Minutes of the meeting of
the Safety & Environment Committee
Held on Thursday 13 October, 2016 at 1130
at the UK Chamber of Shipping,
30 Park Street, London, SE1 9EQ
Attendees
Tom Strang (Chairman) Carnival UK
Sandy Apostolatou Watson Farley Williams
John Cameron DOF(UK)
Rover Chang Evergreen
Rob Collier Shell Shipping
Louis de Wolff Calmac Ferries
Stephen Fairlie DFDS
Marija Filipovski DNV GL
Michelle Horsfield BP Shipping
Kenneth Hunter Cemex UK
Aqeel Hyder Red Funnel Ferries
Tony Kirk James Fisher Everard
Nigel Lehmann-Taylor Maersk
Sudhir Malhotra LOC
Kenneth McConnell Northern Marine
Dimitris Monioudis GSCC
Saurabh Sachdeva BP Shipping
Barry Smith Wightlink
Moto Tsuchiya LR
Robert Twell Global Marine Systems Ltd
Claire Womersley Holman Fenwick Willan
Lachie Wotherspoon Calmac Ferries
Max Wu Lloyds Register
Evgeny Zimovets Lomar Shipping
WITH
David Balston Secretariat
Robert Merrylees Secretariat
Adrian Mundin Secretariat
1 Introduction
The Chairman welcomed everyone to the thirteenth meeting of the Safety & Environment Committee.
2 Minutes of last meeting
The minutes of the last meeting, held on 7 April 2016 and circulated on 20 April, were agreed. Extant action points were picked up during subsequent agenda items.
3 Compliance with competition law
A copy of the Chamber’s policy, as approved by the Board, had been circulated with the papers for the meeting. The Committee noted and acknowledged members’ individual responsibility for compliance with competition legislation.
4 IMO agenda items
MEPC and MSC issues were discussed under relevant agenda items.
5 Environment
a) Review of MARPOL
· Sulphur
The report was noted. The secretariat added that the UK was certain to support 2020 as the implementation date for the global sulphur limit and was likely to push hard for a decision at MEPC 70. The conflicting findings of the IMO and BIMCO/IPECA studies were discussed in detail and in particular the safety concerns raised in the latter report. Notwithstanding this, there was unopposed support for 2020 on the grounds that once there was certainty, the various availability and safety issues would be resolved but if there was delay and continued uncertainty then nothing would be done to resolve these concerns. The need for clarity was seen as the overriding consideration.
· Carbon
Further to the agenda notes, the secretariat reported that ICAO had agreed to introduce an MBM for international aviation called CORSIA – Carbon Reduction and Offsetting Scheme for International Aviation. It is voluntary until 2027 after which it becomes compulsory and aims to achieve a carbon neutral growth based on 2020 emissions. This has not satisfied environmentalists but places shipping in a positive light given all that has been achieved through EEDI and other efficiency measures and the willingness for the industry to strive for a meaningful roadmap at the IMO.
The secretariat was also able to report that the Industry Energy and Research (ITRE) Committee of the EU parliament had voted for a compromise agreement that has left carbon reduction for international shipping within the remit of the IMO which makes the introduction of an EU ETS for shipping less likely in the near future at least.
During a discussion on possible outcomes at MEPC 70 the point was made that the IMO does not need to wait for data collection to agree a roadmap. This view was supported and the members of the committee again endorsed the more proactive approach that has been adopted by the chamber.
· EU MRV – IMO MRV
The report was noted. The secretariat also reported that at a recent chamber MRV event comments by the Commission did not inspire confidence that the EU would align its MRV to whatever is agreed at the IMO. It is therefore more than likely that the industry will end up with two different reporting requirements.
· EEDI
During a detailed discussion on the difficulties in including ro-pax vessels in the EEDI (the correction factors do not work) it was felt that ro-pax should nonetheless not be exempted or excluded from the regulation but rather that more work should be done on trying to find a way that they can be included satisfactorily, possibly by sub-dividing these vessels into a number of different categories based on size and type.
· NOX
The report was noted though the point was made that, contrary to the notes, Tier III limits can only be met by LNG 4 stroke engines and that LNG 2 stroke engines would still need some additional treatment system such as an SCR.
· MARPOL Annex I- Integrated bilge treatment system
The report was noted.
· MARPOL Annex V- Port Reception Facilities
Members were encouraged to participate in the EU consultation. Many members commented on the lack of choice of reception facilities at ports, often the only option being an unduly expensive one (barges rather than trucks for example). The chamber was requested to take these concerns forward.
The secretariat to pursue a more flexible and less financially punitive approach being adopted by ports with respect to waste collection and removal.
b) Ballast Water Management Convention
During a detailed discussion on the Ballast Water Convention members confirmed that their priorities remain grandfathering of installed systems so as not to penalise early adopters, clarification on G8 guidelines, clarifying the position on delays to implementation, exemptions for short sea shipping and ‘same risk areas’.
In addition to continuing to pursue the above priorities, the secretariat is to provide clarity on decoupling and specifically trading between two states that have different interpretations or relaxations.
c) Recycling
The report was noted. A question was raised on the various applicability dates of the EU ship recycling regulations and the secretariat agreed to check and publish the information in these minutes.
Though the EU Directive is in force, many of the more technical aspects have yet to be included and this includes the list of approved facilities. That list will be published in late 2016.
The EU-regulation on Shiprecycling states under Art 32 that the EU-list comes into effect, when
1. requirements laid down in Article 32 a) are met
2. or if not, according to Article 32 b) on 31 December 2018.
Article 32
Application
1. This Regulation shall apply from the earlier of the following two dates, but not earlier than 31 December 2015:
(a) 6 months after the date that the combined maximum annual ship recycling output of the ship recycling facilities included in the European List constitutes not less than 2,5 million light displacement tonnes (LDT). The annual ship recycling output of a ship recycling facility is calculated as the sum of the weight of ships expressed in LDT that have been recycled in a given year in that facility. The maximum annual ship recycling output is determined by selecting the highest value occurring in the preceding 10-year period for each ship recycling facility, or, in the case of a newly authorised ship recycling facility, the highest annual value achieved at that facility; or
(b) on 31 December 2018.
DG Environment have confirmed that it will take at least 6 months after the EU-list has been published to evaluate if the capacity-requirements are fulfilled otherwise the entry into force will be on 31.12.1018 at the latest.
With respect to the potential financial scheme, the Commission has been instructed to report before the end of 2016 on "the feasibility of a financial instrument that would facilitate safe and sound ship recycling". A recent study conducted by DNV GL and Ecorys on behalf of the Commission recommended 31 December 2020 as the implementation date as that aligns with the introduction of the mandatory carriage of an Inventory of Hazardous Materials for non EU vessels.
ECSA has been encouraged to consider an alternative approach to address the possible circumvention of the EU Regulation through out-flagging. For information, the ECSA approach that the chamber has helped develop is set out below and is considered by the DG Environment Director-General Daniel Calleja as a positive approach:
(1) an active campaign to ratify the Hong Kong Convention
(2) an inclusive EU list pending the entry into force of the Convention
(3) incentives for third country yards that are striving towards international recognition
(4) active involvement and support of shipowners.
d) Environment AOB
The Chairman led a wide ranging discussion on the future of the Safety & Environment Committee and whether members would like to see changes or a move to subject specific working groups and events rather than meetings per se or would prefer for the current system to remain unchanged.
There was almost universal agreement that the meetings provided a very usual service to members, greatly enhancing the value of the detailed notes together with the opportunity to share views and ideas with other members. Suggestions were made for intersessional virtual meetings (via telephone conferencing for example) and to invite subject matter experts to give presentations when appropriate. Both these ideas will be further considered by the secretariat and the need for better horizon scanning for future issues of import.
It was therefore agreed that the current meeting structure would be maintained but possibly enhanced as covered above.
There was no other environment AOB.
6 Safety
a) Review of offshore planning
· UK marine planning
The report on marine planning was noted.
Furthermore a new consultation on four proposed Special Protection Areas (pSPA) around Scottish waters looking to protect bird species was reported. It was highlighted that some of the management measures being considered were a concern to shipping and the secretariat agreed to distribute consultation documentation and collate a response.
· Offshore renewables
Further to the report, the Secretariat indicated that the consultation for Hornsea Project Three, is expected this autumn. Members affected are likely to be approached directly, but were requested to keep the Secretariat informed of any concerns.
Tidal renewable energy systems were also discussed, in particular with the UK a leader in this technology, coupled with strong tidal streams around the coast, there was potential for the small number of projects, currently under development, to increase dramatically. The use of St Katherine’s Deep was mentioned as a site for experimental work.
b) Passenger ship safety
· EU REFIT study
The Secretariat confirmed that this work was in its final stages with the EU Council due to approve it shortly. It will bring a welcome rationalisation of some existing EU passenger ship safety Directives, except that passenger reporting procedures are set to become more bureaucratic.
Separately, EU Directive 2009/45/EC, which brings certain amendments to SOLAS into force for domestic vessels, is being updated to reflect recent work at IMO. Effective from July 2017, the majority of amendments will only impact new ships constructed after 1 January 2018, although some will apply to existing ships, such as the need to have FSS compliant breathing apparatus and conduct enclosed space drills. In summary, the amendments are:
· Implementation of the requirements of the IMO Noise Code applicable to all new ships constructed after 1 January 2018 and over 1600GT.
· Amendment to allow steering gear trials to be conducted with the vessel not at its deepest seagoing draught.
· Changes to firefighting systems, fire detection and fireman outfit requirements.
· Changes to bulkhead insulation requirements for special category spaces.
· Increased means of escape requirements for machinery space workshops.
· The introduction of prescriptive ventilation system requirements.
· Updates to introduce drills for enclosed space rescue, and a means to recover persons from the water on all ships.
The MCA is expected to consult on these changes early New Year.
c) Review of safety of navigation
· ICS survey into pilotage, towing and mooring services
The Secretariat briefed that this survey, aimed at gathering data on the quality of pilotage services, was underway and had been extended by one month to 16 November. Noting it was online and responses would not been seen immediately by the UK Chamber, Members were requested to keep the Secretariat informed of any significant issues.
· LRIT post implementation review
Further to the report, the Secretariat clarified that EMSA currently hosted the LRIT data centre, on behalf of IMO, for the world and that this arrangement was open ended. With cost now a concern, EMSA was looking to pass on the responsibility. It remains to be seen if this will spark a discussion over the future of LRIT, noting AIS was now more capable. It was pointed out by Members that the system was brought in on the basis that there would be no cost to shipowners, although this had already been contradicted with many having to fit dedicated transponders. Any further costs pushed towards the shipowner should be resisted.
· COLREGs – proposal for 3 all-round green lights for vessels crossing a TSS
Following consultation with Members, the UK Chamber’s position was not to support the universal adoption of this idea, although it was pointed out that it might have merit for particular areas. In forming a case against, the following points have been:
· The OOW / look-out will develop a tendency to look for the three green lights and make an assumption that other vessels not displaying such a signal are not crossing. This would lead to them ignoring or missing all those under 50m, which are excluded from the requirement to show the green lights.
· In all other cases apart from port and starboard sidelights the use of coloured lights in the COLREGs are used to identify particular conditions or the status of a vessel, which cannot be simply determined by observation (ie fishing, NUC, minesweeping etc). In this case the proposal departs from that principle in that the use of coloured lights is being proposed to identify a steering and sailing condition, which a competent mariner should be able to identify anyway from the current light configuration.
· A potential unintended consequence of the proposal would no doubt be that displaying such 'special' lights would lead to some assuming that the measure accords their vessel some kind of special status that gives them a 'right of way' over other vessels.
· Placing another three lights at the masthead will add to the maintenance burden and increases the need for hazardous working at height. The cost of this to the world fleet would be huge and there will be many vessels which due to their mast configuration may not be able to fit such lights.