In demonstrating its ongoing commitment to support the work of the International Maritime Organization (IMO), IACS will attend the next meeting of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 6) that will meet from 18 to 22 February 2019. IACS has submitted three papers to this meeting on the following issues:
- PPR 6/11/5 IACS provides comments on the proposed draft amendments to the 2015 Guidelines for Exhaust Gas Cleaning Systems (EGCS) contained in Annex 2 of the Correspondence Group report (PPR 6/11). The paper addresses the following issues: the conduct of environmental testing as part of the approval of the system; the monitoring system for daily spot checks of the exhaust gas monitoring system; the prevention of exhaust gases leak from the damper of a bypass line; the function that should be provided to the data recording and processing device; how non-compliant reports are clearly identifiable; addressing the washwater drain in the provisions regarding discharge water; and how "open-loop scrubbers" without treatment equipment are addressed in the Guidelines.
- PPR 6/16 IACS has developed and finalized an update to its Unified Interpretation (UI) MPC98 regarding the phrase "time of the replacement or addition of the engine" in regulation 13.2.2 of MARPOL Annex VI. This update reflects resolution MEPC.286(71) that adopted amendments to MARPOL Annex VI designating the Baltic Sea and the North Sea ECAs as NOx Tier III emission control areas. IACS has modified the text of the UI to negate the need for any further consequential changes if more NOx Tier III emission control areas are designated in the future.
- PPR 6/16/3 IACS seeks clarification on the recording requirements with regard to the engine operating status as required by regulation 13.5.3 of MARPOL Annex VI. IACS seeks clarification from PPR 6 as to whether the recording requirement in regulation 5.3 of MARPOL Annex VI applies to replacement engines (Tier II) subject to resolution MEPC.230(65), after the relevant NOx Tier III emission control area takes effect. IACS offers a draft unified interpretation to facilitate global and consistent implementation of this regulation.
IACS will also provide advice and comments to the Sub-Committee, both in plenary and the Working and Drafting Groups that will be established, on a number of issues. In particular, IACS will contribute to the discussions on:
- Revised Guidance on Ballast Water Sampling and Analysis (agenda item 4)
- Consideration of the impact on the Artic of emissions of black carbon from international shipping (agenda item 7)
- Consistent implementation of regulation 14.3 of MARPOL Annex VI (agenda item 8)
- Standards for Shipboard gasification of waste systems and associated amendments to Regulation 16 of MARPOL Annex VI (agenda item 10)
- Review of the 2015 Guidelines for Exhaust Gas Cleaning Systems (Resolution MEPC.259(68)) (agenda item 11)
- Amendments to the 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants (Resolution MEPC.227(64)) to address inconsistencies in their application (agenda item 14)
- Ammonia emissions from marine diesel engines equipped with SCR systems (agenda item 19)
Any enquiries on the above should be sent to Paul Sadler, IACS Accredited Representative to IMO, at firstname.lastname@example.org