PART III OF THE SEEMP - SHIP OPERATIONAL CARBON INTENSITY PLAN

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2022-09-04
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General

The Carbon Intensity Indicator (CII) is a rating system for ships that the International Maritime Organization (IMO) developed. This will be a mandatory measure under MARPOL Annex VI, which comes into force in 2023.

The measure will impact all following mentioned vessels above 5,000 gross tonnage (GT) and trading internationally.

Bulk carrier,
Gas carrier (LPG carrier),
Tanker,
Containership,
General cargo ship,
Refrigerated cargo carrier,
Combination carrier,
Ro-ro cargo ships (Vehicle carrier),
Ro-ro cargo ship,
Ro-ro passenger ship,
LNG carrier,
Cruise passenger ship,

The SEEMP shall include:

a description of the methodology that will be used to calculate the ship's attained annual operational CII required by regulation 28 of MARPOL Annex VI and the processes that will be used to report this value to the ship's Administration;
the required annual operational CIIs, as specified in regulation 28 of MARPOL Annex VI, for the next three years;
an implementation plan documenting how the required annual operational CIIs will be achieved during the next three years; and
a procedure for self-evaluation and improvement.

The required annual operational CII is to be calculated in accordance with regulation 28 and taking into account the guidelines developed by the Organization.

In addition, pursuant to regulation 28 of MARPOL Annex VI, part III of the SEEMP is further to include calculation methodologies and a plan of corrective actions for ships that are rated D for three consecutive years or rated as E.

The ship's attained annual operational carbon intensity is to be calculated taking into account the guidelines developed by the Organization.

Ships of 5,000 gross tonnage and above that are subject to regulations 26.3 and 28 of MARPOL Annex VI are strongly encouraged to review part I of their SEEMP to revise it as needed to reflect the actions taken to achieve the ship's CII requirements.

The goal setting, as referred to in paragraph 4.1.7 in part I, should be consistent with the requirements of regulation 28 of MARPOL Annex VI and should include the ship's required annual operational CII for the next three years following the updating of the SEEMP.

In addition, while ships subject to regulation 28 of MARPOL Annex VI may relay on the CII requirements when defining goals under part I of the SEEMP, they are encouraged to consider setting additional ship-specific goals that go beyond the applicable CII requirements and strive for energy efficiency improvements and carbon intensity reductions beyond such requirements.

A standardized data reporting format for the parameters to calculate the trial carbon intensity indicators on a voluntary basis is presented here.

Part III of the ship's SEEMP should be updated in case of voluntary modifications or necessary corrective actions are involved (every three years).

Attained annual operational cii calculation methodology; data collection plan and

Data quality

Taking into account the guidelines developed by the Organization, part III of the SEEMP provides detailed information on how the ship's attained annual operational CII should be calculated. Regulation 28 of MARPOL Annex VI states that the attained annual operational CII shall be calculated, using the data collected in accordance with regulation 27 (Fuel Oil Data Collection System).

In describing the calculation methodology, part III of the SEEMP should include a detailed description of the data required for the calculation of the attained annual operational CII. The data collection should follow the relevant methodology and requirements on the Fuel Oil Data Collection System pursuant to regulation 27 of MARPOL Annex VI (see part II of these Guidelines).

In case of transfer of the ship from one company to another according to regulation 27.5 or 27.6 of MARPOL Annex VI, all relevant data necessary for the calculation of the attained annual operational CII should be submitted by the former company to the receiving company within one month after the date of transfer. The data should have been verified by the Administration or any organization duly authorized by it according to regulation 6.7 of MARPOL Annex VI before they are transferred to the receiving company. The format of the transfer should be consistent with here and such that the receiving company can use it in the calculations of the attained annual operational CII for the whole year in which the transfer takes place.

In case the former company does not transfer the required data, the Administration may make relevant data submitted to the IMO Fuel Oil Consumption Database available to the receiving company. In case of a transfer of both company and Administration concurrently, the incoming Administration may make a request to the Organization for access to the data according to regulation 27.11. If no such data is available, the attained annual operational CII can be calculated and verified using the available data covering a period of the preceding calendar year as long as practically possible.

In case of transfer of a ship from one Administration to another according to regulation 27.4 of MARPOL Annex VI the data needed for calculating the annual attained CII is already in the possession of the relevant company and no further exchange of data is needed.

Required annual operational CII for next three years

Part III of the SEEMP describes the required annual operational CII values for the ship for each of the next three years, calculated in accordance with regulation 28 of MARPOL Annex VI and taking into account the guidelines developed by the Organization, as the basis for those calculations.

Three-year implementation plan

The three-year implementation plan describes the measures the ship plans to take to continue to achieve the required annual operational CII over the next three-year period.

The three-year implementation plan is ship-specific.

The three-year implementation plan should be SMART (Specific, Measurable, Achievable, Realistic, and Time bound) to the extent envisaged and feasible. It should include:

a list of measures that improve the energy efficiency and reduce the carbon intensity of the ship, with time and method of implementation necessary for achieving the required operational CII;
a description of how, when the listed measures are implemented, the required operational CII will be achieved, taking into consideration the combined effect of the measures on operational carbon intensity;
the company personnel responsible for the three-year implementation plan, and for monitoring and recording performance throughout the year for the reviewing of the effectiveness of the three-year implementation plan; and
Identification of possible impediments to the effectiveness of the measures for improving the energy efficiency and reducing the carbon intensity of the ship, including possible contingency measures put in place to overcome these impediments.

The three-year implementation plan should be monitored and adjusted when necessary, and the data to be monitored, identified.

Process for self-evaluation and improvement

The purpose of self-evaluation is to evaluate the effectiveness of the planned measures and their

implementation, to deepen the understanding of the overall characteristics of the ship's operation, such as what types of measures can function effectively, and how or why, to comprehend the trend of the efficiency improvement of that ship, to understand trends in the ship's utilization in terms of cargo carried and areas of operation, and to develop an improved action plan for the next cycle. This evaluation should produce meaningful feedback based on experience in the previous period, to enhance performance in the next period.

Procedures for self-evaluation of the ship's energy usage and carbon intensity should be developed and included in this section of the SEEMP. Self-evaluation should be carried out periodically based on data collected through monitoring. It is recommended that the cause and effect of the ship's performance in the evaluated period be identified in order to identify measures for improving performance during the next period.

The process of self-evaluation and improvement could consist of the following elements:

regular internal shipboard and company audits to verify implementation and the effectiveness of the system;
improvement, i.e. implementing preventive or modifying measures (responsible personnel within the company should evaluate such audit reports and implement corrective actions including preventive or modifying measures); and
periodical review of the SEEMP and associated documents, to update the SEEMP in a manner which minimizes any administrative and unnecessary burdens on company's personnel and ship's staff.

The content of the self-evaluation and improvement could include the following elements:

criteria for evaluation, including elements to evaluate, such as quality of monitoring, record-keeping, effectiveness of implemented measures (including cause and effect) and achievement of the goal;
the evaluation of the effectiveness of the different measures taken, in terms of energy efficiency and carbon intensity;
which measures contribute the most and how much, which measures do not contribute and are therefore not efficient, which ship and/or company-specific elements adversely affect the CII and how these could be improved;
timeline for starting the review process ahead of the end of the compliance period and for implementation of new measures in the subsequent year;
measures identified to address deficiencies and discrepancies including correction of data gaps and system weaknesses, new measures to improve implementation (e.g. training) as well as new carbon intensity improvement measures as needed;
where relevant, actions that will be taken to bring the ship into better CII ratings including estimated quantification of the additional expected reduction in carbon intensity;
where applicable, if a plan of corrective actions is required, the plan should include items listed under 15.4.5 to bring the ship out of inferior performance; and
where relevant, identification of critical factors that contributed to missing the CII target.

Review and update of part III of the SEEMP

Regulation 26.1 of MARPOL Annex VI provides: "Each ship shall keep on board a ship-specific Ship Energy Efficiency Management Plan (SEEMP). This may form part of the ship's safety management system. The SEEMP shall be developed and reviewed, taking into account guidelines adopted by the Organization". Regulation 26.3.2 of MARPOL Annex VI provides: "For ships rated as D for three consecutive years or rated as E, in accordance with regulation 28 of this Annex, the SEEMP shall be reviewed in accordance with regulation 28.8 of this Annex to include a plan of corrective actions to achieve the required annual operational CII".

The company should ensure that the SEEMP is reviewed and updated when necessary.

The SEEMP should include a log for when it has been reviewed and updated and identify which parts have been changed.

Plan of corrective actions

A plan of corrective actions is not required to be included in the SEEMP unless a ship has been rated D for three consecutive years or E for one year.

For a ship that is required to develop a plan of corrective actions in accordance with regulation 28.7 of

MARPOL Annex VI, a revised SEEMP including the corrective actions for CII reduction shall be submitted to the Administration or any organization duly authorized by it for verification in accordance regulation 28.8 of MARPOL Annex VI. The revised SEEMP should be submitted together with, but in no case later than one month after reporting the attained annual operational CII in accordance with regulation 28.2.

Regulation 28.9 of MARPOL Annex VI further provides that "A ship rated as D for three consecutive years or rated as E shall duly undertake the planned corrective actions in accordance with the revised SEEMP."

Developing the plan of corrective actions

The purpose of the plan of corrective actions is to set out what actions a ship that was rated D for three consecutive years or E for one year should take to achieve at least a C rating for the calendar year following the adoption of the plan of corrective actions and ultimately the required annual operational CII.

The plan of corrective actions is ship-specific.

The plan for corrective action should describe the actions that the ship plans to take, the timeline in which those actions will be applied, and the expected impact their application will have on the ship's CII rating. It should be demonstrated how the corrective actions will contribute to achieving the required annual operational CII, so as to ascertain the effectiveness of the corrective actions. Experience gained from previously taken corrective actions and their degree of effectiveness should be taken into account when selecting the proper corrective actions.

The plan of corrective actions should be SMART (Specific, Measurable, Achievable, Realistic, and Time bound). It should include:

an analysis of the cause of the inferior CII rating;
an analysis of the performance of implemented measures;
a list of additional measures and revised measures to be added to the implementation plan with time and method of implementation necessary for achieving the required operational CII;
designation of a company person to be responsible for the added and revised measures in the implementation plan, monitoring and recording performance throughout and reviewing of the effectiveness of the corrective actions; and
identification of possible impediments to the effectiveness of the measures for improving the energy efficiency and reducing the carbon intensity of the ship, including possible additional contingency measures put in place to overcome and how these impediments will be overcome.

The implementation of the plan of corrective actions should be monitored and adjusted when necessary. Additional measures should be taken to strengthen corrective actions in case of insufficient intermediate results.

The company should ensure that it is in a position to perform the actions set out in the plan of corrective actions and confirm that it is able to do so when submitting its updated SEEMP.

General

Regulation 26.3.1 of MARPOL Annex VI specifies that, for certain categories of ships of 5,000 GT and above, on or before 1 January 2023, the SEEMP shall include:

a description of the methodology that will be used to calculate the ship's attained annual operational CII required by regulation 28 of MARPOL Annex VI and the processes that will be used to report this value to the ship's Administration;
the required annual operational CIIs, as specified in regulation 28 of MARPOL Annex VI, for the next three years;
an implementation plan documenting how the required annual operational CIIs will be achieved during the next three years; and
a procedure for self-evaluation and improvement.

The required annual operational CII is to be calculated in accordance with regulation 28 and taking into account the guidelines developed by the Organization.

The ship's attained annual operational carbon intensity is to be calculated taking into account the guidelines developed by the Organization.

A standardized data reporting format for the parameters to calculate the trial carbon intensity indicators on a voluntary basis is presented here.

Part III of the ship's SEEMP should be updated in case of voluntary modifications or necessary corrective actions are involved (every three years).

Attained annual operational cii calculation methodology; data collection plan and

Data quality

Required annual operational CII for next three years

Three-year implementation plan

The three-year implementation plan describes the measures the ship plans to take to continue to achieve the required annual operational CII over the next three-year period.

The three-year implementation plan is ship-specific.

The three-year implementation plan should be SMART (Specific, Measurable, Achievable, Realistic, and Time bound) to the extent envisaged and feasible. It should include:

a list of measures that improve the energy efficiency and reduce the carbon intensity of the ship, with time and method of implementation necessary for achieving the required operational CII;
a description of how, when the listed measures are implemented, the required operational CII will be achieved, taking into consideration the combined effect of the measures on operational carbon intensity;
the company personnel responsible for the three-year implementation plan, and for monitoring and recording performance throughout the year for the reviewing of the effectiveness of the three-year implementation plan; and
Identification of possible impediments to the effectiveness of the measures for improving the energy efficiency and reducing the carbon intensity of the ship, including possible contingency measures put in place to overcome these impediments.

The three-year implementation plan should be monitored and adjusted when necessary, and the data to be monitored, identified.

Process for self-evaluation and improvement

The purpose of self-evaluation is to evaluate the effectiveness of the planned measures and their

The process of self-evaluation and improvement could consist of the following elements:

regular internal shipboard and company audits to verify implementation and the effectiveness of the system;
improvement, i.e. implementing preventive or modifying measures (responsible personnel within the company should evaluate such audit reports and implement corrective actions including preventive or modifying measures); and
periodical review of the SEEMP and associated documents, to update the SEEMP in a manner which minimizes any administrative and unnecessary burdens on company's personnel and ship's staff.

The content of the self-evaluation and improvement could include the following elements:

criteria for evaluation, including elements to evaluate, such as quality of monitoring, record-keeping, effectiveness of implemented measures (including cause and effect) and achievement of the goal;
the evaluation of the effectiveness of the different measures taken, in terms of energy efficiency and carbon intensity;
which measures contribute the most and how much, which measures do not contribute and are therefore not efficient, which ship and/or company-specific elements adversely affect the CII and how these could be improved;
timeline for starting the review process ahead of the end of the compliance period and for implementation of new measures in the subsequent year;
measures identified to address deficiencies and discrepancies including correction of data gaps and system weaknesses, new measures to improve implementation (e.g. training) as well as new carbon intensity improvement measures as needed;
where relevant, actions that will be taken to bring the ship into better CII ratings including estimated quantification of the additional expected reduction in carbon intensity;
where applicable, if a plan of corrective actions is required, the plan should include items listed under 15.4.5 to bring the ship out of inferior performance; and
where relevant, identification of critical factors that contributed to missing the CII target.

Review and update of part III of the SEEMP

The company should ensure that the SEEMP is reviewed and updated when necessary.

The SEEMP should include a log for when it has been reviewed and updated and identify which parts have been changed.

Plan of corrective actions

A plan of corrective actions is not required to be included in the SEEMP unless a ship has been rated D for three consecutive years or E for one year.

For a ship that is required to develop a plan of corrective actions in accordance with regulation 28.7 of

Developing the plan of corrective actions

The plan of corrective actions is ship-specific.

The plan of corrective actions should be SMART (Specific, Measurable, Achievable, Realistic, and Time bound). It should include:

an analysis of the cause of the inferior CII rating;
an analysis of the performance of implemented measures;
a list of additional measures and revised measures to be added to the implementation plan with time and method of implementation necessary for achieving the required operational CII;
designation of a company person to be responsible for the added and revised measures in the implementation plan, monitoring and recording performance throughout and reviewing of the effectiveness of the corrective actions; and
identification of possible impediments to the effectiveness of the measures for improving the energy efficiency and reducing the carbon intensity of the ship, including possible additional contingency measures put in place to overcome and how these impediments will be overcome.

The company should ensure that it is in a position to perform the actions set out in the plan of corrective actions and confirm that it is able to do so when submitting its updated SEEMP.

SAMPLE FORM OF SHIP OPERATIONAL CARBON INTENSITY PLAN (PART III OF THE SEEMP)

STANDARDIZED DATA REPORTING FORMAT FOR THE PARAMETERS TO CALCULATE THE TRIAL CARBON INTENSITY INDICATORS ON VOLUNTARY BASIS

Background

Anti-fouling paints are used to coat the bottoms of ships to prevent sea life such as algae and mollusks attaching themselves to the hull – thereby slowing down the ship and increasing fuel consumption.

The new Convention defines “anti-fouling systems” as “a coating, paint, surface treatment, surface or device that is used on a ship to control or prevent attachment of unwanted organisms”.

In the early days of sailing ships, lime and later arsenic were used to coat ships' hulls, until the modern chemicals industry developed effective anti-fouling paints using metallic compounds.

These compounds slowly "leach" into the sea water, killing barnacles and other marine life that have attached to the ship. But the studies have shown that these compounds persist in the water, killing sea life, harming the environment and possibly entering the food chain.

One of the most effective anti-fouling paints, developed in the 1960s, contains the organotin tributylin (TBT), which has been proven to cause deformations in oysters and sex changes in whelks.

The adoption of the new Convention marked the successful outcome of the task set by Chapter 17 of Agenda 21 developed by the 1992 Rio Conference on Environment and Development. Chapter 17 called on States to take measures to reduce pollution caused by organotin compounds used in anti-fouling systems.

Agenda 21 sets out a plan of action to guarantee that life in the next millennium will change substantially for the better. It was endorsed by the world's governments at the UN Conference on Environment and Development, in Rio de Janeiro, on June 1992.

The harmful environmental effects of organotin compounds were recognized by IMO in 1989. In 1990 IMO’s Marine Environment Protection Committee (MEPC) adopted a resolution which recommended that Governments adopt measures to eliminate the use of anti-fouling paint containing TBT on non-aluminum hulled vessels of less than 25 meters in length and eliminate the use of anti-fouling paints with a leaching rate of more than four micrograms of TBT per day.

In November 1999, IMO adopted an Assembly resolution that called on the MEPC to develop an instrument, legally binding throughout the world, to address the harmful effects of anti-fouling systems used on ships. The resolution called for a global prohibition on the application of organotin compounds which act as biocides in anti-fouling systems on ships by 1 January 2003, and a complete prohibition by 1 January 2008.

This instrument was later adopted as the International Convention on the Control of Harmful Anti-Fouling Systems on Ships.

The International Convention on the Control of Harmful Anti-Fouling Systems on Ships, which was adopted on 5 October 2001, will prohibit the use of harmful organotin compounds in anti-fouling paints used on ships and will establish a mechanism to prevent the potential future use of other harmful substances in anti-fouling systems. The Convention entered into force on 17 September 2008.

Under the terms of the Convention, Parties to the Convention are required to prohibit and/or restrict the use of harmful anti-fouling systems on ships flying their flag, as well as ships not entitled to fly their flag but which operate under their authority and all ships that enter a port, shipyard or offshore terminal of a Party.

Annex 1 attached to the Convention states that by an effective date of 1 January 2003, all ships shall not apply or re-apply organotin compounds which act as biocides in anti-fouling systems, and by 1 January 2008 (effective date), ships either:

shall not bear such compounds on their hulls or external parts or surfaces; or
shall bear a coating that forms a barrier to such compounds leaching from the underlying non-compliant anti-fouling systems.

This applies to all ships (except fixed and floating platforms, floating storage units (FSUs), and floating production storage and off-loading units (FPSOs) that have been constructed prior to 1 January 2003 and that have not been in dry-dock on or after 1 January 2003).

Ships of above 400 gross tonnages and above engaged in international voyages (excluding fixed or floating platforms, FSUs and FPSOs) will be required to undergo an initial survey before the ship is put into service or before the International Anti-Fouling System Certificate is issued for the first time; and a survey when the anti-fouling systems are changed or replaced.

Ships of 24 meters or more in length but less than 400 gross tonnage engaged in international voyages (excluding fixed or floating platforms, FSUs and FPSOs) will have to carry a Declaration on Anti-Fouling Systems signed by the owner or authorized agent. The Declaration will have to be accompanied by appropriate documentation such as a paint receipt or contractor invoice.

At its seventy-first session in July 2017, MEPC approved a new output to amend Annex 1 to the AFS Convention to include controls on cybutryne. While work on this matter is ongoing in the Sub-Committee on Pollution Prevention and Response (PPR), the scientific data presented so far indicates that cybutryne causes significant adverse effects to the environment, especially to aquatic ecosystems.

Ban on use of Anti-Fouling Systems that contains Cybutryne

New AFS Convention’s amendment

IMO adopted amendments to the AFS Convention vide Resolution MEPC 331 (76) to include controls on Cybutryne and an operative paragraph with respect to issuance of the new International Anti-Fouling System Certificate. The amendments will enter into force on 1 January 2023. The amendment prohibits application or re-application of anti-fouling systems containing Cybutryne or Irgarol (CAS No. 28159-98-0) on all ships from 1 January 2023.

CONTROLS ON ANTI-FOULING SYSTEMS

Ship owners/ managers and masters are advised to take note of above requirements and accordingly ensure that necessary planning is done while procuring anti-fouling paints so that it does not contain Cybutryne. In case of ships where anti-fouling system already contains Cybutryne (CAS No. 28159-98-0) as on 1 January 2023, planning will be required for either the removal of such anti-fouling paint or for application of a sealing coating in consultation with the paint manufacturer in order to comply with the amended requirements.

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