project and the related TEST (Transfer of Environmentally Sound Technologies) Biofouling Project, Norwegian Agency for Development Cooperation (Norad) support developing countries to implement the Biofouling Guidelines.

Recommendations for maritime transport of plastic pellets agreed

The risks to the marine environment from plastic pellets haves been highlighted by incidents, including the X-Press Pearl in 2021, during which 11,000 tonnes of plastic pellets were spilled off the shore of Sri Lanka.

The Sub-Committee agreed a draft MEPC circular on recommendations for the carriage of plastic pellets by sea in freight containers. The draft text will be submitted to the Sub-Committee on Carriage of Cargoes and Containers (CCC 9, which meets 20-29 September) for input.

The draft circular recommends that plastic pellets should be packed in good quality packagings which should be strong enough to withstand the shocks and loadings normally encountered during transport. Packaging should be constructed and closed so as to prevent any loss of contents which may be caused under normal conditions of transport, by vibration or acceleration forces.

According to the draft circular, transport information should clearly identify those freight containers containing plastic pellets. In addition, the shipper should supplement the cargo information with a special stowage request. Freight containers containing plastic pellets should be properly stowed and secured to minimize the hazards to the marine environment without impairing the safety of the ship and persons on board. Specifically, freight containers containing plastic pellets should be stowed: under deck wherever reasonably practicable; or inboard in sheltered areas of exposed decks.

The PPR Sub-Committee invited Member States and international organizations to submit any relevant information on packaging to the CCC Sub-Committee for consideration. Following review by the CCC Sub-Committee, the draft recommendations could be finalized by the next session of the PPR Sub-Committee (PPR 11 in 2024) and approved by MEPC 81 in spring 2024.

The Sub-Committee invited Member States and international organizations to submit concrete proposals on potential mandatory measures to a future session of the Sub-Committee taking into account discussions to date, and experience from the implementation of any non-mandatory measures.

The Sub-Committee also agreed that plastic pellets should not be carried in bulk. The Sub-Committee invited Member States and international organizations to submit relevant proposals to a future session of the Sub-Committee on potential regulatory changes that may be needed to prevent the shipment of plastic pellets in bulk.

Preparedness and response to incidents involving plastic pellets

The Sub-Committee approved terms of reference for a correspondence group to develop a draft guide on clean-up of plastic pellets from ship-source spills. A draft guide should be submitted to PPR 11 for consideration.

Reporting of fishing gear losses

The Sub-Committee continued its work on developing draft amendments to MARPOL Annex V to enhance the reporting of fishing gear losses. The Sub-Committee noted general agreement that globally consistent thresholds to report lost or discharged fishing gear should be developed, taking into account the wide variety of fisheries and fishing gear. There was also general agreement that recreational vessels should be exempted from mandatory reporting requirements without any prejudice to any other MARPOL requirements.

The Correspondence Group on Marine Plastic Litter from Ships was tasked with continuing the work, including considering what data should be reported; who will be responsible for reporting; access to a future IMO database; and templates for reporting.

The Correspondence Group will also further develop draft amendments to MARPOL Annex V to provide for the reporting mechanisms, the modalities and the information to be reported to the Administrations and IMO to facilitate and enhance reporting of the accidental loss or discharge of fishing gear; and consider specific guidelines and relevant draft amendments to the 2017 Guidelines for the implementation of MARPOL Annex V (resolution MEPC.295(71)).

Marking of fishing gear

The Sub-Committee continued its discussions related to the marking of fishing gear. The Sub-Committee invited interested Member States and international organizations to submit proposals to PPR 11 for a draft MEPC circular to promote the implementation of fishing gear marking systems and the Food and Agriculture Organization of the United Nations (FAO) Voluntary Guidelines for the Marking of Fishing Gear as well as draft amendments to MARPOL Annex V.

This should take into account work by the FAO, which has published A framework for conducting a risk assessment for a system on the marking of fishing gear – VGMFG Supplement 1; and Manual for the marking of fishing gear – VGMFG Supplement 2.

GloLitter Partnerships project

The global GloLitter Partnerships project, which aims to reduce sea-based marine plastic litter, has published a study on Reporting and retrieval of lost fishing gear: recommendations for developing effective programmes, which describes systems for fisher-led reporting and retrieval of lost fishing gear, and a report on Legal aspects of abandoned, lost and otherwise discarded fishing gear (ALDFG), which examines the legal responses to ALDFG in the context of marine fisheries.

Ballast water management

The Sub-Committee agreed to a draft Protocol for verification of ballast water compliance monitoring devices, to be submitted to MEPC 80 for approval.

This Protocol is an important tool to support effective implementation of the BWM Convention by enabling the use of devices for a variety of purposes that satisfy a common level of quality. These include commissioning testing of ballast water management systems, port State control inspections, and ships' self-monitoring.

The development of the Protocol follows intensive work in the Sub-Committee, including in a dedicated Correspondence Group, over a number of years.

Additionally, the Sub-Committee agreed to a draft unified interpretation to the form of the International Ballast Water Management Certificate (IBWMC) and regulations B-3.5 and B-3.10 of the BWM Convention, regarding the "date of construction" for a ship which has undergone a major conversion in order to implement the BWM Convention. The unified interpretation will be submitted to MEPC 80 for approval.

Inventory of Hazardous Materials – revision of guidelines approved

The Sub-Committee approved the revised 2023 Guidelines for the development of the Inventory of Hazardous Materials, following amendments to the Anti-Fouling Systems (AFS) Convention to include controls on cybutryne. The 2023 Guidelines will be submitted to MEPC 80 for adoption.

Reducing impact on Arctic of emissions of Black Carbon from international shipping

The Sub-Committee continued its work to further develop the draft guidelines on goal‑based control measures to reduce the impact on the Arctic of Black Carbon emissions from international shipping. It further considered potential control measures, in conjunction with discussions on measurements methods and a standardized sampling, conditioning and measurement protocol.

Following discussion in a working group, the correspondence group on Prevention of Air Pollution was re-established to continue the work intersessionally and report to PPR 11. The correspondence group is tasked with further developing, with a view to finalization, draft guidelines on recommendatory goal-based control measures to reduce the impact on the Arctic of Black Carbon emissions from international shipping.

Operational Guide on the Response to Spills of Hazardous and Noxious Substances (HNS)

The Sub-committee agreed the final draft of the Operational Guide on the Response to Spills of Hazardous and Noxious Substances (HNS), for submission to MEPC 80, with a view to approval and subsequent publication. The guidance is for first responders and decision-makers in preparation for and during a maritime incident at sea or in port, when such an incident involves HNS.

Guidelines for thermal waste treatment devices agreed

The Sub-Committee approved the draft 2023 Guidelines for thermal waste treatment devices, for submission to MEPC 80 with a view to adoption.

Marine diesel engine replacing a steam system – draft MARPOL Annex VI amendments

The Sub-Committee agreed draft amendments to regulation 13.2.2 of MARPOL Annex VI on a marine diesel engine replacing a steam system, for submission to MEPC 80 for approval, with a view to adoption at MEPC 81.

The Sub-Committee also agreed associated draft amendments to the 2013 Guidelines as required by regulation 13.2.2 of MARPOL Annex VI in respect of non-identical replacement engines not required to meet the Tier III limit. Also agreed were consequential amendments to the unified interpretations to regulation 13.2.2 of MARPOL Annex VI, for adoption or approval by MEPC, as appropriate.

Unified interpretation to regulations 18.5 and 18.6 of MARPOL Annex VI

The Sub-Committee agreed to a new unified interpretation to regulations 18.5 and 18.6 of MARPOL Annex VI, for approval by MEPC 80 and inclusion in a revision of MEPC.1/Circ.795/rev.7 on unified interpretations to MARPOL Annex VI.

The unified interpretation states that the Bunker Delivery Note (BDN) required by regulation 18.5 is acceptable in either hard copy or electronic format provided it contains at least the information specified in appendix V to MARPOL Annex VI and is retained and made available on board in accordance with regulation 18.6. An electronic BDN should be protected from edits, modifications or revisions. Authentication should be possible by a verification method such as a tracking number, watermark, date and time stamp, QR code, or GPS coordinates.

Reduction of Volatile Organic Compound (VOC) emissions

The Sub-Committee agreed to a draft scope of work on the Reduction of Volatile Organic Compound (VOC) emissions, for submission to MEPC 80 for concurrence. This work would aim to investigate how the reduction of Volatile Organic Compound (VOC) emissions could contribute to the implementation of the IMO GHG Strategy.

The draft scope of work on the reduction of VOC emissions includes: considering how to involve terminals in the reduction of Volatile Organic Compound (VOC) emissions; considering new and existing regulations on VOC, including the application of a revised regulation 15 of MARPOL Annex VI, taking into account ship design safety and effectiveness, as well as safety of ship operations; considering new and existing guidance documents on VOC, taking into account ship design safety and effectiveness, as well as safety of ship operations; and requesting input of other sub-committees as appropriate.

Evaluation of products

The Sub-Committee agreed with the completed evaluation of products and of cleaning additives as carried out by the ESPH Technical Group.

The Sub-Committee noted that 19 tripartite agreements were due to expire in December 2023 and would be deleted from the next edition of the MEPC.2/Circular (MEPC.2/Circ.29, due to be issued on 1 December 2023) if evaluation requests are not submitted to ESPH 29 - or if the information submitted is not sufficient for ESPH 29 to evaluate the corresponding products. Consequently, the Sub-Committee invited Member Governments to take action as appropriate to avoid any delay in the carriage of these products beyond their expiry dates.

Chemicals to be transported in bulk must be listed in Chapter 17 or 18 (or chapter 19) of the IBC Code or contained in the Provisional Categorization of Liquid Substances in accordance with MARPOL Annex II and the IBC Code (MEPC.2/Circular), which sets out the carriage requirements under which it may be transported.

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