Why do we need to change the 2015 EGC guidelines so soon? In fact, the change has been needed since before 2015. The 2015 version of the guidelines was a quick fix prior to the entry into force of SOx ECAs, addressing the problem of testing discharge pH four metres from the vessel at maximum engine power while still at quayside. As with most measurement problems, one first discovers them when the instruments are put into use. Other changes were wanted and needed, but they weren’t considered as urgent as the pH issue. Their nature is more related to guideline definitions and interpretations.
The work at PPR 7 won’t have to start from scratch. Some extensive preparations have already been made – not just in typing things up, but also in coming to agreements between all stakeholders when working on the draft for submission to IMO.
Which stakeholders are those, you may ask? Back in 2014, the EU Commission set up a focus group called the ESSF (European Sustainable Shipping Forum), which was split into various subgroups, including one focused on scrubbers or EGCS (exhaust gas cleaning systems). This subgroup’s members included officials from member states and representatives from the shipping industry, classification societies, ports, bunker providers, environmental NGOs, subsystem providers and naturally scrubber manufacturers like Alfa Laval. Even the United States contributed to the work.
It took us two years and 13 rounds of correspondence to arrive at the draft originally issued as MEPC 71/9/1. That draft then entered correspondence led by Finland, resulting in PPR 6/11, which is now on the table for discussion at PPR 7.
Looking at the draft text, you’ll see that there are no proposals relating to quality control measurements for emissions. That topic was considered inappropriate for the ESSF to discuss. Another interesting observation is that class societies and scrubber manufacturers have more or less implemented the changes already. How can I know this? In the course of discussions, a consensus and understanding of how to read the guidelines was achieved. Since the proposed changes make sense to all parties, it’s more or less expected that they will be accepted by IMO.
My hope for PPR 7 is that the 28 EU member states submitting the proposal will remember that it represents two years of hard work by all stakeholders, including the marine industry itself. Moreover, I hope that the terminology established will also be used when we get to discuss the new output relating to “liquid effluents from EGCS”, a different agenda item from the amendment of the 2015 EGC guidelines.
