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Intercargo Circular: Disposal of HME Cargo Residues No Longer Allowed at Sea
During the recent session of IMO’s Marine Environment Protection Committee (MEPC 69) a decision was taken not to continue with the provisions set out in MEPC.1/Circ. 810.
The circular allowed for the discharge of cargo hold wash water from holds previously containing solid bulk cargoes classified as Harmful to the Marine Environment (HME), but only when the vessel was outside a special area.
The reasoning behind this decision was that by extending the deadline of MEPC.1/Circ. 810 it may actually serve as a disincentive for ports to provide adequate Port Reception Facilities (PRF).
Intercargo made available to the committee the results of a recent survey which showed that out of 204 ports in 55 countries, only 23 provided adequate PRF. Obviously this decision and the current lack of PRF is likely to give rise to operational difficulties and increased costs for vessels carrying HME cargo. Any such cost increase is unwelcome in current market.
One of the objections made during MEPC 69 was that no official notifications had been made to the IMO regarding the lack of adequate PRF.
Should Members encounter difficulties in landing HME cargo residues, they should report it to their Flag Administration and if possible, the competent Authority in the port state. Such reports should follow the format set out in Appendix I of MEPC.1/Circ.834 and include details of all costs incurred for the landing of HME residues. It is hoped that this will assist future efforts by industry bodies to ascertain the number and location of ports with inadequate PRF.
Crews should familiarise themselves with the current regulations and have a clear understanding of the conditions permitting certain discharges. “Consolidated Guidance for Port Reception Facility providers and users” is intended to be a practical guide for crew who seek to discharge HME cargo residues and waste wash water.
Advanced planning is a key element of minimizing the amount of waste retained on board, but also assists with logistical and commercial considerations.
A list of the current MARPOL Annex V compliant ports can be accessed by clicking here.
In light of the above decision, and in order to reduce the potential for disputes, the operational costs and the costs associated with delays relating to disposal of HME residues should be agreed in the charterparty.
The club has previously issued a circular on these clauses which may be read here.
Further advice on this topic can be accessed at the links below:
www.nepia.com/insights/industry-news/marpol-annex-v-hme-wash-water-extension/
The topic of Shipping Cargoes Harmful to the Marine Environment has also been covered in our Loss Prevention Newsletter on page 10 of Signals issue 91.
