BLG 17 External · 2013-01-22 · LR BLG 17 Agenda preview © Lloyd's Register 2013 ≤

LR BLG 17 Agenda preview (Overview) © Lloyd's Register 2013

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IMO BLG 17 Agenda Preview

Introduction

The 17h session of the IMO Sub-Committee on Bulk Liquids and Gases (BLG 17) will be held from 4 to 8 of February 2012, at the IMO headquarters in London. This briefing summarises subjects under discussion which are relevant to the work of Lloyd's Register out of documents submitted by 15th January. Due attention should be made to the “Advice” and “Application” where they are given.

Overview of agenda items

The following agenda items are relevant to the work of Lloyd’s Register. Decision of other IMO Bodies (Agenda item 2) BLG 17 will consider the outcome of FSI 20, MSC 90, C 107, C109, FP 56, DSC 17, MEPC 63 and MSC 9. Inter-alia, the following instructions from MEPC 64 will require attention: • a BWM circular on the application of the BWM Convention to Offshore Support Vessels • in developing sampling and analysis procedures for port State control, take into account MEPC 64's decision

that such procedures should be no more stringent than what is required for Type Approval of ballast water management systems

• prepare additional guidance with regard to application of the provisions contained in Guidelines (G8), including expansion of BWM.2/Circ.28

• consider the proposals made in document MEPC 64/2/15 on monitoring and sampling of certain ballast water management systems and advice the MEPC accordingly

• note MEPC 64's view that, in order to progress the development of the procedures on sampling of fuel oil being used on board matter, it would be necessary for future submissions to demonstrate the compelling need for such procedures and to provide concrete proposals on the matter

A discussion on re-organization of IMO (outcome of C109 and MSC91) will affect future work arrangements of BLG.

Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments (Agenda item 3) BLG 17 will consider the outcome of the ESPH Working Group and the various issues submitted to this session. The following is the expected primary discussion points: • Evaluation of new products • Evaluation of new cleaning additives • Review of MEPC.2/Circular – Provisional classification of liquid substances transported in bulk and other

related matters • Consideration of the outcome of the most recent session of GESAMP/EHS • Matters arising from FP 55 • Review of products requiring oxygen-dependent inhibitos and proposals to amend MSC/Circ.879-

EPC/Circ.348. • Consideration of further guidance for the re-issuing of chemical tanker certification.


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• amendments to the Revised Guidelines and specifications for oil discharge monitoring and control systems for oil tankers (resolution MEPC.108(49).

• Review of safety criteria guidelines in chapter 21 of the IBC Code to address inconsistencies in chapters 17 and 18.

For details, please refer to Annex 1 to this document. Ballast Water Management issues (Agenda item 4, 5 and 6) BLG 17 will discuss various matters relating to Ballast Water Management under separate agenda items. Discussions will revolve around issues relating to: • Development of guidelines and other documents for uniform implementation of the 2004 BWM Convention • Production of a manual entitled "Ballast Water Management – How to do it" • Consideration of improved and new technologies approved for ballast water management systems and

reduction of atmospheric pollution For details, please refer to Annex 2A to this document. Improved and new technologies approved for reduction of atmospheric pollution (Second part of agenda item 6) New technologies for atmospheric pollution will be addressed under this agenda item. For details, please refer to Annex 2B to this document. Development of international measures for minimizing the transfer of invasive aquatic species through biofouling of ships (Agenda item 7) Bio-fouling is considered to be a significant factor in the transfer of organisms and its control forms the second initiative by the IMO in its commitment to minimise the translocation of invasive species, the Ballast Water Convention being the other. For details, please refer to Annex 3 to this document. Development of international code of safety for ships using gases or other low-flashpoint fuels (Agenda item 8) BLG 17 will consider the report of the correspondence group and the various issues submitted to this session. Primary elements for discussion at this session will be: • Various proposed changes to the draft code (BLG 17/8. BLG 17/8/1, BLG 17/8/2, BLG 17/INF.11, BLG

17/INF.14) • Inclusion of fuels other than LNG such as Methyl/Ethyl alcohol (BLG 17/8/3, BLG 17/INF.10) • Operational issues, such as bunkering (BLG 17/8/4) • Others ( BLG 17/INF.13)

There will be a working group during BLG 17. For details, please refer to Annex 4 to this document. Development of revised IGC Code (Agenda item 9) Primarily discussion points at BLG 17 will be • Various editorial improvement ( BLG 17/9/1) • Emergency shutdown arrangement (BLG 17/9/2)


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• Application of requirements to existing ships, in particular, Emergency Shutdown System (EDS) (BLG 17/9/3) • Limit State Design Concept (BLG 17/9/3) – there will be not text for consideration at BLG 17 • Reference to MARPOL Convention (BLG 17/9/5) • Status of the code, i.e., revision to existing code or a new code (BLG 17/9/6) For details, please refer to Annex 5 to this document. Consideration of the impact on the Arctic of emissions of Black Carbon from international shipping (Agenda item 10) BLG 17 will review the outcome of the correspondence group established by BLG. For details, please refer to Annex 6 to this document. Review of relevant non-mandatory instruments as a consequence of the amended MARPOL Annex VI and the NOx Technical Code (Agenda item 11) BLG 17 will consider the guidelines prepared by the correspondence group established by BLG 16 (BLG 17/11 and BLG 17/INF.5) There are comments submitted to these draft prepared by the group. • Draft guidelines for replacement engines not required to meet the Tier III limit • Draft guidelines to outline the information to be submitted as part of the required notification from an

Administration to the Organization in respect of the approval of an Approved Method • Draft guidelines pertaining to equivalents set forth in regulation 4 of MARPOL Annex VI and not covered by

other guidelines (BLG 17/11/3) • Dual fuel engine issue (BLG 17/11/1) • Exhaust Gas Cleaning System (BLG 17/11/2, BLG 17/INF.3) For details, please refer to Annex 7 to this document. Development of a code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (Agenda item 12). BLG 17 will continue its consideration of the item with a view to deciding on how best to proceed with the development of the draft OSV Chemical Code, taking into account taking into account the report of the correspondence group formed following BLG 16, submissions made by Member Governments and international organizations to the session. For details, please refer to Annex 8 to this document.

LR BLG 17 Agenda preview (Annex 1 - Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments (Agenda item 3)) © Lloyd's Register 2013

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Annex 1 - Evaluation of safety and pollution hazards of chemicals and preparation of consequential amendments (Agenda item 3)

Overview

BLG 17 will consider the outcome of the ESPH Working Group and the various issues submitted to this session and documents submitted to BLG 17. The following is the expected primary discussion points: 1 Outcome of the ESPH Working Group This is a standing item on the BLG agenda which deals with issues relating to MARPOL Annex II and the IBC Code. The work is carried out by the BLG Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals (ESPH Working Group), which always meets during BLG and at one other occasion in a year. BLG will discuss and consider the report of the ESPH Working Group. In addition BLG will consider a number of issues as submitted to this meeting. The following are the main part of the outcome: • Evaluation of new products • Evaluation of new cleaning additives • Review of MEPC.2/Circular – Provisional classification of liquid substances transported in bulk and other

related matters • Consideration of the outcome of the most recent session of GESAMP/EHS • Matters arising from FP 55 • Review of products requiring oxygen-dependent inhibitos and proposals to amend MSC/Circ.879-

EPC/Circ.348. • Consideration of further guidance for the re-issuing of chemical tanker certification. • amendments to the Revised Guidelines and specifications for oil discharge monitoring and control systems

for oil tankers (resolution MEPC.108(49). • Review of safety criteria guidelines in chapter 21 of the IBC Code to address inconsistencies in chapters 17

and 18. 2 Other submissions Proposals are primarily on the outcome of the ESPH Working Group.

Background

This is a standing item on the BLG agenda which deals with issues relating to MARPOL Annex II and the IBC Code. The work is carried out by the BLG Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals (ESPH Working Group), which always meets during BLG and at one other occasion in a year. This is an open ended continuous agenda item.

Lloyd’s Register’s Position

In general, Lloyd’s Register welcomes the outcome of the ESPH Working Group. However, Lloyd’s Register has concerns on the following issues: • ODME guidelines


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The draft guideline for approval has an element on the requirement of spare part. Lloyd’s Register considers that further clarification is required as the application requirements (may be for new approval only) and scope of the spare that are required.

Advice to clients

The evaluation of chemicals leads to the assignment of the carriage requirements of new and existing substances

Applicability

The amendments to the IBC code will affect all tankers certified under the IBC and BCH Codes.

Documents submitted

BLG 17/3 - Report of the eighteenth session of the Working Group on the Evaluation of Safety and Pollution Hazards of Chemicals This document reports on the outcome of the eighteenth session of the Working Group on the Evaluation of the Safety and Pollution Hazards of Chemicals (ESPH 18) which was held from 22 to 26 October 2012. BLG 17 is requested to:

.1 agree to the evaluation of new products and the consequential inclusion in the IBC Code

.2 concur with the evaluation of cleaning additives;

.3 note the concern with regards to the use of cleaning additives components that are carcinogenic, mutagenic, reprotoxic or sensitizing;

.4 agree to the evaluation of Trade-named mixtures representing safety hazards and their consequential inclusion in List 3 of the MEPC.2/Circular with validity for all countries and no expiry date;

.5 note the review undertaken of MEPC.2/Circ.18 and the amendments and deletion of products from the lists that have reached their expiry dates;

.6 agree to the addition of three new bio-fuels to annex 11 of the MEPC.2/Circular;

.7 concur with the Group that bio-fuel blends should be fully assessed before they can be transferred to the Guidelines for the carriage of blends of petroleum oil and bio-fuels;

.8 note the outcome of the GESAMP/EHS 49 meeting and the continuing work on the review undertaken of GESAMP Reports & Studies No.64 with a view to reissuing this guidance document;

.9 note that, as endorsed by MEPC 64 and MSC 90, the discussions on the outcome of FP 55 were forwarded directly to FP 56 for their consideration and to take action on the resulting outcome of this as appropriate;

.10 note the discussions on issues arising from FP 55 and agree with the proposed amendments to the IBC Code

.11 note the discussion on the reissue of chemical code certificates and the request for further information to be submitted to BLG 17 for consideration;

.12 agree to the proposed amendments to the Guidelines and Specifications for Oil Discharge Monitoring and Control Systems for Oil Tankers and take action accordingly (paragraphs 9.1 to 9.3 and annex 5);

.13 note that as a consequence of the review of the above guidelines consequential amendments will need to be made to the IOPP Certificate, Form B, point 6.1.5;

.14 note the continuing discussions on the options to further develop the criteria for assessing products based on the GESAMP Hazard Profile together with a consideration of physical properties and endorse the conclusions reached; and

.15 approve the future work programme of the ESPH Working Group. BLG 17/3/1 (Brazil) - List 3 Entry – Surfom CS 5015 This document contains information for the assessment of the product Surfom CS 5015, which is proposed for inclusion in List 3 of the MEPC.2/Circular with no expiry date and with validity for all countries. BLG 17/3/2 (Netherlands, Norway and CEFIC) - Evaluation Of Safety and Pollution Hazards of Chemicals And Preparation Of Consequential Amendments This document elaborates on the use of safety hazards such as the Water Reactivity Index and irritation, corrosion and long-term health effects for the assignment of Ship Type, Tank type or other carriage requirements. This document is linked to document BLG 17/INF.12.


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BLG 17/3/3 (Finland) - Tall oil soap, crude Tall oil soap, crude is proposed for inclusion in chapter 17 of the IBC Code BLG 17/3/4 (United States) - Alkanes (C10-C26), linear and branched (flashpoint≤60oC) This document contains information for the classification of Alkanes (C10-C26), linear and branched (flashpoint�60°C) in chapter 17 of the IBC Code BLG 17/3/5 (United States) - List 3 Entry – Methoxypolyglycol Basic This document contains information for the classification of Methoxypolyglycol Basic in List 3 of the MEPC.2/Circular. BLG 17/3/6 (South Africa) - List 3 Entry – MP Cresol 45 MP Cresol 45 is proposed for inclusion in List 3 of the MEPC.2/Circular with no expiry date and validity for all countries. BLG 17/3/7 (Republic of Korea) – References to related information and recommendations for ascertaining carriage requirements for products in bulk The document contains a proposal for the inclusion of references to related information and recommendations for ascertaining the carriage requirements for products in bulk as a new annex of MEPC.2/Circular (Provisional Categorization of Liquid Substances) for the convenience of industries. BLG 17/INF.12 (Netherlands, Norway and CEFIC) - Proposed revision of chapter 21 – Big volume and frequently moved chemicals This document explores the possible effects a revised chapter 21 of the IBC Code will have on the transport requirements of a number of big volume and frequently moved chemicals in order to consider whether it can be applied for a more complete review of chapters 17 and 18 Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 2 – Ballast Water Management (Agenda items 4, 5 & 6)) © Lloyd's Register 2013

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Annex 2A – Ballast Water Management (Agenda items 4, 5 & part of 6)

Overview

The agenda was designated to discuss: • Development of guidelines and other documents for uniform implementation of the 2004 BWM Convention • Production of a manual entitled "Ballast Water Management – How to do it" • Consideration of improved and new technologies approved for ballast water management systems and

reduction of atmospheric pollution Current submissions are: • Sampling guidelines, including monitoring scheme (BLG 17/4, BLG 17/4/1, BLG 17/4/2, BLG 17/INF.15, BLG

17/INF.16) • Application to offshore support vessel (BLG 17/4/3) • Type approval procedures (BLG 17/4/4) • Compatibility between BWM system and ballast tank coatings (BLG 17/6)

Background

After the adoption of the 2004 International Convention for the Control and Management of Ship’s Ballast Water and Sediments (BWM Convention), BLG was tasked to continue developing guidelines associated with the Convention. Development of the PSC guideline is one of the key task given to the BLG. Lloyd’s Register has produced a series of guidance on ‘Understanding Ballast Water Management’ including status of technology, installation requirements and how to comply with the convention. This is available to download from www.lr.org/bwm Further In October 2010 LR issued the document "Ballast Water Treatment Systems - Guide for ship operators on procurement, installation and operation". The latest document is available on the LR website at the same link as above. Target completion year of the work is 2013.


Lloyd’s Register closely monitors the development of guidelines for sampling as that will be an element in the PSC guideline being developed by the FSI Sub-Committee. This will be one of the crucial points when enforcing the Convention as these. In general, the following are the LR’s views on this: • Sampling in general Lloyd’s Register supports the decision that PSC sampling and analysis procedures should be no more stringent than what is required for Type Approval. This is not trivial as PSC is unlikely to adopt the same testing methodology as is used for Type Approval, and hence calibration of the PSC is required to ensure that PSC does not take action against ships that are in compliance with the BWM Convention. Finally Lloyd’s Register also supports the application of consistent procedures and equipment for undertaking PSC sampling, and would also support proposals to limit PSC actions until such time as consistent procedures and equipment have been implemented.


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Lloyd’s Register supports the development of consistent and effective tools and procedures for self-monitoring of BWM Systems to allow PSC to determine whether the BWM System is operating correctly (e.g. there are no faults with the system and that the properties of the BW being treated are within the capability of the system) and whether the BW to be discharged has been effectively treated (i.e. that the quantity of BW that has been treated matches the quantity of ballast water to be discharged). This will reduce the likelihood of PSC action against ships that are in compliance with the BWM Convention. The approach proposed by Germany (MEPC 64/2/15 and BLG 17/4/2) appears to be satisfactory • Monitoring scheme (BLG 17/4/2) In general, Lloyd’s Register supports this approach. • Revision to type approval guidelines Lloyd’s Register shares the views on the need for revising the guidelines to provide greater clarity on the operational capabilities of approved BWM Systems. This will make it easier for ship operators to select a BWM System that suits the geographic locations that their ship is trading between. It will also reduce the likelihood of non-compliance as operators will be less likely to take up ballast water that their system is unable to treat effectively, or to operate the BWM System in a way that reduces treatment effectiveness. Reliability and repeatability are important elements. However, Lloyd’s Register also recognises impacts on the systems that have been already type approved, or systems under type approval process. Lloyd’s Register will carefully monitor the discussion. • Compatibility between BWM system and ballast tank coatings (BLG 17/6) Lloyd’s Register encourages all interested parties to work together to produce a unified test procedure for assessing the impact of treated ballast water on ballast tank coatings. Proposals given in BLG 17/6 appears to propose a satisfactory test procedure with clear pass/fail criteria. Their proposal to include the test within the Active Substance approval is supported. One concern may be the proposed duration of testing, currently 182 days, as this may delay the Active Substance approval (G9) and therefore final Type Approval (G8). Recognising that the performance of ballast tank coating systems varies significantly depending on the quality of the epoxy used, and that many existing ships will have ballast tank coatings that are not PSPC approved, Lloyd’s Register would encourage additional testing for compatibility with older, non-PSPC approved, ballast tank coating systems.

Advice to clients

Owners & operators: Discussion on sampling may affect choice of the system and potentially port operation. It is recommended to closely monitor the outcome. Builders & Manufacturers: This sampling issue may result in the review of the type approval guideline. If that happen, there will be significant impacts on the product already approved or those in the process for approval. Flag Administrations: The sampling issue is considered one of the barriers for the ratification. It is hoped that, BLG comes up with a workable solution.


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Applicability

Once the Convention enters into force, it will apply to all ships as follows: 1. All ships will be required to manage their ballast water and, in accordance with the Convention time scale,

will have to ensure that all ballast water discharged to the sea meets the D-2 discharge standard. It is expected that most ships will comply by installing an IMO Type Approved ballast water management system Additional requirements include the implementation of an approved ballast water management plan and maintenance of a ballast water record book.

2. All ships over 400 gt will be required to be surveyed and issued with a ballast water management certificate

valid for 5 years, subject to annual and intermediate surveys. For ships below 400 gt an Administration may specify a certification regime for applicable for their fleet for ships less than 400gt.

Documents submitted

BLG 17/4 & Corr.1 (Bahamas, Greece, Japan, Liberia, Panama, ICS, BIMCO, INTERTANKO, SIGTTO, INTERCARGO, InterManager and IPTA) - Implementation of PSC in absence of agreed IMO sampling guidelines This document suggests sampling exercises should not be undertaken before IMO concludes robust, transparent and simple PSC sampling guidelines. BLG 17/4/1 (Chairman) - Finalization of the draft circular on ballast water sampling and analysis protocols This document provides an overview of the requirements of the Ballast Water Management Convention, Guidelines (G2) and (G8), other guidance documents regarding this matter and their relations with the draft circular on ballast water sampling and analysis protocols BLG 17/4/2 (Germany) - Further comments and details on the monitoring and sampling of certain ballast water management systems This document proposes detailed self-monitoring standards for ballast water management systems (BWMS) and develops the proposals contained in document MEPC 64/2/15 (Germany) in more detail. BLG 17/4/3 (Vanuatu) - Methods for offshore support vessels compliance with the BWM Convention – draft circular This document contains a draft circular to allow near-coastal support vessels more flexibility in their methods of complying with the BWM Convention and meeting the functional requirements of the Convention by recognizing the operational patterns of such vessels BLG 17/4/4 (Liberia, Marshall Islands, ICS, INTERTANKO, INTERCARGO, InterManager, IPTA, IPPIC and NACE International) -Proposed amendments to BWM.2/Circ.28 and resolution MEPC.175(58) This document has been submitted to propose amendments to BWM.2/Circ.28 and resolution MEPC.175(58) as invited by MEPC 64. The proposed amendments are intended to improve the robustness and transparency of the Type Approval process and the associated approval documents and certificates. BLG 17/6 (IPPIC and NACE) - Compatibility between ballast water management systems and ballast tank coatings The majority of the current Type-Approved ballast water management systems make use of Active Substances to comply with the International Convention for the Control and Management of Ships' Ballast Water and Sediments. These substances may, depending on the substance, concentration, variation of operating conditions and exposure duration, have an adverse effect on the ballast tank coatings, ballast piping systems, and/or anodes within the tank. IPPIC and NACE International were invited to harmonize their recommendations on this matter and to provide a joint submission to BLG 17. This document contains a harmonized recommendation on corrosivity by IPPIC and NACE International


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BLG 17/INF.15 (EC) - The development of a sampling protocol and threshold to test whether a vessel is in gross non-compliance with the BWM Convention This report provides an update on work commissioned by the European Maritime Safety Agency on the development of a sampling protocol to test for gross non-compliance of the BWM Convention. BLG 17/INF.16 (Germany) - Information on a project concerning effective new technologies for the assessment of compliance with the Ballast Water Management Convention This document provides information on a project of the German Federal Maritime and Hydrographic Agency on identifying promising technologies to assess the compliance of ships with regulation D-2 of the Ballast Water Management Convention. Return to overall summary at start of document


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Annex 2B – Improved and new technologies approved for reduction of atmospheric pollution (Part of agenda item 6)

Overview

Agenda item 6 has two elements, i.e., one for technologies for ballast water management system and one for reduction of atmospheric pollution. In this annex, Lloyd’s Register addresses the elements of atmospheric pollution.

Background

The revised text of the MARPOL ANNEX VI introduced the following SOx control scheme.

Global Emission Control Area Currently: 4.5% Currently:1.5% From entry into force of revised Annex ( 1 July 2010) – 4.50 %

1 July 2010: 1.00%

1 January 2012: 3.50% 1 January 2015: 0.10% 1 January 2020: 0.50% ( or 1 January 2025: 0.50% depending of the review of the fuel availability in 2018)

This is an open ended continuous agenda item.


Lloyd’s Register will closely monitor the discussion.

Advice to clients

Owners / operators: LR agrees that there is a wide and diverse range of technological options available for reducing SOx emissions and that reductions of more than 80% are achievable. LR would advise operators that the decision over which SOx reduction technology to apply (eg. clean distillate, LNG, exhaust gas cleaning or alternate) will have to be analysed on a case by case basis. This will consider, but it not limited to, the time a vessel spends in an ECA, vessel particulars, the suitability of each technology for the ships in question and the financial paypack. There is no “one size fits all” solution and operators will need to give careful consideration to their SOx emissions reduction strategy, advising that early planning is necessary. LR has confidence in the capability of almost all of the technologies proposed to clean exhaust gas with SOx reduction of 80% and above if correctly designed, installed, commissioned and operated. Builders: Ship designers and builders will need to consider the means of meeting SOx emissions limits from the earliest stages of the design process. In particular, is the vessel to use a clean fuel or use exhaust gas cleaning. There is a wide and diverse range of technologies for cleaning exhaust gas and there is no “one size fits all” solution and ship builders will need to work with their customers in determining the most suitable SOx emissions reduction to meet the owners requirements. LR has confidence in the capability of almost all of the technologies proposed to clean exhaust gas with SOx reduction of 80% and above if correctly designed, installed, commissioned and operated. Manufacturers: Manufacturers are advised to engage with Recognised Organisations and flag administrations to ensure that they fully understand the requirements of applicable emissions to air regulations. In particular, there are options to demonstrate compliance and manufacturers should identify the most cost effective and suitable compliance verification options to recommend to their clients.


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Flag Administrations / Recognized Organizations: There remains a degree of confusion and uncertainty over the approach of different administrations to alternative means of compliance and the interpretation of the regulations. In particular the applicability of MEPC184(59) guidelines to technologies other than wet scrubbers. LR recommends that MEPC develops guidelines for each of the available technologies and any emerging technologies so as to ensure a suitably robust, effective and harmonised approach to the certification and emissions verification of alternative means of compliance which ensures consistency in their application

Further information is available on the Lloyd’s Register’s website (www.lr.org/eca)

Applicability

Ship choose to use Exhaust Gas Cleaning Systems as a solution to meet SOx control requirements.

Documents submitted

BLG 17/INF.8 (IMarEST) - Consideration of equivalent technologies for reduction of sulphur oxides (SOx) This document provides an overview of technologies that may achieve at least as effective sulphur oxide (SOx) emission reductions as low sulphur marine fuel. The document also introduces a clearing house for information by the International Council on Clean Transportation (ICCT) that will continue to provide updated state-of-the-art data on such technologies. This initial review of available technologies suggests that there are several different exhaust treatment and alternative fuel technologies that offer the potential for 80 per cent or greater SOx emission reduction. The information repository will be publically available and include information on the technologies' emission reduction potential, installations, technical and policy barriers to using these measures, and technology providers. Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 3 - Development of international measures for minimizing the transfer of invasive aquatic species through bio-fouling of ships (Agenda item 7) © Lloyd's Register 2013

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Annex 3 - Development of international measures for minimizing the transfer of invasive aquatic species through bio-fouling of ships (Agenda item 7)

Overview

Bio-fouling is considered to be a significant factor in the transfer of organisms and its control forms the second initiative by the IMO in its commitment to minimise the translocation of invasive species, the Ballast Water Convention being the other. BLG 17 will continue to discuss any issues and documents submitted under this agenda item, continuing the work from previous BLG and MEPC session.

Background

Following the adoption at MEPC 62 of the Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species, 2011 (resolution MEPC.207(62)), guidance was approved as MEPC.1/Circ. 792 on Guidance for minimizing the transfer of invasive aquatic species as biofouling (Hull fouling) for recreational craft. Lloyd’s Register has developed a model Biofouling Management Plan that the Austalian Department for Agriculture, Fisheries and Forestry refer to as meeting their national requirements. The model plan can be downloaded from www.lr.org/biofouling. Target completion year of the work is 2013.


Lloyd’s Register supports initiatives of developing these guidelines to control the transfer of invasive species via ships as well as the approach for investigating further about the possible further development.

Advice to clients

While management of biofouling is currently voluntary it is expected that this issue will increase in importance and, in the event that the IMO does not implement mandatory requirements in future, port States are likely to impose their own requirements.

Applicability

No immediate impact on Rules or MSPM however client facing offices and account managers should be advised on what services LR can offer clients (operators, builders and manufacturers) to assist with developing Biofouling Management Plans.

LR BLG 17 Agenda preview (Annex 3 - Development of international measures for minimizing the transfer of invasive aquatic species through bio-fouling of ships (Agenda item 7) © Lloyd's Register 2013

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Documents submitted

BLG 17/7 (Australia, the Netherlands and New Zealand) - Draft guidance for evaluating the Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species This document provides updated draft guidance for evaluating the effectiveness of the Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species. BLG 17/INF.9 (Australia, the Netherlands and New Zealand) - Draft performance measures for evaluating the Guidelines for the control and managementof ships' biofouling to minimize the transfer of invasive aquatic species This document provides draft performance measures for evaluating the effectiveness of the different components of the Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species. This information document also includes a draft questionnaire to support the collection of information on the performance measures. Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 4 - Development of international code of safety for ships using gases or other low flashpoint fuels (Agenda item 8)) © Lloyd's Register 2013

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Annex 4 - Development of international code of safety for ships using gases or other low flashpoint fuels (Agenda item 8)

Overview

Primary elements for discussion at this session will be: • Various proposed changes to the draft code (BLG 17/8. BLG 17/8/1, BLG 17/8/2, BLG 17/INF.11, BLG

17/INF.14) • Inclusion of fuels other than LNG such as Methyl/Ethyl alcohol (BLG 17/8/3, BLG 17/INF.10) • Operational issues, such as bunkering (BLG 17/8/4) • Application of the requirements given in SOLAS Chapter II-2 (BLG 17/6) • Location of gas fuel tank – proposed SOLAS regulation (BLG 17/8/7) • Others ( BLG 17/INF.13)

There will be a working group during BLG 17.

Background

MSC 87 considered the justification for, and approved the expand of, the scope of the item on "Development of provisions for gas-fuelled ships" as well as the change of the title of that item to "Code of safety for ships using gas or other low-flash point fuels with properties similar to liquefied natural gas". FP 56 (7 – 11 January) considered fire safety elements of the code; however it could not complete the review. Target completion year of the work is 2013.


There are several technical discussion points to which Lloyd’s Register has views as follows: • Possible approach toward completion of the draft IGF Code, including fuels other than LNG (BLG 17/8/1,

BLG 17/8/3, BLG 17/INF.10) In general, Lloyd’s Register supports the recommendations made by Norway in paragraph 12 and 13 of Paper BLG 17/8/1 “Report of the correspondence group” for IGF Code to only cover natural gas at first publication. The paper put forward by Sweden (BLG 17/8/3 i.e. to include Methanol on first issue of IGF Code) is supported provided inclusion of Methanol does not delay issue of the IGF Code. However, it is suggested that the work required to include Methanol would result in delay. Therefore, in general, Lloyd’s Register supports the recommendations made by Norway in paragraph 12 and 13 of Paper BLG 17/8/1 “Report of the correspondence group” for the IGF Code to only cover natural gas at first publication. This is because there is a need to progress a minimum and common standard for LNG as fuel across the industry. If inclusion of Methanol can be concluded without delay, Lloyd’s Register welcomes the proposal. • Definition of hazardous areas (Lloyd’s Register’s comments on the CG report – BLG 17/8/1)) Lloyd’s Register support the use of consistent IEC standards including definitions • Use of Emergency Shut Down (ESD) and single walled piping


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Although the EDS concept was incorporated into the draft text at BLG 15, Lloyd’s Register still maintains its concerns over the EDS protected machinery space concept • Compressed natural gas in general (Lloyd’s Register’s comments on the CG report – BLG 17/8/1) Lloyd’s Register is of the view that the majority of existing requirements, especially those for High pressure systems will be applicable. • Sect5ion 2.2.34 - Secondary barrier (BLG 17/8/2) Lloyd’s register noted that text is consistent with IGC Code but consideration should be given where thermal insulation is separate to the secondary barrier. See 6.4.2.1 and 6.4.8. Lloyd’s Register is of the view that consistency with IGC code in this regard is not be the sole solution to address the issue. It could be one of the solutions. • Chapter 5 - Requirements for arrangement of entrances and other openings (Lloyd’s Register’s comments on

the CG report – BLG 17/8/1) The following are the views of Lloyd’s Register

o Primarily access should be from the open deck. Where not practicable access can be via an airlock. o Requirements given in sections 5.11.2, 5.11.3, 5.11.4 and 5.11.5 overcomplicate the issue and do not

leave room for potential future installations. Section 5.11.1 sets the principle that should be followed. o 5.12.1 - Only airlock doors opening onto the open deck need to comply with load line o 5.12.1 - Does not include (bolted) hatches. This poses a significant safety risk to individuals. Can be

considered on a case by case basis. o 5.12.4 – Inconsistent with IGC Code. Lloyd’s Register proposed the text from the current text of the IGC

Code (Note – no change is proposed under revision work) should be reinstated: “An audible and visible alarm system to give a warning on both sides of the airlock shall be provided. The visible alarm shall indicate if one door is open. The audible alarm shall sound if doors on both sides of the air lock are moved from the closed positions.”

o 5.13.1 Original text from BLG 16 is preferable to make requirements clearer. Changed for Gas safe to non-hazardous “5.13.1 For non-hazardous spaces with access from hazardous open deck where the access is protected

by an air-lock, electrical equipment which is not of the certified safe type shall be de-energized upon loss of overpressure in the space.

For non-hazardous space with access from hazardous spaces below deck where the access is protected by an air-lock, electrical equipment which is not of the certified safe type shall be de-energized upon loss of underpressure in the hazardous space.”

o New 5.13.3 is proposed as Lloyd’s Register does not want to isolate essential safety systems “5.13.3 Essential equipment required for safety are not to be included in the disconnection and to be

suitably certified. This includes lighting, fire detection, PA/GA” • Section 7.3.5 – on Pipe connection (BLG 17/8/2) The proposal given in BLG 17/8/2 is not supported. This is because Type C tanks require a bottom connection. Lloyd’s Register supports the original text. • Section 7.4.1.3.1 – ballast condition (BLG 17/8/2) Lloyd’s register does not support the Japanese proposal. This is because gas as fuel storage tanks will not form part of ballast conditions. • 7.4.15.4.1 bis – new text on circulation of inert gas (BLG 17/8/2) Lloyd’s Register supports the text is reinstated in the Code as per the IGC Code. Membrane tanks on gas fuelled ships should meet the same requirements as those required by the IGC Code. It is understood that the text put forward by Japan is a copy of the text of the IGC Code.


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• New sections 7.10 to 7.12 - Atmosphere control of fuel containment system (BLG 17/8/2) Lloyd’s Register supports 7.10 in principle but maybe covered elsewhere in the code Support 7.11 and 7.12,, However, it does not support BLG 17/8/2 . Consideration should be given to hold spaces etc especially where vacuum insulated tanks are provided. • Section 14.3.7 – submerged fuel gas pump motor – alarm in low liquid level (BLG 17/8/2) Lloyd’s register welcomes the proposal provided the “low liquid level” and “low-low level” is related to the submerged pump/motor. This is because the intention is to ensure the pump and motor remain submerged. If “low liquid level” and “low-low level” do not relate to the pump/motor then LR does not support the proposed text. • Section 15.2.1.4 – Safety system – redundancy (avoidance of spurious shutdown) (BLG 17/8/2)

Lloyd’s Register if of the view that a gas fuelled shipl has more parameters related to the fuel supply system that may cause a shut-down in comparison to traditional machinery. The risk of a simple signal failure causing shutdown is therefore increased, and necessary, simple precautions should be taken to avoid spurious trips. The subject rule is giving a general design principle to ensure that the most common failures, e.g. in a signal loop will not cause a faulty shutdown. Redundancy may be a way to achieve this functionality, but loop monitoring and correct fail-to-safety action is another option. The general requirements related to redundancy are given in other paragraphs, and the proposed amendment is considered to address other principles than what was the original intention with this particular paragraph. Do not support this modification and propose to keep it as is. • Monitoring and safety functions (Chapter 15) (Lloyd’s Register’s comments on the CG report – BLG 17/8/1)

o It is noted that the requirements of 15.4 have been copied from the IGC Code and need to be updated to reflect the different context of use to that intended in the IGF Code.

o Table 1 - Support the inclusion or deletion of table 1 in chapter 15. As a minimum table has to be updated to ensure consistencies with the text. The table shouldn’t present requirements that are too restrictive based on future designs. Differences between single fuel and duel fuel designs need to be highlighted correctly.

o 15.7 Gas detection - Lloyd’s Register, believes that a redundant gas detection system (a system that has built-in redundancy) is more practical than two independent systems. However the text and table 1 are not consistent. If detection on two detectors is required 15.7.4 needs to be updated to include 2 detectors.

o 15.7.1 – Replace with following text (Thus not supporting BLG 17/2) “15.7.1 Permanently installed gas detectors shall be fitted in:

o the tank connection spaces o in all ducts around gas pipes o in machinery spaces containing gas piping, gas equipment or gas consumers o compressor rooms and fuel preparation rooms o other enclosed spaces containing gas piping or other gas equipment without ducting o other enclosed or semi-enclosed spaces where fuel vapours may accumulate including

interbarrier spaces and hold spaces of independent tanks other than type C Why “other than type C”

o air locks o gas heating circuit expansion tanks “

o Propose to delete existing 15.3.1 and make new reference to table 1 New text for 15.3.1? o Delete 15.3.2, 15.4.6, 15.4.7 and 15.3.3, in view of having more high level requirements. New text:

“15.3.3 Suitable instrumentation devices shall be fitted to allow a local and, or a remote reading of essential parameters to ensure a safe management of the whole fuel-gas equipment including bunkering.”

o 15.8 Requirements for fire detection – Requirement to automatically stop ventilation and close dampers is excessive and may lead to problems. Recommendation is alarm only and manual action to close (existing SOLAS requirement). Only exception is for Tank Connection spaces where the ability to starve the fire as quick is advantageous.


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Summary: o Tank Connection spaces -auto o machinery Spaces – ability to stop and closed remotely – manual* o Rooms containing independent tanks - ability to stop and closed remotely – manual* o Fuel gas processing rooms - ability to stop and closed remotely manual See 13.5 and 13.6 * Unless informed otherwise by risk analysis.

• Use of Portable tanks (Lloyd’s Register’s comments on the CG report – BLG 17/8/1)

o Portable tanks to be located in a dedicated area. If in an enclosed space this is only to be used for the tank storage and to be considered as a tank connection space.

o Portable tank installations to meet the same requirements as fixed tanks in terms of location, tank design, supports, fire etc.

o Dedicated operational procedures will be required. • Bunkering - HAZID report (BLG 17/INF.11) Lloyd’s Register appreciates a recognition that pressurised (Type C) tanks can fail. In Lloyd’s Register’s view, this is not universally accepted, but is supported by collation of accident statistics from UK HSE and Dutch government, etc. Futher, the HAZID report is not as detailed as the HAZIDs we have completed over the last six months. • Section 15.4 - Rollover of fuel (BLG 17/8/2 and BLG 17/INF.11) Rollover should be noted in IGF Code as a “need to consider”. It is judged that specific means to prevent rollover are system/ship/voyage specific and therefore cannot be prescribed but must be informed by risk analysis. • Methods for making the IGF code mandatory Lloyd’s Register in general supports the proposed amendments to the SOLAS. Lloyd’s Register also consider some consideration on the certification methods would be of benefit for all concerned. • Application of requirements given in SOLAS Chapter II-2 (BLG 17/8/6) Lloyd’s Register appreciates this document. However, owing to the timing of the release of the document, it was unable to go through the technical details. The proposals contained here will be reviewed carefully by internal experts. The work being done by the FP Sub-Committee should also be taken into consideration. • Location of gas fuel tank – proposed SOLAS regulation (BLG 17/8/7) This document touched upon an interesting point, however, owing to the timing of the release of the document, LR was unable to go through the technical details in depth. Noting that this paper has also been submitted to SLF 55, LR will review and comment as part of our preparation for that meeting.

Advice to clients

Lloyd’s Register’s Rules for the Classification of Natural Gas Fuelled Ships were published at July 2012 and updated at January 2013. The Rules explain the current Lloyd’s Register’s opinion on the use of natural gas (and low flash point fuel with similar properties, provided any differences are taken into account as a part of the design and their hazards mitigated) as fuel for ships other than LNG carriers. Clients are advised to use the above rules instead of Lloyd’s Register’s Provisional Rules for the Classification of Methane Gas Fuelled Ships (2007) and RESOLUTION MSC.285(86). Lloyd’s Register is continuously developing these Rules to reflect the up to date discussion result on the draft IGF code and clients are welcome to comment and participate in this Rule development. Lloyd’s Register Rules for the classification of Natural Gas Fuelled Ships exclude statutory requirements related to the use of natural gas as fuel.


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It should also be noted that Lloyd’s Register had developed a risk assessment model/method for natural gas a fuel design. The risk assessment model/method is recommended for future design appraisal work.

Applicability

If come into force, it will applicable to all ships, other than LNG carriers, using natural gas or other low flash point liquids mentioned in the code as fuel.

Documents submitted

BLG 17/8 (Chairman of the working group) - Report of the working group (Part 2) This document provides part 2 of the report of the Working Group on the Development of provisions for gas-fuelled ships met during BLG 16. It annexes draft International Code of Safety for Ships Using gases or other low-flashpoint Fuels (IGF Code). BLG 17/8/1 (Norway) – Report of the correspondence group This document contains the report of the Correspondence Group on the Development of the IGF Code established at BLG 16. It annexes further revised draft IGF code prepared by the correspondence group. BLG 17/8/2 (Japan) – Proposals for amendments to the draft IGF Code This document provides proposals for amendments to the draft IGF Code. The annex to the document contained various proposed amendments i.e. • 2.2.34 – on Secondary barrier • 7.3.5 – on Pipe connection • 7.4.1.3.1 – Liquefied gas fuel containment system – including ballast condition load • 7.4.1.4.3 and 7.4.9.5.2 – Accidental Design Condition and Loads caused by buoyancy – Loads due to

flooding • 7.4.12.2.6 – secondary barrier – fracture mechanics • 7.4.12.2.9 – location of tanks – fatigue design condition • 7.4.15.2.2.1 – effect of loads – structural analysis • 7.4.15.4.1 bis – new text on circulation of inert gas • 7.4.15.3.4.1 – Type C independent tank – consideration on static and dynamic stress • 7.10 – New text on Atmospheric control within the fuel storage system • 14.3.7 – submerged fuel gas pump motor – alarm in low liquid level • 15.2.1.4 – Safety system – redundancy (avoidance of spurious shutdown) • 15.7.1 – gas detection – proposal on the location of detectors BLG 17/8/3 (Sweden) - Comments on document BLG 17/8/1 This document comments on the report of the Correspondence Group for Development of the IGF Code established at BLG 16. Sweden presents a proposal on how fuel based Methyl/Ethyl alcohol could be included in the IGF Code. BLG 18/8/4 (Denmark) - Recommendations from the North European LNG Infrastructure Project This document informs about the recommendations from the North European LNG Infrastructure Project and proposes to include the relevant parts of these recommendations in the work on the development of an International Code of Safety for Ships using gases or other low-flashpoint fuels. The recommendation addresses various operational elements such as bunkering. BLG 17/8/5 – not yet posted BLG 17/8/6 (CESA) - Specific requirements for low-flashpoint fuels other than natural gas This document comments on the report of the correspondence group (BLG 17/8/1) and highlights the importance of ongoing work regarding the development of specific requirements for low-flashpoint fuels other than natural gas. In particular specific draft requirements for low-flashpoint diesel fuels are proposed


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BLG 17/8/7 (CESA) - Harmonizing distance criteria for gas fuel tanks and assumed penetration depth providing appropriate collision protection and damage stability The location criteria for gas fuel tanks of the draft IGF Code under development by the BLG Sub-Committee are based on the IGC Code damage assumptions. This approach is neither consistent with the damage stability concept of SOLAS used for passenger ships nor with the location requirements of the IGC Code. This document presents a proposal to harmonize the damage assumptions and subdivision according to SOLAS regulation II-1/8 with regulation 5.3.4.1 of the draft IGF Code (BLG 17/8/1) providing both protection and flexibility.. BLG 17/INF.10 (Sweden) - Additional information on Methyl/Ethyl as marine fuel Risk management plan and GAP-analysis This document provides additional information on Methyl/Ethyl as marine fuel and complements the proposal submitted by Sweden in document BLG 17/8/3. In annex 1 a risk management plan for Methyl/Ethyl alcohol as marine fuel is described. Annex 2 presents a GAP-analysis of the need for specific requirements for Methyl/Ethyl alcohol. BLG 17/INF.11 (Germany and Norway) - HAZID report This document contains the results of a hazard identification for ships using LNG as fuel. BLG 17/INF.13 (Denmark) - Information on recommendations from the North European LNG Infrastructure Project This document informs about the executive summary and the recommendations from the North European LNG Infrastructure Project, which was finalized in May 2012. BLG 17/INF.14 (Germany) - Information for transverse location of fuel tanks This document presents information on a possible procedure for the lateral arrangement of gas fuel tanks with the background of collision safety based on methodology of IMO alternative design. Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 5 - Development of revised IGC Code (Agenda item 9) © Lloyd's Register 2013

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Annex 5 - Development of revised IGC Code (Agenda item 9)

Overview

BLG 17 will consider a consolidated text prepared by the Secretariat which incorporates discussion at BLG 16 held from 30 January to 3 February 2012. Primarily discussion points at BLG 17 will be • Various editorial improvement ( BLG 17/9/1) • Emergency shutdown arrangement (BLG 17/9/2) • Application of requirements to existing ships, in particular, Emergency Shutdown System (EDS) (BLG 17/9/3) • Limit State Design Concept (BLG 17/9/3) – there will be not text for consideration at BLG 17 • Reference to MARPOL Convention (BLG 17/9/5) • Status of the code, i.e., revision to existing code or a new code (BLG 17/9/6)

Background

In October 2007, MSC 83 tasked BLG to review all current areas of the IGC Code with a view to fully revising and updating the Code and, where necessary, to identify other instruments which may be affected and require consequential amendments, taking into account the latest technologies, operational practices and the increasing size of the newest ships. Lloyd’s Register was intimately involved in the SIGTTO project to develop a revised IGC Code. Significant technical input was given by Lloyd’s Register’s specialists as members of the working groups. Therefore the vast majority of the text in the draft code is supported by Lloyd’s Register. Target completion year of the work is 2013.


Limit State Design Concept The concept of limit state design proposed for paragraph “4.26 Guidance on Limit State Design” was rejected during WG5 organized by SIGTTO while preparing a based document that was submitted to BLG 15. Lloyd’s Register voted against the inclusion of this paragraph, as in Lloyd’s Registers’ view, this methodology has not been sufficiently developed. At BLG 16, some issues related to limit state design guidelines were considered by an informal group of interested delegations and BLG 17 endorsed the proposed changes agreed by the group (BLG 16/16, paragraph 7.12). As set out in paragraph 4.27 in the annex to the document BLG 17/9, it was agreed to incorporate short texts for "limit state design for novel concepts". As mentioned in draft paragraph 4.27.3, it was further agreed to develop draft MSC resolution for "The Use of Limit State Methodologies in the Design of Containment Systems of Novel Configuration" as mandatory instrument. Unofficial intersessional work could not produce a base document for discussion at BLG 17 (BLG 17/9/4). Lloyd’s Register understands that further careful work would be needed if “Limit State Design Concept” will be a part of the revised IGC code with a mandatory resolution which will provide details of application. Limit State Design Concept, if introduced in the IGC code, should take into account concept for design and operation as well as casualty data of gas carriers, rather than using those of offshore industry. Otherwise, Lloyd’s Register recommends following established prescriptive approach. Status of the code


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It is still not clear whether the code under discussion is revision to the existing code or a new code. Readers may recall existing code does have elements that are applicable to existing ships, such as operational and training requirements. If this is a new code, there must be a set of corresponding amendments to existing IGC code and Gas code to update such operational and training requirements. At BLG 16, there was substantial progress on the draft text of the code; requirements have been revised to reflect developments in technology as well as many editorial improvements. The draft developed at BLG was forwarded to other relevant Sub-Committees for their review: Filling limit Current proposal on 15 degree limitation could be too rigorous. Lloyd’s Resister, having examined existing gas carrier fleet, concluded that If the 15° list and no separate vapour pocket requirements, as stipulated in IACS Recommendation No. 109 and the draft IGC Code, are applied, representative membrane tanks will require filling limits of less than 98%. Those tanks with a greater width of flat roof are more affected than those with narrower ones. Lloyd’s Register considers that a better way forward is to request that the 15° list be rescinded and that the maximum operational angle of list, under intact stability conditions, be obtained for each ship and this used when determining the maximum filling limit for each cargo tank.

Advice to clients

General • A goal statement has been added to each chapter, although the requirements remain prescriptive

Ship Design and Arrangement • The definition and delineation of gas dangerous spaces has been changed to reflect IEC practice • Changes to the separation of the cargo tank from the side shell • Safety principles and functional requirements introduced into Chapter 4- Cargo Containment • Introduction of new material grade FH • Introduction of “limit state methodologies” for novel configuration of cargo containment design that

cannot meet prescriptive requirements given in the draft revised IGC Code. A further guidance for this “limit state methodologies” are being developed by the BLG Sub/Committee

Electrical systems • Substantial revision of Chapter 10 – Electrical Systems, to reflect current IEC requirements • Tank pressures and hull temperatures to be controlled also in the event of single faults in the electrical

supply. Cargo Handling • Cargo tank pressure relief valve - in the event of a failure or a cargo tank pressure relief valve a safe means

of emergency isolation shall be allowed • Means to monitor the quality of inert gas supplied to the insulation space • Introduction of requirements for vapour oxidation which include boilers and gas combustion units Operation • Requirements for a Cargo Operation Manual • Method to assess the acceptability of increased filling limits • Sequential lifting of relief valves in order to minimise the release of vapour. • The number of Safety Equipment sets increased from two to three • Cargo transfer – requirements for a pre-cargo operation meeting


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Applicability

All new ships constructed after the date defined by the IMO

Documents submitted

BLG 17/9 (Secretariat) - Draft revised IGC Code This document provides the draft revised IGC Code/ At BLG 16, a text indicating amendments to the previous version was produced (BLG 16/WP.7). This is a consolidated version of the most updated draft prepared by the Secretariat. BLG 17/9/1 (Japan and SIGTTO) - Editorial modification to the draft revised IGC Code This document proposes editorial modifications to the draft revised IGC Code set out in the annex to document BLG 17/9. BLG 17/9/2 (Japan, Marshall Islands, United Kingdom and SIGTTO) - Proposed modification of draft revised IGC Code (ESD requirements) This document proposes modifications to the draft revised IGC Code regarding Emergency Shutdown (ESD) systems (i.e. section 18.10 in the annex to document BLG 17/9) BLG 17/9/3 (Japan and SIGTTO) - Application of the requirements to existing ships This document provides comments on the draft revised IGC Code set out in the annex to document BLG 17/9 in regard to the application of the requirements to existing ships. This document, in particular, address the application of Emergency Shutdown System given in paragraph 18.10.1 of the draft code. BLG 17/9/4 (Germany, Japan, Norway and SIGTTO) - Standards for the use of limit state methodologies in the design of containment systems of novel configuration This document informs the Sub-Committee of the consideration on the draft MSC resolution for use of limit state methodologies in the design of containment systems of novel configuration. The group of experts in Germany, Japan, Norway and ship classification societies have tried to prepare the draft MSC resolution based on the text in paragraph 4.26 in annex 1 to document BLG 16/7, taking into account the document BLG 16/7/1. However, additional discussion is needed for some points, e.g. methods for deriving relevant safety factors prior to finalization of the draft resolution. It is the intent of the co-sponsors to submit the final draft to the next session of the Sub-Committee. BLG 17/9/5 (Japan and SIGTTO) - Reference to the MARPOL Convention in the draft revised IGC Code This document provides comments on the draft revised IGC Code set out in the annex to document BLG 17/9. The draft revised IGC Code, set out in the annex to document BLG 17/9, refers to the MARPOL Convention in many places, while the existing IGC Code does not refer to the Convention and the Convention does not refer to the IGC Code. BLG 17/9/6 (Japan and SIGGTO) - Application of the Code and relevant amendments to the Code and SOLAS Convention This document requires clarification of the status of the draft revised code and proposes modifications to the draft revised code and possible amendments to the SOLAS Convention Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 6 - Consideration of the impact on the Arctic of emissions of Black Carbon from international shipping (Agenda item 9) © Lloyd's Register 2013

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Annex 6 - Consideration of the impact on the Arctic of emissions of Black Carbon from international shipping (Agenda item 10)

Overview

BLG 17 will review the outcome of the correspondence group established by BLG and documents submitted to BLG 17.

Background

The concept of black carbon has recently entered the environmental protection lexicon. It refers to small particles that have light-absorbing characteristics local to where they are emitted. Early signs show the Arctic region is particularly susceptible to these effects, and as the nearest industrialised land mass to the Arctic, the European Union is paying close attention to the causes and effects of black carbon in relation to its potential impact on climate change. The impact that international shipping has on the production of such elements is not yet known, but certainly requires consideration.


Lloyd’s Register will closely monitor the discussion in IMO as well as other international forum on this development.

Advice to clients

This is still early stage of the discussion. No concrete requirements for ships are envisaged. Nevertheless, it is encouraged to closely monitor the discussions.

Applicability

To be decided at a future session.

Documents submitted

BLG 17/10 (United States) – Report of the Correspondence Group This document provides the report of the correspondence group established at BLG 16 under this agenda item. A drat definition of Black carbon is provided as follows: “Black Carbon from international shipping is formed by incomplete combustion of hydrocarbon fuels, and is the most effective component of particulate matter (PM), by mass, at absorbing solar energy." A set of control measures are also proposed. BLG 17/10/1 (EUROMOT) - Proposal for a measurement method to determine Black Carbon emissions on test beds and on board ships This document proposes to determine Black Carbon emissions via the filter smoke number method (FSN). It is an optical measurement technique, which is derived from automotive industry applications, hence technically well proven and standardized in ISO-10054. It is robust, technically relatively simple and can easily be applied to test bed measurements, as well as on board ships. BLG 17/10/2 (CSC) - Comments on the progress in the Correspondence Group and the investigation of appropriate control measures (abatement technologies) to reduce Black Carbon emissions from international shipping This document provides comments on certain aspects of document BLG 17/10, the report of the Correspondence Group considering the impact on the Arctic of emissions of Black Carbon from international

LR BLG 17 Agenda preview (Annex 6 - Consideration of the impact on the Arctic of emissions of Black Carbon from international shipping (Agenda item 9) © Lloyd's Register 2013

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shipping, and notes that the independent report on appropriate control measures presented in document BLG 17/INF.7 contributes to answering the concerns and the request for studies expressed during the Correspondence Group. BLG 17/10/3 (CSC) - Comments on the progress in the Correspondence Group and the revised estimates of Black Carbon emissions from global and Arctic shipping This document provides comments on certain aspects of document BLG 17/INF.2 reviewing black carbon emissions inventories in the Arctic, and provides recent additional data on Arctic melting, the opening and the use of Arctic sea routes in 2012 BLG 17/INF.2 (IMarEST) - Revised estimates of Black Carbon emissions from global and arctic shipping This document provides a critical review of marine Black Carbon (BC) inventories, identifies differences in published estimates, and revises the IMO BC inventory based on measured emission factors and refinements to emission factor estimates. IMarEST finds a wide range of estimates in BC emissions from international shipping due primarily to uncertainties in emission factors. Using higher-resolution emission factors drawn from real-world testing on ships and activity data taken from both the second IMO GHG study and the peer-reviewed literature, IMarEST estimates that shipping was responsible for about 184,000 tonnes of BC in 2007 and about 2,800 tonnes in the Arctic in 2004. These estimates are higher by 42% and 90%, respectively, than previously published IMO and peer-reviewed estimates. BLG 17/INF.4 (United States) - Report of the Correspondence Group – Comments submitted to the Correspondence Group This document provides a collation of comments received during the work of the correspondence group established at BLG 16 under this agenda item BLG 17/INF.7 (Secretariat) - Investigation of appropriate control measures (abatement technologies) to reduce Black Carbon emissions from international shipping This document provides the report of an investigation of appropriate control measures (abatement technologies) to reduce Black Carbon emissions from international shipping. Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 7 - Review of relevant non-mandatory instruments as a consequence of the amended MARPOL Annex VI and the NOx Technical Code (Agenda item 8)) © Lloyd's Register 2013

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Annex 7 - Review of relevant non-mandatory instruments as a consequence of the amended MARPOL Annex VI and the NOx Technical Code (Agenda item 8)

Overview

BLG 17 will consider the guidelines prepared by the correspondence group established by BLG 16 (BLG 17/11 and BLG 17/INF.5) There are comments submitted to these draft prepared by the group. • Draft guidelines for replacement engines not required to meet the Tier III limit • Draft guidelines to outline the information to be submitted as part of the required notification from an

Administration to the Organization in respect of the approval of an Approved Method • Draft guidelines pertaining to equivalents set forth in regulation 4 of MARPOL Annex VI and not covered by

other guidelines (BLG 17/11/3, BLG 17/11/4) • Dual fuel engine issue (BLG 17/11/1) • Exhaust Gas Cleaning System (BLG 17/11/2, BLG 17/INF.3)

Background

After the adoption of the 2008 revision to MARPOL Annex VI, MEPC tasked BLG to continue the revision of guidelines and other issues affect by this revision. Target completion year of the work is 2013.


Various issues will be addressed under this agenda item. Lloyd’s Register has the following views for each discussion points: • Draft guidelines for replacement engines not required to meet the Tier III limit LR supports the development of guidelines for replacement engines not required to meet the tier III limit and for the working/drafting group to develop such guidelines based on the criteria agreed and as proposed in the report of the correspondence group. However, in depth examination as to current engine replacement may need to be further examined. • Draft guidelines to outline the information to be submitted as part of the required notification from an

Administration to the Organization in respect of the approval of an Approved Method LR supports the development of guidelines for the approval of Approved Methods and for the working/drafting group to develop such guidelines based on the criteria proposed in the report of the correspondence group. Lloyd’s Register is of the view that, as a contract point, the engine manufacturer of the engine in question should be nominated. • Draft guidelines pertaining to equivalents set forth in regulation 4 of MARPOL Annex VI and not covered by

other guidelines (BLG 17/11/3, BLG 17/11/4)


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LR supports the development of guidelines for demonstrating equivalence of alternative methods and procedures of compliance, using annex 3 to BLG 17/11, as a starting point and taking into account the criteria for determining equivalency as well as the elements of guidelines for considering equivalency under regulation 4 of MARPOL Annex VI, as suggested by the correspondence group. However, due to the complexity of the issue, Lloyd’s Register envisages further works after BLG 17. • Dual fuel engine issue (BLG 17/11/1) LR does not support the proposal as this is deviation from the fundamental principle set out in the existing NOx technical code as follows: 1.3 Definitions 1.3.10 Where an engine is intended to be operated normally in the gas mode, i.e. with the main fuel gas and only a small amount of liquid pilot fuel, the requirements of regulation 13 have to be met only for this operation mode. Operation on pure liquid fuel resulting from restricted gas supply in cases of failure shall be exempted for the voyage to the next appropriate port for the repair of the failure. 5.3 Test Fuel Oils Duel fuel engines using liquid fuel as pilot fuel shall be tested using maximum liquid to gas fuel ratio. The liquid fraction of the fuel shall comply with 5.3.1, 5.3.2 and 5.3.3. • Exhaust Gas Cleaning System (BLG 17/11/2, BLG 17/INF.3) LR believes that the existing wash water guidelines are suitable and sufficient and that the issues around wash water discharge monitoring are a result of a misinterpretation of the requirements rather than any failings of the guidelines. LR believes that the discharge limits are appropriate and that there is no reason to change these limit values based on arguments that they are below levels expected to damage the marine eco system given that the purpose in developing these limits was to safe guard the marine eco system.

Advice to clients

• Where replacing an engine Lloyd’s Register would advise clients to engage with Lloyd’s Register to ensure that where a replacement engine is required and it is not possible to fit a Tier III compliant engine as soon as possible to ensure that the new engine is acceptable under statutory requirements.

• Where an Approved Method is approved for a clients systems then Lloyd’s Register recommends that they engage with the equipment supplier and Lloyd’s Register to manage the implementation of any changes required to such systems.

• At present the MEPC184(59) guidelines are being applied to exhaust gas cleaning technologies which are not wet scrubbing systems, LR would advise clients that these guidelines are applicable only to wet scrubbing systems and that they can only be applied to other technologies where it can be demonstrated that they are suitable and sufficient. In particular, if considering any technology which discharges wash water to sea then we would advise clients to engage with LR to confirm that wash water quality control and monitoring arrangements are adequate, this will also need the approval of the flag state.

• Lloyd’s Register would advise clients that the wash water requirements of MEPC184(59) do not require monitoring of water quality at a point 4m from the hull and that where they are faced with advice to this effect then they should contact Lloyd’s Register who can provide clarification of these wash water requirements.

• Any clients considering an averaging scheme as a means of alternative compliance is advised to engage with both Lloyd’s Register and the Flag State at the earliest opportunity so as to consider the acceptability, approval and implementation of such a scheme.

• Suppliers and operators of dual fuel engines should continue to monitor developments on possible changes to the NOx approval of such engines, at the moment there is no reason to make any change to existing arrangements.


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Applicability

• Ships which operate in emissions control areas. • All clients which may be considering replacing old engines on existing vessels.

Documents submitted

BLG 17/11 (United States) - Report of the Correspondence Group This document provides the report of the correspondence group established at BLG 16 under this agenda item BLG 17 is invited to consider the report of the correspondence group and take action as appropriate and, in particular, to:

.1 consider, with a view to agreeing, in principle, to the criteria for development of draft guidelines for replacement engines not required to meet the tier III limit, set out in annex 1; and instruct the working/drafting group to develop such guidelines based on the criteria agreed;

.2 instruct the working/drafting group to further develop, with a view to finalization, the draft guidelines to outline the information to be submitted as part of the required notification from an Administration to the Organization in respect of the approval of an Approved Method as required under regulation 13.7.1 of MARPOL Annex VI, using annex 2 as a basis;

.3 consider the need to develop guidance regarding the alternative option to comply by means of the provisions of regulation 13.7.1.2 of MARPOL Annex VI; and

.4 instruct the working/drafting group to further develop the guidelines for demonstrating equivalence of alternative methods and procedures of compliance, using annex 3 as a starting point and taking into account the criteria for determining equivalency as well as the elements of guidelines for considering equivalency under regulation 4 of MARPOL Annex VI, as suggested by the correspondence group in paragraphs 11 and 15 of this document.

BLG 17/11/1 (Japan and EUROMOT) - Proposal to amend the NOx Technical Code 2008 concerning use of dual fuel engines "Marine diesel engines" include dual fuel engines according to the NOx Technical Code 2008 (the Code). However, due to lack of definitions of fuel gas composition and some of factors in the relevant formulae, NOx emission cannot be calculated for dual fuel engines by the current Code. In order to resolve this situation, this document proposes amendments to the Code, so that dual fuel engines can also be appropriately certified in accordance with the Code. BLG 17/11/2 (Denmark) - Issues related to resolution MEPC.184(59) on 2009 Guidelines for Exhaust Gas Cleaning Systems This submission addresses outstanding issues with regards to the amendments to the washwater discharge criteria for exhaust gas cleaning systems as found in section 10 of the 2009 Guidelines for Exhaust Gas Cleaning Systems, adopted through resolution MEPC.184(59). BLG 17/11/3 (United States) - Guidelines for Equivalent Methods: Regional emissions averaging Draft guidelines pertaining to equivalents set forth in regulation 4 of MARPOL Annex VI should include the use of emissions averaging schemes to demonstrate compliance with MARPOL Annex VI requirements. A well-designed, regionally-limited emission averaging programme can meet the requirement of equivalent emission reductions while providing shipowners with compliance flexibility and reducing their compliance costs. BLG 17/11/4 (CSC) - Equivalents under regulation 4 of MARPOL Annex VI and emissions trading This document provides comments on certain aspects of document BLG 17/11, the report of the correspondence group relating to the development of guidelines pertaining to, among other things, equivalents set forth in regulation 4 of MARPOL Annex VI. BLG 17/INF.3 (Denmark) - Assessment of possible impacts of scrubber water discharges on the marine environment This document provides information on the study: "Assessment of possible impacts of scrubber water discharges on the marine environment" carried out by COWI on behalf of the Danish Ministry of Environment. The study was carried out in order to attain a more detailed assessment, to inform the ongoing international evaluation


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of criteria for washwater from wet scrubbers (Exhaust Gas Cleaning Systems). It was found that compared to current environmental acceptability levels the discharges from scrubbers can be expected to be considerably below the levels of ecological concern. BLG 17/INF. 5 (United States) - Report of the Correspondence Group � Comments submitted to the Correspondence Group This document provides a collation of comments received during the work of the correspondence group established at BLG 16 under this agenda item. Return to overall summary at start of document

LR BLG 17 Agenda preview (Annex 8 - Development of a code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (Agenda item 12)) © Lloyd's Register 2013

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Annex 8 - Development of a code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (Agenda item 12)

Overview

BLG 17 will continue its consideration of the item with a view to deciding on how best to proceed with the development of the draft OSV Chemical Code, taking into account taking into account the report of the correspondence group formed following BLG 16, submissions made by Member Governments and international organizations to the session.

Background

MEPC 60 tasked BLG to update the existing “Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk in Offshore Support Vessels” (A.673(16)) and to develop a replacement Code. The rationale for this is to take into account advances in technology, the increased size of Offshore Support Vessels (OSVs) and the increased quantities of flammable, hazardous and noxious liquid substances carried by these vessels. In addition, the existing guidelines are open to interpretation which has lead to a variance in their application. Target completion year of the work is 2013.


Lloyd’s Register has followed the discussions in the correspondence group with interest. There remain a number of areas where there are still some discussions to be taken place before consensus can be reached. LR will continue to monitor developments with interests. It is expected that the target completion date is currently 2013.

Advice to clients

As the work on the development is at its infancy, it is still not possible to predict precise impact to the industry at this stage. Early indications are that there will be an increase in the quantity of hazardous or noxious liquid substances which will be permitted to be carried. The damage stability requirements are also expected to be changed with the assistance of the SLF Sub-Committee.

Applicability

The new Chemical Code will be applicable to OSVs.

Documents submitted

BLG 17/12 (Denmark) - Report of the Correspondence Group This document contains the report of the correspondence group on the development of the draft Code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (OSV Chemical Code) established at BLG 16. Major issue raised during intersessional work was a damage stability. BLG 17 is invited to extend target completion date.

LR BLG 17 Agenda preview (Annex 8 - Development of a code for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk in offshore support vessels (Agenda item 12)) © Lloyd's Register 2013

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BLG 17/INF.6 (Denmark) - Report of the Correspondence Group – Draft OSV Chemical Code and comments received during the work of the Correspondence Group This document provides the text of the draft OSV Chemical Code and a collation of comments received during the work of the correspondence group established at BLG 16 under this agenda item. Return to overall summary at start of document

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