Published: 1 August 2016

At the recent 69th session of the IMO’s Environment Protection Committee (MEPC 69) it was decided not to renew or continue the provisions of MEPC.1/Circ 810 (the circular).  The circular permitted the discharge of cargo hold wash containing residues of solid bulk cargoes considered as harmful to the marine environment (HME) in certain special areas, a practice that would usually not be allowed.  The exemption expired on 31 December 2015.  This exemption was originally made to acknowledge the fact that shipowners were having difficulty finding adequate reception facilities ashore at receiving terminals for HME residues.

This issue was highlighted in a report from INTERCARGO which drew attention to the fact that this decision not to re-new the exception was taken despite the fact that  it  is generally accepted that adequate port reception facilities (PRF) to receive HME residues are still not available. INTERCARGO also noted that during informal discussion with the International Association of Ports and Harbours (IAPH) on the subject of reception facilities for HME cargo residues, many ports said they were not considering developing such facilities as it would simply not be economical.

A cargo is considered as HME if it fails any of seven specified criteria, as set out in  the UN Globally Harmonized System of Classification and Labelling of Chemicals (UN GHS) as the following :  acute toxicity, chronic toxicity, carcinogenicity, mutagenicity, reproductive toxicity, repeated exposure of specific target organ toxicity [STOT] and the presence of plastics, rubber or synthetic polymers.  In general, HME cargoes may be taken as any of the metal concentrate shipped in bulk.??   It is the shipper’s obligation to verify whether or not any cargo may be considered HME and this should be clearly identified in the shipper’s cargo declaration which is required under SOLAS.

INTERCARGO recommends that before accepting a HME cargo it should be made clear that the charterer accepts all costs arising from the landing of dry residues and washing water containing such residues and also any delays or off-hire incurred due to a lack of reception facilities in the scheduled discharge port or next port of call.

One of the objections of those IMO member states which opposed the continuation of circular 810 was that no official notifications had been made to the IMO regarding the lack of adequate PRF.  INTERCARGO believes that it is important that ships report to the IMO and to their flag state all instances when difficulties are found landing HME cargo residues. There is a standard format to make such notifications which is contained in MEPC.1/Circ.834.