Prevention of Air Pollution from Ships

Prevention of Air Pollution from Ships

Regulations for the Prevention of Air Pollution from Ships
were adopted in the 1997 Protocol to MARPOL 73/78
are included in Annex VI of the Convention.
The Protocol of 1997 (MARPOL Annex VI)
July 2005 amendments
Review of Annex VI
Greenhouse gases
Background on air pollution and development of the
MARPOL regulations
Information resources on prevention of air pollution from
ships

The Protocol of 1997 (MARPOL Annex VI)

The Protocol adopted in 1997 included the
new Annex VI of MARPOL 73/78, which
entered into force on 19 May 2005.
MARPOL Annex VI sets limits on sulphur
oxide and nitrogen oxide emissions from
ship exhausts and prohibits deliberate
emissions of ozone depleting substances.
The annex includes a global cap of 4.5%
m/m on the sulphur content of fuel oil and calls on IMO to
monitor the worldwide average sulphur content of fuel.
Annex VI contains provisions allowing for special SOx
Emission Control Areas (SECAS) to be established with
more stringent controls on sulphur emissions. In these
areas, the sulphur content of fuel oil used onboard ships
must not exceed 1.5% m/m. Alternatively, ships must fit
exhaust gas cleaning system or use any other technologic
method to limit SOx emissions. The Baltic Sea Area is
designated as a SOx Emission Control area in the Protocol
The North Sea was adopted as SOx Emission Control Area
July 2005.
Annex VI prohibits deliberate emissions of ozone depleting
substances, which include halons and chlorofluorocarbons
(CFCs). New installations containing ozone-depleting
substances are prohibited on all ships. But new installation
containing hydro-chlorofluorocarbons (HCFCs) are permitt
until 1 January 2020.
Annex VI also sets limits on emissions of nitrogen oxides
(NOx) from diesel engines. A mandatory NOx Technical
Code, which defines how this shall be done, was adopted
the Conference under the cover of Resolution 2.
The Annex also prohibits the incineration onboard ship of
certain products, such as contaminated packaging materia
and polychlorinated biphenyls (PCBs).
July 2005 amendments
The Marine Environment Protection Committee (MEPC) at
53rd session in July 2005 adopted amendments to MARPO
Annex VI, including one on the new North Sea SOx Emissi
Control Area (SECA). The entry into force date for the Nor
Sea SECA amendment is expected to be 22 November
2006, with its full implementation 12 months later.
The Committee noted information gained from monitoring
the worldwide sulphur content in fuel oils for 2004 which
gave a three-year (2002-2004) rolling average of sulphur
content in fuel oil worldwide of 2.67% m/m.
The MEPC adopted Guidelines on on-board exhaust gas-SO
cleaning systems; Survey Guidelines under the Harmonize
System for Survey and Certification for MARPOL Annex VI
Unified interpretations of MARPOL Annex VI; and Guidelin
for Port State Control under MARPOL Annex  VI.
The MEPC also adopted amendments to update the NOx
Technical Code.
The MEPC approved Interim Guidelines for Voluntary Ship
CO2 Emission Indexing for Use in Trials.

Review of Annex VI
At its 53rd session in July 2005, the MEPC agreed on the need to undert
review of Annex VI and the NOx Technical Code with a view to revising the regulations to take account of
current technology and the need to further reduce emissions from ships. MEPC instructed the Sub-Committee
Bulk Liquids and Gases (BLG) to carry out the review by 2007, and specifically to:

examine available and developing techniques for the

 reduction of emissions of air pollutants; review the
relevant technologies and the potential for a reduction o
NOx emissions and recommend future limits for NOx
emissions;
review technology and the need for a reduction of SOx
emissions and justify and recommend future limits for
SOx emissions;
consider the need, justification and possibility of
controlling volatile organic compounds emissions from
cargoes;
with a view to controlling emissions of particulate matte
(PM), study current emission levels of PM from marine
engines, including their size distribution and quantity,
and recommend actions to be taken for the reduction o
PM from ships. Since reduction of NOx and SOx emissio
is expected to also reduce PM emission, estimate the
level of PM emission reduction through this route;
consider reducing NOx and PM emission limits for existi
engines;
consider whether Annex VI emission reductions or
limitations should be extended to include diesel engines
that use alternative fuels and engine systems/power
plants other than diesel engines; and
review the texts of Annex VI, NOx Technical Code and
related guidelines and recommend necessary
amendments.

MEPC 56 outcome
The MEPC at its 56th session July 2007 endorsed a propos
by Secretary-General Mitropoulos to commission a
comprehensive study, by an informal cross
government/industry scientific group of experts, to review
the impact on the environment, on human health and on
the shipping and petroleum industries, of applying any of
the proposed fuel options to reduce SOx and particulate
matter generated by shipping and the consequential impa
such fuel options could have on other emissions, including
CO2 emissions from ships and refineries, taking into accou
the availability of CO2 abatement technologies.

The study will be funded by donations from Member State

and non-governmental organizations. An initial contributio
from IMO, of 20,000 US dollars, will come from the balanc
of funds from the Onassis Foundation Prize for the
Environment, which was awarded to the Organization in
1997.

The group has already begun its work with a view to

reporting to the twelfth session of the Sub-Committee on
Bulk Liquids and Gases (BLG) in February 2008 and the
MEPC in March-April 2008.

The MEPC working group on air pollution continued work o

reviewing MARPOL Annex VI and the NOx Technical Code,
following the April 2007 session of the BLG Sub-Committe
which developed a number of options for revising the
regulations in relation to the emissions of NOx, SOx, volat
organic compounds and particulate matter.

BLG 12 is expected to finalize the preparation of draft

amendments to MARPOL Annex VI, taking into account th
report of the aforementioned scientific study. The aim is t
have the draft amendments approved at MEPC 57, in the
Spring of 2008, and to adopt them at MEPC 58, in the
Autumn of 2008. The amendments to MARPOL Annex VI
could then enter into force 16 months after adoption, in
accordance with the tacit acceptance procedure stipulated
Article 16 of the MARPOL Convention.
Ships' fuel sulphur content continues downward
trend
The Committee noted the results of the ships' fuel sulphur
monitoring programme for 2006. It revealed the average
sulphur content for the year was 2.59%, a reduction from
the 2005 average of 2.70%. The three year (2004-2006)
rolling average was 2.66%, a slight reduction from the
previous year's rolling average of 2.70%.
Update of the 2000 IMO Greenhouse Gas (GHG) Stu
The MEPC confirmed the need to update the 2000 IM
GHG Study, and agreed a timeframe, scope and term
of reference for that purpose. The study, it agreed,
should cover current global inventories of GHGs and
relevant substances emitted from ships engaged in
international transport; any methodological aspects
and future emission scenarios; identify progress
made to date in reducing GHG emissions and other
substances; identify possible future measures to
reduce emissions of GHGs and undertake a cost
benefit analysis, including environmental and public
health impacts, of options for current and future
reductions in GHG emissions and other relevant
substances from international shipping. Finally, it
should identify the impact of emissions from shippin
on climate change. The aim is to submit the updated
study to the 59th session of the MEPC.

Meanwhile, the MEPC established an Intersessional

Correspondence Group on GHG Related Issues to discuss
and compile possible approaches on technical, operational
and market based measures to address GHG emissions
from ships and present a written report to MEPC 57 in
March-Arpil 2008.
MEPC 55 outcome
The Marine Environment Protection Committee (MEPC) at
55th session in October 2006 agreed a work plan, with a
timetable, to identify and develop the mechanisms needed
to achieve the limitation or reduction of carbon dioxide
(CO2) emissions from ships, noting that climate change
caused by greenhouse gas emissions from the burning of
fossil fuel is a steadily growing concern for most countries
The MEPC noted that shipping, although an environmenta
friendly and fuel-efficient mode of transport, nevertheless
needs to take action on greenhouse gases (GHG).

The work plan provides for the further development of the

CO2 Emission Indexing Scheme, with Member States and
the industry asked to continue to carry out trials in
accordance with the Interim Guidelines for Voluntary Ship
CO2 Emission Indexing for Use in Trials (MEPC/Circ.471,
issued in 2005); the consideration and evaluation of
methodology for CO2 emission baseline(s); and the consideration of technical, operational a
market-based methods for dealing with GHG emissions. The aim is to complete the work by 2008/2009.

Following discussions in the Working Group on Air Pollution, the MEPC moved forward with other issues
relating to air pollution as follows:

it agreed eight unified interpretations relating to the

  implementation and enforcement of MARPOL Annex VI,
the NOx Technical Code and related guidelines;
it approved the standard form of the Sulphur Emissions
  Control Area (SECA) Compliance Certificate to facilitate
uniform enforcement and port State control;
it approved the establishment of a correspondence
  group to develop washwater discharge criteria for
exhaust gas SOx cleaning systems;
  regarding standardization of on-shore power supply
connections with ships, it agreed that a global standard
would benefit the shipping industry but agreed to await
the finalization of such a standard before taking any
decision on its possible inclusion in the revised MARPOL
Annex VI, noting that the International Organization for
 Standardization (ISO) and the International
Electrotechnical Commission (EIC) have established a
working group on standardization of on-shore power
supply for ships at berth; and
it agreed that that co-operation between the
secretariats of the International Civil Aviation
  Organization (ICAO) and IMO should be strengthened
and that developments related to GHG emissions in bot
Organizations should be communicated to each other.

The Sub-Committee on Bulk Liquids and Gases (BLG) is

currently undertaking a comprehensive review of MARPOL
Annex VI and the NOx Technical Code and an intersession
meeting of the BLG Air Pollution Working Group was held
from 13 to 17 November 2006 in Oslo, Norway, to progres
the work further.
Sulphur monitoring
The MEPC noted the results of monitoring of the worldwid
average of sulphur content of residual fuel oils, which
indicated that in 2005, almost 90% of the samples had
sulphur contents between 1.5 and 4% m/m. Almost 50%
was between 2 and 3% m/m. 219 out of 79,592 (0.3%) o
the samples were over 4.5% m/m sulphur, and 5 samples
contained more than 5% sulphur (compared to 7 samples
2004). The sulphur content of residual fuel measured for
2003, 2004 and 2005 gave a three year rolling average fo
the period of 2.7%. The rolling average for 2002-2004 wa
2.67%.
MEPC 54 outcome
At its 54th session in March 2006, a working group was
established to consider issues relating to the prevention o
air pollution from ships, including follow-up action to the
IMO Policies and practices related to the reduction of
greenhouse gas emissions from ships (resolution
A.963(23)).

Following the work by the group, the MEPC approved two

circulars aimed at assisting implementation of MARPOL
Annex VI:

1.     The MEPC Circular on Bunker Delivery Note and Fuel

Oil Sampling, to clarify how to comply with regulation 18,
which places requirements on ship owners and fuel oil
suppliers in respect of bunker delivery notes and
representative samples of the fuel oil received and on
Parties to the 1997 Protocol to regulate the bunker
suppliers in their ports. The circular urges all Member
States, both Parties and non-Parties to the 1997 Protocol,
to require fuel oil suppliers in their ports to comply with th
requirements and to raise awareness of the necessity to
enhance implementation and enforcement of regulation 18
of Annex VI.

2.     The MEPC circular on Notification to the Organization

on ports or terminals where volatile organic compounds
(VOCs) emissions are to be regulated, which notes that
regulation 15 of Annex VI requires Parties to inform the
Organization of their intention to introduce requirements f
the use of vapour emission control systems and to notify
the Organization of ports and terminals under their
jurisdiction where such requirements are already in force.
However, many terminals are implementing or operating
such practices without notification to the Organization. Th
Committee shared the concern that, since there is no
circulation of such information, it is difficult for owners an
operators to prepare for these changes at ports and
terminals. The circular reiterates that Parties to the 1997
Protocol are required to notify the Organization without
delay with information on ports and terminals under their
jurisdiction at which VOCs emissions are or will be
regulated, and on requirements imposed on ships calling a
these ports and terminals. Any information received by th
Organization on the availability of vapour emission contro
systems will be circulated through MEPC circulars so that
owners and operators will have up to-date information on
current and future requirements for the utilization of such
systems.

As instructed by MEPC 53, the Sub-Committee on Bulk

Liquids and Gases (BLG) will undertake a review of MARPO
Annex VI and the NOx Technical Code with a view to
revising the regulations to take account of current
technology and the need to further reduce air pollution fro
ships. The progress of this work will be reported to the ne
session of the MEPC.

The Committee and its Working Group on Air Pollution had

long and extensive debates on how to follow up resolution
A.963(23) on IMO Policies and Practices related to the
Reduction of Greenhouse Gas Emissions from Ships. By th
resolution, the Assembly urged MEPC to identify and
develop the necessary mechanisms needed to achieve the
limitation or reduction of GHG emissions from internationa
shipping. Among the items considered was whether only
emission of CO2 or of all six greenhouse gases identified b
the Kyoto Protocol should be included. The MEPC agreed t
consider the follow-up actions to resolution A.963(23) in a
technical and methodological perspective and to
concentrate the work on CO2 emissions. The Committee
also agreed to continue the work at the next session and,
particular, to consider further a draft work plan to identify
and develop the mechanisms needed to achieve the goal s
by the Assembly.
Greenhouse gases
In November 2003, IMO adopted resolution A.963(23)
Policies and practices related to the reduction of
greenhouse gas emissions from ships.
At its 52nd session in October 2004, the Marine
Environment Protection Committee (MEPC) made progress
on developing draft Guidelines on the CO2 Indexing Schem
and urged Members to carry out trials using the scheme
and to report to the next session. One purpose of
developing guidelines on CO2emission indexing is to devel
a simple system that could be used voluntarily by ship
operators during a trial period.
The Committee agreed that a CO2 indexing scheme should
be simple and easy to apply and take into consideration
matters related to construction and operation of the ship,
and market based incentives. At its 53rd session in July
2005, the MEPC approved Interim Guidelines for Voluntary
Ship CO2 Emission Indexing for Use in Trials.
Meanwhile, the Committee recognized that IMO guidelines
on greenhouse gas emissions have to address all six
greenhouse gases covered by the Kyoto Protocol (Carbon
dioxide (CO2); Methane (CH4); Nitrous oxide (N2O);
Hydrofluorocarbons (HFCs); Perfluorocarbons (PFCs); and
Sulphur hexafluoride (SF6).
The MEPC at its 56th session July 2007 confirmed the nee
to update the 2000 IMO GHG Study, and agreed a
timeframe, scope and terms of reference for that purpose
(the 2000 GHG study may be found here). The study, it
agreed, should cover current global inventories of GHGs a
relevant substances emitted from ships engaged in
international transport; any methodological aspects and
future emission scenarios; identify progress made to date
reducing GHG emissions and other substances; identify
possible future measures to reduce emissions of GHGs an
undertake a cost benefit analysis, including environmenta
and public health impacts, of options for current and futur
reductions in GHG emissions and other relevant substance
from international shipping. Finally, it should identify the
impact of emissions from shipping on climate change. The
aim is to submit the updated study to the 59th session of
the MEPC.

Meanwhile, the MEPC established an Intersessional

Correspondence Group on GHG Related Issues to discuss
and compile possible approaches on technical, operational
and market based measures to address GHG emissions
from ships and present a written report to MEPC 57 in
March-Arpil 2008.
Background on air pollution
The issue of controlling air pollution form ships - in
particular, noxious gases from ships' exhausts - was
discussed in the lead up to the adoption of the 1973
MARPOL Convention. However, it was decided not to inclu
regulations concerning air pollution at the time.
Meanwhile, air pollution was being discussed in other
arenas. The 1972 United Nations Conference on the Huma
Environment in Stockholm marked the start of active
international cooperation in combating acidification, or aci
rain. Between 1972 and 1977, several studies confirmed t
hypothesis that air pollutants could travel several thousan
kilometres before deposition and damage occurred. This
damage includes effects on crops and forests.
Most acid rain is caused by airborne deposits of sulphur
dioxides and nitrogen oxides. Coal and oil-burning power
plants are the biggest source of sulphur dioxides while
nitrogen oxides come from car, truck - and ship - exhaust
In 1979, a ministerial meeting on the protection of the
environment, in Geneva, resulted in the signing of the
Convention on Long-range Transboundary Air Pollution by
34 governments and the European Community. This was
the first international legally binding instrument to deal wi
problems of air pollution on a broad regional basis.
Protocols to this Convention were later signed on reducing
sulphur emissions (1985); controlling emissions of nitroge
oxides (1988); controlling emissions of volatile organic
compounds (1991) and further reducing sulphur emission
(1994).
During the 1980s, concern over air pollution, such as glob
warming and the depleting of the ozone layer, continued t
grow, and in 1987 the Montreal Protocol on substances th
Deplete the Ozone Layer was signed.
The Montreal Protocol is an international environmental
treaty, drawn up under the auspices of the United Nations
under which nations agreed to cut consumption and
production of ozone-depleting substances including
chlorofluorocarbons (CFCs) and halons in order to protect
the ozone layer.
A Protocol was adopted in London in 1990 - amending the
original protocol and setting the year 2000 as the target
completion date for phasing out of halons and ozone-
depleting CFCs. A second Protocol was adopted in
Copenhagen in 1992, introducing accelerated phase-out
dates for controlled substances, cutting short the use of
transitional substances and the introduction of phase-out
dates for HCFCs and methyl bromide(a pesticidal gas whic
depletes the ozone layer).
CFCs have been in widespread use since the 1950s as
refrigerants, aerosol propellants, solvents, foam blowing
agents and insulants. In shipping, CFCs are used to
refrigerate ship and container cargo, insulate cargo holds
and containers, air condition crew quarters and occupied
areas and refrigerate domestic food storage compartment
Halons, manufactured from CFCs, are effective fire
extinguishers used in portable fire extinguishers and fixed
fire prevention systems.
IMO begins work on air pollution
At IMO, the Marine Environment Protection Committee
(MEPC) in the mid-1980s had been reviewing the quality o
fuel oils in relation to discharge requirements in Annex I
and the issue of air pollution had been discussed.
In 1988, the MEPC agreed to include the issue of air
pollution in its work programme following a submission fro
Norway on the scale of the problem. In addition, the Seco
International Conference on the Protection of the North Se
held in November 1987, had issued a declaration in which
the ministers of North Sea states agreed to initiate actions
within appropriate bodies, such as IMO, "leading to
improved quality standards of heavy fuels and to actively
support this work aimed at reducing marine and
atmospheric pollution."
At the next MEPC session, in March 1989, various countrie
submitted papers referring to fuel oil quality and
atmospheric pollution, and it was agreed to look at the
prevention of air pollution from ships - as well as fuel oil
quality - as part of the committee's long-term work
programme, starting in March 1990.
In 1990, Norway submitted a number of papers to the ME
giving an overview on air pollution from ships. The papers
noted:
Sulphur emissions from ships' exhausts were estimated
4.5 to 6.5 million tons per year - about 4 percent of total
global sulphur emissions. Emissions over open seas are
spread out and effects moderate, but on certain routes th
emissions create environmental problems, including Englis
Channel, South China Sea, Strait of Malacca.
Nitrogen oxide emissions from ships were put at aroun
5 million tons per year - about 7 percent of total global
emissions. Nitrogen oxide emissions cause or add to
regional problems including acid rain and health problems
local areas such as harbours.
Emissions of CFCs from the world shipping fleet was
estimated at 3,000-6,000 tons - approximately 1 to 3
percent of yearly global emissions. Halon emissions from
shipping were put at 300 to 400 tons, or around 10 perce
of world total.
Adoption of resolution
Discussions in the MEPC and drafting work by a working
group, led to the adoption in 1991, of an IMO Assembly
Resolution A.719(17) on Prevention of Air Pollution
from Ships.
The Resolution called on the MEPC to prepare a new draft
Annex to MARPOL 73/78 on prevention of air pollution.
The new draft Annex was developed over the next six yea
- and was finally adopted at a Conference in September
1997. It was agreed to adopt the new Annex through
adding a Protocol to the MARPOL 73/78 Convention, which
included the new Annex. This enabled specific entry into
force conditions to be set out in the protocol.
 
 
 

The Protocol of 1997 (Annex VI - Regulations for

the Prevention of Air Pollution from Ships)
Adoption: 26 September 1997
Entry into force: 19 May 2005

The Protocol was adopted at a Conference held from

15 to 26 September 1997 and adds a new Annex VI on
Regulations for the Prevention of Air Pollution
from Ships to the Convention.

The rules set limits on sulphur oxide (SOx) and

nitrogen oxide (NOx) emissions from ship exhausts
and prohibit deliberate emissions of ozone depleting
substances.

The new Annex VI includes a global cap of 4.5% m/m

on the sulphur content of fuel oil and calls on IMO to
monitor the worldwide average sulphur content of fuel
once the Protocol comes into force.

Annex VI contains provisions allowing for special  "SOx

Emission Control Areas" to be established with more
stringent control on sulphur emissions. In these areas,
the sulphur content of fuel oil used on board ships
must not exceed 1.5% m/m. Alternatively, ships must
fit an exhaust gas cleaning system or use any other
technological method to limit SOx emissions.

The Baltic Sea is designated as a SOx Emission Control

area in the Protocol.

Annex VI prohibits deliberate emissions of ozone

depleting substances, which include halons and
chlorofluorocarbons (CFCs). New installations
containing ozone-depleting substances are prohibited
on all ships. But new installations containing hydro-
chlorofluorocarbons (HCFCs) are permitted until
1 January 2020.

The requirements of the IMO Protocol are in

accordance with the Montreal Protocol of 1987, as
amended in London in 1990. The Montreal Protocol is
an international environmental treaty, drawn up under
the auspices of the United Nations, under which
nations agreed to cut CFC consumption and production
in order to protect the ozone layer.

Annex VI sets limits on emissions of nitrogen oxides

(NOx) from diesel engines. A mandatory NOx Technical
Code, developed by IMO, defines how this is to be
done.

The Annex also prohibits the incineration on board ship

of certain products, such as contaminated packaging
materials and polychlorinated biphenyls (PCBs).
Format of Annex VI

Annex VI consists of three Chapters and a number of

Appendices:

   Chapter 1 - General
Chapter II - Survey, Certification and Means of
 
Control
Chapter III - Requirements for Control of Emissions
 
from Ships
Appendices, including the form of the International
Air Pollution Prevention Certificate; criteria and
procedures for designation of SOx emission control
areas; information for inclusion in the bunker
  delivery note; approval and operating limits for
shipboard incinerators; test cycles and weighting
factors for verification of compliance of marine
diesel engines with the NOx limits; and details of
surveys and inspections to be carried out.