Review of MARPOL Annex V

The revision of MARPOL Annex V has caused concerns among Finnish shipowners. The proposed regulations 6.1.2 and 6.1.3 will produce operational and safety problems in the Baltic Sea traffic if the revised text is going to be agreed as such in the MEPC 62 meeting. Part of the revised draft in question is attached at the end of this document.

The regulation 6.1.2 about discharge of cargo residues

According to the revised draft of Annex V, ships are allowed to discharge cargo hold washing waters containing non-harmful cargo residues en route at not less than 12 nautical miles from the nearest land if there are no adequate reception facilities in port.

There are ships which do wash cargo holds en route, but in many cases it is not economical or environmentally friendly to sail empty. Ships try to unload and load in the same port. If they change the cargo type, washing might be needed in between. Adequate port reception facilities are then essential.

Adequate reception capacity for an approximate pump power 10-50 m3/h is needed in port. Ships try to minimize time spent in port and washing cargo holds should not slow down operation too much. An average washing takes 1-2 h/hold if there are no restrictions with reception capacity. We suggest that the adequacy of reception facilities should be investigated and cargo unloading process needs to be made more effective in ports with requirements of obligatory sweepers and hoovers for example. It is worth noting that even during very careful loading and unloading processes much more cargo is ending to the sea than during cargo hold washing.

It could be against the ship's safety to send her out from port to wash cargo holds before loading. Bunker consumption and air emissions will also increase because of extra sailing. During the winter time the ice breaker escort might be needed both ways. It has been reported that in some Finnish port the fairway dues have been charged both ways in such a case.

Open questions and suggestions:

-Could this regulation come into force conditionally depending on the availability of adequate port reception facilities?
-Is there a limit when the amount of the non-harmful cargo residues could be thought to be negligible after dry cleaning and discharge to sea is allowed at port?
-Could the municipal drainage system accept washing waters with cargo residues in port?
-Will cargo hold washing waters be included in the concept of ‘waste and garbage' under the no-special-fee system?
-What will be the practice with fairway dues if ships are sent out to sea to wash cargo holds?
-What is the relationship and application area between MARPOL Annex V, IMSBC CODE and SOLAS chapter V?
- Is the revised draft of Annex V in line with the regulations in Annex II concerning noxious liquid substances?

The regulation 6.1.3 about cleaning agents and additives

According to the revised draft of Annex V, ship must be en route when discharging into the sea cleaning agents and additives contained in deck and external surfaces washing waters. We would like to emphasize that this regulation shall apply to all ships and forbid the use of environmentally friendly cleaning agents in port or anchor if discharging into the sea.

-Are car decks included in the definition "deck and external surfaces"?

Most of the time ships use water to wash external surfaces and car decks but cleaning agents are needed to get rid of all dirt, like soot, and to prevent rust. We propose that the use of environmentally friendly and biodegradable cleaning agents should be allowed in ports within a special area. In the following we have listed some practical problems with that regulation:

-Deck washing with environmentally friendly cleaning agents is needed often between unloading and loading.
-External sides can normally only be washed in port as it poses a major safety risk for the crew to hang outside the ship while en route.
-It is necessary to use environmentally friendly cleaning agents to remove soot, oil and dirt.
-Environmentally friendly cleaning agents are needed while washing funnel and it could be done only in port.
-During the voyage washing is not possible because of decks/car decks are full of cargo (ro-ro and ro-pax).
-During the voyage washing is not possible because there are a lot of passengers out in decks and due to watch keeping there is no extra crew to do washing (ro-pax).