New Amendments (1 January 2013): SOLAS & MARPOL
The 2013 amendments: lifeboat on-load release hooks, EEDI/SEEMP energy efficiency, the US Caribbean ECA and the revised garbage rules.
Key Principles at a Glance 6 points
- On 1 January 2013 the IMO brought into force new regulations aimed at improving energy efficiency of international shipping and preventing accidents during lifeboat launching.
- SOLAS amendments (adopted May 2011) add a new paragraph 5 to regulation III/1 requiring lifeboat on-load release mechanisms not complying with the new LSA Code requirements to be replaced no later than the first scheduled dry-docking after 1 July 2014, but in any case not later than 1 July 2019.
- MARPOL amendments (adopted July 2011) added a new chapter 4 (Regulations on energy efficiency for ships) to Annex VI, making mandatory the Energy Efficiency Design Index (EEDI) for new ships and the Ship Energy Efficiency Management Plan (SEEMP) for all ships, applying to ships of 400 GT and above.
- Under regulation 19 the Administration may waive the requirements for new ships up to a maximum of 4 years; the EEDI is a non-prescriptive, performance-based mechanism, leaving the choice of technology to industry.
- Amendments to Annex VI designated the US Caribbean Sea Emission Control Area (Puerto Rico and the U.S. Virgin Islands) for NOx, SOx and particulate matter, effective 1 January 2014, and exempted old steamships from the fuel sulphur requirements in the North American and US Caribbean ECAs.
- Annex IV amendments allowed Special Areas and designated the Baltic Sea, with stricter discharge requirements for passenger ships; the revised Annex V prohibits discharge of all garbage into the sea except as expressly provided (food waste, animal carcasses, cargo residues and certain cleaning water, only if not harmful to the marine environment).
1. SOLAS Amendments — Lifeboat On-Load Release Hooks
- Amendments to the International Convention for the Safety of Life at Sea (SOLAS) aimed at preventing accidents during lifeboat launching entered into force on 1 January 2013.
- The amendments, adopted in May 2011, add a new paragraph 5 to SOLAS regulation III/1.
- They require lifeboat on-load release mechanisms not complying with the new International Life-Saving Appliances (LSA) Code requirements to be replaced:
- no later than the first scheduled dry-docking of the ship after 1 July 2014, but
- in any case not later than 1 July 2019.
- The amendment is intended to establish new, stricter safety standards for lifeboat release and retrieval systems, and requires the assessment and possible replacement of a large number of lifeboat release hooks.
- Information submitted by flag States on their assessments of existing lifeboat hooks is available on the Global Integrated Shipping Information System (GISIS) under Evaluation of Hooks.
Faulty on-load release gear had caused fatal accidents during lifeboat drills — hooks releasing when they should not, or not releasing when they should. The amendment forces assessment and replacement of non-compliant hooks within a fixed timetable.
2. MARPOL Amendments — Energy Efficiency (EEDI & SEEMP)
- The amendments to MARPOL were adopted in July 2011, and new regulations aimed at improving the energy efficiency of international shipping entered into force on 1 January 2013.
- A new chapter 4 (Regulations on energy efficiency for ships) was added to MARPOL Annex VI, making mandatory:
- the Energy Efficiency Design Index (EEDI) for new ships, and
- the Ship Energy Efficiency Management Plan (SEEMP) for all ships.
- Other amendments to Annex VI add new definitions and the requirements for survey and certification, including the format for the International Energy Efficiency (IEE) Certificate.
- The regulations apply to all ships of 400 gross tonnage and above; however, under regulation 19 the Administration may waive the requirements for new ships up to a maximum of 4 years.
The Two Mechanisms:
- EEDI — a non-prescriptive, performance-based mechanism that leaves the choice of technologies to the industry; as long as the required energy-efficiency level is attained, ship designers and builders are free to use the most cost-efficient solutions.
- SEEMP — establishes a mechanism for operators to improve the energy efficiency of ships; ships are required to keep on board a ship-specific SEEMP.
3. Annex VI Emissions & Annex IV Sewage Amendments
Annex VI Emissions:
- Amendments to MARPOL Annex VI designate certain waters adjacent to the coasts of Puerto Rico (United States) and the U.S. Virgin Islands (United States) as the US Caribbean Sea Emission Control Area for the control of emissions of nitrogen oxides (NOx), sulphur oxides (SOx) and particulate matter under regulations 13 and 14 of MARPOL Annex VI.
- Another amendment makes old steamships exempt from the requirements on sulphur content of fuel oil used on board ships in both the North American and United States Caribbean Sea ECAs.
- The new US Caribbean Sea ECA takes effect 12 months after entry into force, i.e. 1 January 2014.
Annex IV Sewage:
- Amendments to MARPOL Annex IV (Prevention of pollution by sewage from ships) include the possibility of establishing Special Areas.
- The actual designation of the Baltic Sea as a Special Area under Annex IV.
- The introduction of stricter discharge requirements for passenger ships while in a Special Area.
4. Revised Annex V Garbage Amendments
- The revised MARPOL Annex V (Regulations for the prevention of pollution by garbage from ships) entered into force, following a comprehensive review to bring the Annex up to date.
- The main feature of the revision is the prohibition of the discharge of all garbage into the sea, except as expressly provided otherwise in the Annex.
- The discharges permitted in certain circumstances include:
- food wastes;
- animal carcasses;
- cargo residues; and
- water containing cleaning agents or additives used for washing deck and external surfaces or cargo holds.
- Cargo residues and cleaning agents/additives must only be considered for discharge if they are not harmful to the marine environment.
- The changes also include:
- the updating of definitions;
- the introduction of an en-route requirement for the discharge of garbage at sea; and
- the regrouping of the garbage categories for the purpose of the Garbage Record Book.
From 2013, the default is "all garbage discharge is prohibited", with only a short list of expressly permitted discharges. Plastics remain prohibited, discharge at sea is generally allowed only en route, and cargo residues/cleaning agents must be not harmful to the marine environment.
Surveyors commonly ask: "What new amendments came into force on 1 January 2013?" Give the two headlines first: SOLAS lifeboat on-load release hooks (III/1) and MARPOL energy efficiency (EEDI + SEEMP, Annex VI chapter 4), then add the US Caribbean ECA, Baltic Annex IV Special Area and revised Annex V.