ESA SAFETY BULLETIN 000/2017 1

ESA Ship Management Ltd. Malta #000/2017

IN THIS NUMBER:

--- EU-MRV: an introduction --- New SOLAS requirements for lifeboat servicing --- Living with Cyber-Risk --- Fighting antibiotic resistance – it is in your hands --- International Ballast Water Convention & US Ballast Water Management

The regulation aims to quantify and reduce the CO2 emissions from shipping. The EU-MRV Regulation (Monitoring, Reporting, and Verification) entered into force / came into effect on the 01st July 2015.

All ship owners and operators will have to monitor and report the verified amount of CO2 emitted by their vessels (>5000) on voyages to, from and between EU ports. Information such as fuel consumption, cargo loads and energy efficiency parameters will also need to be provided.

The EU is calling for a global approach to reducing greenhouse gas emissions from international shipping – a large and growing source of emissions. As a first step, large ships using EU ports will be from 2018 required to report their verified annual emissions and other relevant information. Maritime transport emits around 1000 million tonnes of CO2 annually and is responsible for about 2.5% of global greenhouse gas emissions (3rd IMO GHG study). Shipping emissions are predicted to increase between 50% and 250% by 2050 – depending on future economic and energy developments. This is not compatible with the internationally

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agreed goal of keeping global temperature increase to below 2°C compared to pre-industrial levels, which requires worldwide emissions to be at least halved from 1990 levels by 2050.

Ships' energy consumption and CO2 emissions could be reduced by up to 75% by applying operational measures and implementing existing technologies (2nd IMO GHG study). Many of these measures are cost-effective and offer net benefits, as reduced fuel bills ensure the pay-back of any operational or investment costs. Further reductions could be achieved by implementing new innovative technologies.

The EU and its Member States have a strong preference for a global approach led by the International Maritime Organization (IMO) as this will be most effective. Considerable efforts to agree such an approach have been made over recent years within both the IMO and the United Nations Framework Convention on Climate Change (UNFCCC).

In 2011, the IMO adopted the:

Energy Efficiency Design Index (EEDI), which sets compulsory energy efficiency standards for new ships, and

Ship Energy Efficiency Management Plan (SEEMP), a management tool for ship owners.

However, international discussions have yet to bring agreement on global market-based measures or other instruments that would cut emissions from the sector as a whole, including existing ships. Recently, new ideas on technical and operational measures have been proposed, with a perspective of agreeing on a global data collection (or monitoring, reporting and verification) system as the next step.

The European Commission contributes €10 million funding to an EC-IMO energy efficiency project. The 4-year project aims to establish Maritime Technology Cooperation Centres in 5 regions: Africa, Asia, the Caribbean, Latin America and the Pacific. Through technical assistance and capacity-building, the centres will promote the uptake of low carbon technologies and operations in maritime transport in the less developed countries in the respective region. This will also support the implementation of the internationally agreed energy efficiency rules and standards (EEDI and SEEMP).

The Commission's 2011 White Paper on transport suggests that the EU's CO2 emissions from maritime transport should be cut by at least 40% from 2005 levels by 2050, and if feasible by 50%. However, international shipping is not covered by the EU's current emissions reduction targets. In 2013, the Commission set out a strategy for progressively integrating maritime emissions into the EU's policy for reducing its domestic greenhouse gas emissions.

The strategy consists of 3 consecutive steps:

Monitoring, reporting and verification of CO2 emissions from large ships using EU ports

Greenhouse gas reduction targets for the maritime transport sector

Further measures, including market-based measures, in the medium to long term

The MRV shipping Regulation adopted in April 2015 creates an EU-wide legal framework for the monitoring, reporting and verification of CO2 emissions and other relevant information from maritime transport. It also helps the EU generate momentum for the best possible outcome in the international discussions. Please note that further to the Decision 215/2016 of the EEA Joint Committee from 28th October, the MRV shipping Regulation has been included in the EEA agreement, all references in the MRV shipping Regulation to Member States should be interpreted as including all relevant EEA States (the EU Member States, Iceland and Norway).

It requires large ships (over 5 000 gross tonnes) irrespective of where the ship or the company is registered calling at EEA ports from 1 January 2018 to monitor their CO2 emissions and other relevant information emitted on journeys to, from and between EEA ports of calls, and also when in EEA ports of call.

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Companies having assumed the MRV responsibility for ships visiting EEA ports will have to:

By 30 August 2017 submit to an accredited MRV shipping verifier a Monitoring Plan, consisting of complete and transparent documentation of the monitoring method and procedures to be applied for each of the ships under its responsibilities;

From 1s January 2018, monitor and report to an accredited MRV shipping verifier, data on each ships' CO2,, fuel consumption and other parameters, such as distance, time at sea and cargo carried, so as to determine the ships' average energy efficiency;

From 2019,by 30 April of each year submit electronically to the Commission satisfactorily verified Emissions report for each of the ships concerned

From 2019, by 30 June of each year ensure that, all ships having performed activities in the precedent reporting period and visiting EU ports, carry on board a document of compliance issued by an accredited MRV shipping verifier. This might be subject to inspections by Member States' authorities.

In order to complete the MRV shipping legal framework, the Commission adopted on 22 September 2016, two Delegated Regulations amending the monitoring methods and rules in Annexes I and II to Regulation 2015/757, and further specifying rules for verification and accreditation of MRV shipping verifiers. These two delegated Regulations aim at helping companies to fulfil their monitoring and reporting obligations in a harmonised way, and set additional rules for verification and accreditation of MRV shipping verifiers. Also two Implementing Regulations have been adopted by the Commission and will enter into force in November 2016.

Implementing Regulation (EU) 2016/1928 on determination of cargo carried for categories of ship others than passenger’s ro-ro and container ships pursuant to Regulation (EU) 2015/757

Implementing Regulation (EU) 2016/1927 setting templates for monitoring plans, emissions reports and documents of compliance pursuant to Regulation (EU) 2015/757

What is the geographical scope of EU MRV?

All voyages calling at an EEA port of call are subject to EU MRV

EU Member States: Belgium, Bulgaria, Croatia, Republic of Cyprus, Denmark, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Latvia, Lithuania, Malta, Netherlands, Poland, Portugal, Romania, Slovenia, Spain, Sweden and the UK.

EEA Member States: EU Member States + Iceland + Norway

EEA outermost regions: Açores, Canary Islands, French Guiana, Guadeloupe, Madeira, Martinique, Mayotte,

Reunion and Saint Martin

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New SOLAS requirements for lifeboat

servicing

Michael Røssland, Vice President, Norsafe Academy

focused on the “New SOLAS requirements for

lifeboat servicing“. He referred to the new

resolution and amendments to SOLAS approved by

IMO regarding requirements for periodic service of

lifesaving equipment. Mr Røssland explained that

this resolution requires documented competency

and approval of personnel conducting services and

outlined necessary actions for vessels, shipowners,

flag, class and servicing companies to comply.

A new resolution concerning Life Saving Appliances

(lifeboats, davits, winches, rescue boats, hooks) has

been approved by IMO and as every regulation has

its challenges when it comes to implementation, we

are going to address what this will specifically

require.

During last decades, several accidents, detention and

losses that have been reported and calling for new

regulations. Ten years ago, the MSC Circ.1206

addressed seven main reasons for lifeboat accidents.

The Committee noted that most accidents fell under

the following categories:

1. Failure of on-load release mechanism

2. Inadvertent operation of on-load release

mechanism

3. Inadequate maintenance of lifeboats, davits and

launching equipment

4. Communication failures

5. Lack of familiarity with lifeboats, davits,

equipment and associated controls

6. Unsafe practices during lifeboat drills and

inspections and

7. Design faults other than on-load release

mechanisms

From the above, categories under issue 2,3,4,5,6 are

clearly related to competency fields. On an

international basis, when an accident occurs, we

tend to blame the equipment. Some say that the

equipment itself is the major factor of the accident.

Failure of on-load release mechanisms was a hot

topic for years and eventually lead to a new

regulation, requiring all on-load hooks to be replaced

with new ones; this is currently ongoing. The sad

thing is that accidents continue to happen. Who to

blame now? The answer is still bad or the absence of

maintenance. Maintenance and its requirements

have been a topic under discussion for many years

among industry associations. This year, a new

resolution is adopted requiring an amendment to

SOLAS to solve the problems of maintenance.

MSC 96 approved amendments to SOLAS Regulation

III/20 regarding operational readiness, maintenance

and inspections and also instructions for onboard

maintenance. Specifically, resolution MSC 402(96)

adopted entitled ‘’Requirements for maintenance,

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thorough examination, operational testing, overhaul

and repair of lifeboats and rescue boats, launching

appliance and release gear.’’ The resolution will be

effective from 2020.

The new resolution addresses the following:

1. 5 year cycles for inspections

There is still requirement of 5-year cycles for

inspections. The fifth year there will be a thorough

examination; a 5 yearly inspection will take place.

2. Maintenance cycle of LSA

Inspections and maintenance are two completely

different things. During one year, from one annual

inspection to the next, there would be need for

weekly maintenance, monthly maintenance as well

as repairs and replacement of parts.

3. Roles and responsibilities

The original equipment manufacturer or authorized

service companies are responsible to conduct the

annual inspections. However, from one annual

inspection to the next, the ship crew has

responsibility for all the maintenance on board (52 x

weekly maintenance/ 12 x monthly maintenance /

repairs / replacement of parts)

4. Competence requirements

▪ The original equipment manufacturer does not

need any approval for conducting services.

▪ Other service companies may be approved by

flag/class based on:

▪ Approved quality system

▪ Access to original parts, manufactures checklists

and drawings, service notices, product notices etc.

▪ Service engineers personal certification or

documented training for each brand and type of

equipment

Training of service engineers shall include practical

technical training on thorough examination,

operational testing, maintenance, repair and

overhaul techniques using the equipment for which

the personnel are to be certified.

Ships crew’s competency is maintained by;

▪ On board training (by senior officers)

▪ Maintenance training at the manufacturer’s

training site

▪ Some STCW courses includes maintenance (i.e.

Fast rescue)

Weekly and monthly inspections and routine

maintenance as specified in the equipment

maintenance manual(s), shall be conducted by

authorized service providers, or by shipboard

personnel under the direction of a senior ship’s

officer in accordance with the maintenance

manual(s).

The time has come to introduce robust certification

and approval processes for all electronic equipment

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on board ships. This is the only realistic way of

tackling cyber-risk within the shipping industry.

There has always been a certain degree of risk

associated with entrusting computers to perform

tasks previously carried out manually. This is not a

new phenomenon. It has been with us since the

1960s and 1970s since electronic systems escaped

the laboratory and found their way into real-life

applications.

The reason the subject comes under intense scrutiny

today is that these systems are becoming ever more

complex and are increasingly interconnected. The

complexity makes it harder to detect errors that

could lead to irrevocable failure. Greater connectivity

allows failures to propagate or cascade through a

system and also gives hackers, whatever their

motivation, much greater scope to find a weak point

of entry into a system. Such is the scale of the

problem that, in defence circles, it is a widely held

view that the next war will be fought not on the

battlefield but in cyberspace.

Where does that leave the maritime industry? The

equipment found on ships is traditionally subject to

countless prescriptive rules, standards and

regulations aimed at ensuring the safety of crew,

vessels and their cargoes, as well as the environment.

However, not all equipment is treated equally. There

are gaps in this regulatory oversight. The hardware

for establishing connectivity between ship and shore

is a particularly glaring omission. It is all the more

worrying as ships grow more reliant on electronic

communications in their operations, especially for

safe navigation but also for the ongoing

maintenance and upkeep of machinery systems, and

to satisfy official and commercial reporting

requirements.

From LRIT and GMDSS, to AIS and ECDIS, bridge

hardware has to be designed and built to agreed

standards (formulated jointly by authorities and

industry) in order to gain certification that allows

manufacturers to supply and install it. Yet, there are

no equivalent requirements for antennas, modems

and other satellite communications equipment. Each

satellite services provider will have a different way of

addressing security and cyber-risk. That is a big risk

in my view.

Modems, for instance, may be supplied with default

passwords, which are rarely changed or are easy to

crack. This was the technique employed to great

effect by hackers carrying out the Mirai DDOS attack

on Internet infrastructure last October. Once known

to malicious third-parties, this information could be

used to disable the antenna. This could already have

serious repercussions for the manned vessels of

today. In the case of the unmanned ships currently

under development it would be disastrous. Without a

hardened communications channel an autonomous

ship is unlikely to ever leave port – let alone ply a

commercial voyage.

The lack of effective certification for communications

equipment has consequences for other equipment.

When Transas manufactures an ECDIS capable of

downloading chart updates over the Internet, the

router and hardware firewall component is

scrutinised in the approval process to ensure we are

not leaving the ECDIS console and thus mariners

exposed to any cyber vulnerability. If we decide to

switch to a different router, we have to start over.

Apart from the time involved, this is also an expensive

exercise, with costs ultimately feeding through to the

end-user. However, there is no similar obligation on

manufacturers of satellite communications

hardware. In my view, this creates a dangerous gap

in the regulatory framework for protecting ships –

and one that should be plugged quickly.

Some communications providers propose cyber-

security add-ons as part of their offering to ship-

owners, which are typically filtering solutions. In my

view, this approach addresses symptoms that

present themselves at the service level, but not any

underlying vulnerabilities found in the infrastructure.

The complexity of modern software and hardware

makes it difficult, if not impossible, to develop

components without flaws or to detect malicious

insertions. Vulnerabilities could exist right down to

the firmware or chip level. The Mirai attack

mentioned above was so effective because the

default password had been burnt into the firmware.

It is therefore incumbent on IMO and allied

organisations to step up and address this reality.

Furthermore, we have to proceed on the assumption

that flaws do exist and take a risk-based approach to

ensure that when something goes wrong, we have

steps in place to minimise the impact. For this reason,

the role of class societies cannot be underestimated.

Certification for all electronic equipment will provide

a level of assurance to mariners that the equipment

they rely on is fit for purpose.

However, certification for manufacturers is only half

the story. One appeal of a risk-based approach to

tackling cyber threats is that it can be implemented

at various levels. Shipping companies can self-audit

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and implement their own internal procedures geared

towards securing their computer systems. These

should cover operations both on ship and on shore.

The cyber discussion in maritime is driven by fear.

Some have even argued we should remove tech from

ships completely and run them like we did 50 or 100

years ago, which is patently unrealistic. As with so

much in life, we cannot eliminate risk entirely, but we

can take steps to minimise exposure to unnecessary

risks.

'Fight antibiotic resistance - it's in your hands'

WHO urges you to focus on the fight against antibiotic resistance in the context of hand hygiene and infection prevention and control (IPC) program. You can do this by supporting the 5 May 2017 calls to action. Hand hygiene is at the core of effective IPC to combat antibiotic resistance, and campaigning each year on or around 5 May is one important part of improving behaviour towards IPC best practices. This year the campaign materials are all co-branded with ‘Antibiotics, handle with care’ to demonstrate unity between antimicrobial resistance and IPC efforts.

Who we want action to be taken by:

we want health workers to clean their hands at the right times, building on hand hygiene improvement efforts made up to now;

we want chief executive officers and managers to support hand hygiene campaigning and infection prevention and control programmes, to protect patients from antibiotic-resistant infections;

we want IPC leaders to lead hand hygiene campaigning and start their journey of meeting the core components for infection prevention and control;

we want policy makers to stop antibiotic resistance spread by demonstrating national support and commitment to infection prevention.

International Convention for the Control and

Management of Ships' Ballast Water and

Sediments, 2004 and US Ballast Water

Management(BWM) Regulations

The IMO’s International Convention for the Control

and Management of Ships’ Ballast Water and

Sediments, 2004 (the “Convention”) will enter into

force on 8 September 2017. The Convention seeks to

prevent the spread of harmful aquatic organisms

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from one region to another, by the establishment of

standards and procedures for the management and

control of ships’ ballast water and sediments. As of

11 January 2017, there are 54 Contracting States to

the Convention representing 53.30% of the world’s

global tonnage.

The United States (US) is not a State Party to the

Convention. Instead the US has its own

requirements. In particular, US Coast Guard (USCG)

Regulations require the installation on most ships

operating and discharging ballast water in US waters

of a BWM system approved by the USCG that meets

the USCG’s testing standards at the first scheduled

dry docking after 1 January 2016.

The USCG testing standards have, up until the

adoption last year of the 2016 IMO Guidelines for

approval of ballast water management systems (G8),

been considered more robust than IMO Guidelines

for the approval of BWM systems. As is noted below,

the State of California has its own BWM standards,

which will be even stricter than those of the USCG.

The inconsistent nature of the various Regulations

has caused some confusion in the industry.

IMO BWM Convention

Under the Convention, all ships engaged on

international voyages will be required to manage

their ballast water and sediments to a certain

standard, according to a ship-specific BWM plan,

approved by the Member’s Flag Administration. All

ships will also have to carry a ballast water record

book and an international BWM certificate. The

BWM standards will be phased in over a period of

time. Eventually, most ships will need to install an

onboard ballast water treatment system meeting the

IMO’s standards by the date of a ship’s first renewal

of its International Oil Pollution Prevention (IOPP)

certificate after the Convention enters into force on

8 September 2017 (as prescribed in IMO Assembly

Resolution A.1088 (28)).

As an example, a ship that completes her IOPP

renewal survey on 7 September 2017 may then have

until 7 September 2022 before the ship will be

required to comply with Regulation D-2 of the

Convention and thereby fit a type-approved BWM

system. States Parties to the Convention are given

the option to take additional measures which are

subject to criteria set out both in the Convention and

agreed IMO guidelines. Members should contact

their Flag States, if they are States Parties to the

Convention, to determine whether any such

additional measures will be taken. Once the

Convention enters into force, ships’ Ballast Water

Record Books must record when ballast water is

taken on board; circulated or treated for BWM

purposes, and discharged into the sea. It should also

record when ballast water is discharged to a

reception facility as well as accidental or other

exceptional discharges of ballast water.