Regulatory Update

INTERTANKO Latin American Panel

Regulatory Update

INTERTANKO Latin American Panel

15/16 October 2009Adam W. Moilanen, SVP Operations

ABS Americas

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Regulatory UpdateRegulatory Update

SOLAS -

AmendmentsMARPOL IV -

Revision

MARPOL VI –

RevisionBWM Convention –

not in force

Ship Recycling –

New ConventionISM Code –

Revision

Future Regulatory Developments

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ECDIS RequirementsECDIS Requirements

Ship Type Date of Build

GT Compliance Date

Passenger ≥

1 July 12 GT ≥

500

At deliveryTanker ≥

1 July 12 GT ≥

3k

Cargo ShipexcludingTankers

≥

1 July 13 GT ≥

10k

≥

1 July 14 3k ≥

GT < 10k

Passenger < 1 July 12 GT ≥

500 1st

Svy ≥

1 July 14

Tanker < 1 July 12 GT ≥

3k 1st

Svy ≥

1 July 15

Cargo ShipexcludingTankers

< 1 July 13 GT ≥

50k 1st

Svy ≥

1 July 16

< 1 July 13 20k ≥

GT < 50k 1st

Svy ≥

1 July 17

< 1 July 13 10k ≥

GT < 20k 1st

Svy ≥

1 July 18

Electronic Chart Display and Information SystemSOLAS Amendment - MSC.282(86)Performance Standards – A.817(19)

Implementation (New and Existing Ships)

May exempt ECDIS if ship scrapped within 2 yrs of compliance

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BNWAS RequirementsBNWAS Requirements

Ship Type Date of Build GT Compliance Date

Cargo ≥

1 July 11 GT ≥

150 At deliveryPassenger ≥

1 July 11 - At deliveryPassenger < 1 July 11 - 1st

Svy ≥

1 July 12

Cargo < 1 July 11GT ≥

3k 1st

Svy ≥

1 July 12500 ≥

GT < 3k 1st

Svy ≥

1 July 13150 ≥

GT < 500 1st

Svy ≥

1 July 14

Bridge Navigational Watch Alarm System (BNWAS)SOLAS Amendment - MSC.282(86)Performance Standards - MSC.128(75)

Implementation (New and Existing Ships)

BNWAS installed < 1 July 11 may be exempted from compliance with MSC.125(78)

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SOLAS –

Means of Embarkation/DisembarkationSOLAS –

Means of Embarkation/DisembarkationApplication of SOLAS II-1/3-9 - MSC.256(84)

All ships > 500 gtNew: Keel laid > 1 Jan 2010Existing: Keel laid < 1 Jan 10

Design Standard (new equipment)Installations on new ships MSC.1/Circ.1331 containsrecommended standards whichinclude ISO StandardsGangways/accommodation laddersMax load/inclination to be marked

Onboard Certification (new & existing equipment)Initial operational test for new installationsStatic load test of gangway and winches every five years:- MWL applied for new ladders- if MWL unknown for existing gangways, owner nominates loadAnnual SLE Survey- visual inspection of gangway and winches- review log-book of inspection, maintenance and repairs- wires maintained as per SOLAS III/20.4 (lifeboat falls)

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SOLAS –

Emergency Towing ProcedureSOLAS –

Emergency Towing Procedure

Application - MSC.256(84)All ships > 500 gt, includingtankers ≥ 20,000 dwtNew and existing ships

CompliancePassenger ships by 1 Jan 10Cargo ships:- keel laid ≥ 1 Jan 10 - at delivery- keel laid < 1 Jan 10 - by 1 Jan 12

Emergency Towing Booklet (approval not required):May be part of ISM emergency preparednessArrangement drawingsInventory of equipmentMeans of communicationMethod of conducting tow

Emergency Towing Guidance (MSC.1/Circ.1255)Recommendations for assessing and developing the procedure

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SOLAS –

Long Range ID & Tracking System (LRIT)SOLAS –

Long Range ID & Tracking System (LRIT)Application

Cargo ships (incl HSC) > 300 gtPassenger ships (incl pass HSC)Self-propelled MODUs (except on station)

ComplianceNew ships (keel laid > 31 Dec 08) at deliveryExisting ships: at First Safety Radio Survey :≥ 31 Dec 2008 for A1/A2/A3≥ 01 July 2009 for A1/A2/A3/A4

N/A to ships with AIS operated exclusively in Sea Area A1LRIT Survey and Certification

Type Approval:- Radio/Navigation equipment TA per SOLAS IV/14 or V/19-1; or- IEC 60945; or- SOLAS-approved SSAS

Initial survey (within SLR window)- controlled by SLE Certificate/Record:- ASP must be recognized by flag State; and- Conformance test by ASP must correspond to equipment

Renewal/Annual Surveys:- Check that conformance test report corresponds to equipment

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MARPOL Annex IV –

Recent InterpretationsMARPOL Annex IV –

Recent Interpretations

Sewage Treatment Plants- enhanced performance- “installed on or after 1 Jan 2010” means:

(a)

Installed on new ships -

built ≥

1 Jan 2010

(b)

Installed on existing ships if: -

contractual delivery date

≥

1 Jan 2010; or -

equipment delivery date

≥

1 Jan 2010, if no CDD

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Adopted SOx (Sulphur Content) LimitsAdopted SOx (Sulphur Content) Limits

* Note: Effective year (2020 or 2025)

will be decided by 2018.

+

Note: Alternative Technology

is also acceptable and

includes Exhaust Gas

Cleaning Systems

and onboard blending

MEPC approved the 200nmi (0.10%) USA/Canada ECA

(Current ECAs –

Baltic and North Sea)

Global (1 January)

Emission Control Areas (SOx, NOx and PM controls)

Entry Into Force Date

≥

2012 to

< 2020/25* ≥

2020/25*

≥

1 July 2010

to < 1 Jan 2015

≥

1 Jan 2015

Limit (mm) 3.5% + 0.5% + 1.0% + 0.10% +

Current Limit (m/m) 4.5 % 1.5 %

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Adopted NOx Emission LimitsAdopted NOx Emission Limits

Ship Constructed(≥1 January)

Application of Requirements

EmissionLimits

Compliance at engine’s delivery except as below

1990to

2000Retroactiveto existingengines

Engine size > 5000 kW and

≥

90 liters / cylinder Tier I

1st

IAPP Renewal Survey≥

12 mo after IMO advisedby Party of availability

(physical and cost) of “upgrade kit”

2000 ≤

x <2011

> 130 kW

----2011 ≤

x <2016Tier II

≥

2016 Operation outside of ECA≥

2016two exceptions + Tier III Operation within ECA

RPM

Total Weight of NO2

Emission (g/kWh) Relative NO2

Reduction from Tier I

< 130 130 ≤

n < 2000 ≥

2000

Tier I 17.0 45*n(-0.2) 9.8 CurrentTier II 14.4 44*n(-0.23) 7.7 15.5% -

21.8%Tier III 3.4 9*n(-0.2) 2.0 80%

+ L<24m if used for recreational purposes or total power <750kW if unable to achieve due to design limitations

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BWM Convention –

Methods of TreatmentBWM Convention –

Methods of Treatment

Exchange Treatment Systems Retention/Reception

SequentialFlow

Through Dilution

Mechanical

Filtration

Cyclonic Separation

Physical

Ultraviolet Lights

Cavitation

Deoxygenation

Chemical

Biocides

Electrolytic Chlorination

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BW Management Convention -

Implementation BW Management Convention -

Implementation

Ballast Cpty (m3)

Build Date

First Intermediate or Renewal Survey, whichever occurs first, after the anniversary date of delivery in the respective year ®

2009 2010 2011 2012 2013 2014 2015 2016 2017

<1500

<

2009 D1

or D2 D2 ®

in 2009 D1;

D2 by “2nd

Annual but not beyond 31 Dec 11”

or EIF, whichever is later (Note)

>2009 D2 (at delivery or EIF, whichever is later)

≥1500

or

≤5000

<

2009 D1

or D2 D2 ®

in 2009 D1;

D2 by “2nd

Annual but not beyond 31 Dec 11”

or EIF, whichever is later (Note)

>2009 D2 (at delivery or EIF, whichever is later)

>5000< 2012 D1

or D2 D2 ®

>

2012 N/A D2 (at delivery or EIF, whichever is later)

Enters Into Force (EIF)12 months after ratification by 30 States with 35% world’s GTAs of Feb 2009, 17 States (15.35% GT) have ratified the ConventionA.1005(25) delays D2 implementation for ships built in 2009 w/ Bst Cpty < 5000m3

Implementation (D1 = Exchange Standard, D2 = Biological Standard)Ships of signatory flag States / All ships in jurisdictional waters of signatory States

Note: Signatory States may not invoke delayed D2 enforcement permitted by A.1005(25).

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BWM Convention -

System ConsiderationsBWM Convention -

System Considerations

•

Estimated Operating Cost -

$0.02 to $0.40 / m3

•

Location -

hazardous areas

•

Footprint size- 3m2

to 70m2

-

depending on capacity•

Flow Rates

-

250 to 2500 m3/hr•

Ease of Operation

•

Maintenance•

Training

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US BWM Regulations …..in a nutshellUS BWM Regulations …..in a nutshell

•

Applicability: All vessels operating or bound to US ports •

Exemptions:

-

Crude oil tanker in coastwise trade

-

Vessel operating within one COTP zone -

Vessel on innocent passage

•

Documentation:–

Maintain BWM Plan

–

Report 24 hours before arrival–

Maintain records on board for two years

•

Exchange Ballast Water: –

At water depth > 2000m and ≥

200nmi offshore

•

Good Operational Practices: –

Remove tank sediments

–

Rinse anchors/lockers–

Minimize uptake near dredging operations

–

Train personnel•

Penalties: –

Knowing-violation is class C felony

–

Civil penalty not > $27,500/day of continuous violation

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Scope of ApplicationAll new ships – keel laid on/after entry into forceExisting ships – to the extent practicable for hardware

Certification of Recycling FacilitiesGovernment authorizesCompetent Authorities toapprove Facilities in its jurisdictionSafe and environmentally soundremoval/disposal of materials

Preparation for recyclingShip Recycling Plan prepared by Recycling Facility with ship ownerSRP is to address Inventory of Hazardous Materials:Part I - Yard responsible for hardware (new build/modifications)

- Authorized “Experts” for hardware (existing ships)Parts II/III - Owner records wastes/stores

Entry Into Force Provisions – 24 months after:15 States ratifying States with at least 40% world’s GTCombined maximum annual ship recycling volume of ratifying States during preceding 10 years is at least 3% GT of ratifying States.

Ship Recycling ConventionShip Recycling Convention

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Ship Recycling –

Final Certification ProcessShip Recycling –

Final Certification Process

Ship Recycling

Facility

Ship Owner

Final survey and IRRC

cannot be concluded

Final survey complete

and IRRC issued

IHM represents shipSRP addresses IHMSRP contains

safe-for-entry/hot workSRF has valid DASR

SRP

Flag State /RO

noyes

noyes

CA issues DASR

Competent Authority

SRP approvedExplicit approval

CA confirms SRP received without

objection in 14 days

Tacit approval

Final Survey

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ISM Code revised by MSC.273(85)Implementation ≥ 1 July 2010SMS to be periodically reviewed

by MasterCorrective action to include measures

to prevent recurrenceSMC renewal window same

as SOLAS certificatesCompany to carry out mandatory

annual internal audits

ISM Guidelines - A.913(22)Under revision based on experience gainedIACS EG/ISM-ISPS developing input

MSC/Circ.1231RecommendationCargo and special purpose ships- if GRT < 500 GRT, no longer exempted if ITC 69 > 500 gt)

Recommend compliance not later than 1 Jan 2010

ISM Code RevisionsISM Code Revisions

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Regulation Under Development –

What’s on the horizonRegulation Under Development –

What’s on the horizon

Cargo Tank Coating Standard

Similar in scope to ballast tank coating standardApplies to new crude oil tankersCombination carriers excluded

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Keep Pace with Regulatory DevelopmentsKeep Pace with Regulatory Developments

http://www.eagle.org/eagleExternalPortalWEB/