Confusion Surrounds Wastewater Discharge Rules

Confusion surrounding the entry into force date of MEPC 227(64), the amended regulation governing ship wastewater discharge overboard requirements, could see some shipowners falling foul of the new rules.

Mark Beavis, the Managing Director of ACO Marine, a supplier of MEPC.227(64) compliant wastewater treatment systems, believes that any further delay from the IMO’s Marine Environment Protection Committee (MEPC) in formally announcing a new date will create further confusion.

“A number of shipowners believe the deferred entry into force applies to MEPC.227(64) in its entirety, but this is not our understanding. The International Maritime Organisation, at its MEPC 68 postponed only the entry-into-force date of the ‘Special Area’ sewage discharge requirements. The rest of the regulation still remains very much in force.”

Apart from the Special Area clause – Section 4.2 for passenger ships (>12 passengers) – MEPC.227(64) came into effect on the 1st January this year, superseding MEPC.159(55).

According to a statutory update published in the December 2015 issue of Lloyd’s Register’s Class News:  “Entry into force of MARPOL Annex IV requirements prohibiting passenger vessels from discharging sewage within the Baltic Sea special area (and any future IMO designated Special Areas was intended to apply to new passenger ships from 1 January, 2016. However, a delay in arranging and/or confirming reception facilities in the nine Baltic Sea States means that the special area cannot take effect on this date. Therefore, the IMO’s MEPC has agreed in principle (i.e. without formally amending MARPOL Annex IV yet) to implement the requirements from 1 June, 2019 (and from 1 June, 2021, for existing ships). Ships other than passenger vessels must still comply with the Resolution MEPC.227(64) performance test and standard requirements (excluding the nitrogen and phosphorus removal standard) on or after 1 January, 2016, though this is subject to final confirmation at MEPC 69 [in April].”

“I don’t believe that IMO has made any formal announcement about the June 2019 and June 2021 dates, so the industry is still in the dark on this,” said Beavis. “Nevertheless, passenger ship owners operating in ‘Special Areas’ should not use IMO’s postponement to defer the installation of MEPC.227(64) [including Section 4.2] compliant treatment plant.

“Currently the Baltic Sea is the only IMO designated Special Area, but other areas are applying for special area status and so there would potentially be a wider impact on passenger ship operations. Owners and yards really do need to start specifying plant now if they are to comply with the new rules in time,” he added.