No time to waste

Following an appeal from Intercargo, the IMO now has eased rules on hold waste water dumping when no compliant portside facilities exist, and allow – in some cases - its discharge outside designated areas, 12 miles from shore until 2016.

Euroshore fears a further delay of compliance obligation by shippers, ports and terminals will not solve problems. Even though the original MARPOL's Annex V is in force since 1988 there are still little to no cleaning agents, or receptions facilities handling and storing the hazardous hold waste waters. Today, only 82% of port facilities handling HME cargoes do not offer suitable waste reception facilities in place. And there is also little guidance as to what ships must do if no such facilities are available.

Waiting for Godot

While ports and terminals were supposed to have new facilities in place on January 1, Dry Bulk ports lament that they normally never have to receive waste water, and have no infrastructure or systems to accept, store and dispose of it. They also feel that they have had not been given the time or the necessary guidance to enable them do so. Ports also state that they do not know the type of facilities and infrastructure that will be required as the process of classifying cargoes that are environmentally harmful will not be completed until the end of 2014.

Common sense compliance protocols

However, Euroshore feels that enough information is at hand for ports to make a decisive call. The starting point is to consider the nature of the cargo carried, and the hold cleaning chemicals used. If the cargo or the chemicals used to clean the holds are harmful to the marine environment, Annex V will apply. Operators can consult the UN Globally Harmonized System for Classification and Labelling of Chemicals. The responsibility to declare whether or not the cargo is harmful lies with the shipper under the International Maritime Solid Bulk Cargoes Code.

Practical steps

Furthermore, it will not do to wait for new clauses to be created to clarify between the parties where risk falls for non-compliance with Annex V. Ports can already draft protocols to know that ship operators and shippers adhere to Annex V, and what the precise nature of the cargo and the hold cleaning chemicals used is.

The port of Zeebrugge already approaches the issue in a practical sense. It demands all harmful environmental products or dangerous substances must be reported to the port by ships at least 24 hours prior to arrival. Cargo residues and Annex I oils are taken up their Garbage Plan, and cargo residues also go to private-collectors. The organisation and costs are then carried by the receiver of the goods.

No time to waste

Euroshore feels that the clamour for more time should stop:

"We must remember that ports and terminals are already living on borrowed time. And advocate shippers, ports and terminals alike treat the IMO circular as the interim solution it is, while striving for full compliance. Declarations should be accurate and proper port reception facilities should be provided as soon as possible but in any case, within the timeline agreed by IMO." - Darren Lagea

by Darren Laguea
^{President of Euroshore}