IMO / REGULATORY MATTERS
Let’s not forget about safety, says IBIA’s IMO representative Dr Edmund Hughes
The focus and content of my articles to date have been on the development of the “IMO Net-Zero Framework”. This will be the key regulatory driver under MARPOL Annex VI for the future energy transition of international shipping. However, of equal importance, many in shipping would say of greater importance, is the regulatory framework for the safe operation and use of the alternative fuels and technologies that will be required to enable shipping to achieve the GHG emission reduction goals set by the IMO.
Historically, international shipping regulation was all about safety – going back to the RMS Titanic in 1912 and the subsequent introduction of the Safety of Life at Sea (SOLAS) Convention in 1914 – but safety regulation also plays a critical role in enabling ships to be insured for international trade. This goes even further back to the establishment of the Lloyd’s ‘Register of Ships’ in the 18th Century to address the nefarious practice of “coffin ships”! Insurance and charter parties are mutually linked not least in clauses on “sea worthiness”.
To date the majority of the work on alternative fuels has taken place under the IGF Code, or International Code of Safety for Ships Using Gases or Other Low-flashpoint Fuels, that entered into force on 1 January 2017 and is a mandatory code under the SOLAS Convention. The IGF Code was first developed when the use of gas as a fuel on ships, other than gas carriers, started to become more common place in response to increasingly stringent emission control requirements, in particular, reducing SOx and NOx emissions. The IGF Code provides a set of safety standards to ensure the safe operation of these vessels by regulating the design, installation, and operation of related machinery and systems and aims to minimise the risk to ships, their crews and the environment, given the nature of the fuels involved.
With the introduction and use of “other low-flashpoint fuels”, there was a need for additional provisions for those other fuels and in November 2020 the Maritime Safety Committee (MSC) of IMO approved ‘Interim Guidelines for the safety of ships using methyl/ethyl alcohol as fuel’, aiming to provide an international standard for ships using such fuels. Importantly, the development of these interim guidelines has provided the initial framework for the uptake of alternative fuelled ships, primarily methanol, but now we are seeing growing interest in ethanol. This is due to the possible different production pathways of the fuels and the fact that the “Well to Wake” life-cycle assessment of ethanol, when compared with methanol, – in terms of the amount of equivalent carbon dioxide emitted against the energy produced (gCO2e/MJ) – may provide advantages for compliance with the GHG emission reduction requirements. Such a comparison will become increasingly important for all fuels supplied to ships.
However, as an example of the need for the design and operation standards for these alternative fuels to be constantly reviewed and updated, it has been noted that there are some differences in properties between methanol and ethanol and, as such to ensure the safe use of ethanol as a marine fuel, the interim guidelines needed to be amended.
To this effect IBIA members raised the matter and a draft document, co-sponsored with Brazil, was prepared and submitted to MSC in June. Following consideration, the document was forwarded for further consideration to the IMO Sub-Committee on Carriage of Cargoes and Containers taking place in September.
The above IGF Code example illustrates not only the work of IMO but how much time and effort are required to develop the international regulatory framework to address safety risks. And this is just the technical risks. Of equal, if not of greater importance, are the risks associated with the ‘human element’. A comprehensive review of the Standards of Training, Certification and Watchkeeping (STCW) Convention is ongoing. Much of this review is focused on the identification of training needs to develop the skills and competencies needed to effectively and safely manage these alternative fuels.
Yes, the International Safety Management (ISM) Code can be used already by ships using these fuels but the seafarers and those ashore handling these fuels need to have the opportunity for training and awareness to fully understand the risks and how to mitigate them. However, it is often the case in the shipping industry that this training only gets procured/provided when there is a mandatory requirement to obtain certification – as, if mandatory, then insurers require it.
One of the other areas of significant development in international shipping is digitalisation. IBIA – with the assistance of its dedicated working group – has already contributed to the development by IMO of the data set for electronic Bunker Delivery Notes (eBDN) that ships will share with ports when exchanging information via the mandatory “Single Maritime Window”. Indeed, as many of you will know use of eBDN is already mandated in Singapore. This is just one aspect of digitalisation that will impact the marine fuel supply chain and IMO, under its Facilitation Committee (FAL), has initiated the development of a comprehensive IMO Strategy on Maritime Digitalization. Of potentially greater importance to IBIA and its membership is that digitalisation will become the basis on which increasing amounts of information on each stem of marine fuel delivered to a ship will be transferred through the marine fuel supply chain.
With the IMO Net-Zero Framework set to mandate “Well-to-Wake” accounting of GHG intensity of marine fuels then information will need to be collated, verified and certified, across the whole marine fuel supply chain.
From production, processing, storage and transport including bunkering.
All elements of the supply chain will need to be accounted for and the GHG intensity for the marine fuel provided to the ship. Without this information the ship cannot demonstrate compliance with the GHG intensity targets set in the new regulations and, critically, it will be the basis for calculating any financial penalties (purchase of “remedial units”) and/or “rewards” that the ship may pay/receive.
As currently framed in the draft regulations this information “may accompany the BDN” as it is already recognised that, for example, “Proof of Sustainability” (or other equivalent instrument) may not be available at the time the fuel is delivered to the ship.
It is evident that the volumes of information being transferred throughout the marine fuel supply chain will grow exponentially and the only realistic way of handling and effectively managing that volume will be digitally. Of course, there may well be a roll for AI in all this and no doubt there are those working on this already.
The MSC meeting in June held extensive discussions on the development of regulations under the various instruments to ensure safety risks associated with use of alternative fuels and GHG reducing technologies are effectively mitigated.
It is evident that in the multi-fuel future for international shipping greater emphasis will be needed by the marine fuel supply chain on developing specialist skills and knowledge of both the fuels but also the risks they present and how they should be managed effectively. For companies a clear risk is staff knowledge and competencies, or lack thereof. To address this risk there is a need for training current staff to obtain competencies and, should you have staff with the competencies already, keeping hold of them! Likewise shore based staff will increasingly need to adopt systems that ensure that certified information can be collated from across the whole marine fuel supply chain and then supplied at point of sale. Change is coming and the future is digital!
Wishing you all a fair wind and safe seas.
Edmund Hughes