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SOLAS and MARPOL Amendments – 5 (2022 and beyond)

Q. In respect of the amendments coming in force in April 2022, what new definitions are added to annex VI of MARPOL?
These are related to the Sulphur content and sampling. 
Thus,

Q. What is the amendment, scheduled to come in force in April 22 in respect of fuel oil sampling and testing?
These are the amendments to regulation 14. New paragraphs related to in-use and onboard fuel oil sampling and testing, requires one or more sampling points to be fitted or designated for the purpose of taking representative samples of the fuel oil being used or carried for use on board the ship. This being to verify the fuel oil complies with the regulation.  This would also cause amendments to the International Air Pollution Prevention (IAPP) certificate. Thus, the IAPP certificate would have reference to sampling points and also to indicate where there is an exemption to the provision for low-flashpoint fuel. This would also affect the fuel verification procedure.

Q. What are the amendments expected in respect of BWM?
In June 22, amendments to BWM Convention, regarding commissioning testing of ballast water management systems are to come in force. This would also amend the form of the International Ballast Water Management Certificate.

Q. What changes would be caused due IMDG Code 40-20?
Adopted by MSC 102:
These changes are related to:

Q. What amendments are expected in January 2024 in respect of IGF Code?
These are amendments to parts A and A-1 of the IGF Code, which is International Code of Safety for Ships using Gases or other Low-flashpoint Fuels. These are in respect of:

Q. What are the amendments to LSA code, expected in 2024? 
The amendments affecting chapters IV and VI of the LSA code, relate to general requirements for lifeboats and launching and embarkation appliances.  

Q. What amendments are expected to enter in respect of moorings?  
Amendments to chapter II-1 of the International Convention for the Safety of Life at Sea (SOLAS),is related to towing and mooring. MSC Circ.1175 dated December 2020, is ‘revised guidance on shipboard towing and mooring equipment’ in this respect. The amendments to SOLAS regulation II-1/3-8 (Towing and mooring equipment), require appropriate and safe-to-use designs of mooring arrangements. The guidelines aim to provide clear unobstructed work area. It also introduce a maintenance and inspection regim. Related guidelines were also adopted, covering the design of mooring arrangements and the selection of appropriate mooring equipment and fittings for safe mooring; inspection and maintenance of mooring equipment including lines; as well as revised guidance on shipboard towing and mooring equipment. The eventual idea being to minimize the exposure of personnel involved in mooring operations to the dynamic loads of mooring lines.

Q. What is the provision about total load which can be applied to a fitting tn respect of towing or mooring?
The design load should be applied to fittings in all directions that may occur by taking into account the arrangement shown on the towing and mooring arrangements plan. Where the towing line takes a turn at a fitting, the total design load applied to the fitting is equal to the resultant of the design loads acting on the line. However, in no case does the design load applied to the fitting need to be more than twice the design load on the line as shown below.

Q. In case of a fitting, say bolards / bitts, what is the provision in respect of attachment point?
The acting point of the towing force on shipboard fittings should be taken at the attachment point of a towing line or at a change in its direction. For bollards and bitts the attachment point of the towing line should be taken not less than 4/5 of the tube height above the base as in the  figure below.

Q. What is Safe working load (SWL), Safe towing load (TOW) and Ship Design Minimum Breaking Load (MBLSD) as provided in ‘Revised guidance on shipboard towing and mooring equipment’?
Safe working load (SWL) means the safe load limit of shipboard fittings used for mooring operations in harbours or similar sheltered waters. Safe towing load (TOW) means the safe load limit of shipboard fittings used for normal and other towing. Ship Design Minimum Breaking Load (MBLSD) means the minimum breaking load of new, dry mooring lines for which shipboard fittings and supporting hull structures are designed in order to meet mooring restraint requirements.

Q. What is the relationship between TOW and the design load?
Safe towing load (TOW), used for normal towing operations and TOW used for other towing operations should not exceed 80% of the design load as given in relevant paras of guidelines. For fittings used for both, normal and other towing operations, the greater of the safe towing loads should be used. TOW, in tonnes, of each shipboard fitting should be marked (by weld bead or equivalent) on the fittings intended for towing. For fittings intended to be used for both, towing and mooring, SWL, in tonnes, should be marked in addition to TOW. These provisions on TOW apply for the use of no more than one towing line.

Q. What amendments to IGF code are expected to enter into force on 1 January 2024?
Amendments to the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code), related to the fuel containment systems, fire safety, welding of metallic materials and non-destructive testing.

Q. What amendments to IGC code are expected to enter into force on 1 January 2024?
Amendments to the International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code), related to welding procedure tests for cargo tanks and process pressure vessels.

Q. What steps are taken by IMO in respect of control on Cybutryne in the AFS system?
The amendments were adopted to the AFS Convention regarding controls on cybutryne and the form of the International Anti-fouling System Certificate. The amendments will enter into force on 1 January 2023. From this date the application or re-application of an AFS containing cybutryne will be prohibitted.
Ships with an AFS that contains Cybutryne in the external coating or external parts or surfaces shall either: remove the anti-fouling system; or apply a barrier coating.
This amendment applies to all ships except existing fixed and floating platforms, floating storage units, and floating production storage and offloading facilities that have been constructed and not been in dry-dock on or after 1 January 2023; ships not engaged in international voyages; and ships of less than 400 gross tonnage engaged in international voyages.
The latter part though, applies to the next scheduled renewal of the AFS after 1 January 2023, but no only for 60 months following the last application of an AFS with Cybutryne.

Q. What are the terms: GHG, EEXI, CII?
GHG is greenhouse gas emissions;  EEXI is Energy Efficiency Existing Ship Index; and
CII is carbon intensity indicator.

Q. What are the new IMO measures in respect of above?
The new measures will require all ships to calculate their Energy Efficiency Existing Ship Index (EEXI) following technical means to improve their energy efficiency and to establish their annual operational carbon intensity indicator (CII) and CII rating. Carbon intensity links the GHG emissions to the transport work of ships. The attained Energy Efficiency Existing Ship Index (EEXI) is required to be calculated for ships of 400 gt and above, in accordance with the different values set for ship types and size categories. 
The amendments apply to ships of 5,000 gross tonnage and above (the ships already subject to the requirement for data collection system for fuel oil consumption of ships). These ships are required to have determined their required annual operational carbon intensity indicator (CII). Ships will get a rating of their energy efficiency (A, B, C, D, E – where A is the best), which will be incorporated in their mandatory Statement of Compliance to be issued by the Administration. Administrations, port authorities and other stakeholders as appropriate are also encouraged to provide incentives to ships rated as A or B.
The amendments to MARPOL Annex VI are expected to enter into force on 1 November 2022, with the requirements for EEXI and CII certification coming into effect from 1 January 2023. Thus, the first annual reporting on carbon intensity will be completed in 2023, with the first rating given in 2024.

Q. What are the amendments to MARPOL regarding use of HFO in the Arctic?
The MEPC adopted amendments to MARPOL Annex I, adding a new regulation 43A to introduce a prohibition on the use and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters on and after 1 July 2024. Thus, prohibition will cover the use and carriage for use as fuel of oils having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s. Ships engaged in securing the safety of ships, or in search and rescue operations, and ships dedicated to oil spill preparedness and response would be exempted. Ships which meet certain construction standards with regard to oil fuel tank protection would need to comply on and after 1 July 2029.

Q. What are the amendments to MARPOL Annexes I and IV concerning the exemption of UNSP barges from survey and certification requirements?
The MEPC adopted amendments to draft amendments to MARPOL Annexes I and IV concerning the exemption of unmanned non-self-propelled  (UNSP) barges from survey and certification requirements. 
Thus, the Administration may exempt a UNSP barge from the annual survey and certification requirements, for a period not exceeding 5 years provided that the UNSP barge satisfies certain conditions.  A form for the International Oil Pollution Exemption Certificate for Unmanned Non-self-propelled Barges is provided. A circular in this respect is also issued on guidelines for exemption of UNSP barges. 

Q. In future what work is expected regarding underwater noise form ships?
The MEPC agreed to work in respect of the reduction of underwater noise from commercial shipping to address adverse impacts on marine life.

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