PPR 11 makes progress on significant environmental issues

Published: 26 February 2024

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Transparency on local restriction on the discharge of scrubber washwater 

There was broad support at PPR 11 for a database of local restrictions on the discharge of water from exhaust gas cleaning systems (EGCS, known as scrubbers) as proposed by BIMCO. We will actively support the IMO secretariat in establishing such a database and encourage all port- and coastal states to inform IMO of any local restrictions; existing, as well as potential future restrictions.  

Read BIMCO’s proposal to PPR 11 here.

Restriction on the discharge of water from scrubbers within the territorial waters 

PPR 11 discussed whether or not coastal states may unilaterally introduce regulations on discharge of water from scrubbers in waters beyond their territorial seas, ie in their exclusive economic zone (EEZ). 

The conclusion was clear: according to the UN Convention on the Law of the Sea (UNCLOS), coastal states cannot impose restrictions on discharge of water from scrubbers in their EEZ.  

However, where coastal States have reasonable grounds for believing that a particular, clearly defined area within their EEZ requires special restrictions on discharges of water from scrubbers, they may, through consultation with IMO, implement regulations on discharge of water from scrubbers. 

So far, no country has consulted IMO concerning introduction of regulations on discharge of water from scrubbers within their EEZ. 

Development of guidance on in-water cleaning 

To complement and support implementation of the 2023 Biofouling Guidelines the Sub-committee agreed to establish a correspondence group to develop guidelines for in-water cleaning for completion in 2025. The guidelines will take into consideration the two papers submitted by BIMCO to this session on “before, during and after in-water cleaning” and on verification and certification of in-water cleaning systems (available here).

The correspondence group will address the following: 

• planning, conducting and reporting on in-water cleaning operations, including documenting and mitigating any damage to anti-fouling coatings;  
• verification and testing of in-water cleaning systems, including compatibility with anti-fouling coatings, and, if feasible, measurable performance criteria such as on removal, capture and effluent contents;  
• conducting pre-cleaning and post-cleaning inspections; and  
• verification or other form of expectations for in-water cleaning service providers; 

We will continue to represent our members in the correspondence group deliberations to ensure that ships can have access to in-water cleaning in ports around the world in order to enable them to contribute both to biosecurity and GHG emissions reductions.   

Transport of plastic pellets in containers 

In 2023, the IMO adopted a two-stage approach to reduce the environmental risk posed by the carriage of plastic pellets (also called nurdles) in freight containers which includes the issuance of a circular followed by the potential introduction of a mandatory measure.  The sub-committee at this session approved the draft Marine Environmental Protection Committee (MEPC) circular on “Recommendations for the carriage of plastic pellets by sea in freight containers” which provides guidance on packaging, identification, and stowage.  Noting recent high-profile events, such as the recent spill off the coast of Spain, it was recognised that the issuance of the circular should be dealt with urgently and as such it is expected that MEPC will approve the circular at its 81st session to be held at the end of March.  

We support the implementation of the recommendations within the circular and as such will circulate to BIMCO members once approved by MEPC. 

Additionally, PPR approved the IMO Guidelines on best practice relating to clean-up of plastic pellets from ship-source releases. Whilst these are intended mainly to provide practical guidance to member states on clean-up activities, they include some guidance to shipowners on notifications, liability, and involvement in clean-up. The guidelines are expected to be approved at MEPC 82 later this year, but stakeholders are encouraged to start using them as soon as possible. These will also be provided to interested members when available.  

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