Prohibition on use of Single Use Plastic

 

DGS Order No. 05 of 2019 Reg Prohibition on use of Single Use Plastics.

Director General of shipping, GOI vide DGS Order No. 05 of 2019 (copy attached) has imposed a ban on single use plastic on all Indian ships and foreign ships while in Indian waters, as follows;

Following Single use plastics are prohibited to be used on board Indian ships and foreign ships when such ships are at a port or place in India;

Items prohibited w.e.f. 01.01.2020:

Bags, trays, containers, food packaging film;

Milk bottles, freezer bags, shampoo bottles, ice cream containers;

Bottles for water and other drinks, dispensing containers for cleaning fluids, biscuit trays;

Hot drink cups, insulated food packaging, protective packaging for fragile items;

Microwave dishes, ice cream tubs, potato chip bags, bottle caps.

Items prohibited with immediate effect:

Cutlery, plates and cups;

Up-to 10 litres bottles for water and other drinks;

Garbage and shopping bags; and

Dispensing containers for cleaning fluids which are less than 10 litres volume.

Enforcement of above requirements on Indian ships:

Verification of compliance to the above requirement to ensure that Single use plastics are not used/ stored on board any ship will be done during surveys, inspections and audits of Indian ships.

Further, during Flag State Inspections, in case of non-compliance to the above requirement, a deficiency will be raised to be rectified prior departure. If the deficiency is repeated during next inspection, it may lead to detention by Flag State Inspector.

Enforcement of above requirements on Foreign Flag ships:

During Port State Inspection, verification will be carried out to ensure that Single use plastics are not in use and are kept locked in a store during ships stay in Indian ports and on their passage through the territorial waters of India.

Foreign ships intending to enter an Indian port are advised to make a log entry identifying the “Single Use Plastic Items” on board the ship and stating the time, latitude and longitude when along with the location of the store where these items are stored prior entering Indian territorial waters. Further no single use plastic items are to be discharged to port reception facility at an Indian port. Same will be verified during Port State Inspection.

Ship owners, operators and masters are advised to be guided by above.

Mooring System Management Plan (MSMP)

 The management of mooring operations is a key aspect of the management of ships and ensuring the safety of seafarers. The fourth edition of the Mooring Equipment Guidelines (MEG4) issued by OCIMF recognises this and outlines many of the related requirements. This is further reinforced with references to the various planning procedures in the seventh edition of the Vessel Inspection Questionnaire (VIQ7).

INTERTANKO has issued new guidance which covers the implementation of the Standard “Mooring System Management Plan (MSMP)”, the “Mooring System Management Plan Register (MSMPR)” which is a subset of the MSMP and the “Line Management Plan (LMP)”.  This guidance is developed to help Members comply with MEG4 and to address the questions in VIQ7.

These plans are new tools to assist Members with managing equipment and lines from design to retirement. MEG4 states that the plans should remain on the ship throughout its life as part of the management of change records to ensure that documents and records are not lost and it is recommended that all information relevant to the mooring of the ship is considered together as a complete system. The plans should also include a record of any changes that have occurred to the mooring equipment and arrangements since the vessel was built

Mooring System Management Plan: The MSMP should be written to ensure the mooring system is inspected, maintained and operated in accordance with the original design basis. The information contained should be available to anyone who needs to review it. The MSMP is to be ship specific and complement the ship’s safety management system. Through a ‘goal-based’ approach, core elements of the mooring system are identified against which high level ‘goals’ are established supported by more detailed ‘functional requirements’. A register of the mooring system components is maintained for the ship’s life in an accompanying Mooring System Management Plan Register.

The MSMP should contain the following:

Part A – General ship particulars

Part B – Mooring equipment design philosophy

Part C – Detailed list of mooring equipment

Part D – Inspection, maintenance and retirement strategies

Part E – Risk and change management, safety of personnel, and human factors

Part F – Records and documentation

Part G – Mooring System Management Plan Register (MSMPR)

Line Management Plan: Contained within section 5.4.2 of Mooring Equipment Guidelines (MEG4) is a description of the Line Management Plan (LMP). The LMP is specific to an operator, ship type, and trade route; however, MEG4 gives general guidance on establishing a LMP. The LMP should contain all the requirements for how the lines are maintained, inspected and retired and each of these parts should be detailed in the plan. For example, in the maintenance section it should detail the installation, storage, repair, maintenance and wear and tear, while at every stage referencing any 

Confined Place Entry - Requirments

 

Based on recent casualty where three people were asphyxiated while working onboard a laid up Mobile Offshore Drilling Unit (MODU) the USCG has issued a Marine Safety Alert 04-19 (copy attached) on the dangers of confined space entry.

The incident that caused death of 3 crew member was occurred during dewatering of MODU’s legs while crew were preparing it for a heavy lift transport to an overseas ship breaking facility.

The Coast Guard says that Studies have shown that people often miss the obvious cues of a situation while under stress and because their focus is upon another effort or action that needs to be accomplished. Several sources indicate that over 50% of the workers in enclosed / confined spaces die while attempting to rescue their coworkers.

The investigators were concerned, due to the fact that the Captain decided to enter the space with two other people without personal protective gear and a SCBA.

Therefore, in light of this incident, the Coast Guard strongly encourages all who work or may be employed onboard vessels in any role, whether they be senior shipboard officers or crew, riding crew, shore side managers, owners/operators, and other personnel to:

Obtain the requisite level of knowledge and training of confined space entry procedures including emergency and rescue procedures;

Ensure crews undergo periodic confined space training and participate in routine and practical onboard emergency drills;

Verify all required confined space entry and rescue safety equipment is onboard, maintained, tested and fully functional; and

Continually appreciate the dangers involved in confined space entry and educate yourself by further study.

Ship owners/ operators and masters are advised to take note of above and bring the marine safety alert to the attention of all crew serving onboard, addressing the hazard and the related consequences with the aim to prevent recurrence

Exhaust Gas Cleaning System (EGCS) - MARPOL Annex VI, Regulation 4

 Instructions with respect to Exhaust Gas Cleaning System (EGCS):

Ships intending to use Exhaust Gas Cleaning Systems (EGCS) under the ‘equivalent’ means of compliance permitted by MARPOL Annex VI, Regulation 4, are required to comply withMEPC.259 (68) Guidelines for Exhaust Gas Cleaning. Such ships are required to carry following documents on board

a. SOx Emission Compliance Plan (SECP) approved by RO on behalf of Administration detailing the method of compliance for all fuel oil combustion machinery installed on board. 

b. SOx Emission Compliance Certificate (SECC) issued by RO on behalf of Administration. 

c. EGCS Technical Manual for Scheme A (ETM-A) or EGCS Technical Manual for Scheme B (ETM- B) as applicable duly approved by RO on behalf of Administration

d. An On-board Monitoring Manual (OMM) prepared to cover each EGCS unit provided for the fuel oil combustion equipment.

e. An EGC Record Book prepared by manufacturer and approved by RO.

f. A data recording and processing device meeting the requirements detailed in MEPC. 259(68).

Wash water resulting from exhaust gas cleaning systems are not to be discharged into the sea, including enclosed ports, harbours and estuaries unless the wash-water meets the criteria set out in Resolution MEPC.259(68) and applicable local regulation. Instructions with respect to Exhaust Gas Cleaning System (EGCS):

Ships intending to use Exhaust Gas Cleaning Systems (EGCS) under the ‘equivalent’ means of compliance permitted by MARPOL Annex VI, Regulation 4, are required to comply withMEPC.259 (68) Guidelines for Exhaust Gas Cleaning. Such ships are required to carry following documents on board:

a. SOx Emission Compliance Plan (SECP) approved by RO on behalf of Administration detailing the method of compliance for all fuel oil combustion machinery installed on board.

b. SOx Emission Compliance Certificate (SECC) issued by RO on behalf of Administration.

c. EGCS Technical Manual for Scheme A (ETM-A) or EGCS Technical Manual for Scheme B (ETM- B) as applicable duly approved by RO on behalf of Administration. 

d. An On-board Monitoring Manual (OMM) prepared to cover each EGCS unit provided for the fuel oil combustion equipment.

e. An EGC Record Book prepared by manufacturer and approved by RO. 

f. A data recording and processing device meeting the requirements detailed in MEPC. 259(68).

Wash water resulting from exhaust gas cleaning systems are not to be discharged into the sea, including enclosed ports, harbours and estuaries unless the wash-water meets the criteria set out in Resolution MEPC.259(68) and applicable local regulation.

iii. Indian ships faced with EGCS breakdown are advised to report malfunction that lasts more than one hour or repetitive malfunctions to the PSC Cell of the Directorate along with an explanation of the steps the ship operator is taking to address the failure. The ship operator to follow the process to identify and remedy the malfunction in the EGCS as per the approved EGCS Technical Manual or in other documentation provided by the EGCS manufacturer. Foreign ships coming to India are required to report all such cases to jurisdictional Principal Officer and the ship is to change over to compliant fuel oil within 4 hours of arrival.

Instructions to approved Bunker Suppliers: :<br>

i. Approved bunker suppliers are required to be guided by MEPC.1/Circ.875/Add.1- for assuring the quality of fuel ii. No fuel oil with sulphur content exceeding 0.5% m/m is to be supplied to any ship (Indian or Foreign) without keeping a copy of Supplement to IAPP Certificate indicating equivalent compliance for records. <br>

iii. No fuel oil with sulphur content exceeding0.50% m/m is to be supplied to any ship (Indian or Foreign and claiming to have a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research in accordance with Regulation 3.2 of MARPOL Annex VI) without concurrence of the competent authority in DGS, GOI. :<br>

iv. Each case of supply of fuel oil with sulphur content exceeding 0.5% m/m will be specially audited by Auditors during Annual/ Renewal Bunker Suppliers audits for compliance to above requirements.

iii. Indian ships faced with EGCS breakdown are advised to report malfunction that lasts more than one hour or repetitive malfunctions to the PSC Cell of the Directorate along with an explanation of the steps the ship operator is taking to address the failure. The ship operator to follow the process to identify and remedy the malfunction in the EGCS as per the approved EGCS Technical Manual or in other documentation provided by the EGCS manufacturer. Foreign ships coming to India are required to report all such cases to jurisdictional Principal Officer and the ship is to change over to compliant fuel oil within 4 hours of arrival.

Instructions to approved Bunker Suppliers: <br>

i. Approved bunker suppliers are required to be guided by MEPC.1/Circ.875/Add.1- for assuring the quality of fuel ii. No fuel oil with sulphur content exceeding 0.5% m/m is to be supplied to any ship (Indian or Foreign) without keeping a copy of Supplement to IAPP Certificate indicating equivalent compliance for records. :<br>

iii. No fuel oil with sulphur content exceeding0.50% m/m is to be supplied to any ship (Indian or Foreign and claiming to have a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research in accordance with Regulation 3.2 of MARPOL Annex VI) without concurrence of the competent authority in DGS, GOI. :<br>

iv. Each case of supply of fuel oil with sulphur content exceeding 0.5% m/m will be specially audited by Auditors during Annual/ Renewal Bunker Suppliers audits for compliance to above requirements.

Requirement of MARPOL Annex VI

DGS guidelines on compliance with the provisions of MARPOL Annex VI Regulation.

Director General of shipping, GOI vide<a  href=” https://www.dgshipping.gov.in/writereaddata/ShippingNotices/201908280416058978387Eng_Cir_02of2019.pdf” >Engineering circular no. 02 of 2019</a> has provided guidance and requirements for of MARPOL Annex VI Regulation 14 As per MARPOL Annex VI, regulation 14, the sulphur content of any fuel oil used on board ships outside Emission Control Areas shall not exceed 0.50% m/m on or after 1 January 2020. The interpretation of ‘fuel oil used on board’ includes fuel oil used in all emission sources including emergency equipment.

The regulation 14 also prohibits carriage of fuel oil with sulphur content more than 0.5% m/m for use on board ships on or after 1 March 2020. However, the prohibition on the carriage does not apply to ships fitted with ‘equivalent’ means of compliance permitted by MARPOL Annex VI, Regulation 4, such as exhaust gas cleaning system (EGCS). Also the prohibition does not apply to carriage of fuel oil with sulphur content more than 0.5% m/m as cargo.

The Supplement to IAPP Certificate is revised vide Resolution MEPC. 305(73) by addition of a new paragraph 2.3.3 to include compliance with above prohibition. The revised certificate will be annotated to state that “This Certificate will be effective from 01/03/2020.

MARPOL Annex VI, Regulation 18 provides that in cases where compliant fuel is not available, a ship is not expected to deviate from the intended route or unduly delay the voyage to procure compliant bunker fuel. Further (due to said reasons despite its best efforts to procure compliant fuel oil), the ship can undertake intended voyage after bunkering non-compliant fuel oil, provided the Master/Owner/operator informs the ship’s Flag State and the port State of next port of call well in advance. To standardize this information, FONAR (Fuel Oil Non-Availability Report) has been developed and provided in MEPC 320(74).

Instructions to ship Owners:

i. MEPC.1/Circ.878-Guidance on development of a ship implementation plan for consistent implementation of 0.5% sulphur limit under MARPOL Annex VI. The ship implementation plan is not a mandatory requirement, however Administrations and Port State Control authorities may consider the ship implementation plan as an evidence of due diligence by the ship owner when verifying compliance with 0.5% sulphur limit requirement.

ii. Cleaning of bunker tanks, pipelines, filters etc, may be considered to prevent compatibility and stability. It is to be noted that any modification in the fuel oil system is to be approved by the vessel’s classification society. Also any changes/ modification to engines is to be approved by the engine manufacturer.

v. Owners/operators are advised to be guided by MEPC.1/Circ.875 which provides guidance on best practice for fuel oil purchaser/users for assuring the quality of fuel oil used onboard ships.

 

 

 

 

Ballast Water Management Plan - Amendments

The International Maritime Organization (IMO) vide Resolution, MEPC. 306(73) adopted amendments to the Guidelines for Ballast Water Management and Development of Ballast Water Management Plans (G4).

The amendments requires Ballast Water Management Plans to include contingency measures in case a ship is unable to manage ballast water in accordance with its approved Ballast Water Management Plan to meet the D-1 or D-2 standard.

Based on above, DGS, GOI has provided following requirements in respect of BWM Plans for GOI flagged ships:

a. Ballast Water Management System meeting D-2 standards already fitted on ships to include contingency measures prior next Annual/ Intermediate / Renewal surveys.

(Compliance to above requirement will be verified at the next Annual / Intermediate / Renewal BWMC survey whichever comes first)

b. New Ballast Water Management System meeting D-2 standards to include contingency measures during re-approval of BWM Plan while the system meeting D-2 standard is fitted.

 

The Ballast Water Management Plans to include contingency measures taking into account the “Guidance on contingency measures under the BWM Convention” published as BWM.2/Circ.62 and must include atleast the following:

a. Information to Port State and Flag State.

b. Permission from Port State or Directorate General of Shipping (Indian / Foreign Ships in India) for discharging Ballast Water meeting D-1 standards.

c. Assessment of;

Need for shore discharge connection, in case Ballast Water is required to be discharged to shore reception facility due to failure of BW Management System installed to achieve D-2 standards.

Cleaning of tank.

Safety issue while discharging to shore reception and procedures for same.

Ship owners/ operators and masters of GOI flagged ships are advised to be guided by above.