At the spring meetings of the International Maritime Organization (IMO), we prepared international regulation, standardisation and guidelines. Global regulation ensures that ships, their systems and responsibilities are subject to the same requirements everywhere. By promoting digitalisation and automation, Finland strives for efficiency, safety and sustainability. In this way, we promote sustainable business and service development.

Automation can be used in shipping to improve the wellbeing and occupational safety of crew, among other things. Partial automation or remote performance of lookout tasks would allow for more flexible resting periods. The most dangerous work situations can be reduced, for example, by means of autonomous rescue vessels or remote pilotage.

Finland supports global electronic data exchange

At the meeting of the Facilitation Committee (FAL) in May, amendments were adopted, which require public authorities to have a system for the electronic transmission of the data required during a port call, to ensure that information only needs to be submitted once.  In addition, rules on health safety were adopted based on lessons learned from the pandemic. The amendments are due to enter into force on 1 January 2024.

The Committee also decided to extend the IMO Compendium with five new data sets on ship reporting systems, ship and company certificates and port state control inspections. The Committee decided to prioritise passenger data and the electronic or ocean bill of lading in its continued drafting. The bill of lading is a key document for merchant shipping and logistics chains. Finland supports the maintenance of the Compendium in 2023.

The harmonisation of data aims at interoperability of systems. By providing the information in digital format through interfaces only once, we enhance the exchange of information and transports. The main benefits are achieved at system level, so the exchange of port information and reporting formalities are an important part of the work of the IMO. By utilising data, consignments can be optimised, for example, by sharing route, time and cargo information, as well as by using AI-based applications.

Roadmap for automation guidelines and regulation

The IMO’s Maritime Safety Committee (MSC) has decided to prepare guidelines on maritime automation in accordance with a common roadmap with the ultimate goal of binding legislation. The guidelines will initially cover cargo ships and will subsequently be assessed for application to passenger ships. Finland supports technology neutrality, that is, a balanced approach to the use of different technologies, in the preparation of regulation.

The roadmap contains not only the key themes identified in the inventory of regulatory barriers, but also possible new themes. In our opinion, these themes should include artificial intelligence, cybersecurity and other principles enabling trust in automation.

The aim is for the guidelines to support the preparation of binding regulations on automation. Application developers must design their systems in such a way that they can be approved for use as reliable and the authority can verify that they are compliant and safe. Simulation and experiments are key tools in this work. The authorities, for their part, develop risk assessment, which requires that they receive sufficient information about, for example, automation experiments. Cooperation between business and public authorities is very important.

The Maritime Safety Committee’s automation roadmap supports Finland’s view on the progress of automation. It is not yet time to decide whether a vessel can be completely unmanned. First, solutions and equipment that support safe decision-making must be made available. Drawing the line between what new legislation is needed and what existing legislation is applicable is still ongoing. We need a debate on what a Maritime Autonomous Surface Ship (MASS) is from the point of view of IMO legislation.

The work of the Maritime Safety Committee will continue in the correspondence group, in which we need the views of industry and other authorities on the needs and objectives of the guidelines. The most challenging issues will be dealt with in cooperation by the Maritime Safety Committee, the Facilitation Committee and the Legal Committee (LEG), as the cross-cutting issues concern conventions for which they are all responsible. Important issues are related, for example, to the roles and responsibilities of the shipmaster, crew and other stakeholders, starting with the question of whether a vessel may be controlled from outside the vessel. In Finland legislation already allows, for example, remote maintenance.

Possible national introduction before international regulation

The guidelines may be used in national waters, where applicable, even before the entry into force of binding international legislation. We are currently carrying out a preliminary study of the needs and possibilities for amending national legislation if necessary. Opportunities could be offered in the coming years by, for example, an autonomous tug, a cable ferry, a taxi boat, remote pilotage or a road ferry on which experiments have already been carried out. Finnish expertise is also of a high standard in port automation.

Nationally, work will continue in the direction indicated by the resolution on promoting automation in the transport sector, which includes the maritime sector. We warmly welcome all interested parties to participate in the development work.

A consortium between by U.S. classification society American Bureau of Shipping (ABS) and U.K.’s consultancy provider Arcsilea has won a tender from the European Commission to carry out a technical study on the future of ship energy efficiency measures introduced by the International Maritime Organization (IMO).

As disclosed, the partners won the tender from the European Commission’s Directorate-General for Mobility and Transport (DG MOVE).

The 15-month-long project will analyze the IMO’s Carbon Intensity Indicator (CII), Energy Efficiency Existing Ship Index (EEXI) and Energy Efficiency Design Index (EEDI) framework.

Moreover, the parties will provide recommendations for further development, effective implementation and enforcement.

The initiative is part of the Smart and Sustainable Mobility Strategy adopted by the European Commission, which calls for the European Union (EU) to establish sustainability standards with the IMO.

The strategy was adopted to meet the target set under the European Green Deal, which is to reduce transport-related greenhouse gas emissions by 90% by 2050.

“Energy efficiency measures are cumulatively changing the shape of our industry before our eyes. We can see how they are driving change on fleets and operations as owners understand how to adapt their existing assets and new orders to perform in the new business environment they create,” said Georgios Plevrakis, ABS Vice President, Global Sustainability.

“We are very pleased to continue our collaboration with DG MOVE and ABS to help drive practical improvements to the IMO short-term measures,” Edwin Pang, Arcsilea Founder and Principal Consultant added.

Last year, IMO agreed on a set of draft guidelines to support mandatory measures approved by the Marine Environment Protection Committee (MEPC) to cut the carbon footprint of all ships.

IMO’s MEPC 78, held from 6 June to 10 June 2022, saw the organization addressing short-term measures to reduce GHG emissions, mid-term measures including strengthening the carbon intensity indicator for ships and start considering a revision of the IMO’s GHG strategy.

IBIA believes full Well-to-Wake lifecycle emissions should be taken into account to ensure the IMO’s greenhouse gas policy is holistic, and continued efforts to decarbonise shipping doesn’t end up causing increased overall GHG emissions.

At its 78th session, the Marine Environment Protection Committee (MEPC 78, 6-10 June) held a truncated discussion on this complex subject due to time constraints.

Rather than having a full consideration of proposals, MEPC 78 agreed instead to establish a correspondence group on marine fuel lifecycle GHG analysis to further the work. The correspondence group will submit an interim report to MEPC 79, and final draft guidelines to be adopted by MEPC 80.

The majority view at the IMO is that the LCA guidelines will allow for a Well-to-Wake calculation, including Well-to-Tank and Tank-to-Wake emission factors, of total GHG emissions related to the production and use of alternative marine fuels.

Discussions also include which type of GHGs to be calculated (e.g. not just CO2 but possibly also methane, nitrous oxide, black carbon) and whether to include 20-year global warming potential (GWP) as well as 100-year GWP for each type of fuel and its GHG emissions for comparison purposes.

At present, IMO regulations only deal with Tank-to-Wake emissions from ships.

Apart from the complexity surrounding the LCA guidelines, in particular how to certify the Well-to-Tank part of emissions, the big question is how such LCA guidelines are eventually incorporated into IMO regulations.

The correspondence group has been asked to further develop the draft guidelines on lifecycle GHG intensity of marine fuels (draft LCA guidelines), and in doing so:

– Identify main initial fuel production pathways and feedstocks for inclusion
– Further consider sustainability criteria issues and further develop the Fuel Lifecycle Label (FLL)
– Develop methodologies that allow for the calculation of Well-to-Tank, Tank-to-Wake and entire Well-to-Wake GHG emissions default values
– Develop procedures that allow for continuous review of GHG emissions default values
– Develop guidance for third-party verification and certification schemes

Guidelines for the transport and handling of limited amounts of hazardous and noxious liquid substances in bulk on Offshore Support Vessels, for new and existing U.S. Offshore Supply Vessels

The Coast Guard Office of Design and Engineering Standards has released CG-ENG Policy Letter 03-12 – Ch 1, Implementation of IMO Resolution A.673(16), Guidelines for the Transport and Handling of Limited Amounts of Hazardous and Noxious Liquid Substances in Bulk on Offshore Support Vessels, For New and Existing U.S. Offshore Supply Vessels.

IMO resolutions MEPC.318(74) and MSC.460(101) adopted amendments to the IBC Code, updating carriage requirements for a significant number of products. These amendments became effective on January 1, 2021 and affected several cargoes listed in appendix one to CG-ENG policy letter 03-12.  On 16 May, 2022, 03-12 CH-1 was published, which includes a second enclosure with changes in carriage requirements for affected cargoes.

Vessel companies have been granted extensions to their certificates of fitness in the interim between the effective date of the amendments and the publishing of the updated policy letter. As of now, those extensions have been granted until December 31, 2022.

Before the expiration of vessel COFs, a plan must be proposed to CG-ENG-5 at hazmatstandards@uscg.mil to meet the updated requirements for affected products, or with proposed equivalencies to specific requirements. Once a plan is approved, the modifications will be required by the vessel’s next drydock date.

International Maritime Organization discussions for introducing a global shipping carbon tax are being held at its Marine Environment Protection Committee meeting this week.

A carbon tax is definitely what shipping needs. If structured carefully, it can push the industry to emit less by incentivising initiatives to improve efficiency and implementation of zero-carbon technology and fuels.

While most of the industry stands firmly behind a global carbon tax, there are widespread concerns about the process and its likely outcome.

The mandatory carbon intensity measure, coming into force in 2023, will set the IMO on a dangerous course.

It is based on Carbon Intensity Indicator (CII) metrics, which build on a grossly imperfect metric based on the theoretical cargo intake of a vessel, without factoring in the performed transportation work.

These metrics disregard operational and trading efficiency, and introduce misguided incentives.

Recent proposals on global carbon taxes — one tabled by China and backed by Brazil, Argentina, South Africa and the United Arab Emirates; and one of two proposals tabled by Japan — are particularly worrying.

Both proposals want to levy a carbon tax on ships based on their CII scores. If the carbon tax proposals penned by China and Japan are implemented, the regulation will further penalise the vessels and operations with the lowest emissions per transported tonne of cargo — ultimately favouring empty ships.

‘Senseless’ approach

This approach, well-meaning as it may be, is senseless. It is as if the International Air Transport Association were to introduce metrics that reward airlines for flying jumbo jets half-empty. It is wasteful, it is wrong and it is misguided. The devil is in the detail.

Operational and trading efficiency is paramount for cutting emissions before zero-emission technology and fuels are widely available for all shipping segments.

Efficiency will also remain a critical factor in the future when the industry switches to zero-emission fuels, as these will be two to three times more expensive than fossil fuels.

To put it bluntly, adopting a poorly developed regulatory framework that disregards the importance of operational and trading efficiency will hamper the industry’s transition towards the large-scale use of sustainable zero-emission fuels.

We call on governments in the European Union, the UK and Norway to ensure that shipping regulations are practical and sensible. As leading maritime nations, they have a loud voice and a big responsibility.

We must work to avoid senseless, unconstructive compromises.

How can we come up with a more constructive regime? Rather than creating more perverse incentives for the industry, the IMO should follow the EU’s lead.

In 2023, the EU is due to include shipping in its emissions trading system (ETS), a levy based on the actual carbon emissions of the vessels themselves. These regulations offer a suitable mechanism for curbing emissions.

They also demonstrate that it is practical to have both a straight carbon tax and a cap-and-trade scheme like the EU’s ETS linked to the actual emissions of ships.

An approach like this would push the industry to collaborate, improving efficiency in every part of the seaborne supply chain. It would also stimulate investment in tomorrow’s zero-emission fuels.

In a sector responsible for roughly 3% of greenhouse gas emissions, carefully crafted regulations and incentives are sorely needed. Poorly conceived compromises, blocking positive change, are not.

If the IMO rules are implemented as proposed by China and Japan, we risk ending up with another imperfect and counterproductive piece of regulation.

MAN Energy Solutions has signed a Letter of Commitment (LOC) with ship manager, Anglo-Eastern, at its Hong Kong head office to supply its Overridable Power Limitation solution, including service installation, to meet the impending IMO MARPOL VI EEXI regulation.

In preparation for the upcoming EEXI regulation, MAN Energy Solutions developed retrofit solutions to satisfy vessels in need of an OPL scheme, both for MC- and ME- engines.

Early in the process, Anglo-Eastern requested suggestions for suitable solutions for those elements of its fleet in need of a retrofit. Anglo-Eastern has approximately 300 vessels requiring an OPL solution, spanning mechanically- as well as electronically-controlled engines.

Carsten Ostenfeldt, chief operating officer, Anglo-Eastern Univan Group, said: “It was important for us to have a solution for our customers and vessels that was timely and cost competitive. We knew pressure would build up across the many vessels in the world in need of an OPL solution, which is why we wanted to be an early mover to ensure sufficient capacity for the retrofit of our vessels.”

Sarath Prasannan, managing director MAN Energy Solutions, Hong Kong and Head of MAN PrimeServ, Marine & Power (APAC), said: “The Anglo-Eastern Group is a Global Key Account for MAN Energy Solutions and is well prepared in its approach to meeting the IMO regulatory requirements due to come into effect in 2023. We will work together with Anglo-Eastern in ensuring that the engines in its fleet have the latest class approval and access to tamper-proof EEXI compliant solutions.”

The development of OPL is spurred by the introduction of the IMO’s MEPC 335(76) regulation – to be enforced from January 2023 – that will require vessels already in service to meet the EEXI (Energy Efficiency eXisting ship Index).

Man Energy Solutions released information regarding the deal, on 8 June, although it was signed off on 1 March.

Zero-emission vessels and fuels need to be commercially viable by 2030 for the whole shipping sector to decarbonise by 2050, however, the market alone cannot solve this challenge.

New policies are needed, regulating and incentivising shipowners, operators, and fuel providers in a direction that drives investments in scalable zero-emission fuels, technologies, and vessels. And we need to set all sails now.

Over the next year, the IMO’s Marine Environment Protection Committee (MEPC) will meet three times with MEPC 78 from 6-10 June, MEPC 79 in December, and MEPC 80 in mid-2023.

These meetings are scheduled to negotiate and adopt a revised GHG Strategy setting the necessary reduction targets for shipping and ensuring an equitable transition.

During these meetings, governments also have the chance to develop the policies and detailed regulations that will set a price on carbon through a market-based measure (MBM), phase out lifecycle (well-to-wake) GHG emissions from fuels through a fuel standard and agree on a design standard effectively ending the production of vessels solely powered on fossil fuels.

These three elements — the GHG Strategy, an equitable transition, and the combination of economic and technical measures to deliver lifecycle GHG reductions — are highly interdependent and one cannot be developed without parallel development of the others.

The strategy sets the levels of ambition and principles to know what measures should be designed to achieve and by when, and how they could also address the measures’ potential disproportionately negative impacts on states and ensure an equitable transition.

In parallel, detailed development of both economic and technical measures as well as agreement on central elements of an equitable transition would deliver the needed clarity on how to achieve shipping decarbonisation. Clarity that both the public and private sector are in strong need of if the necessary large-scale investments are to be made in due time.

The next year constitutes a great opportunity for governments to get things right. But, at the same time, failing to agree on one issue could jeopardise the whole basket of measures.

It is critical for the credibility and long-term sustainability of our industry that the IMO and its Member States demonstrate progress by adopting regulation allowing shipping to decarbonise in line with the Paris Agreement and public expectations.

At the latest working group meeting in May, Member States and Organizations expressed clear consensus to put a price on emissions. The meeting outcome is a clear and positive step towards having meaningful mid-term measures adopted by 2025 and achieving a 1.5-aligned and equitable transition.

With this in mind, we are calling on the IMO and the Member States to urgently address three priorities over the next three MEPC meetings:

Firstly, the IMO must align international shipping with the Paris Agreement’s 1.5 degree temperature goal by adopting a target of full decarbonisation of international shipping well before 2050. Further, 1.5-aligned interim targets for GHG emissions reduction by 2030 and 2040 as well as corresponding carbon intensity reduction targets should also be adopted.

Secondly, the IMO must adopt a so-called basket of mid-term measures that includes a measure setting an incentivising, sufficiently high price on carbon as well as a well-to-wake GHG fuel standard and an end-date to the production of fossil-fueled only vessels. The price on GHG and fuel standard should be adopted by 2025 in support of the revised GHG Strategy’s levels of ambition. The design requirements for new vessels should aim to enter into force before the end of the decade.

Thirdly, the Strategy and the mid-term measures must support a globally effective and equitable transition to zero emission shipping. Revenue from the MBM could be reinvested in decarbonisation, such as green electricity for marine fuels in all parts of the world, and could also financially support developing countries, especially Small Island Developing States (SIDS) and Least Developed Countries (LDCs), as for example explained by a recent report from the World Bank.

By translating these priorities to policies, the IMO and Member States will create the necessary clarity for industry to be able to take the necessary steps towards full decarbonisation. Decarbonising shipping is possible, but it will require urgent and sustained action by the private sector as well as by governments. Let us move forward together to make shipping a zero-emission industry beneficial to all countries, so we can honestly tell the younger and future generations that we recognised the urgency of addressing climate change and acted accordingly when the window of opportunity was still open.

This article was written by Alexander Saverys, CEO, CMB NV, Ioannis Zafirakis, director, chief financial officer, chief strategy officer, treasurer and secretary, Diana Shipping; Katharine Palmer, shipping lead — UN High-Level Climate Champion; Simon Bennett, general manager — sustainable development, Swire Pacific Offshore; Simon Bergulf, director of regulatory affairs, A P Møller-Mærsk; Ingrid Sidenvall Jegou, project director, Global Maritime Forum.

The IMO’s Maritime Safety Committee (M S C) decided at its meeting 20-29 April 2022 to commence work on the development of a new goal-based instrument regulating the operation of maritime autonomous surface ships (MASS). BIMCO reports from the meeting.

The prospect of autonomous ships operating internationally with little or no human intervention has revealed the need for a regulatory framework for such ships, including their interaction and co-existence with conventional manned ships. The current regulatory framework generally assumes manning and human intervention.

MSC 105 agreed to develop a non-mandatory, goal-based code for MASS, potentially entering into force on 1 January 2028 as a mandatory code through SOLAS and other IMO instruments, as relevant, upon experience with its application.

A roadmap for the development work was approved. The roadmap includes the consideration of key principles, purpose and objectives for the new goal-based code, the consideration of its scope and structure, and the consideration of a common understanding of MASS terminology. The roadmap also includes the consideration of how common challenges that have been identified across several IMO instruments could be addressed, for example the need to clarify the role and responsibility of the “master” for circumstances where shore personnel might control the ship, or the functional requirements of a remote-control centre.

“The work at IMO has been divided in two. The first step, which was completed last year, was for the identification of provisions in the IMO regulation in terms of applicability to MASS. The second step is where we are today, embarking to assess and determine the most appropriate way of addressing MASS operation, taking into account eg. the human element, technology and operational factors”, says Jeppe Skovbakke Juhl, Manager, Maritime Safety & Security at BIMCO.

“In parallel to the scoping exercise, the IMO/MSC finalised guidelines for the trial of MASS operations. The aim of the guidelines is to assist relevant authorities and stakeholders ensuring that the trials of MASS related systems and infrastructure are conducted safely, securely, and with due regard for protection of the environment”, says Juhl.

And continue: “This also include that appropriate steps should be taken to ensure sufficient cyber risk management of the systems and infrastructure when conducting MASS trials, as well as considering manning and qualifications of personnel involved in MASS trials.”

MSC 105 decided to establish a correspondence group with the aim, until MSC 107 in June 2023, advance the initial steps of the development of a non-mandatory, goal-based code for MASS, noting that the overall discussions indicate deviating views on how to effectively address automation of ship functions.

In parallel, a joint MASS working group for the IMO’s Maritime Safety Committee (MSC), Legal Committee (LEG) and Facilitation Committee (FAL) will be established to address common high-priority issues to ensure a holistic approach.

The MASS Code may become a mandatory instrument in the future.

Ports and Maritime Organization (PMO) lodged a complaint to the International Maritime Organization (IMO) over the seizure of its tanker in Greek waters

Chief Executive of Iranian Ports and Maritime Organization (PMO) announced the strong protest of the country to the International Maritime Organization following the seizure of Iranian oil tanker by the Greek government.

While protesting against the illegal seizure of Iranian oil tanker by Greece which was done with the support of US government, Deputy Minister of Roads and Urban Development Ali Akbar Safaei said that the Greek government’s illegal action against Iranian ship is contrary to the goals and positions of the International Maritime Organization (IMO) as an international maritime authority.

Speaking with the Secretary-General of the IMO Kitack Lim, Safaei emphasized that this is not the first time that Iranian merchant ships and oil tankers have been directly or indirectly seized by the United States.

In recent years, a number of Iranian tankers have been seized by the United States and subsequently, Iranian Ports and Maritime Organization, on behalf of the Islamic Republic of Iran, lodged its complaint to the Legal Division of the International Maritime Organization (IMO), he continued.

Stating that the US actions are against the security in the seas as well as safe passage, the deputy roads minister stipulated, “Our ships and sailors have been under constant threat following harsh US sanctions. Therefore, we hope that IMO will pay special attention to this issue.”

As Iranian ship had requested emergency assistance from the Greek authorities, they, with the support of the United States, have seized the Iranian merchant and cargo ship and unloaded its cargo, he said, adding that such move is considered ‘an act of piracy’.

IMO Secretary-General, for his part, said that members of the International Maritime Organization are aware of Iran’s concern and protest against the recent events and “We are opposed to any discrimination or attack on maritime safety and security.”

Kitack Lim stated that he will bring up the issue in the upcoming meeting of IMO Assembly to find a solution.