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Trends, Developments and Challenges for the International Maritime Organization – Australian input

EFFECTIVENESS OF THE IMO ................................................................................ 2

1. Maritime Transport Security Regulation ....................................................... 2

2. Effectiveness of IMO Measures ..................................................................... 4

MARITIME SAFETY ................................................................................................... 6

3. Increasing size and draught of commercial ships ....................................... 6

4. Harmonisation of aeronautical and maritime search and rescue (SAR) .... 8

5. Reliance on Global Navigation Satellite System (GNSS) .......................... 10

6. Hydrographic Surveys ................................................................................. 11

7. Use of gases and low-flashpoint fuels ........................................................ 14

8. Ongoing need to develop and maintain standards for the safe carriage of bulk cargoes and dangerous goods.................................................................. 16

MARITIME SECURITY ............................................................................................. 19

9. Piracy in the Asian Region........................................................................... 19

10. Emerging Technologies, including practical e-navigation outputs ......... 21

11. Increased administrative burden for ship’s officers .................................. 23

MARITIME TRADE FACILITATION ......................................................................... 24

12. Shipping and the ‘Blue Economy’ ............................................................... 24

13. The Single Window ....................................................................................... 26

14. Maritime Communications ........................................................................... 29

15. Implementation of VTS ................................................................................. 30

MINIMISING SHIP SOURCED ENVIROMENTAL DAMAGE ................................... 31

16. Greenhouse Gas Emissions ........................................................................ 31

17. Availability of low-sulphur fuel .................................................................... 34

18. Management of Garbage from Ships .......................................................... 38

19. Illegal, Unreported an Unregulated (IUU) Fishing ...................................... 42

20. Managing Ships’ Biofouling ......................................................................... 44

21. Ballast Water Management .......................................................................... 46

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EFFECTIVENESS OF THE IMO

1. Maritime Transport Security Regulation

Short description

The International Ship and Port Facility Security (ISPS) Code has served the international community well since its inception. However, with the 20th anniversary approaching in 2022, it may be timely to review the Code to ensure its adaptability to the changing security environment and improving international regulatory practices.

Narrative covering trends and developments

The ISPS Code was developed in response to a specific historical event and at a time where there was no international framework to provide for maritime transport security. While there is a degree of flexibility within the Code, further refinement could be considered to help with facilitating international trade where Flag, Port or Coastal states consider security risks to be very low or negligible.

Security threats are highly variable between countries and regions. This is somewhat in contrast to maritime safety and environment issues, where risk of accident is relatively constant due to the inherent nature of shipping operations.

The IMO Public Consultation on Administrative Requirements in Maritime Regulations, which was conducted in 2013, revealed a perception in the maritime community that the ISPS regulations were burdensome. The report recommended actions to improve security awareness. The IMO Council has supported the recommendation and requested that Maritime Safety Committee consider it further.

Opportunities for amending ISPS and increasing its flexibility may prove beneficial, particularly as:

i. Reducing the burden of unnecessary regulation is being pursued by many Governments and businesses.

ii. For many Contracting Governments there has been a normalisation of a low, but constant, maritime transport security risk. The peak security environment in which ISPS was established has altered and the maritime transport security environment is not a unilateral high risk.

iii. Risk perceptions and appetite may differ and change as the threat environment evolves. In contrast to the time of ISPS’s drafting, many Contracting Governments now have a substantial knowledge and experience of regulating maritime transport security.

iv. Concepts of maritime transport security, and how and by whom these issues should be managed, differ between Contracting Governments. Security costs being passed on to the supply chain could distort the market without any security benefit.

v. There is an evolving view that safety and security regulations could be more mutually reinforcing.

vi. The size and capability of shipping is changing, and the speed of adoption of new technologies continues to increase. For example, the use of unmanned vessels by Government and industry is growing rapidly. These developments have implications which currently fall outside ISPS, which relies on traditional maritime operating concepts.

Supporting data

There is very little publicly available/easily accessible data concerning the types of threats and incidents that the ISPS Code was established to combat. Conversely, piracy and armed robbery has been well reported over the past decade and much work has been done by the IMO and other organisations to address this problem. Piracy, however, is managed differently

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by individual IMO Contracting Governments and is not necessarily even addressed through domestic application of the ISPS Code.

Control Risks’ 2015 Maritime Risk Work notes that, in addition to piracy, the primary international maritime security risks are connected to: port and anchorage crime, domestic instability and civil unrest, political violence, territorial disputes, and migration1. This situation suggests that there may be benefit in reviewing the ISPS framework to identify opportunities for increasing flexibility towards more proportionate regulatory responses.

The challenges facing the maritime community

In the continuing wake of the global financial crisis, numerous Contracting Governments have faced significant pressure to find opportunities to support their national economies. Options to reduce the regulatory burden, without increasing risk or affecting the security outcomes, are being investigated. The initial spike in security concern in the early 2000s has been tempered for many Governments, particularly in relation to terrorism in the maritime sector. For many states with a low threat profile, a non-compliance with ISPS does not necessarily equate to an increase in overall security risk.

That being said, security measures provide a level of benefit to industry, which has a commercial interest in adequately managing their security risk. Security standards should remain both robust and flexible enough to keep abreast of the ever changing modus operandi of those who wish to unlawfully interfere with maritime transport. There could also be benefit in promoting greater synergy between maritime transport safety, counter-terrorism and counter-piracy measures to reduce overlapping/unnecessary regulation.

Concern by states to maintain sovereignty over security for their ships has been a significant force in the development of codes and tools within the IMO. This has resulted in a broad security regime for ships, but has not provided Port and Coastal states with additional powers in relation to the presence of foreign ships in their waters or ports, which needs to be proportionate to local risks.

1 http://www.maritime-executive.com/article/2014-Piracy-Terrorism--Diverse-Maritime-Threats-2014-03-14

http://www.maritime-executive.com/article/2014-Piracy-Terrorism--Diverse-Maritime-Threats-2014-03-14

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2. Effectiveness of IMO Measures

Short description

The suite of IMO conventions contains countless measures designed to improve the efficiency and safety of international shipping, as well as protect the marine environment. These measures are adopted following careful negotiation between Member States.

Monitoring the effectiveness of these measures (to ensure that the measure negotiated and implemented has achieved its aim) is currently not carried out consistently and is arguably carried out in a reactive manner, for example based on an incident or an issue raised by a Member State.

Placing greater emphasis on reviewing the effectiveness of IMO regulations would help ensure that these requirements remain current, efficient and proportionate, and achieve the outcomes envisaged by the maritime community. This would reduce the need for Member States to raise such regulatory issues reactively as unplanned outputs and would increase the maritime community’s confidence in IMO measures.


Generally, emphasis is placed on negotiating and agreeing Convention text and then implementing the requirements of the text, with much less emphasis placed on reviewing its effectiveness. To put in simple business management terms, the focus is on ‘Plan’ and ‘Do’ and much less on ‘Check’ and ‘Act’ (or ‘Adjust’).

Regulatory measures could be routinely reviewed to establish whether they are achieving the required outcomes, and if not, whether the measure itself is ineffective or whether implementation of the measure, such as communication or behavioural change, needs to improve.

Routinely reviewing the effectiveness of IMO measures would provide an opportunity for IMO to better target its work and minimise the need for Member States to raise issues as unplanned outputs. Unplanned outputs can often lead to overloaded Committee or Sub-Committee work plans, resulting in delayed work on strategic issues.

Routine review would also reduce regulatory burden by identifying ineffective or superseded measures which may require repeal or amendment.

Reviews could be prioritised based on consultation with Member States and the shipping industry to identify the issues that are most relevant to the ongoing safety of ships and crew and the protection of the marine environment.

Issues to be considered may include maintaining regulatory certainty, and ensuring early adopters are not unfairly penalised.

Supporting data

Examples of measures which would benefit from assessment of their effectiveness include:

i. Absence of requirement to regularly test discharge from sewage treatment plants

(STPs).

While MARPOL Annex IV (sewage) requires a ship to undertake an STP renewal

survey every five years, at the latest, to ensure that the structure, equipment, systems,

fittings, arrangements and materials fully comply with the requirements under Annex

IV, there are no requirements for the effluent from an STP to be tested regularly, or at

specific intervals, to ensure that the system is producing effluent in accordance with the

prescribed requirement.

Under the Port State Control (PSC) Guidelines (A.1052(27)), an inspector may review

whether the sewage treatment system is operational, has been used and any alleged

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inadequacies, such as discharge piping connections, as well as if the ships personnel

are familiar with the correct operation of the system. However, the inspector does not

test the efficacy of the system. In addition, no record of sewage discharge is required

to determine if discharges, particularly those not undertaken via a treatment system,

have been undertaken in accordance with Annex IV requirements. Although a STP

may appear to be working, there is currently no requirement to collect or provide

evidence that the system is producing effluent or operating effectively as intended by

the regulations under Annex IV.

Such assessments would confirm whether a STP is achieving its intended objective

and is effectively protecting the marine environment.

ii. Accidents resulting from the failure or incorrect use of lifeboat release mechanisms.

A review of seafarer fatalities revealed a major cause of accidents resulted from the

failure or incorrect use of lifeboat release mechanisms. Measures were introduced to

address the problem, including functional standards for new and existing release

mechanisms, and improved seafarer training. There is currently no tool for assessing

the effectiveness of these measures. A possible method would be to compare lifeboat

accident data between periods before and after the introduction of the measures. If

there is little change, it would suggest the measures have not been effective and

further examination would be required to determine the underlying issues, for example

a lack of awareness and training of seafarers, or inadequacies of the physical

equipment.


- Measures under IMO Conventions have been developed following extensive negotiation between Member States. It is therefore essential that these measures are efficient and effective and achieve the outcomes envisaged. IMO instruments should be routinely reviewed to assess effectiveness and to address any identified drafting or implementation issues.

- Developing consistent measures of effectiveness would need to occur in consultation with the shipping industry and be subject to regular review. This may involve strengthening the port State control mechanism. Any tool for assessment of the effectiveness of a regulatory change could often be found in the justification contained within the initial proposal for that change.

- Should a consistent measure of effectiveness be agreed, this would allow the IMO to place a greater focus on strategic issues rather than reactive issues and on unplanned outputs.

- Consideration could be given to updating the requirements for developing new planned outputs in MSC-MEPC.1/Circ.4, to include information on how the effectiveness of the proposed measure could be monitored. Alternatively, new measures could include a mandatory implementation section which articulates the process for assessing the effectiveness of the proposed measures.

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MARITIME SAFETY 3. Increasing size and draught of commercial ships

Short description

The size, speed and draught of commercial vessels is increasing as a result of commercial pressures, resulting in reduced safety margins between each vessel and the seabed, and consequential requirements for increased accuracy of nautical charts within ports, their approaches and constrained waterways.

While the capability for high accuracy hydrographic surveys within ports is adequately met via commercial organisations, the resulting charting of those surveys for use by mariners, as well as the conduct of hydrographic surveys in constrained coastal waterways away from ports, has significant resource implications, which are often not available when balanced against other national priorities. Therefore the necessary modern surveys and nautical charts may not be available, and expectations or forecast future requirements of the maritime community may not be met. Consequently, ships are increasingly turning to ‘unofficial’ data and bespoke systems for managing under-keel clearance in critical areas, with ‘official’ charts relegated to a secondary role.

Ships are required to abide by the International Convention for the Safety of Life At Sea (SOLAS), as adopted into legislation by the various coastal States. This includes requirements to use charts produced by or on behalf of a national hydrographic authority (‘official’ charts), but many national hydrographic authorities are falling behind mariner expectations for high accuracy surveys and highly detailed nautical charts of ports and constrained waterways.


Dynamic under-keel clearance systems

In ports where under-keel clearances are at their maximum, mariners increasingly rely upon local services provided by ports, particularly in the form of dynamic under-keel clearance systems, with information supplied to the marine pilot via non-certified bespoke systems. This is typically a Portable Pilotage Unit. Under SOLAS, these are merely aids to navigation and the ‘official’ chart is the primary legal document. However in practice, dynamic under-keel clearance systems provide the most recent information supplied directly by the port, contain more detailed information than can be included in a chart, have height of tide integrated into the solution, and can present a clear go and no-go depiction. As these are isolated systems available only to the marine pilot, this has the secondary effect of relegating the Master (without the benefit of the information supplied to the pilot), to a supporting role.

Constrained waterways

Commercial shipping is always seeking higher accuracy and more detailed depths in order to maximise the draught (and hence the tonnage of cargo). Within constrained coastal waterways, the Australian Hydrographic Service (AHS) has twice published a series of electronic charts intended to support the smaller margins between progressively larger ships and the seabed - the AHS has actually produced more high density Electronic Navigational Charts (ENC) than any other producer nation. However, the AHS found it impossible to produce a practical high density ENC with the 0.1 metre contours sought by mariners for these areas, while still remaining within the IMO’s 5MB file size limitation. On each attempt, the services were withdrawn on the basis of not meeting the full user requirement, despite every extra 10 cm of draught representing hundreds of thousands of dollars of additional cargo for no additional transport cost.

Developments

The S-57 standard governing current generation ENC is based upon early 1990s technology and is limited to 5MB. S-101 ENC will likely be limited to 10MB, but for selected areas, a more

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practical limitation, based upon experience, would be 50MB. While the next generation S-101 ENC represents a doubling of file size limitation, this is not proportionate with the quantum increase in processing and file storage capacity in even the most basic IT systems available today. Similarly, it does not reflect the connectivity that is already available in many ships, nor the bandwidths that will be available in ships by the time S-101 ENC are in widespread use.


The requirement for ships to use official charts and publications has relegated use of dynamic under-keel clearance systems to secondary aids when, in reality, they contain newer, better and more complete information than official charts, leaving their status and use unclear. The proposed International Hydrographic Organization (IHO) Standard for under-keel clearance data will contribute to bringing this system into the mainstream.

File size limitations for ENC has resulted in an inability to produce genuinely fit for purpose ENC of constrained shallow waterways, and will continue to limit usefulness into the next generation of ENC. Ideally prescriptive file size limitations should be removed from any IMO ECDIS documentation.

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4. Harmonisation of aeronautical and maritime search and rescue (SAR)

Short description

Harmonisation of a State’s aeronautical and maritime Search and Rescue (SAR) efforts facilitates a timely and coherent SAR response, particularly in terms of identifying existing synergies in the aeronautical and maritime SAR operations of a State. The subsequent outcome is improvements in SAR response times, information flow and the optimisation of SAR assets.


ICAO/IMO – Joint working group.

The International Civil Aviation Organization (ICAO)/International Maritime Organization (IMO) Joint Working Group (JWG) on Harmonization of Aeronautical and Maritime Search and Rescue was established in 1993 with the objective of assisting ICAO and IMO in developing provisions regarding new SAR techniques and procedures, where both aeronautical and maritime interests were involved.

The JWG has eight ICAO nominated aeronautical SAR technical expert members and eight IMO nominated maritime SAR technical expert members. Members are expected to serve as individual SAR experts rather than State representatives. The JWG has no power to make recommendations to States, nor to any organization other than ICAO and IMO.

The annual JWG has seen a growth in the number and complexity of aeronautical and maritime SAR matters being presented to it during the past five years. Since 2011, the JWG has seen the number of meeting papers submitted for its consideration grow from 12 in 2011 to 50 in 2015, which challenges the JWG’s ability to adequately deal with the growing list of issues. This trend is expected to continue, especially with ICAO now more focussed on SAR matters and the need to urgently address global SAR deficiencies, Annex 12 compliance and development of the Global Aeronautical Distress and Safety System (GADSS).

Policies and structures that enhance the harmonisation of Aeronautical and Maritime SAR

IAMSAR: the International Aeronautical and Maritime Search and Rescue (IAMSAR) manual calls for a Global SAR Plan, established under the International Convention on Civil Aviation (1944) Annex 12 (SAR) and the International SAR Convention 1978, which would provide a harmonised approach to aeronautical and maritime SAR.

Cooperative mechanisms in National/Regional SAR Plans: Cooperative mechanisms included in National/Regional SAR Plans are facilitating harmonisation of aeronautical and maritime SAR through:

Joint Rescue Coordination Centres (JRCC) – Since coordination is a key element of SAR, a JRCC resolves the shortcomings in the delay and/or risk to accuracy of information shared between separate aeronautical and maritime rescue coordination centres. Interestingly there are approximately 36 JRCCs in a total of approximately 300 rescue coordination centres around the world.

Military/Civilian SAR – discussions between States in forums such as the ICAO/IMO JWG on greater international engagement regarding a State capitalising on both military and civilian search and rescue capacities, aiming to maximise strengths and remove costly redundancies across both maritime and particularly aviation resources.

Capability Development Programs - SAR training and exercises that often form a significant part of Capability Development Programs include enhancing SAR Mission Coordinator (SMC) cross-competency in aeronautical and maritime SAR. SAR exercises usually involve scenarios that require the coordination of the broadest possible use of both aeronautical and marine SAR resources, in order to optimise the

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training outcomes across a wide range of SAR capabilities for the participating agencies.

Regional Capacity Building - the harmonisation of aeronautical and maritime SAR resources among participating regional States is critical to the success of programs to build regional capacity, as it supports a lower overall SAR cost to each of the participating regional States by sharing the overall cost burden.

Optimisation of Technology – harmonisation opportunities occur when there is a sharing of SAR systems; maritime, aeronautical or space-based alerts; and communication systems.


Financial capacity - Developing States are struggling to implement the global SAR system due to the lack of financial capacity. This may impede the harmonisation of aeronautical and maritime SAR.

A number of States are yet to ratify relevant international SAR conventions, or develop responsive National SAR Systems taking into account the requirements of IAMSAR and the need for a Global SAR Plan.

ICAO/IMO IAMSAR manual – there is concern amongst the ICAO/IMO JWG that IAMSAR’s three year publication cycle does not adequately keep pace with the rapid changes in the SAR environment and therefore may not adequately support effective harmonisation of aeronautical and maritime SAR as developments in either or both evolve.

ICAO/IMO JWG capacity – as noted above, the capacity of the JWG to deal with the ever expanding issues for consideration by the JWG (as reflected in the steady significant increase in the number of papers submitted to the annual JWG) is of concern to the JWG members. For example, there will be a high workload during the development of the GADSS and its integration with various elements of air traffic management, coordination of SAR resources, and how the provision of data is processed in RCCs.

The financial capacity of ICAO/IMO to resource the technical expertise required to facilitate effective harmonisation of aeronautical and maritime SAR is limited. An example is the Australian SAA Technical Officer secondee. While ICAO is grateful for the assistance from Australia to help address the large list of emerging global SAR issues, including the harmonisation efforts of the JWG, this secondment ends at the end of 2016. Whilst ICAO has indicated it is planning to resource a permanent SAR Technical Officer, it is unclear what ICAO’s plans are and whether it has resources to support such a position.

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5. Reliance on Global Navigation Satellite System (GNSS)

Short description

Mariners are increasingly dependent upon GNSS as the primary navigation input to Electronic Chart Display and Information Systems (ECDIS), particularly out of sight of land. However, out of sight of land does not mean out of harm’s way from potential navigation hazards in the event that GNSS signals are interfered with or blocked. Despite this risk, the emphasis on navigation via astronomical or other non-GNSS means is decreasing, or no longer part of active discussions within the navigation community.

Additionally, with the ability to accept waypoints as part of route planning and monitoring, there have been an increasing number of incidents of head-on encounters where ships are using exactly the same route, rather than offsetting to the starboard side of a channel or fairway.


Global Positioning System (GPS) jammers are now readily able via the internet. While there is much discussion within the IMO regarding alternative precise navigation systems, the reality is that ships are still equipped with gyros for bearings, radars for ranges, echo sounders for depth, and other nautical instruments such as sextants. Radar images are often available as an ECDIS underlay, when in range of land. This leaves navigation outside visual and radar range as the most at risk aspect of navigation in the event that a GNSS signal is blocked, spoofed or not available due to equipment failure.

Ship-fitted equipment and portable instruments remain readily available. Sextants and relevant software applications to reduce sights make astronomical positioning a relatively quick alternative form of positioning. However, effectiveness and reliability remain dependent upon training and practice, whether for taking sextant sights or using other forms of positioning when out of sight of land. The level of competence in using alternative positioning systems and techniques at sea is declining due to the convenience of simply monitoring a GNSS position on a screen.

The widespread introduction of GPS created the practice of accepting waypoints as part of route planning and monitoring. The rollout of the ECDIS and ENC carriage requirement is likely to exacerbate this, particularly where single recommended or preferred routes remain charted. There is a strong trend for watch keepers to stay firmly on the planned track rather than consider availability of suitable waters a suitable distance away from the centreline, and thereby causing avoidable close quarters encounters between oncoming ships.

Some nations have noted this trend and are progressively converting charted recommended routes into broader fairways or two way routes. However, mariners still need to be encouraged to displace their planned track away from the centre of the route.


Heavy reliance on (and assumption of) continuous availability and integrity of GNSS and the associated decline in skills required to navigate using non-GNSS instruments such as sextants.

Considering additional functionality in future generations of ECDIS to include a route offset function to be applied to a planned route before route checking is undertaken, with the ability to modify all or part of the offset in response to the results of route checking.

Possible limitations associated with the GPS signal should be acknowledged. Watch keepers should be alerted and made aware of the possible dangers of relying on a single method of position fixing. Such awareness could only be canvassed by the relevant Ship Management Designated Person Ashore ensuring that ships’ Safety Management Systems reflect this and are verified accordingly. A review of the reliability of the GPS signal and associated equipment would assist in this regard.

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6. Hydrographic Surveys

Short description

There is currently a worldwide lack of capacity and progress in hydrographic surveying and nautical charting. While reliable ship operators will take into account the limitations of information provided in nautical charts, particularly for inadequately surveyed or unsurveyed waters, less reliable operators may ignore these limitations and create risks to human life and the environment.


General surveying and chart accuracy in coastal waters

Most national hydrographic services are responsible for conducting hydrographic surveys outside port limits, and nautical charting within ports and coastal areas as well as nominated areas of the high seas. The focus areas are port and coastal areas, where ships can strike the seabed, or where undetected features may be a hazard to shipping.

A study was undertaken by the Australian Hydrographic Service in 2015 as part of an IHO technical working group. The study encompassed over 14 million square kilometres of coastal Electronic Navigational Chart from 32 nations, and highlighted that while ships today can navigate to an accuracy of better than 15 metres using satellite based systems, 99% of the surveys used to produce the charts upon which they are navigating have positional accuracy worse than 20 metres, with over 45% worse than 500 metres.

Notably, hydrographic surveys conducted prior to 1945 (initial widespread availability of echo sounders for national surveying) are now considered inadequate due to the lack of position integrity and failure to detect hazards between the spot lead-line depths. Surveys conducted between 1945 and the early 1970s (initial availability of side scan sonars) are considered only temporarily adequate as the depths to which full investigations were conducted of initial shoal detections were driven by the draughts of vessels existing at the time, plus a small growth margin, however the draughts of modern ships can exceed that margin, and are beyond anything envisaged at the time. In any area surveyed without the benefit of a sonar sweep to detect uncharted features between the lines of soundings there still remains the possibility of undetected features, mitigated only by the maximum draught of previous vessels to have passed many times through such an area.

Developments

In simple terms, there is a widening gap between the relatively poor overall quality of hydrographic surveys and nautical charts, and the requirements and navigation capabilities of deep draught shipping. There are currently no technological developments that can adequately address this widening gap – LiDAR is highly effective in certain circumstances but is limited by water clarity, while satellite derived bathymetry is only suitable for very shallow waters and remains a largely unproven capability for reliable hydrographic surveys. A pro-active approach to crowd sourcing could yield better results, something which the IHO is actively encouraging.

Supporting data

The following assessment of the quality of hydrographic surveys is extracted from over 14 million square km of world-wide published and commercially available Electronic Navigational Chart coastal and approach coverage (Navigation Purposes 3 and 4), as available in April 2015:

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Category of Zone Of Confidence CATZOC / (ZOC)

(% area of world cruise Navigation Purpose 3 & 4 ENC)

Quality of survey coverage

1 / (A1) 0.7 % Very good – Seafloor features detected and measured

2 / (A2) 1.0 % Good – Seafloor features detected and measured

3 / (B) 30.5 % Adequate – Features hazardous to surface navigation are not expected but may exist

4 / (C) 21.8 % Inadequate (caution) – Depth anomalies may be expected

5 / (D) 20.5 % Highly inadequate or unsurveyed (extreme caution) – Large depth anomalies may be expected.

6 / (U) 25.4 % Unknown, (inadequate or worse)

Table 2 - World coastal waters coverage supplied to ships includes SQ KM for each listed ENC producer nation:

AR - 27,455

BH - 3,514

BR - 627,112

C1 - 1,434,096

C2 - 3,774

CA - 434,475

DE - 27,329

DK - 11,889

ES - 250,303

FR - 539,393

GB - 2,907,340

GR - 574,406

ID - 1,560,393

IN - 620,150

IT - 47,809

JP - 1,000,902

KR - 474,527

LK - 289.

MM - 1,061

MS - 46,965

MY - 422,082

NL - 29,164

NO - 17,081

PK - 12,391

PT - 100,493

RU - 1,314,122

TH - 228,488

TR - 69,458

US - 1,230,302

UY - 100,283

VN - 6,629

ZA - 94,569

Total area of coastal waters: 14,218,244 sq km


Approximately 70% of the world’s coastal waters remain inadequately surveyed or unsurveyed. Responsibility lies with the coastal States, not the IHO, and remains largely unrecognised.

The vast majority of hydrographic data contained in modern charts was collected using systems that do not meet modern standards for feature detection and seafloor

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coverage. The full investigation of those shoals that were detected using the older techniques was guided by the draught of vessels afloat at the time, plus a small margin for growth, but the growth in vessels draughts applied by past surveyors has now been exceeded.

While reliable ship operators will consider inadequately or unsurveyed waters as a limitation, with possible economic consequences, less reliable operators may ignore these limitations and create risk to lives and the environment.

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7. Use of gases and low-flashpoint fuels

Short description

Annex VI (air pollution) of the International Convention for the Prevention of Pollution from Ships (MARPOL) contains regulations to control emissions from ships, limiting the amount of pollutants in exhaust gases from ships’ diesel engines. The limits within these regulations have been agreed to be reduced progressively over the coming years. To achieve the resulting limits for particulate matter, nitrogen oxides and sulphur oxides, additional engineering controls will be required.

Methane and other low-flashpoint gases and liquids burn with lower pollutants in their emissions and the engine technology for methane in particular is already well developed. Many owners are therefore already designing and operating ships that use methane as fuel and this leads to concerns surrounding the safe storage and use of such fuels.

The International Convention for the Safety of Life at Sea (SOLAS) currently only permits oil fuels such as diesel to be used as fuel for main propulsion and auxiliary power machinery.


As emission limits under MARPOL have been reduced, research on alternatives to engineering controls to achieve these limits has been undertaken. Engineering controls add to the cost of buying, operating and maintaining the diesel engines and research has therefore considered alternative ways to deal with the pollutants.

Diesel emissions can be controlled in various ways depending on what pollutant is being controlled. Sulphur Oxides (SOx) can be reduced by lowering the sulphur content of the fuel being used. Depending on the sulphur content of the crude being refined there may need to be further processes carried out to reduce the sulphur content to the desired level, noting the traditional refining processes (distillation and cracking) do not generally reduce the sulphur content at all.

Nitrogen oxides (NOx) can be reduced by the addition of technologies to existing engines in the exhaust system. For example, Selective Catalytic Converters (SCRs) can be added, which use various metallic filters and added chemicals (urea) to react with the exhaust gases and reduce the pollutants.

Particulate matter in diesel exhausts can be reduced by ensuring highly efficient burning of the fuel in the engine, and by the addition of a particulate filter in the exhaust system.

The use of non-diesel fuels has also been explored. Gas, methane and Liquefied Natural Gas (LNG) carriers have been able to use the boil off gas from their cargo as fuel for specially adapted duel fuel engines for several decades. The engine technology to enable the use of either diesel or methane gas is therefore well advanced. The main problem faced by owners who are considering fitting such dual fuel engines to their vessels (which aren’t LNG carriers), is that SOLAS currently only permits the use of oil fuels with a flashpoint less than 60 degrees centigrade.

The IMO has recognised that safe use of low flashpoint fuels is essential to economically achieve the low pollutant levels expected in modern marine engines. Over the last six years a new Code has been developed for the safe use of low flashpoint fuels on ships - the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (the IGF Code). At the 95th session of the Maritime Safety Committee (MSC) in June 2015, the new Code was adopted along with amendments to SOLAS that permit the use of low flashpoint fuels. These amendments and Code will come into effect on 1 January 2017. The Code will provide mandatory provisions for the arrangement, installation, control and monitoring of machinery, equipment and systems using low-flashpoint fuel to minimize the risk to the ship, its crew and the environment, having regard to the nature of the fuels involved.

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The IGF Code currently concentrates on the use of LNG as there is already a safe framework surrounding general storage, distribution and use onboard. Work continues at the IMO to add new chapters and requirements for other low flashpoint fuels such as ethyl/methyl alcohol (ethanol/methanol), fuel cells and other low flashpoint liquid fuels.

Supporting data

Acceptance of the Code provides clarity to the shipping industry on regulatory standards, outlining best practice in the use of gases or other low-flashpoint fuels and also ensuring international regulatory consistency in ship building and seafarer training standards. This will increase maritime safety and security, enhance measures to protect the marine environment and promote smooth, effective and efficient international trade.

Currently, an estimated 65 LNG fuelled vessels are in service worldwide. There are at least another 80 vessels in design or construction stages. Developmental work is also ongoing into a range of alternate fuel sources including compressed natural gas, hydrogen fuel cells and various low-flashpoint liquids.


The maritime community will rely on the IMO to continue to add alternative fuel options to the IGF Code, widening the choice of fuels with low flashpoints. Technologies such as fuel cells are developing quickly using a variety of fuel sources, some of which like hydrogen, present substantial challenges in terms of safe storage and use.

Additions to exhaust systems will become increasingly expensive as pollution limits are reduced further. Diesel fuel produces exhaust gases that contain elements which are undesirable – being able to use a fuel with less (or even no) undesirable elements will permit owners to choose to purchase equipment that can use these ‘cleaner’ fuels at a lower lifetime operation cost.

Engines that can burn LNG are available at a reasonable cost compared to those that only burn diesel. LNG itself is a plentiful resource and as more ships are built that demand the supply of LNG as fuel, the availability of the fuel worldwide will become cheaper and more widely available.

IMO’s core activities are to promote safe and efficient shipping and to reduce pollution - the use of low flashpoint fuels assists in these goals, as well as ensures IMO instruments continue to take into account ever-changing technologies that increase safety and reduce pollution.

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8. Ongoing need to develop and maintain standards for the safe carriage of bulk cargoes and dangerous goods

Short description

Packaged dangerous goods possess hazardous and dangerous properties when loaded, transported and discharged on or from ships. Dangerous goods in packaged form are classified against the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The UN GHS is used internationally for all transport modes. For international sea transport, the International Maritime Organization (IMO) is the body that develops and agrees the standards for the transport of dangerous goods by sea.

Solid bulk cargoes are currently assessed using the same tests and criteria as used for packaged dangerous goods. They may, however, possess hazardous properties that lie between ‘no hazards’ and being a dangerous good, or hazards related to the amount of cargo being carried (a cargo with minimal or insignificant risk in small quantities may become a significant risk in solid bulk transport), or possess hazards ‘unique’ to carriage in a ships hold and to the loading and discharge methods used.

The hazardous properties of packaged dangerous goods and solid bulk cargoes have been recognised by the IMO, and requirements have been mandated in the International Convention for the Safety of Life at Sea (SOLAS) to ensure the safe transport by sea of these cargoes. SOLAS mandates the use of the International Maritime Dangerous Goods (IMDG) Code for the transport of packaged dangerous goods and the International Maritime Solid Bulk Cargoes (IMSBC) Code for the transport of solid bulk cargoes by sea. Regular updates to these codes are essential to ensure innovation and new technologies are not impeded.


The safe transport of packaged dangerous goods has been addressed within the United Nations since 1956; however the IMO first recognised this issue at the 1929 International SOLAS Conference, which recommended that rules on the subject have international effect. The classification of dangerous goods and certain general provisions concerning their transport in ships were adopted by the 1948 SOLAS Conference.

At the 1960 SOLAS conference, the IMO decided to establish a unified international code for the transport of dangerous goods by sea. IMO's Maritime Safety Committee (MSC) oversaw the development of a Code for the transport of dangerous goods by sea. This new International Maritime Dangerous Goods (IMDG) Code was approved by the MSC and recommended to Governments by the Assembly of IMO in 1965. During the development of SOLAS and the Code itself at the IMO, the IMDG Code became mandatory by way of SOLAS in 2004.

The pollution risks of sea transport were also recognised during the development of the International Convention for the Prevention of Pollution from Ships (MARPOL), and Annex III was included to provide measures to prevent pollution from packaged dangerous goods. MARPOL also requires carriage of dangerous goods by sea to be undertaken in accordance with relevant parts of the IMDG Code.

Carriage of solid bulk cargoes by sea may present the same hazards as dangerous goods although magnified by the volume of the substance (cargo). These hazards may not meet the criteria to be classified as a dangerous goods hazard, but in solid bulk volumes such hazards may be significant, or they may present hazards unique to loading, carriage and discharge of the material in solid bulk form.

The hazards of the carriage of solid bulk cargoes were recognised at the 1960 SOLAS conference, and the conference recommended that the IMO should develop a suitable code of safe practice for bulk cargoes (except grain). The first edition of the Code of Safe Practice for Solid Bulk Cargoes (BC Code) was published in 1965.

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In 1994 SOLAS Chapter VI was amended to include requirements for carriage of solid bulk cargoes and Chapter VII, relating to dangerous goods, was amended to include dangerous goods when carried in solid bulk form.

In 2008 the IMO agreed that there should be a mandatory Code for carriage of solid bulk cargoes and in 2009 the first edition of the International Maritime Solid Bulk Cargoes Code was published, coming into mandatory effect by way of SOLAS Chapter VI (and VII for dangerous goods in solid bulk form) from 1 January 2011.

The IMDG Code is updated every two years after the UN Model Regulations have been amended – also on a two year cycle. The IMSBC Code is similarly updated every two years and all updates take into account the latest technology and new hazards, substances, articles and cargoes. The IMDG Code and IMSBC Codes are updated in alternate years.

Supporting data

The IMDG and IMSBC Codes provide mandatory and consistent provisions for carriage of dangerous goods and solid bulk cargoes that minimize the risk to the ship, its crew and the environment.

Bulk cargoes can vary immensely in their make-up and composition. For example, iron ore can vary from a fine powder to large lumps of 100mm or more. Historically the finer parts of the mined ore were not commercially desirable, however over the years buyers and technology have moved on and the fines have attained a value. Iron ore fines are now exported as a cargo without lumps and the traditional lumps cargo no longer has tight control over the proportion of fines present. The BC Code and the IMSBC Code contained only one schedule for the safe carriage of iron ore and that was a ‘Group C’ schedule. Group C means the cargo presents no hazards that would make it Group B (chemical hazards and dangerous goods properties) or Group A (liable to liquefy if the moisture content exceeds a tested and measured Transportable Moisture Limit (TML)).

Over several years there were incidents at sea involving ships carrying both iron ore and iron ore fines. In 2011 there were three incidents reported by India to the IMO involving ships carrying iron ore loaded at Indian ports. These included listing and capsizing as the result of something that occurred on board. Analysis of these incidents provided evidence that the cargo was a factor in the incidents and research was initiated into iron ore. Global iron ore exporters were positively engaged noting the quantities of this cargo they ship.

The research was conducted over two years and it was concluded that a proportion of iron ore fines – particles below a certain size – in a cargo of iron ore lumps could mean the cargo possessed the Group A property. A cargo made up of fines in its entirety could also possess this Group A property. Where the moisture content of a Group A cargo is increased at any time and it exceeds the TML, this would likely lead to the cargo in the holds acting as though it was a liquid. On ships designed to carry solid bulk cargoes, where the weight of the cargo does not move from where it is loaded, this shifting of weight affects stability and can be catastrophic, with listing that cannot be corrected by moving ballast water and ultimately capsizing of the vessel.

The outcome of the research was the ability to identify certain cargo properties and characteristics indicating if the cargo was liable to liquefy. This included a particle size distribution (PSD - in effect a proportion of fines) which could be used as criteria for Group A or not, plus a proportion of a certain element in the ore (goethite) above which the cargo would not exhibit Group A properties regardless of the proportion of fines.

Following this research, IMO Members cooperated to include new schedules in IMSBC Code amendments that provide all exporters of iron ore clear and safe criteria for the carriage of a cargo shipped in large volumes worldwide. The safety of ships and seafarers when carrying iron ore as a cargo has been improved greatly, with Group A iron ore cargoes able to be

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identified and declared by shippers, leading to measures to control the moisture content of the cargo.

With the advancements in the technologies and knowledge surrounding the carriage of dangerous goods and solid bulk cargoes by sea continuing, it is essential that the IMDG and IMSBC Codes continue to be updated frequently to ensure current and new cargoes continue to be transported safely and without pollution of the marine environment.


The maritime community for the IMDG and IMSBC Codes is mainly made up of shippers of the goods and cargoes covered by the Codes, as well as by the masters and owners of the ships used to transport goods. Transport of the cargoes without any controls of the risks that are present would return these two sectors of marine transport to practices of over 100 years ago, when a lack of knowledge of the risks led to incidents resulting in injuries and losses of lives and ships.

If the Codes are not routinely updated, the changes of technologies in the transport sectors would quickly ‘overtake’ the Code requirements. The need to follow the outdated Codes would lead to a lack of innovation and would mean safer transport methods would be stifled. If individual nations undertook to amend their local requirements beyond the international Codes, this would lead to issues of an uneven playing field for shippers in those countries. In turn that leads to issues in implementation and compliance and enforcement for the authorised bodies in these countries.

The Codes have embodied the IMO core activities to promote safety and reduce pollution for at least 50 years and their practical and agreed amendment every two years at the IMO will ensure they continue to do so for the foreseeable future.

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MARITIME SECURITY

9. Piracy in the Asian Region

Short description

The security of shipping lanes throughout Asia is essential for international trade. A recent increase in piracy in the Asian region is a threat to maritime trade and should be addressed by the IMO.


Efforts have begun to reduce the incidents of piracy and armed robbery throughout the Asian region, notably through establishment of the Regional Cooperation Agreement on Combating Piracy and Armed Robbery against Ships in Asia (ReCAAP) Information Sharing Centre (ISC) in 2006. ReCAAP is a government to government regional forum dedicated to piracy and sea robbery issues. It facilitates regional cooperation to mitigate the risk of piracy and robbery at sea. Members are committed to the eradication of piracy and the maintenance of secure and safe trade via the sea.

Despite this, there was an increase in the number of piracy and armed robbery incidents against ships incidents in Asia in 2014 compared to the past four years (2010-13). A total of 183 incidents comprising 168 actual incidents and 15 attempted incidents were reported.

When comparing the Asian region to the rest of the world, globally, in 2011, 439 piracy and armed robbery against ships incidents were reported with over half occurring in the Horn of Africa and nearly a quarter occurring in South East Asia. These two regions are therefore widely recognised as global hotspots. The percentage of piracy and armed robbery against ships that occurred by region in 2011 included:2

Horn of Africa – 55%

West Africa – 12%

South East Asia – 23%

South Asia – 4%

Rest of the world – 6%

There has been a shift in the type of vessels boarded during incidents, from traditional tug boats towing barges, to bigger ships such as bulk carriers, general cargo ships, and tankers.

In 2014, 11 incidents involved theft of cargo oil by perpetrators who boarded the ship. Most of these incidents involved the perpetrators being armed with guns and knives; included larger groups of men who took control of the ship; threatened, tied and locked the crew in the cabin; siphoned the fuel/oil onboard the ship to another tanker/barge that came alongside; and before escaping, destroyed the ship’s communication and navigational equipment and took the crew’s cash and personal belongings.

In 2015, incidents involving hijacking tankers (majority <5000 GT) for theft of bunkers occurred one to two times per month, on average.

Supporting data3-

There has been an increase in the number of piracy and armed robbery incidents against ships in Asia in 2014 compared to the past four years (2010-2013). A total of 183 incidents comprising 168 actual incidents and 15 attempted incidents were reported. On a year-on-year comparison, this represents an increase of 22% in the total number of incidents in 2014 compared to 2013. Of the 183 incidents, 13 (7%) were Category 1 (very significant) incidents,

2 Data provided by the International Maritime Bureau – Piracy Reporting Centre (IMB-PRC)

3 ReCAAP Annual Report 1 Jan to 31 Dec 2014 Executive Summary, pg 3

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41 (23%) were Category 2 (moderately significant) incidents and 114 (62%) were Category 3 (less significant) and petty theft (minimum significance) incidents.

Of the 13 Category 1 incidents, 11 incidents were siphoning of ship fuel/oil by perpetrators who boarded the ship to siphon the ship manifest of fuel/oil. Most of these incidents were Category 1 in nature because the perpetrators were armed with guns and knives; involved larger group of men who took control of the ship; threatened, tied and locked the crew in the cabin; siphoned the fuel/oil on-board the ship to another tanker/barge that came alongside; and before escaping, destroyed the ship’s communication on and navigational equipment and took the crew’s cash and personal belongings.

In light of the development of the situation in Asia in 2014, more needs to be done collectively by the shipping community in building trust and confidence in timely reporting, information sharing and operational responses.


There is a need for continuous efforts to tackle these incidents by the authorities and shipping industry collectively. This includes:

sharing information to enable the ReCAAP Information Sharing Centre to provide timely situation update to all stakeholders to enable optimal deployment of resources;

implementation of anti-piracy measures more effectively and efficiently;

more stringent enforcement of the International Ship and Port Facility Security Code; and

effective policing and patrolling by relevant agencies and enforcing prosecution on land.

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10. Emerging Technologies, including practical e-navigation outputs

Short description

E-navigation is defined as “the harmonized collection, integration, exchange, presentation and analysis of marine information on board and ashore by electronic means to enhance berth to berth navigation and related services for safety and security at sea and protection of the marine environment.”

The e-navigation concept has been developed by the IMO to address the critical lack of human-centred design that prevails within the commercial shipping sector, though similar conditions exist within the naval sector. A sound e-navigation strategy is dependent upon two factors – systems and information. Commercial mariners have reached a point of information and reporting over-load due to the separation of onboard systems and inability to reuse data for multiple purposes. Similarly, Navy (and other Defence areas acquiring systems requiring maritime information) repeatedly acquire systems using a variety of bespoke data formats.

The IMO has selected the International Hydrographic Organization’s S-100 “Universal Hydrographic Data Model” as the carrier to address this existing data incompatibility. The S-100 standard is optimised for maritime use. It brings together an integrated suite of ISO standards and will be used as the backbone for multiple services, including electronic charts, nautical information, environmental information, marine protected areas, security and maritime boundaries, high density bathymetry, and other services. All will be accessible via integrated ship systems.


The sea / shore information gap

In the same way that information ashore is now primarily accessed and provided electronically, a high proportion of information at sea is sent, received and accessed electronically as well. However, unlike ashore where systems development and take-up is rapid, systems at sea evolve extremely slowly and represent only a small ‘market’ for system manufacturers, creating an ever widening gap between ship operators and those that supply or receive information ashore. Typically, this gap is addressed by simply adding another bespoke system on the already information-crowded bridge of a ship. The ease of accessing information ashore also drives an expectation that this is just as easy on the ship, so there is a growing requirement for additional reporting, unfortunately still done on multiple separate systems under an assumption that information at sea can be easily found, accessed and filtered – an assumption that is as equally misguided as the initial expectation, particularly when dependent upon multiple systems and formats and communications connectivity.

Cyber-security

As dependency upon electronic information grows, so does the need for increased cyber-security. While protection of data must be considered the highest priority, no virus detection software is completely infallible, so a number of additional factors must be considered for critical electronic navigation systems and protection of the data within them. These include:

The dilemma between having navigation systems connected via the internet for push or pull update services, and keeping them isolated as a means of protecting these navigation-critical systems from malicious viruses.

The dilemma between keeping navigation-critical chart information displayed despite it possibly being partially corrupted, on the basis that “some navigation information is better than none”, even though the user may be unaware of the corruption, and the alternative of blocking access to corrupted files at least makes it obvious to the user that those files have been corrupted. Alternatively, some level of integrity warning between these two extremes may be more appropriate.

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The possibility that satellite based positioning systems may be spoofed resulting in a plausible but misleading position for the ship, noting that a plausible error is significantly more dangerous than an unbelievable one or cessation of the service.

The possibility that satellite based positioning systems may fail either deliberately or through a fault, and the resultant loss of timing seriously degrades the integrity of other automated time-dependent systems, such as Automatic Identification Systems (AIS).

Coordination of development to meet e-navigation requirements

Development is currently dependent upon isolated interested individuals, even though they may be members of larger organisations. This is unlikely to drive integration or human-centred design. A coordinated approach is required against a targeted list of specific problems and desired outcomes. To date, no such list of requirements exists.


The challenges facing the maritime community due to lack of a coordinated e-navigation capability include:

Lack of awareness in the wider maritime community that a coordinated approach is possible and that bespoke solutions should be avoided. This will require education and promotion of solutions.

Lack of a specific list of challenges to be addressed. The IMO’s e-navigation user specification will provide a good starting point for this.

Security of services delivered by electronic means, including alerts when data may have been compromised but still appears reliable, quantifying the quality of services which are obviously degraded, and backup arrangements.

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11. Increased administrative burden for ship’s officers

Short description

The ease of communications between ship and shore via email has increased significantly over recent years, ensuring that ships remain in constant contact throughout international voyages.

However, this ease of communication has subsequently resulted in a significant workload increase on Masters in regards to the paperwork and reporting required during each voyage. In particular, the growing desire from shore-side administrators for Masters to complete and return often complex documents quickly may detract from the Master’s primary role of ensuring the ongoing safety and security of the ship and crew.


While much of this communications traffic is observed to be between the Master and the parent company, these distractions are increasingly causing Masters and crew to be taken away from their key work functions. This is exacerbated by the general trend of reducing crew levels, which places a greater administrative burden on the Master. Crewing levels are focussed on getting a ship safely from port to port with the minimum number of crew to operate the vessel, however do not take into account the increasing administrative overheads being shared among a smaller number of ships officers. This burden is further increased by the variety of document formats requested, which often provide the same or similar information to multiple authorities with differing responsibilities in different ports and countries.

Developments

While S-100 may have been selected as the Universal Hydrographic Data Model for exchange of navigational and related information, it does not address administrative information requirements and overheads.


The challenges facing the maritime community with regard to the administrative burden placed upon Masters and ships officers include:

The effect additional requests may have on rest periods when not on watch.

The effect this may have on ongoing training of junior officers by experienced ships officers.

The example this sets for the next generation of ships officers.

The opportunities to standardise forms and reports at an international level in order to minimise ‘re-packaging’ of the same information into the unique layouts and requirements of multiple individual shore-side authorities.

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MARITIME TRADE FACILITATION

12. Shipping and the ‘Blue Economy’

Short description

Global ocean economic activity is estimated to be in the realm of USD $3–5 trillion per year. The economic potential of the world’s oceans is significant; countries and businesses are increasingly thinking about how to tap ocean resources for economic growth and investment. However, unchecked economic ocean activity poses a real threat to the ecological health of the world’s oceans. A blue economy is one in which our ocean ecosystems bring economic and social benefits that are efficient, equitable and sustainable. IMO Member States have substantial assets, knowledge and expertise focused on the productive and sustainable management of our ocean resources to contribute to the blue economy.


While there is no internationally agreed definition, the blue economy concept is emerging to mean marine economic activity as a driver of sustainable growth and development. The Economist’s working definition describes a sustainable ocean economy as emerging when ‘economic activity is in balance with the long-term capacity of ocean ecosystems to support this activity and remain resilient and healthy.’4

IMO Member States’ ocean governance faces multiple challenges including shipping and coastal port development, food security, fisheries management, oil and gas exploration, sea level rise, and ocean acidification. Marine spatial planning is a strategic process that helps support decisions to manage risks and balance the trade-offs across the three pillars of sustainability – social, environmental and financial.

Supporting data

Around 80 percent of global trade by volume, and over 70 per cent by value, is carried by sea and handled by ports worldwide. World seaborne trade grew by four per cent in 2011, to 8.7 billion tonnes and container traffic is projected to triple by 2030.

The maritime sector makes an essential contribution to the Australian economy. In 2009-10, 4,344 ships involved in international shipping entered Australia. In the same period, there were 11,392 voyages from overseas ports to Australia. In 2009-10, the total amount of international sea freight to and from Australia was 947.6 million tonnes, with a total value of AUD $335.8 billion.


In pursuing a blue economy agenda, coastal States need to position themselves in terms of facilities and capacities to cater for this growing maritime trade and optimise benefits. Blue economy highlights the role that biodiversity, including marine life and ecosystems, plays in supporting this marine economic activity.

The IMO has brought in new shipping industry wide measures to increase efficiency, and reduce greenhouse gas emissions and pollution. More needs to be done to address the issues of invasive alien species from ballast water and hull fouling. Even with these challenges, maritime trade is set for growth and economic benefits whilst reducing impacts, offering expanding blue employment opportunities for the foreseeable future. Benefits for the blue economy can accrue through support for simple measures in countries which have limited capacity for delivering adequate port facilities, including through provision for waste reception.

Of significant use to shipping will be Marine Spatial Planning (MSP) to support the management of multiple uses. This involves the integration of ecosystem-based approaches,

4 The Blue Economy: Growth, Opportunity and a Sustainable Ocean Economy, An Economist Intelligence Unit

briefing paper for the World Ocean Summit 2015, p 7, http://www.economistinsights.com/sites/default/files/Blue%20Economy_briefing%20paper_WOS2015.pdf

http://www.economistinsights.com/sites/default/files/Blue%20Economy_briefing%20paper_WOS2015.pdf

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spatial and scale considerations, as well as multi-level policy framework (e.g. agreements, regulations, licensing and legislation). Expertise in marine spatial planning helps ensure wise decisions are made around the best uses of coastal and marine assets.

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13. The Single Window

Short Description

While domestic economic reforms to improve the efficiency of logistics chains are recognised as key priorities among many IMO members, it is increasingly recognised that improved international connectivity is critical to the success of domestic economic reforms. The IMO has a critical role to play in improving the end-to-end efficiency of logistics chains through further work on the single window and other means of promoting trade facilitation.

Narrative Covering Trends and Developments

IMO members rely heavily on local and international shipping services to provide safe, secure, sustainable and efficient shipping connections to access domestic and international markets. Facilitating more efficient commercial arrangements for shipping is a key challenge, with the linkage between domestic initiatives, policies and international rules being a key consideration.

Initiatives to improve the efficiency of logistics chains, such as improved infrastructure, intermodal connections and best practice regulatory frameworks have been recognised as critical policy solutions to address port-side and land based inefficiencies. However, it has also been recognised that the international components of logistics chains – the areas where international standards developed by the IMO and other UN bodies prevail – can be the limiting factor in realising efficiency gains. In this context, the physical infrastructure and electronic systems available in ports take on added significance. In the Australian context, ports have been working closely with state and federal transport agencies on initiatives in recognition of this critical role.

Several Australian Government agencies currently undertake their functions, or parts of their functions, (including customs, quarantine and immigration) through electronic reporting interfaces with industry. This is supported through the legislative framework which requires agencies to (in most circumstances) accept electronic signatures and forms. Beyond the maritime sector, the Australian Government is progressing the development of a number of cross-sectoral trade facilitation services through digital transformation initiatives to digitise, link and streamline government service delivery. This is also supported by the development of a business advisory service providing industry with a central source of information on domestic export and import procedures. Initial discussions suggest that the Australian shipping industry supports the development of a joint government portal for maritime data submission, citing the development of agency specific data submission requirements in isolation from one another as one of the key challenges for industry.

Internationally, initiatives to promote trade facilitation goals have been gathering pace, including the single window concept, defined by the United Nations Centre for Trade Facilitation and Electronic Business as, “…a facility that allows parties involved in trade and transport to lodge standardized information and documents with a single entry point to fulfil all import, export and transit-related regulatory requirements”. Similar challenges to those facing Australia’s maritime and ports industries have been addressed through the successful implementation of a maritime single window in a number of countries including Norway, Republic of Korea, the Netherlands, Japan and Israel. The IMO has played a crucial role in developing and sharing expertise in relation to the implementation of the maritime single window, focusing predominantly on ship clearance.

The IMO, at the 37th session of the Facilitation Committee approved the Guidelines for setting up a Single Window System in Maritime Transport (FAL.5/Circ.36) providing an in depth description of the core aspects of the development of a maritime single window. Subsequently, at the 38th session of the Facilitation Committee, a Correspondence Group on electronic measures for the clearance of ships was established to share lessons learned and further explore some of the challenges regarding the use of electronic certificates.

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Critically, the Correspondence Group concluded that the use and acceptance of electronic certificates is a policy issue, not a technological one, as there is adequate technology available to ensure integrity and validation of electronic certificates. The Group also noted the vulnerability of electronic certificates to technological failure and cyber-attack and recognised the central role that Port State Control Officers play in identifying which and under what circumstances electronic records will be accepted in their jurisdictions. As a result of the Correspondence Group’s work, amendments to the Interim Guidelines for use of Electronic Certificates were implemented through FAL.5/Circ.39/Rev.1. The addition of both the application of the single window and matters relating to electronic certificates are valuable inclusions on the agenda for the 40th session of the Facilitation Committee, to be held in 2016.

Supporting data

United Nations Conference on Trade and Development statistics indicate international exports and imports have grown globally at a rate of around 19% in the period between 2008 and 2014 with growth observed in developing, developed and transition economies. Data also suggests that shipping is increasingly relied on for the movement goods internationally with an estimated growth in annual global container throughput of 25% in the period between 2008 and 2014.

World Trade Organization reports that participation in global economies is a growing priority for many nations, increasing the demands on international shipping. However, a recent joint monitoring exercise between the WTO and the OECD, which sought input from developing economies on the major barriers to participation Global Value Chains, found that standards compliance, border procedures and burdensome documentation are among the top 11 most significant barriers.

Technological solutions in response to growing freight tasks, such as the single window have been advocated by numerous international organisations including the United Nations Centre for Trade Facilitation and Electronic Business, World Customs Organization, International Chamber of Commerce, International Civil Aviation Organization, APEC and the IMO.

The Challenges Facing the Maritime Community

In light of the growing freight task, the development of the single window presents number of opportunities for the shipping industry and government agencies as well as broader economic benefits arising from increased trade efficiency. However, in order to fully realise these potential opportunities a number of challenges need to be addressed. This includes aligning the technological and organisational structures involved in international commerce.

Standardisation of the design and implementation of the maritime single window will play a crucial role in facilitating productive and efficient international trade. In this context the IMO has, and should continue to, play a central role is providing frameworks, guidance and resources to achieve this. Acknowledging the varying objectives across the range of international organisations, there remains a need for regular and ongoing dialogue between the IMO and with other relevant international organisations with an interests and expertise in this area.

The IMO should take on a valuable leadership role in providing guidance to IMO members on effective frameworks for the development of single windows, including the management of electronic documentation in the shipping industry. Acknowledging that IMO member states’ domestic legislative frameworks governing shipping are in many cases driven by IMO instruments, further dialogue amongst member states could be beneficial to identify the practical, legal and administrative challenges associated with acceptance of electronic certificates and record books as specified within IMO instruments. The challenges identified through the Correspondence Group’s work on the use of electronic record books under MARPOL, suggests that similar issues to those identified in relation to MARPOL may be relevant in relation to other IMO instruments.

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One of the primary challenges of implementing a single window is likely to be securing agreement between government agencies and industry on the scope and structure of the single window. That process would be assisted if there were case studies of how other countries had gone about the task of synthesising the critical elements of the domestic government and industry arrangements necessary to make a single window work. This is particularly relevant because of the added challenge of integrating national single window systems into a regional or international single window.

Collectively, this data supports the ongoing inclusion of the maritime single window on the agenda of the Facilitation Committee and other IMO Committees. Greater coordination between IMO Committees could help to ensure that facilitation issues are taken into account during the pursuit of the IMO’s safety, environmental and security goals.

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14. Maritime Communications

Short description

Clear communication is critical to ship operations, and presents a challenge in a global and multi-lingual industry. Maritime communication has been identified as a key enabler for e-navigation, and the ability to transmit information in digital and language independent format provides an opportunity to also address the current nature of onboard, ship-ship and ship-shore communications.


While the international language of seafarer communication is English, the international nature of shipping and diversity of languages used onboard ships is increasing. The importance of clear communication has recently been raised as an issue by the International Association of Marine Aids to Navigation and Lighthouse Authorities (IALA), which is currently working on the issue of communication in the Vessel Traffic Service (VTS) committee.

The proportion of communications undertaken via text messaging is increasing. For both this and the existing level of voice communications there are generic translation software and applications available. However, these may not recognise essential nautical terms in frequent use when attempting to ensure collision avoidance, when interacting with Vessel Traffic Service and Vessel Monitoring Service operators, or when planning a port entry or departure. The IMO initially developed the Standard Marine Navigational Vocabulary (SMNV) and now has the Standard Marine Communication Phrases (SMCP). In addition, the International Code of Signals remains a resource to aid in communications.

Maritime communications technologies have increasingly been developed and maritime communications capabilities are evolving to include more digital data forms using advance radio communications technology. These technologies take advantage of software definable radios (SDR) on ‘grouped’ spectrum to provide greater data throughput. Work on this approach has commenced following the provision of very high frequency (VHF) spectrum at the International Telecommunications Union (ITU) World Radio Conference (WRC) in 2012 (the VHF Data Exchange System or VDES). Combining digital data and machine-to-machine communications, there is an opportunity to digitize existing lexicons, moving towards a language independent communications capability.

As systems and technology develops there will be a need to ensure the latest standards are adhered to, which will require clearly defined and practical testing standards for equipment to be developed by the International Electrotechnical Commission (IEC).

This is a quickly evolving and developing environment, and work in this area will need coordination with other international bodies, such as ITU, IEC and IALA.


The challenges facing the maritime community with regards to maritime communication include:

Key ship to ship and ship to shore communications may be confused in translation or, when combined with background noise, radio static and other distractions, simply not understood.

Developments of capabilities that span multiple international agencies, yet are required to be implemented in a timely and agile manner.

An increasing reliance placed on text information, and a need for standardisation of technology and translation software is essential.

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15. Implementation of VTS

Short description

Ships are increasingly operated within the limits of Vessel Traffic Services (VTS) or Local Port Services (LPS). Both are defined by IALA in the IALA VTS Manual, and through various IALA Recommendations and Guidelines. VTS itself is identified in IMO SOLAS Chapter V, Regulation 12 and IMO Resolution A.857(20).

Not all member states have implemented VTS in strict accordance with the SOLAS Regulation and Resolution. In addition, while IALA has developed VTS training and promotes this through the IALA World Wide Academy, not all VTS operators have completed a comparable level of training, nor are services provided in a similar manner.

The status and authority of the service varies from one system to another, while perceptions of the need for shore-side operators to be Master mariners, and the opposite perception that the vessel Master needs to maintain autonomy, is variable. While recognising that it is difficult to compare the shipping and aviation industry, the approach to VTS contrasts markedly with the aviation industry where the relationship between pilot-in-command and air traffic controller is clear and well accepted.


IMO has identified VTS as a means to facilitate safe, efficient and pollution free transits. Although a service provided from a shore position, the service is provided to vessels. There are a number of areas that can cause confusion to mariners, which include:

Level of training and experience of VTS operators can vary significantly from member state to member state;

The identification of the need for a LPS versus a VTS may not be consistently implemented;

The requirement to use ‘results oriented’ communications can cause additional confusion, especially when there are issues of language and communication.

The level of knowledge of what VTS and LPS are varies between individual ship’s officers.

The increasing use of ECDIS and ENC allows for the geographic limits of VTS and similar services to be clearly defined on layers which can be switched on and off, along with more detailed routeing measures than could be depicted on paper charts. The adoption of next generation S-101 ENC will enhance this capability. With developing work on maritime service portfolios there is an opportunity to better recognise the shore side element in shipping and ship movements.


The challenges facing the maritime community with regard to the operations within VTS and LPS include:

Varying levels of training and operational procedures from VTS to VTS.

Use of results oriented language, inconsistencies in the use of language and difficulties with comprehension / translation.

Confusion among ships’ officers and Masters as they encounter different areas and different levels of control or advice.

Differing levels of comprehension and understanding of what VTS and LPS are, and how the shore element can fit in with the ship board operations (training level of ships’ officers and masters on VTS).

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MINIMISING SHIP SOURCED ENVIROMENTAL DAMAGE

16. Greenhouse Gas Emissions

Short description

A major challenge for the IMO to address is ensuring the shipping sector keeps pace with climate change developments under the United Nations Framework Convention on Climate Change (UNFCCC) and other international bodies, and plays its part in global action on climate change. The IMO has already implemented a number of important measures to address greenhouse gas (GHG) emissions and remains the most appropriate body at which to discuss these and any future measures.


Since 1990 international shipping emissions have doubled, despite a 10% decrease in shipping during the economic downturn between 2007 and 2012. The CO2 emissions from maritime transport in 2050 are projected to be between 50% and 250% higher than current levels, depending on how global trade increases in different scenarios. This would mean that shipping emissions in 2050 could represent between 6% and 14% of total global emissions.

Shipping emissions are regulated by the IMO. The 1997 Kyoto Protocol, made under the UNFCCC, requires that developed country (Annex I) Parties pursue limitations or reductions in GHG emissions from international shipping through the IMO.5 A similar arrangement applies to emissions from international aviation, where Annex I Parties are expected to pursue measures through the International Civil Aviation Organization (ICAO).

In September 1997, an International Conference of Parties to MARPOL adopted Resolution 8 on CO2 emissions from ships. This resolution invited the Marine Environment Protection Committee (MEPC) to consider what CO2 reduction strategies might be feasible in light of the relationship between CO2 and other atmospheric and marine pollutants.

In December 2003, the IMO Assembly adopted Resolution A.963(23) on IMO Policies and Practices related to the reduction of greenhouse gas emissions from ships, which urged MEPC to identify and develop the mechanism(s) needed to achieve the limitation or reduction of GHG emissions from international shipping.

A variety of market-based mechanisms to reduce shipping emissions were discussed at the IMO in 2010/11, including a fuel tax, emission trading schemes and a range of further measures.

The main measures taken by the IMO are the Energy Efficiency Design Index (EEDI) and the Ship Energy Efficiency Management Plan (SEEMP). These regulations entered into force on 1 January 2013, with the SEEMP applying to existing international ships of 400 gross tonnage and above, and the EEDI applying to international ships of 400 gross tonnage and above built from 1 January 2013.

MEPC is currently discussing technical and operational measures that would improve energy efficiency of the existing fleet. MEPC agreed that better data is needed to determine if additional measures are required and what those measures might be, and consequently is developing a data collection system.

More recently, a quantifiable GHG emissions reduction target for international shipping was presented to MEPC for discussion. It was proposed that such a target would start immediately and apply beyond 2020 and include evolving measures to achieve the target, including implementation support and measurement, reporting and verification (MRV) processes.

At the same time as the IMO has been discussing shipping emissions, work on global emissions has been progressed under the UNFCCC. In 2009 at the Copenhagen Climate

5 Article 2.2

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Summit, UNFCCC parties agreed to a global goal to limit temperature rise to below 2°C above pre-industrial levels. The 21st UNFCCC Conference of the Parties will be held in Paris in December 2015, where parties will adopt a new legal agreement that will apply to all countries from 2020, with the aim of keeping global warming below 2°C.

ICAO has also been exploring market-based measures, including emissions trading, emission related levies and emissions offsetting, as part of a broader mitigation strategy to address GHG emissions from international aviation. ICAO has also taken on a global aspirational goal of carbon-neutral growth from 2020.

The International Transport Forum, in its October 2015 Policy Brief, Shipping and Climate Change: Where are we and which way forward, stated that, “If the shipping sector would apply a 2°C pathway, it would have to cut CO2 emissions from its ships to 0.4 billion tonnes by 2050 and achieve zero carbon emissions by 2080.”

In May 2015, the Secretary-General indicated his, and the IMO’s, solidarity and commitment to reduce GHG emissions from shipping, and made clear that while the IMO has already taken important steps to reduce GHG emissions, more can be done and that the IMO is the appropriate place to discuss appropriate measures.

Supporting data

In 2000, the first IMO GHG Study was published, which estimated that ships engaged in international trade in 1996 contributed about 1.8% of the world total CO2 emissions. The second IMO GHG Study 2009 found that international shipping was estimated to have emitted 870 million tonnes, or about 2.7% of the global emissions of CO2 in 2007. The Third IMO GHG Study 2014 estimates that international shipping emitted 796 million tonnes of CO2 in 2012, or about 2.2% of the total global CO2 emissions for that year.

The Third IMO GHG Study found that total GHG emissions from all shipping have fallen substantially since 2008, stabilising to around 10-15% lower than 2007-08 levels. Meanwhile global emissions have continued to rise. As a result, international shipping accounted for an average of 2.4% of global emissions over the period 2007-2012 (and only 2.1% in the year 2012 alone), compared to 2.7% in the Second IMO GHG study. The Study attributes the downturn in emissions to the global fleet currently operating at or near historic lows, due to a weak global economy since 2008.

The studies also find that total fuel consumption of shipping is dominated by three ship types; oil tankers, containerships and bulk carriers.


The Third IMO GHG Study 2014 inventories underscore the importance of slow steaming (i.e. lower operating speeds) in the recent emissions reductions but also identifies the risk that this trend is at best a short-term phenomenon. Should market conditions improve, average ship speeds will increase and emissions will increase even further.

The Third IMO GHG Study states that, “Emissions projections demonstrate that improvements in efficiency are important in mitigating emissions increase. However, even modelled improvements with the greatest energy savings could not yield a downward trend. Compared to regulatory or market-driven improvements in efficiency, changes in the fuel mix have a limited impact on GHG emissions, assuming that fossil fuels remain dominant.” In essence, the measures already adopted — the EEDI and SEEMP — will not, on their own, be enough to reduce international shipping emissions.

The Second IMO GHG Study 2009 concluded that there is a significant potential for reduction of GHG emissions through technical and operational measures. Together, if implemented, these measures could increase efficiency and reduce the emissions rate by 25% to 75% below the current levels. Many of these measures appeared to be cost-effective, although non-

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financial barriers may discourage their implementation. The report found that market-based measures were cost-effective policy instruments with a high environmental effectiveness.

The development of practical measures to address emissions from the international shipping sector will require robust data on the efficiency and emissions of individual ships. The current work at MEPC to finalise a data collection system for international shipping is vital to inform future debates on whether there should be an emissions reduction target for the sector or other regulatory measures.

There is concern about the need to appropriately address the projected growing share of emissions from the international shipping sector. However, in considering appropriate measures, it is important that the international shipping sector remains commercially viable and that those measures do not unfairly impact shipping interests. Shipping is an energy efficient form of transport and its environmental benefits should continue to be promoted. The IMO continues to be the most appropriate body at which to discuss measures that will deliver an environmental benefit and ensure the sustainability of the shipping industry. To ensure that the regulation of international shipping emissions remain within the remit of the IMO, Member States and observers must remain conscious of developments under the UNFCCC and ICAO and continue to carefully consider technical and operational innovations to ensure that shipping continues to play its part.

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17. Availability of low-sulphur fuel

Short description

Further consideration of the effective implementation of Annex VI of the International Convention for the Prevention of Pollution from Ships 1973, as modified by the 1978 and 1997 Protocols (MARPOL) is needed to address sulphur oxide particulate matter emissions. Issues to be considered could include the global availability of fuel to meet the 2020 reduction in sulphur content; issues associated with the processes required to change fuel types when operating in an Emission Control Area; and assessment of the effectiveness of the regulations, particularly against changing stakeholder expectations.


Traditionally, shipping has used heavy fuel oil (HFO) as bunkers, with HFO containing very high sulphur content, around 2700 times more sulphur than road fuel. Sulphur contained in fuel generates emissions of sulphur oxide (SOx) and particulate matter (PM), both of which are particularly harmful to humans and the environment. These emissions are known to have major impacts on human health, with shipping air pollution estimated to cause approximately 50,000 premature deaths per year in Europe.

Annex VI of MARPOL aims to combat the environmental impact of air emissions from ships, including SOx. Regulation 14 of Annex VI states that the sulphur content of any fuel oil must not exceed 3.50% m/m on and after 1 January 2012, moving to a limit of 0.5% m/m on and after 1 January 2020 (dependent on the global availability of fuel to meet this standard). In addition, when a ship is operating within an Emissions Control Area (ECA), the sulphur content of fuel oil used on board ships is to be no more than 0.10% m/m as of 1 January 2015. ECAs currently include the Baltic Sea, the North Sea area, and the North American and Caribbean Sea area.

Options available to ship operators to comply with these requirements include:

Use a fuel oil with a sulphur content not exceeding the stated limits;

Use approved abatement technology, such as scrubbers; or

Use an alternative fuel (LNG, biofuel).

Fuel Availability

As provided for in Regulations 14.8, 14.9 and 14.10 of MARPOL Annex VI, there is worldwide acknowledgement that the fuel required to meet the standards set out in Regulation 14 may not be available for ships use by 2020. While a determination on the availability of fuel is currently being undertaken to determine if the regulation date needs to be extended to 2025, ongoing monitoring and analysis of the availability of fuel and the costs associated with this provision, may be required by the IMO past the agreed entry into force date.

Processes to change fuel systems en route

As ships move between ECA and non-ECA areas, there is generally a requirement for the ship to ‘change over’ their fuel systems to use lower sulphur fuel in order to meet the IMO standards. It has been acknowledged that there are issues, primarily of a safety nature, associated with the fuel change over processes which may require consideration by the IMO in the future.

Effectiveness of Regulation 14 of Annex VI

To ensure the effective implementation of Regulation 14 of MARPOL Annex VI, and in particular the standards associated with sulphur limits in ECAs, the aim of this regulation needs to be compared and analysed against measured results. This analysis would ensure that the regulation is meeting the desired outcome.

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Supporting data

Along with forecasting CO2 emissions from shipping in the future, the Third IMO GHG study also reviewed the average sulphur content of fuel worldwide, modelled according to IMO global sulphur monitoring reports. The study identified that sulphur content in fuel has been reasonably consistent between 2007 and 2012, at around 2.5%. It also identified that approximately 98% of the sulphur in fuel will be converted to gaseous SO2, with approximately 2% of the sulphur to be found in particulate matter.6

The introduction of Regulation 14.1.3, mandating the use of fuel oil with 0.5% sulphur content by 2020, is expected to have a significant impact on emissions in the shipping industry. A study undertaken by the Det Norske Veritas GL Maritime7 on the Australian State of New South Wales’s Greater Metropolitan Area identified that changing from typically heavy fuel oil (2.7% sulphur content) to low sulphur distillates (with 0.5% or 0.1% sulphur) whilst in this area will reduce SOx emissions by approximately 80% or 96% respectively and remove approximately 90% of PM.

Fuel Availability

The IMO is currently undertaking a study on the availability of fuel to meet the standards set out in Regulation 14.1.3 of MARPOL Annex VI, in accordance with Regulation 14.8 of the Annex. At the 68th session of the Marine Environment Protection Committee (MEPC), the Committee requested that the fuel oil availability review be initiated in accordance with agreed terms of reference by 1 September 2015, with a view to the final report of the fuel oil availability review being submitted to MEPC 70 in late 2016.

In 2008 Tetra Tech and UltraSystems undertook research into whether enough low-sulphur marine distillate fuel, at the major bunkering ports used by vessels calling at the San Pedro Bay ports, would be available to implement fuel requirements implemented by the U.S. government (outside of the MARPOL Annex VI ECA framework).8 The study identified that the world supply of low-sulphur fuel to meet the increasing demand is not likely a technical issue but, rather, an economic one. The study anticipated that the demand for low-sulphur fuel would be more likely met by world refineries as long as there is a strong economic incentive.


Regulation 14.3.4 of MARPOL Annex VI mandates that the sulphur content in fuel does not exceed 0.10%.when operating within an ECA. As a result, vessels using higher sulphur content fuels need to change to ultra-low sulphur (ULS) fuel oil to comply. Industry groups, such as INTERTANKO and the European Community Shipowners Association (ECSA), have reported that there are major technical and operational issues related to the changeover of fuel, which may require continued IMO attention. In an overview document, the ECSA outlined the key challenges that ships faced when undertaking fuel changeover on entering an ECA including9:

technical challenges in the changeover process, including flushing through the fuel oil service and high fuel temperature changes;

6 Third IMO GHG Study 2014; International Maritime Organization (IMO) London, UK, June 2014; Smith, T. W. P.;

Jalkanen, J. P.; Anderson, B. A.;Corbett, J. J.; Faber, J.; Hanayama, S.; O'Keeffe, E.; Parker, S.; Johansson, L.; Aldous, L.; Raucci, C.; Traut, M.; Ettinger, S.; Nelissen, D.; Lee, D. S.; Ng, S.; Agrawal, A.; Winebrake, J. J.; Hoen, M.; Chesworth, S.; Pandey, A. 7 DNV-GL (2015). NSW Ship Emission Study. Emissions from ships operating in the Greater Metropolitan Area.

NSW Environment Protection Authority. http://www.epa.nsw.gov.au/resources/air/gma-ship-emissions.pdf p. 131 8 Rogozen, M. & Charng-Ching Lin (2008) Low-Sulfur Marine Fuel Availability Study. Tetra Tech and Ultra Systems

report. 9 Overview of ‘fuel changeover’ issues and challenges as they affect ECA-SOx compliance – November 2014,

European Community Shipowners’ Association

http://www.epa.nsw.gov.au/resources/air/gma-ship-emissions.pdf

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managing the changeover transition, including viscosity differences and ensuring written procedures are clear for crew;

operational safety concerns, which could potentially lead to injury if not properly managed; and

inspection uniformity by port states and regulators.


The effectiveness of MARPOL Annex VI requirements and, in particular, whether the MARPOL regulations governing low sulphur content fuel adequately meet stakeholder concerns regarding air pollution, have also been raised. Media reports10 indicate that residents who live near busy ports are significantly affected by the emissions from berthed ships and are looking for regulators to implement measures which will alleviate their concerns. A summary of submissions that the Australian state of New South Wales Environment Protection Agency collected during a recent regulatory change showed that while industry groups believed national regulations should follow international obligations as set out in MARPOL, community groups were concerned that the regulations did not go far enough in regulating air pollution from ships.11


Fuel Availability

MEPC has been working on the issue of sulphur emissions and the subsequent availability of fuel to meet these requirements for a number of years.

To date, much of the work on fuel availability has been focused on Europe and North America, where current ECAs have been located and a large percentage of the shipping trade occurs. However, Asia is set to become a major hub for oil markets in the future, and the shipping task within Asia is set to rise even further in the coming decades. As such, it is important that the IMO looks at the type of fuel oil that is able to be produced globally, including Asian markets, and how this may impact on ships compliance with Regulation 14.1.3 in Annex VI.

In addition, fuel availability in these areas will be of a greater focus if there are submissions in the future for the designation of new ECAs, as this will impact on the demand for low sulphur fuel in more areas. It is suggested that this issue continue to be monitored by the IMO to ensure that the provision of the necessary fuels is maintained to ensure ships have the ability to comply with regulations.


Challenges associated with the changing of fuel systems en route to meet ECA requirements will also test the shipping community in the coming years and as such, this issue requires the attention of the IMO. Low sulphur fuel, as mandated by MARPOL Annex VI, will require ships that operate in ECAs to change their fuel while all systems are operational and at sea. This has led to reports of safety issues for crews involved, mainly through machinery space fuel leakages.12 Furthermore, there are a number of technical challenges involving ship design that shipowners will need to overcome to fully comply with low sulphur requirements. The IMO is well placed to deliver or assist in providing solutions for these challenges.

10

Clay Lucas, (2015), ‘Ship Emissions Rile Residents Out Loud’, The Age. Found at http://www.theage.com.au/victoria/ship-emissions-rile-residents-living-by-port-20150331-1mbzw5.html 11

New South Wales Environment Protection Agency, Summary of Submissions - http://www.epa.nsw.gov.au/resources/air/150605-submissions-summary.pdf 12

http://www.marinelog.com/index.php?option=com_k2&view=item&id=8811:uscg-issues-safety-alert-on-fuel-switching&Itemid=231

http://www.theage.com.au/victoria/ship-emissions-rile-residents-living-by-port-20150331-1mbzw5.html

http://www.epa.nsw.gov.au/resources/air/150605-submissions-summary.pdf



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Effective implementation of MARPOL Annex VI, and whether the globally agreed regulations will meet stakeholder expectations (including the communities most impacted by shipping emissions), should remain a priority for the IMO.

Some countries have identified the need to implement their own emissions standards, above those set out in MARPOL Annex VI, to meet these expectations. For example, in the Australian state of New South Wales, the use of low sulphur fuel (0.1% or less) by all cruise ships has been mandated for ships at berth in Sydney Harbour from 1 October 2015 and will apply in all of Sydney Harbour after 1 July 2016. In Hong Kong, China all ocean-going vessels (500 GT and above) are required to switch to low-sulphur fuel (or LNG/or similar approved fuels) during the periods the ship is at a berth, excluding the first and last hour of the berthing period. The sulphur content of the fuel may not exceed 0.5%, with strict enforcement and compliance measures to support these requirements.

These measures arguably indicate that the wider community has certain expectations for air pollution management that MARPOL Annex VI may not currently meet. As emissions from on-road and other sources decrease markedly, as a result, for example, of changing fuel and automotive standards, attention is increasingly turning to shipping. As such it is considered imperative that the IMO continues to carefully consider air pollution issues. This should include an analysis of whether Regulation 14 is meeting its desired outcomes.

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18. Management of Garbage from Ships

Short description

Further consideration is needed of the effective implementation of MARPOL Annex V, including trends, developments and challenges in the management of garbage generated on board ships. While land-based sources are the major contributor to marine debris, and shipping is one of the few contributors that is actively controlled at a global level (through MARPOL), evidence suggests that garbage from shipping continues to enter the marine environment.


Marine debris has been recognised as a global issue. Potential impacts from marine debris, in particular plastics, include negative impacts on fishing and tourism activities, entanglement and ingestion by marine species, hazards to navigation and safety at sea, and threats to human health. Plastic debris consistently represents the major category of marine debris on a global basis.

Since 1988, Annex V has imposed a complete ban on the disposal into the sea of all forms of plastics. As of January 1 2013, amendments to Annex V have prohibited the discharge of almost all types of garbage, with very limited exceptions.

To assist in the management of waste in accordance with these regulations, certain ships are required to carry and implement a garbage management plan, display placards and maintain a garbage record book. Annex V also obligates Parties to the Annex to provide facilities for the reception of ship-generated residues and garbage in all ports and terminals within their jurisdiction. These facilities must be adequate to meet the need of ships using the port, without causing undue delay for ships.

The IMO has developed a range of guidelines to assist stakeholders in the effective implementation of Annex V. Industry and non-government organisations have also taken an interest in the development of mechanisms that can enhance waste management for garbage generated on board ships, for example ISO standards for shipboard garbage management (ISO 21070) and port waste reception facilities (ISO 16304:2013).

However, despite the strict regulations and requirements of MARPOL Annex V and the associated guidance documents and standards that have been developed by the IMO and other organisations to assist with effective implementation of Annex V, evidence suggests that garbage from shipping continues to enter the marine environment and contribute to the global problem of marine debris.

Supporting data

While it has been stated that the contribution of shipping to the marine debris may not be as large as previously thought (previously stated as up to 20%)13, pollution from garbage from shipping remains a significant concern.

Studies on marine debris from both land and sea-based sources have shown that plastics consistently make up 60-80% of all debris14,15. For example, a recent survey of the Australia coastline found 75% of all marine debris consisted of plastics16, although this figure reached

13 United Nations Joint Group of Experts on Scientific Aspects of Marine Environmental Pollution (GESAMP) 14

US EPA (2011), Marine Debris in the North Pacific: A Summary of Existing Information and Identification of Data Gaps. http://www.epa.gov/region9/marine-debris/pdf/MarineDebris-NPacFinalAprvd.pdf 15

Moore, C. J. (2008). Synthetic Polymers in the Marine Environment: A Rapidly Increasing, Long-Term Threat. Environmental Research, 108:131–139. 16

CSIRO, 2015. Sources, distribution and fate of marine debris. http://www.csiro.au/en/Research/OandA/Areas/Marine-resources-and-industries/Marine-debris

http://www.epa.gov/region9/marine-debris/pdf/MarineDebris-NPacFinalAprvd.pdf

http://www.csiro.au/en/Research/OandA/Areas/Marine-resources-and-industries/Marine-debris

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94-95% on sub-Antarctic islands17. As a result of its global usage and slow degradation, the quantity of plastics reaching the marine environment is expected to increase with time18.

There is a lack of data and scientific knowledge regarding the level and impacts of debris from shipping activities, which can impact on the ability to assess the overall efficacy of MARPOL Annex V as well as any future requirements. While numerous studies have made contrasting claims on the effectiveness of Annex V19, 20, 21, 22, 23, evidence suggests that plastic garbage continues to be thrown overboard from commercial ships.

For example, plastic items collected during beach clean-up events in Northern Australia in 2014 have been determined to likely have come from commercial ships24. These items were found not to be sold in Australia, were traced back to catering companies located in Asia that supply commercial ships, and their good condition indicated that they were only in the sea for a short period of time.

As a result of this ongoing issue, Australia has undertaken numerous investigations into the illegal discharge of garbage in Australian waters, which have been successfully prosecuted under the Protection of the Sea (Prevention of Pollution from Ships) Act 1983, as the primary legislation that implements MARPOL in Australia. This suggests that, despite the current Annex V requirements and non-legislative initiatives undertaken by Australia to help minimise garbage pollution from shipping, there are still obstacles or disincentives to dispose of this waste in accordance with of MARPOL Annex V requirements. Details on prosecutions for ship-sourced garbage pollution in Australia are available at the following link: https://www.amsa.gov.au/environment/legislation-and-prevention/prosecutions/garbage/table.asp

Fishing vessels represent a significant proportion of the global fleet and, therefore, a significant potential source of marine debris at sea. In a recent study considered at the 26th SPREP Meeting of Officials in Apia, Samoa (SPREP is the Secretariat of the Pacific Regional Environment Programme), an investigation into over 8,000 marine pollution incidents reported by fisheries observers over the past 10 years suggests that fishing vessels are responsible for significant amounts of marine pollution in the Western and Central Pacific Ocean. Sixty-nine per cent of reported pollution incidents were determined to be related to waste illegally discharged overboard and 13% to Abandoned, Lost or Dumped Fishing Gear. The full report can be accessed at the following link:

https://sprep.org/attachments/2015SM26/official/WP_10.3.3.Att.1_-_Marine_pollution_originating_from_purse_seine_fishing_vessel_operations_in_the_Western_and_Central_Pacific_region_2004-2014.pdf

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Eriksson, C., Burton, H., Fitch, S., Schulz, M. and van den Hoof, J. (2013). Daily accumulation rates of marine debris on sub-Antarctic island beaches. Marine Pollution Bulletin, 66:199-208. 18

Andrady, A. L. (2011). Microplastics in the marine environment. Marine Pollution Bulletin 62 1596–1605. 19

Derraik J.G.B (2002).The pollution of the marine environment by plastic debris: a review. Marine Pollution Bulletin 44: 842-852. 20

Barnes D.K.A. and Milner P. (2005). Drifting plastic and its consequences for sessile organism dispersal in the Atlantic Ocean. Marine Biology 146: 815-825. 21

Henderson J.R. (2001). A pre- and post-MARPOL Annex V summary of Hawaiian monk seal entanglements and marine debris accumulation in the North-western Hawaiian Islands, 1982-1998. Marine Pollution Bulletin 42 (7): 584-589. 22

Santos I.R., Friedrich A.C. and Barretto F.P. (2005). Overseas garbage pollution on beaches of northeast Brazil. Marine Pollution Bulletin 50: 778-786. 23

Spear L.B., Ainley D.G. and Ribic C.A. (1995). Incidence of plastic in seabirds from the Tropical Pacific, 1984-91: relation with distribution of species, sex, age, season, year and body weight. Marine Environmental Research 40 (2): 123-146. 24

Three tonnes of rubbish found on remote far north beach. http://www.abc.net.au/news/2014-10-02/three-tonnes-of-rubbish-found-on-remote-qld-beach/5782138

https://www.amsa.gov.au/environment/legislation-and-prevention/prosecutions/garbage/table.asp

https://www.amsa.gov.au/environment/legislation-and-prevention/prosecutions/garbage/table.asp




http://www.abc.net.au/news/2014-10-02/three-tonnes-of-rubbish-found-on-remote-qld-beach/5782138

http://www.abc.net.au/news/2014-10-02/three-tonnes-of-rubbish-found-on-remote-qld-beach/5782138

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The provision of adequate port waste reception facilities is a significant challenge for the effective implementation of Annex V. Information contained in the Port Reception Facilities Module of the IMO’s Global Integrated Shipping Information System (GISIS) shows that, since 1 January 2013, over 160 reports have been submitted by ship operators alleging inadequate garbage reception facilities in ports around the world, including reports for Australian ports. Whilst these reports are often circumstantial and not a true reflection on the ongoing provision of waste services at a port, they can provide an insight into the ongoing challenges with providing adequate waste reception facilities for Parties.

The challenges associated with the provision of adequate waste reception facilities has also been recognised for many small island countries and territories due to their unique circumstances, such as a shortage of land for disposal sites or limited infrastructure. The recent endorsement at the IMO of a Regional Reception Facilities Plan (RRFP) for the Small Island Developing States (SIDS) in the Pacific Region, which is expected to take effect from May 2016, will allow these SIDS to satisfy their waste reception facility obligations under MARPOL through regional arrangements by identifying ports that could serve as Regional Waste Reception Centres. Further information on the RRFP can be found on the SPREP website (https://www.sprep.org/waste-management-and-pollution-control-home) or in document MEPC 68/11/1.

The supporting data above indicates that there is a need to further consider the effective implementation of MARPOL Annex V and the factors that significantly contribute to the success of the existing regulations in achieving the overall objectives of this Annex.


Whilst the contribution to marine debris from merchant shipping is, on the whole, subject to appropriate and effective regulations, there is still ship-generated garbage entering the marine environment, including plastics, despite this discharge being banned for more than 25 years.

This indicates that there continues to be gaps in the regulatory framework and/or obstacles and disincentives to effective implementation of MARPOL Annex V, which may not be easily identified and addressed until better data and scientific knowledge regarding marine debris from shipping activity is obtained.

This lack of information needs to be addressed by the maritime and scientific community in order to determine whether regulations and enforcement measures, as well as education materials and guidelines, are achieving the desired results and, if not, why not. This would allow a better understanding of the measures that have the most potential to reduce the disposal of garbage from shipping activities.

Effective implementation of MARPOL Annex V presents a variety of challenges due to the sheer size of the ocean and the lack of state jurisdiction beyond approximately 200 nautical miles off the coast, which makes effective enforcement difficult. Due to this, the management of waste on board while a ship is en route, along with the provision and use of waste reception facilities in ports, is of fundamental importance to the overall success of MARPOL Annex V.

Innovation and the development of new technology play an important role in addressing the effective management of waste on board ships. The development of standards to facilitate shipboard gasification waste to energy systems, to be considered in the IMO sub-Committee on Pollution Prevention and Response in early 2016, warrants close consideration.

In addition, the provision of adequate reception facilities worldwide is a complex matter and a significant challenge for industry and regulators. Improved port reception facilities that are simple to use, accessible and affordable should decrease the amount of waste from shipping that ends up as marine debris.

Effective implementation of MARPOL Annex V for fishing vessels also represents a significant challenge. Compliance and enforcement activities for this industry sector are difficult, given

https://www.sprep.org/waste-management-and-pollution-control-home

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the majority of the world’s fishing fleet are less than 100 gross tonnage and, therefore, not required to maintain a garbage management plan or garbage record book on board.

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19. Illegal, Unreported an Unregulated (IUU) Fishing

Short description

Illegal, unreported and unregulated (IUU) fishing continues to undermine cooperative efforts by States to conserve and manage fisheries on a sustainable basis. Efforts to combat IUU fishing rely on direct on-the-water responses targeting fishing operations, combined with port State and market State measures to prevent entry to port for illegal operators and prohibit the trade in fish and fish products from such sources. IUU fishing has close ties to international criminal activity, especially concerning the entities behind the IUU fishing operations and mechanisms for disguising trade flows of fish and fish products in markets. Vessels used to support IUU fishing activities can also be used for other criminal activity.


Illegal fishing refers to activities conducted by vessels in national waters without the permission of the relevant State or in contravention of its laws, or conducted by vessels flagged to States that are parties to a relevant Regional Fisheries Management Organisation (RFMO) but in contravention of the conservation and management measures (CMMs) or relevant provisions of the international law that bind the State. Unreported fishing refers to fishing activities which have not been reported, or have been misreported, to the relevant national authority or relevant RFMO in contravention of applicable national laws and RFMO procedures. Unregulated fishing refers to fishing activities in an RFMO that are conducted by vessels either without nationality or with the flag of a State not party to that RFMO, in a manner which is inconsistent with or contravenes the RFMO CMMs. Unregulated fishing also refers to fishing activities in areas or for fish stocks in relation to which there are no applicable CMMs and where such fishing activities are conducted in a manner inconsistent with the relevant flag State responsibilities under international law.

IUU fishing is an inherent problem for capture fisheries (also known as ‘wild fisheries’). There are opportunities for significant economic gain from avoiding compliance with licensing and administrative regimes imposed by States, regional fisheries and conservation bodies. There are related savings from non-compliance with conservation measures that seek to ensure fishing operations remain sustainable including by, among other things, avoiding over fishing for target species, and limiting the impact of fishing on species associated with or dependent upon target species. These savings arise along the supply chain and in the eventual market for the fish and fish products derived from IUU fishing.

Illegal fishing contravenes national and international laws designed to conserve and manage fisheries on a sustainable basis. Unreported fishing contravenes requirements imposed by States, regional fisheries management and conservation bodies, undermining efforts to properly assess the level and impacts of capture fisheries. Unregulated fishing occurs where fishing activities are conducted in a manner inconsistent with flag State responsibilities to conserve and manage fisheries resources in accordance with applicable conservation measures or international law.

Since the 1990s, the Food and Agriculture Organization of the United Nations (FAO) has taken a leading role in addressing IUU fishing. Global efforts have led to development of the Agreement to promote compliance with international conservation and management measures by fishing vessels on the high seas; the Code of Conduct for responsible fisheries; the Agreement for the implementation of the provisions of the United Nations Convention on the Law of the Sea of 19 December 1982 relating to the conservation and management of straddling fish stocks and highly migratory fish stocks; the International Plan of Action to prevent, deter and eliminate illegal, unreported and unregulated fishing; the Agreement on port State measures to prevent, deter and eliminate illegal, unreported and unregulated fishing; the Global Record of fishing vessels refrigerated transport vessels and supply vessels; and the Voluntary Guidelines for Flag State Performance.

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RFMOs and arrangements have been established to ensure the long-term conservation and sustainable use of marine resources through cooperation among member States. Through RFMOs, member States are cooperating to introduce and strengthen regional monitoring, control and surveillance activities to prevent, deter and eliminate IUU fishing. RFMOs are also working to improve the collection and use of reported data, and ensure consistent implementation of obligations by all members.

The outcomes of effective regional cooperation have been highlighted recently. As a result of regional surveillance data sharing and implementation of effective port State controls through the Regional Plan of Action to Combat IUU Fishing in South East Asia, almost all of the IUU fishing fleet known to be operating in the Southern Ocean are now out of action. Regional cooperation to share surveillance information on suspected IUU fishing activity, build capacity of all countries to take appropriate action and enable more effective monitoring of fishing activities, both along shared maritime boundaries and on the high seas, will continue to be key in the fight against IUU fishing.

IMO has a shared interest in addressing IUU fishing. This interest focuses on compliance with flag State and port State controls and facilitating global recording of vessels engaging in capture fishing operations. Progress is already being made through the Joint FAO/IMO Ad Hoc Working Group on IUU Fishing and Related Matters.

By continuing to work with the FAO and encouraging States to cooperate and collaborate to combat IUU fishing, the IMO can contribute to the effective implementation of international measures and help identify further actions that will contribute to preventing, deterring and eliminating IUU fishing. This would complement the IMO’s work more broadly on maritime crime and maritime security.

Supporting data

There are no precise estimates of the total amount or value of global IUU catch. However, according to a study conducted in 2008, the economic loss from IUU fishing is estimated at USD 10 to 23 billion globally. This roughly equates to between 11 and 26 million tonnes of illegally caught fisheries products reaching the global market annually.25


Those engaging in IUU fishing are adaptive and innovative in their efforts to circumvent national and international conservation and management measures concerning ensuring the sustainability of capture fisheries. Responses to IUU fishing require constant vigilance and intelligence gathering to keep abreast of innovation by IUU fishing operations. These actions require State and international coordination including through IMO and FAO. The trade in fish and fish products sourced from IUU fishing takes advantage of porous local and regional mechanisms, particularly in developing states. Accordingly, capacity building, technical cooperation and information sharing remain significant issues in tackling IUU fishing, as well as significant opportunities for increased future action by IMO.

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Estimating the worldwide extent of illegal fishing, D.J. Agnew; J. Pearce; G. Pramod; T. Peatman; R. Watson; J.R. Beddington; and T.J. Pitcher. 2009, PLoS ONE, 4(2): e4570 http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0004570

http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0004570

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20. Managing Ships’ Biofouling

Short Description

The Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species (the Guidelines) were adopted by MEPC in July 2011. The Guidelines represent a decisive step towards reducing the transfer of invasive aquatic species by ships; however there are no items relating to biofouling management on the MEPC work plan.


The spread of invasive species is now recognised as one of the greatest threats to the ecological and the economic well-being of the planet. These species are causing enormous damage to biodiversity and the valuable natural riches of the earth upon which we depend. Direct and indirect health effects are becoming increasingly serious and the damage to the environment is often irreversible. Moreover, significant economic impact occurs to industries that depend on the coastal and marine environment, such as tourism, aquaculture and fisheries, as well as costly damage to infrastructure26.

The problem of invasive species carried by ships has intensified over the last few decades due to the expanded trade and traffic volume and, since the volumes of seaborne trade continue to increase, the problem may not yet have reached its peak. The effects in many areas of the world have been devastating. Quantitative data show that the rate of bio-invasions is continuing to increase at an alarming rate and new areas are being invaded all the time27.

Biofouling is also considered one of the main vectors for marine bioinvasions. There is now substantial research to suggest that vessel biofouling may be responsible for more non- indigenous marine species (NIMS) introductions than ballast water (see supporting data section for reference). There are also observations that NIMS originally introduced through ballast water are further spread to nearby domestic ports through biofouling pathways.

The issue of the transfer of invasive aquatic species through ships’ biofouling was first brought formally to IMO’s attention in 2006. The Guidelines for the control and management of ships' biofouling to minimize the transfer of invasive aquatic species (the Guidelines) were adopted by MEPC in July 2011 (Resolution MEPC.207(62)) and were the result of three years of consultation between IMO Member States.

The Guidelines are intended to provide a globally consistent approach to the management of biofouling, complementing current maintenance practices within the industry.

Management measures to reduce the risk from biofouling can also improve a ship’s hydrodynamic performance as biofouling leads to significant increases in ship resistance, which impacts both fuel costs and emissions of air pollutants and greenhouse gases. This has been recognized by the IMO and is reflected in the Guidance for the development of a ship energy efficiency management plan (SEEMP) (MEPC.1/Circ.683).

Supporting data

Coutts A (1999) Hull fouling as a modern vector for marine biological invasions: investigation of merchant vessels visiting northern Tasmania, Faculty of Fisheries and Marine Environment, Australian Maritime College, Launceston, Tasmania, 283 pp

Davidson I, Zabin C, Ashton G, Ruiz G (2014) An assessment of the biofouling introductions to the Puget Sound region of Washington State. Report to the Washington Department of Fish & Wildlife and Washington Department of Natural Resources, Olympia, Washington. 111pp.

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http://www.imo.org/en/OurWork/Environment/Biofouling/Pages/default.aspx 27

http://www.imo.org/en/OurWork/Environment/Biofouling/Pages/default.aspx



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Hewitt C, Campbell M, Thresher R, Martin R, Boyd S, Cohen B, Currie D, Gomon M, Keough M, Lewis J, Lockett M, Mays N, McArthur M, O'Hara T, Poore GB, Ross DJ, Storey M, Watson J and Wilson R (2004) Introduced and cryptogenic species in Port Phillip Bay, Victoria, Australia. Marine Biology 144: 183-202

Hewitt C, MC (2008) Assessment of relative contribution of vectors to the introduction and translocation of marine invasive species. AMC National Centre for Marine Conservation and Resource Sustainability, Launceston

Lewis, J. A., Coutts, A. D. M. (2009). Biofouling. In: Dürr, S and Thomason, J. C. (Eds), Biofouling. Blackwell Publishing.


The transfer and introduction of aquatic invasive species through ships' biofouling threatens the conservation and sustainable use of biological diversity. The risk of transfer of invasive aquatic species will continue to increase with the increase in shipping traffic and volumes in the coming years. Additionally, changes to marine environments and temperatures due to climate change may increase the number of locations vulnerable to the introduction of invasive species, as well as increasing the survival range of those species.

Several countries (Australia included) are considering implementing a regulatory approach to manage the risk of introduction of invasive aquatic species through ships’ biofouling.

The risk of species transfer by biofouling has been recognised not only by IMO, but also by several UNEP Regional Seas Conventions (e.g. Barcelona Convention for the Protection of the Mediterranean Sea Against Pollution), the Asia Pacific Economic Cooperation forum (APEC) and the Secretariat of the Pacific Region Environment Programme (SPREP).

In adopting the Guidelines, IMO recognised that they may need to be refined as scientific and technological advances are made. The Guidelines are also non-mandatory in nature and their implementation and effectiveness in reducing risk from biofouling should be reviewed. Guidance was prepared for evaluating the Guidelines (circulated as MEPC.1/Circ.811), however collection and dissemination of information under this circular is also non-mandatory.

Following the adoption of the Guidelines, no additional biofouling work has been considered or included on the MEPC work plan. This is despite the commitment to evaluate the effectiveness of the Guidelines.

Given the continued and increasing risk, and potential changes to regulatory frameworks by individual Administrations, IMO should ensure that the development, implementation and review of measures to manage the risk from ships biofouling is clearly recognised and included on future work plans.

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21. Ballast Water Management

Short Description

Australia is a signatory to the International Convention for the Control and Management of Ships’ Ballast Water and Sediments 2004 (the BWM Convention). Eleven years on from its adoption, the Convention has yet to come into force: current ratification status is 47 parties with the percentage of world tonnage represented currently being verified.


The BWM Convention was developed in response to the increasing concern of the international community, both governments and industry, about the transfer of invasive species in ships’ ballast water.

The BWM Convention sees a move away from deep sea exchange as the primary method of ballast water management, with a move towards a ballast water standard (the D-2 standard) that will generally be achieved through the installation and use of ballast water management systems (BWMS).

Since the adoption of the BWM Convention, 59 BWMS have been Type Approved by Administrations and are available for installation on vessels. Some early adopters installed treatment systems following the adoption of the BWM Convention, well ahead of the phasing in of the D-2 Standard, although their use is not always permitted by Administrations.

While other Administrations have Type Approved BWMS under IMO system, the United States has developed a separate protocol for the approval of ballast water treatment technology (the ETV protocol). No BWMS has received United States type approval to date. Many in the maritime community view the ETV protocol as more stringent and robust than the IMO process.

Regulation B-3 of the BWM Convention set out the application dates for a smooth transition to the D-2 performance standard of the Convention between the years 2009 and 2019. In 2013 Resolution A.1088(28) was passed to provide a relaxing of the schedule for application of the D-2 standard.


Entry into force

Despite strong encouragement from IMO, many signatories have yet to ratify the BWM Convention. As such, it is still unclear when the Convention will enter into force.

IMO should continue to encourage signatories to ratify, agree, or accede to the BWM Convention to ensure that the Convention enters into force without further delay so as to provide for accrual of benefits as soon as possible to the aquatic environment from its early, wide and effective implementation.

IMO should continue efforts to recognise early adopters and ensure measures to facilitate the implementation of the BWM Convention do not penalise this group.

Continued delay of entry into force of the BWM Convention risks reduction in investment in BWMS development. Early adopters that installed BWMS and do not yet use them will have experienced financial losses with respect to these decisions and would be unlikely to again take proactive measures until the BWM Convention comes into force. These factors together will delay the benefits to the marine environment of better management ballast water through implementation of the BWM Convention.

Review of Guidelines (G8)

In recent years, industry has raised concerns about the robustness of the Guidelines to approve BWMS and a review of Guidelines (G8) began in late 2014. This review is expected to be complete in 2016. Key issues being considered in the review include the effects of

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temperature and salinity on ballast water treatment, definition of viable, and definition and use of critical parameters.

The existence of two approval processes for the same technology will cause issues. Canada has recently acknowledged (MEPC68/2/INF.34) that the entry into force of the BWM Convention before the type approval of appropriate systems by the United States would pose challenges for Great Lakes ships. Ships that operate on the Great Lakes would need to comply with both BWM Convention and United States requirements when deballasting in United States waters. Other ships will face similar issues if their regular operations include activity within United States waters.

Without a statement or approach from IMO with regard to the United States protocol, individual Administrations will need to consider how they will recognise (or not) BWMS approved under the different processes from a port State control point of view, and Operators will need to consider the different approval processes when choosing BWMS to be installed in their ships.

Installation of BWMS

The passing of resolution A.1088(28) and the review of Guidelines (G8) should remove the self-identified barriers to industry installing BWMS.

IMO and its associated industry organisations should strongly encourage the installation of BWMS so as to provide for accrual of benefits as soon as possible to the aquatic environment from its early, wide and effective implementation.

Ballast Water Sampling

The development and finalisation of an IMO circular to provide sampling and analysis guidance has been recognised as a high priority by MEPC. A draft circular has been developed (BWM.2/Circ.42) and a trial period associated with this guidance was agreed. Recently MEPC agreed to expand the trial period into an experience building phase. During the experience building phase, it is envisaged that information will be collected (and submitted to IMO) on the use, accuracy and precision of various sampling methods, as well as any treatment approaches that do not meet the D-2 standard, the amount by which the standard is exceeded and any reasons why.

This experience building phase is part of the recently agreed Roadmap for the implementation of the BWM Convention (MEPC68).

IMO should continue to encourage members to participate in the trial and experience building phase to ensure that the sampling guidance can be finalised and give confidence to both port State control, Flags and their ships, that compliance testing against the D-2 standard has been carried out in an agreed and consistent manner, to an IMO standard.

Definitions under the Convention

Administrations have recently highlighted some ambiguity around the definition of the term ‘same location’ in the context of regulation A-3 of the BWM Convention.

IMO should continue to facilitate discussions and agree on definitions for this and other terms (as questions arise) within the BWM Convention to ensure consistent implementation of the Convention and to give Administrations, Flags and their ships confidence that the approaches taken by Administrations are within the context and spirit of the BWM Convention and take into account appropriate scientific methodologies.

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