Minutes

45thMeeting of INTERTANKO’s

Environmental Committee

0900-1730hrs, Thursday 14th September 2017

200 St. Vincent Street

Glasgow

Great Britain

Adopted by correspondence, 9th October 2017

  1. Minutes
  2. Administration

Policy and Discussion Items

  1. Ballast Water Management
  2. Environmental Performance
  3. Environmental Compliance
  4. Biofouling and Antifouling

Reporting Items

  1. Port Reception Facilities
  2. Waste Management
  3. Ship Recycling
  4. NPDES – VGP
  5. Liaison with Environmental Organisations
  6. Environmental Initiatives and Projects
  7. Environmental Information Sharing
  8. Work of Other Pertinent Committees
  9. Any Other Business
  10. Date and Place of next Meeting

Joint Environmental Committee and ISTEC Meeting, 1330-1500hrs

  1. Air emissions
  2. Ballast Water Management
  3. Integrated Bilge Treatment Systems (IBTS)

Attendance:

Company / Name
Stena Bulk AB / Northern Marine Ltd. / Ko Ko Naing (Chairman)
Anglo-Eastern Ship Management Ltd / Sudhir Bhimani
Columbia Shipmanagement / Allan Dutton
Consolidated Marine Management Inc / Antonios Georgantzis
Dorian (Hellas) SA / Marina Hadjipateras
ExmarShipmanagement / Emma Scheiris
GasLog Ltd / George Raptakis
Maran Tankers Management Inc / Stelios Volakis
Marinvest Shipping AB / Magnus Cardfelt
Minerva Marine Inc / Maria Sotiriou
Product Shipping & Trading SA / Stylianos Siafakas
Scorpio Tankers Inc. / Ole Christian Schroder
Team Tankers / Caspar Lavall
INTERTANKO / Michele White
INTERTANKO / Tim Wilkins

Apologies:

Company / Name
Andriaki Shipping Co Ltd / Panagiota P. Chrysanthi
d'AmicoSocietá di NavigazioneSpA / Fabio Tagliavia
Laurin Maritime AB / Par Brandholm
SCF Management Services (Novorossiysk) / Nikolay N. Zinenko
Sea World Management & Trading Inc / Michael Reppas
Teekay Marine (Singapore) Pte Ltd / Pradeep Kale
Thome Ship Management Pte. Ltd. / Atul Vatsa

Prior to the commencement of the meeting INTERTANKO’s Legal Counsel, Michele White, advised the Committee of the INERTANKO’s Anti-Trust and Competition Law Guidelines stating that the meeting would be conducted in accordance with these Guidelines.

The Chairman welcomed all the members to the meeting and welcomed Allan Dutton and Maria Sotoriou to their first meeting as members of the Environmental Committee. The Chairman also noted the departure of Dimitris Stamoudis from the Committee. The Committee extended their gratitude and appreciation to Mr. Stamoudis having served as a member of the Committee since 2001 and Chairman for four years during that period.

1.Minutes

The draft Minutes and Action Plan from the 44thMeeting held in Singapore on Tuesday 28th and Wednesday 29th March 2017 were circulated on 3rd April and subsequently placed on the INTERTANKO website on 20th April as approved. No further comments were received during the meeting.

The Committee reviewed the Action Items with the following comments:

General

  1. Action items should be given a Target Completion Date.

Waste Management

  1. The Secretariat is requested to circulate again a final copy of the Waste Guide for Tankers.
  1. The Chairman requested the secretariat to ensure the section of the Guide on E-waste is up to date and reflect the latest decision and definition agreed by IMO at MEPC 71.

Work of other pertinent Committees

  1. The Secretariat was requested to circulate the remarks provided by OCIMF on how SIRE inspectors are likely to assess a vessel’s ballast water management after entry into force of the Ballast Water Management Convention.

Ballast Water Management

  1. The Committee noted that Saudi Arabia’s ballast water requirements were only applicable in certain ports and only those terminals operated by Saudi Aramco.
  1. Mr. Volakis advised the members that Maran Tankers had had two tankers tested to date. Both vessels used the same technique which measures adenosine triphosphate (ATP). The tests were conducted by SGS.
  1. The Committee also noted that Trinidad and Tobago did not accept the use of a Ballast Water Management System but instead required ballast water exchange.

Ship Recycling

  1. Members noted that both the list of facilities approved by the European Commission as well as the list of facilities which had been granted Statements of Compliance against the Hong Kong Convention standards provided by ClassNK and the Japanese Shipowners’ Association (JSA) were available on the INTERTANKO website.
  1. The Committee agreed that a target completion date should be set for the first draft of the revised Guidance on developing and maintaining the Inventory of Hazardous Materials (IHMs).
  1. Members remarked that class societies were now auditing the IHMs and that crew still knew very little about what was required in terms of updating and maintaining the document.
  1. It was observed that Maersk were continuing to work extensively on the issue of ship recycling and that it would be of value to review the standards as well as the facilities that were being used by Maersk. The secretariat was requested to obtain and circulate information on Maersk’s policy for review and consideration by the Committee.
  1. Members noted that the European Commission were continuing to pursue the concept of a fee mechanism to promote recycling in compliance with the European Ship Recycling Regulation (EU SRR). The Committee requested the secretariat to circulate a copy of the latest study on a European Fee Mechanism for Ship Recycling.

Antifouling and Biofouling

  1. The Secretariat was requested to circulate the revised dry-docking checklist for antifouling coating inspections.

2.Administration

The Committee noted that the total membership for the Committee now stood at 20.

3.Ballast Water Management

3.1Ballast Water Management Systems (BWMS)

The Committee considered the difficulties in gathering detailed information on ballast water management system failures from INTERTANKO members in a standardised survey. It was recognised that completing such a detailed survey would require an extensive amount of time and that many companies already had this data available, albeit in different formats. Noting this, the Committee agreed that it would be best for the secretariat to issue a request for information on BWMS failures in a more general manner to allow members to forward information they had collected in their own format rather than transfer this information into a standardised format. This would likely solicit more information even though the burden would then be placed on the secretariat to review and consolidate the information.

In summary, the Committee agreed on the following way forward:

  1. Request all members to send details of BWMS failures to the secretariat in the format that the member company has already used.
  2. Review and collate the information received and circulate this as a guidance document for review by the Environmental Committee and ISTEC.
  3. Based on the type of information received, develop a standard reporting form for members to use in the future to record failures and advise the secretariat. This information could then be used to update the guidance document and for general circulation to members, as required.

ISTEC also supported this way forward when the proposal was tabled during the joint meeting.

3.2Contingency Measures in the event of a BWMS failure

Members considered the IMO’s guidance issued in BWM.2/Circ.62 and concluded that additional guidance would be useful to develop for members. It was recognised that a failure of a BWMS would likely occur during ballast uptake and as such there should be sufficient time prior to the discharge at the next port of call to be able to notify the port State authority and agree on the contingency measure to be used. The Committee felt that a flow diagram or decision tree would prove useful for ships to determine the most effective and practical contingency measure. In order to develop guidance and a flow diagram, the Committee agreed to form a small Working Group (WG) that would collate and review contingency measures currently being used in members Ballast Water Management Plans (BWMP). The WG would include Mr. Schroder, Mr. Siafakis, Mr. Volakis, Mr. Naing, Mr. Bhimani and Ms. Sotoriou. In order to gather as much information as possible Committee members agreed to submitexamples of the contingency measures currently included in their BWMPs.

Members commented that ballast water exchange was considered the most common and widelyrecognised contingency measure in the event the BWMS failed. In this respect the standard by which the exchange was conducted would also need to be clearly stated in the BWMP and CM guide. A distinction would therefore have to be made as to the degree of exchange that was required and whether the exchange was to be conducted in compliance with the BWM Convention’s Regulation D-1 or the USCG’s standard specified in 151.2005.

3.3Ballast Water Exchange

The Committee agreed that the IMO’s guidance on ballast water exchange as contained in BWM.2/Circ.63 was useful for members and requested the secretariat to once again circulate the document to the Committee and all INTERTANKO members. In practical terms the members recognised that there was still a large degree of uncertainty as to how the port State authority would interpret the guidance in the circular. In this respect the Secretariat was requested to invite feedback from members on cases in which the guidance in BWM.2/Circ.63 had to be used and the port State response to the ship when a complete BWE had not been possible. Information received could be collated and circulated (via the Weekly News or the INTERTANKO website) to the members for inclusion in their BWMPs.

3.4Ballast Water Record Book entries

The Committee agreed that the current form and guidance on completing the Ballast Water Record Book (BWRB) as included in Appendix II of the BWM Convention left some uncertainties with the possibility that different interpretations could lead to problems with port State control. It was agreed that a WG should be established to review the BWRB and develop basic guidance for circulation to members. The WG would include Mr. Georgantzis, Ms. Sotoriou, Mr. Volakis and Ms. Hadjipateras.

Action

  • Circulate the remarks provided by OCIMF on how SIRE inspectors are likely to assess a vessel’s ballast water management after entry into force of the Ballast Water Management Convention.
  • In regards to gathering data on BWMS failures:
  1. Request all members to send details of BWMS failures to the secretariat in the format that the member company has already used.
  2. Review and collate the information received and circulate this as a guidance document for review by the Environmental Committee and ISTEC.
  3. Based on the type of information received, develop a standard reporting form for members to use in the future to record failures and advise the secretariat. This information could then be used to update the guidance document and for general circulation to members, as required.
  • Committee members to send in examples of the contingency measures currently included in their BWMPs.
  • Form a small Working Group (WG) to collate and review contingency measures currently included in members Ballast Water Management Plans (BWMP). The WG would include Mr. Schroder, Mr. Siafakis, Mr. Volakis, Mr. Naing, Mr. Bhimani and Ms. Sotoriou.
  • Draft guidance and a flow chart on contingency measures.
  • Circulate BWM.2/Circ.63 to the Committee and as well as all INTERTANKO members.
  • Invite feedback from members about cases in which the guidance in BWM.2/Circ.63 was required and the port State response to the ship when a complete BWE had not been executed.
  • Establish a Working Group to review the BWRB and develop basic guidance for circulation to members. The WG would include Mr. Georgantzis, Ms. Sotoriou, Mr. Volakis and Ms. Hadjipateras.

4.Environmental Performance

The Committee reviewed the standardised template for inputting data. It was agreed that the revised spreadsheet should be circulated to the Committee for a final round of comments. Following the final review the Committee agreed to submit data to test the form and ensure that the data points were logical and adequate for circulation to the entire INTERTANKO membership.

Action

  • Circulate to the Committee the revised template for gathering environmental data for a final round of comments.
  • Once agreed, ensure each member of the Committee enters data to trial the template prior to its circulation to the entire membership.

5.Environmental Compliance

The Committee agreed on the following broad topics and sections to be included in a guidance document on environmental compliance:

  1. Environmental Compliance Plans and Programmes
  • Training and Awareness
  • Declaration of Commitment
  • Disembarkation Declaration
  1. Voluntary Environmental Reporting
  • Explanation of what this is and why it may be of use to implement.
  1. Whistle-blower Policy
  • What are the advantages and disadvantages.
  • For example, ensure it is working and is frequently tested, e.g. telephone lines open etc.
  • Consider language barriers between crew and hotline responders.
  • What resources are required, e.g. use of third party vendors.
  1. Environmental Compliance Departments
  2. Environmental Leadership Initiatives
  3. Environmental Management Officers Onboard (EMO) and Environmental Compliance Officers (ECO)
  4. Focus on Record Books: Oil Record Books and Garbage Record Books
  • Shoreside reviews.
  1. Shoreside Monitoring

A Working Group would be formed to flesh out the headings as agreed. The Working Group would include Mr. Dutton, Mr. Sudhir, Ms. Sotoriou and Mr Schroder. The secretary suggested that Mr. Vatsa and Ms. Chrysanthi would also likely have valuable contributions to make to this work.

The Committee were advised that NAMEPA had commissioned a guide on whistle-blowing and as such it was important not to overlap or contradict this guidance.

Action

  • The Committee agreed on a broad list of topics and sections to be included in a guidance document on environmental compliance. A Working Group would be formed to flesh out the agreed headings.

6.Biofouling and Antifouling

6.1Biofouling and Antifouling Charter Party Clauses

INTERTANKO’s Legal Counsel, Michele White, introduced the clauses that had been drafted by the Documentary Committee. The clauses relate directly to the issue discussed by the Committee at its previous meeting and address the need for a ship to activate its antifouling system after extended periods of idling. While the clauses were termed ‘storage’ clauses they relate to a number of similar situations that included storage, idle and long-waiting.

In terms of including a specific number of days for the period of continuous days at idle, the Committee agreed that while a figure such as 15 days was good to add, an additional remark was essential to include as guidance. This remark would ensure the period was relative and could be amended depending on the coating and the geographical location of the vessel.

To assist the Documentary Committee, Ms. White requested members to send examples of current charter party clauses used in their companies.

Finally, in concluding that the clauses satisfied the Environmental Committee’s concerns relating to extended periods of idle and the maintenance of the coating system, it was agreed that a chapter on these clauses should be added to INTERTANKO’s revised Antifouling and Biofouling Guide.

6.2Revision of the Guide to Modern Antifouling Coatings and Biofouling Management

The Committee agreed to review the Guide again and requested the Secretariat to circulate the document to members together with the revised and updated dry-dock check lists.

6.3Development of a coating performance standard

After reviewing the list of standards drafted by ABS, the Committee agreed it would be beneficial to gain the views of ISTEC on the list and the possible way forward on the project being proposed by ABS.

Action

  • Include a chapter on relevant antifouling and biofouling charter party clauses in the revised Guide to Modern Antifouling Coatings and Biofouling Management.
  • Forward examples of currently used charter party clause to the Legal Counsel for use by the Documentary Committee.
  • The Committee is to provide comments on the current Guide to Modern Antifouling Coating and Biofouling Management as well as the new dry-dock checklists.
  • Forward ISTEC the list of antifouling and biofouling documents and standards developed by ABS and request their comment and feedback as to possible gaps and the need for a specific performance measurement for antifouling systems for use by owners.

7.Port Reception Facilities

The Committee discussed the implementation of the European Directive on Port Waste Reception Facilities. Notwithstanding the variation in interpretations by some ports, the feedback was in general positive with members commenting that the Commission and EMSA’swork to ensure ports provided the facilities was proving successful in some countries.

Some members commented on the problem associated with the delivery of food waste. Mr. Schroder advised that in the US food waste had to be treated and managed to strict standards which caused problems for the reception facilities. As a consequence, any waste that included food waste was often more expensive to land in the US.

Members also exchanged information about vetting and auditing of reception facilities to ensure that the waste delivered was being managed in an acceptable manner.

8.Waste Management

This issue was considered extensively under the review of the Action Items from the previous meeting. The following Action Items were agreed:

Action

  • Circulate again a final copy of the Waste Guide for Tankers.
  • Ensure the section of the Guide on E-waste is up to date and reflect the latest decision and definition agreed by IMO at MEPC 71.

9.Ship Recycling

This issue was considered extensively under the review of the Action Items from the previous meeting. The following Action Items were agreed:

Action

  • Obtain and circulate information on Maersk’s ship recycling policy for review and consideration by the Committee.
  • Circulate a copy of the latest study on a European Fee Mechanism for Ship Recycling.

10.NPDES VGP

INTERTANKO’s Regulatory Affairs Director, Joe Angelo, advised the Committee that prior to the establishment of a new Administration in the US the EPA had advised that they would release a first draft of the revised (2018) VGP in September 2017. While this deadline is no longer likely to be met, the EPA is still obligated to undertake the revision. The Committee should therefore anticipate a revised VGP to be issued at some point in the near future.