Ship Execution Plan (SEP)

India aims to reduce ships’ use of single-use plastic by 90% during stays in Indian ports in the next 12 months.

On 16 October 2019, the Indian Directorate General of Shipping (DGS) issued Order No.05 of 2019 prohibiting the use of single-use plastic items onboard ships. The order prohibits the carriage of any such items onboard Indian flagged ships while foreign flagged ships are only prohibited from using any such item while at places or ports in India.

While the initial plan was to implement the order in full by 1 January 2020, DGS later decided to postpone its implementation, to allow the shipping industry time to put in place the logistical arrangements needed to comply with the new requirements.

The following changes and clarifications to the original order should be noted:

Definition of single-use plastics

The original order defines single-use plastics as “disposable plastics which are used only once before they are thrown away”. The Addendum further clarifies that the prohibition applies only to such items used onboard ships and which are completely made of plastics. DGS provides the following examples of items not covered by the prohibition:

• tetra pak cartons with plastic caps as used for milk and juice;
• dispensers for liquids such as shampoo, cleaning products, etc. when these are repeatedly re-used/re-filled onboard and not discarded after single use;
• items made of biodegradable plastic with a stamp, mark or certificate from the manufacturer or something similar;
• cargo related items and packaging;
• essential equipment such as personal protective equipment, medical equipment, lifesaving appliances and fire-fighting equipment; and
• for the time being, crew and passenger personnel effects.

Please refer to the original order for a generic list of single-use plastic items covered by the prohibition.

New phase-out schedule – Ship Execution Plan (SEP)

All ships are eventually required to reduce their single-use plastic use by 90% during stays in Indian ports. This will be achieved by a stepwise implementation of the prohibition and will be based on ship type and each ship’s actual inventory of single-use plastic items. To summarise:

• All ships when at Indian ports or places must be able to present an inventory list identifying all single-use plastic items onboard that are covered by the prohibition. The deadline for establishing the inventory list is 31 January 2020 for cargo ships and 31 March 2020 for passenger ships.
• An inventory list should identify the different types of single-use plastic items onboard but need not specify the actual number of each item onboard. As an example, the DGS explains that all plastic bags irrespective of size will be considered as one single-use plastic item.
• For cargo ships, 50% of the items in the inventory list will be prohibited from 1 April 2020, 75% from 1 July 2020 and 90% from 1 October 2020.
• Passenger ships are given two extra months to comply with each step of the phase-out schedule.
• Ship operators are free to decide which items in the inventory list to place in each ‘phase-out category’ and can therefore prioritize based on each ship’s operational requirements and crews’ needs.

The DGS states that the inventory list, once prepared, should not be changed unless there is a need to correct the list.

In accordance with the above order a “Ship Execution Plan” should be available onboard in order to provide guidance on crew for Single use plastics, and to list such items to inventories.

The following types of inventories should be created regarding Single Use Plastics:

1. Initial Inventory (Single Use plastics onboard on 31st January 2020)
2. 10 % Inventory (these items will be used onboard at the end of implementation date)
3. Inventory A – 50% of items of initial inventory which will not be used  after 1st April 2020
4. Inventory B – 75% of items of initial inventory which will not be used after 1st July 2020
5. Inventory C – 90% of items of initial inventory which will not be used after 1st October 2020.

A Single Use Plastic Log is to be completed by the ship when entering or departing Indian waters, ports or places with an attached list of Single Use Plastics onboard.

Ship Execution Plan (SEP)

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