The Club would like to remind Members of the latest amendments to MARPOL Annex V that take effect on 1 March 2018. In brief, these require vessels to implement changes to the way in which onboard garbage is managed as well as with the associated record keeping.
Since MARPOL Annex V entered into force on 1 January 2013 there has been a general prohibition of discharging ship’s garbage into the sea. The rules were further strengthened by the inclusion of bulk cargo residues into the definition of garbage if they were considered to be ‘harmful to the marine environment (HME)’, though the rules did not define mandatory criteria to classify cargoes as either HME or non-HME.
Further amendments to MARPOL Annex V were adopted in October 2016 at the 70th session of the Marine Environment Protection Committee (MEPC 70) and these entered into force on 1 March 2018. These amendments to MARPOL Annex V are contained within IMO Resolution MEPC.277(70): (http://www.imo.org/en/KnowledgeCentre/IndexofIMOResolutions/Marine-Environment-Protection-Committee-%28MEPC%29/Documents/MEPC.277%2870%29.pdf)
The major changes to MARPOL Annex V can be summarised as:
- There is a new format for the Garbage Record Book. The record will now be split in Part I and Part II, with Part I being used to record discharges of garbage from all types of vessels and to include a new category of garbage called e-waste.
- Vessels are to maintain an up to date Garbage Record Book, along with all receipts from shore reception facilities, to be retained on board for a period of two years.
- The inclusion of specific criteria for classifying solid bulk cargoes as HME, along with a requirement for shippers of all solid bulk cargoes (other than grain) to declare whether or not the cargo is classified as HME in accordance with the criteria.
The 2012 guidelines have been replaced by a new version (MEPC.295(71)) that align with the new requirements and also the relevant requirements of the Polar Code: https://www.mardep.gov.hk/en/msnote/pdf/msin1719anx1.pdf
Recommendations
The Club draws Members’ attention to the need to have the new format of Garbage Record Book on board their vessels from 1 March 2018 to ensure compliance with the amended MARPOL Annex V. Moreover, Garbage Management Plans and Placards posted on board vessels should also be reviewed and revised as necessary so as to display valid garbage disposal requirements.
The Club is aware from many previous enquiries from Members that there is no definitive list of cargoes that are HME or non-HME and the changes to MARPOL Annex V do not change this situation. Accordingly, the Club would like to stress the importance of vessels’ crews closely inspecting the Shipper’s Declarations prior to loading to ensure the proposed cargo has been declared as HME, or not. The Shipper’s Declaration is required in accordance with Section 4.2 of the IMSBC Code.
The Club is also aware from frequent contact with Members that some ports still lack the required reception facilities to handle ship generated waste. The Club suggests that this possibility is considered at the voyage planning stage with a view to minimising the amount of waste or cargo residues generated through onboard recycling or ensuring that hold cleaning at the end of discharge removes as much of the cargo as possible.
Moreover, to encourage the establishment of improved reception facilities in ports that are currently inadequate, Members could support their Masters to report any such failings in accordance with the procedures set out in Section 6.2 of MEPC.295(71).
Article by Ken Robson
Syndicate Manager - Loss Prevention
