In demonstrating its ongoing commitment to supporting the work of the International Maritime Organization (IMO), and within its remit as the Organization’s principal technical advisor, IACS will actively participate in the forthcoming 9th session of the Sub-Committee on Pollution Prevention and Response which will meet remotely from 4 to 8 April 2022.

Noting the work IACS Members undertake as Recognized Organizations of IMO Member States, verifying compliance of ships with the IMO agreed requirements, and with a view to achieve clarity for all parties, IACS has submitted or co-sponsored the following papers:

PPR 9/11/1 proposes to clarify the test cycle application by amending the NOx Technical Code 2008 and MARPOL Annex VI Appendix II (regulation 13) by expanding the scope of the E3 and C1 test cycles. IACS also requests clarification from the Sub-Committee on related matters as described in paragraphs 16, 20 and 21 with the aim to facilitate discussions on the use of multiple Engine Operational Profiles, which are linked to the certification test cycles, noting that the current MARPOL Annex VI and the NOX Technical Code test cycle requirements do not adequately address application to variable-speed/variable-load engines used for main propulsion or ship power generation.

PPR 9/14/2 comments on document PPR 9/14 containing the report of the Correspondence Group on Amendments of MARPOL Annex IV and Associated Guidelines and proposes additional considerations regarding the definitions of "new ship", "existing hip" and "passenger ship", as well as modifications to the relevant regulations to further develop the draft amendments to MARPOL Annex IV.

PPR 9/14/3 comments on document PPR 9/14 and presents additional amendments in relation to items due for consideration which include: amendments to MARPOL Annex IV, paragraph 4.1.3 to address sewage treatment plant (STP) commissioning test; draft amendments to the 2012 Guidelines on implementation of effluent standards and performance tests for sewage treatment plants (MEPC.227(68), as amended by resolution MEPC.284(70)) (the 2012 Guidelines), and the development of the STP performance guidelines.

PPR 9/16 proposes the modification to circular MEPC.1/Circ.895 to clarify the interpretation of paragraph of chapter 4 of the NOX Technical Code 2008, that due to the recent diversification of engines in consideration of NOx emission control, the interpretation should in general not be applied to the Engine Family, except where the applicant has provided clear evidence that an Engine Family concept, allowing for different numbers and arrangements of cylinders, will result in same or lower NOX emissions of the engines with different cylinder numbers compared to the NOX emissions of the related parent engine.

PPR 9/16/1 proposes a draft unified interpretation of the application of regulations 14.8 (In-use and onboard fuel oil sampling and testing) and 14.10 (In-use fuel oil sampling point) of MARPOL Annex VI.

PPR 9/16/2 comments on document MEPC 75/3/5 and proposes a unified interpretation of appendix I "Form of International Ballast Water Management Certificate" to the 2004 BWM Convention, concerning the principal ballast water management method(s) employed on the ship in order to issue a certificate in a consistent manner.

IACS will also provide advice and comments to the Sub-Committee on a number of other issues, both in plenary and in the Working Groups that are expected to be established. IACS will contribute to the discussions also on agenda items 7, 8, 11 and 19.

Any enquiries on the above should be sent to Konstantin Petrov, IACS Accredited Representative to IMO, at arimo@iacs.org.uk

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