INTERTANKO Bunker Sub-committee covers MARPOL Annex VI and air emissions

INTERTANKO’s Bunker Sub-committee met in London last week under the chairmanship of the outgoing Chairman Hamish Cubitt. The following is an extract of some of the items discussed.

Guidelines for PSC on compliance with MARPOL Annex VI
The IMO Flag State Implementation (FSI) Sub-committee has drafted guidelines for port state control officers on how to conduct inspections for MARPOL Annex VI which would be considered for adoption by MEPC 53 in July.

The Committee took note of INTERTANKO’s position paper (MEPC 53/4/16) submitted to MEPC 53 and endorsed the suggestions aimed to clarify port state control policies for instances where the ship might experience problems complying with MARPOL Annex VI for reasons beyond its control. It was agreed to monitor developments with respect to whether a flag state which has not ratified MARPOL Annex VI could issue International Air Pollution Prevention (IAPP)/Engine International Air Pollution Prevention (EIAPP) Certificates to ships.

Practice and compliance with Regulations 14 & 18 of Annex VI (quality and sulphur content)
The Committee discussed problems associated with:

  • good practice for fuel sampling and sampling point as recommended by the IMO Guidelines for Bunkering and some practical considerations
  • different possible solutions for ships in case there would be an inadequate supply of low sulphur fuels in different ports which could lead to significant price differences
  • lack and therefore a need of clear operational guidelines with regard to the operational “switch” from residual fuel to the low sulphur fuel when entering a SECA
  • accuracy of test results for determination of the sulphur content in fuels and current practice

It was concluded that INTERTANKO and other industry bodies should make an effort to seek and collate feedback information from ships on experience gained with application of MARPOL Annex VI.

Greenhouse gases (GHG) – establishment of a voluntary trail index
The Committee noted the developments in IMO with regard to a GHG trail indexing. The GHG indexing provides a relative measurement for the efficiency of using a ship in different trading patterns. Since the indexing is dependent on several variables, the assessment needs to be done over a long period of time - say one year. The Committee agreed that GHG indexing could be a useful environmental management tool and, to that extent, it was positive that the methodology was developed by the IMO. A shipping company could use the GHG indexing in two areas: (1) to make an assessment of the efficiency of the ship’s trading pattern and (2) use it for the company’s annual environmental reporting. It was also flagged up that the former element needs to be correlated with the market realities and, more importantly, that such information should not be wrongly interpreted.

Annex VI Charter Party Clause & Bunker Supply Clause
INTERTANKO's Documentary Committee has prepared the INTERTANKO Bunker Emission Clause for Time Charters and the INTERTANKO MARPOL Annex VI Clause for Bunker Supply Contracts to assist owners and charterers in ensuring compliance with MARPOL 73/78 Annex VI regulations for the prevention of air pollution from ships which entered into force on 19 May 2005, and with similar European regulations.

The Sub-committee’s general view was that these are balanced and aimed to be useful for both ship operators and charterers. INTERTANKO will monitor how the clauses are received in the market.

The next meeting was provisionally set for 18 October 2005 in London.

Contact:Dragos Rauta