Continuing the pressure on port states, port authorities and terminals to develop and maintain adequate reception facilities is seen as a vital element associated with the elimination of all ship sourced discharges into the seas.
INTERTANKO will continue to work on this issue at all levels as part of its objective for zero discharges into the seas.
Key reporting forms and guidance on Reception Facilities
January 2017: Update on EU Reception Facilities Directive Implementation
INTERTANKO has been participating in the European Sustainable Shipping Forum’s (ESSF) sub-Group on Port Reception Facilities. The following key documents and guidance has been circulated within the group and is now publicly available on the European Maritime Safety Agency’s (EMSA) and below:
1. EMSA Guidance for Ship Inspections
We would draw your attention to the emphasis on the use of the Advanced Waste Notification Form (ANF) and its submission through the National Single Windows, page 4. Member States (MS) had until December 2016 to implement the mandatory use of the ANF through their national legislation with some MS already taking measures to enforce this requirement.
2. EMSA Technical Recommendations on the Implementation of Directive 2000/59/EC on Port Reception Facilities
This document is aimed at ports and focuses primarily on the development of port waste reception and handling plans. However, it also provides an interpretation of the assessment and determination of sufficient storage capacity, as provided for in Article 7.2 of the Directive. INTERTANKO’s members have been at the receiving end of various interpretations of this article in the past when visiting European ports. Whether this interpretation will assist members is yet to be seen but it is likely that some ports may reference this document in the future when demanding the delivery of ship generated waste and cargo residues.
3. EMSA Study on the Management of Ship-Generated Waste On-board Ships
While this is not a guidance document nor a technical recommendation it is worthwhile noting some of the assumptions and interpretations being made. Particular attention should be paid to the section on Oily Tank Washings (Slops), pages 27-29.
In relation to the implementation and enforcement of the EU Directive, there remains some uncertainty around the mandatory delivery of slops (referred to as Oily Tank Washings). For example, the Port of Tarragona continues to insist on the mandatory delivery of slops. If any members have experienced problems with European ports then please keep the secretariat advised so the matter can be appropriately raised within the ESSF sub-Group and with EMSA.
INTERTANKO’s Environmental Committee have these documents and the issue of port reception facilities on their agenda. However, if members wish to raise issues relating to the above or the issue in general please contact Tim Wilkins.
January 2016: INTERTANKO Lists Ports and Terminals with Inadequacy Reports
Following the concerns expressed by INTERTANKO’s Environmental Committee on low reporting on alleged inadequate port reception facilities by the membership, the Committee requested that details of the ports and terminals with alleged inadequacy reports filed against them by INTERTANKO members are listed on the INTERTANKO website.
The current list of ports and terminals can be found here:
September 2015: Low level of reporting by INTERTANKO members
INTERTANKO’s Environmental Committee is following the issue closely. During its last meeting held in Monaco in September 2015, the Committee agreed that the issue of inadequate port reception facilities continued to remain prevalent. The Committee urges all members to encourage their Masters to submit alleged inadequacy report forms whenever they encounter a problem in delivering waste at ports and terminals around the world.
The IMO’s standard form for reporting alleged inadequacies should be used, with the latest form available here.
Members are encouraged to file Alleged Inadequacy Reports with their Administration and copy the report to the INTERTANKO (firstname.lastname@example.org). This allows INTERTANKO and the flag Administrations to build a stronger case for action at the IMO and Port State level.
INTERTANKO has listed the benefits of reporting previously, click here for the details.
January 2013: Statistics on INTERTANKO member reporting
A review of the alleged inadequacy reports received from the INTERTANKO membership since 2011 shows that there remains a low frequency of reporting to flag administrations by the industry with only 27 reports having been received by INTERTANKO during the two and half year period, 2011-2013.
Members may recall that the INTERTANKO feedback form was withdrawn on the basis that alleged inadequacy reports should be filed using the IMO standard format and sent to the member’s flag administration. To be able to monitor the level of report members were and are encouraged to copy these reports to INTERTANKO.
INTERTANKO’s Environmental Committee, when it last met in Istanbul, reviewed the data collected. From the reports received since the beginning of 2011 the Committee noted that only five have been submitted to the IMO by the receiving flag administrations. This indicates that there is a considerably high level of under reporting by the flag administrations. If this figure is indicative of all reports sent to flag administrations by the industry as a whole then only 19% (5 out of 27) of reports are being forwarded for inclusion in the IMO’s Port Reception Facilities Database (PRFD). This may go some way in explaining the relatively low number of reports in the IMO’s PRFD and the general feeling among some IMO member states that the problem of inadequate port waste reception facilities is no longer significant.
In its assessment of the data, the Environmental Committee also concluded that there exist two major bottle-necks in terms of information on inadequate port reception facilities. Firstly, that the industry continues to remain reluctant to report. This is based on what is considered as a low number of reports copied to INTERTANKO over two and half years, i.e. 27 reports. Secondly, that even when such reports are submitted only about 1 in 5 are actually forwarded to the IMO for inclusion in the PRFD.
Summary of Alleged Inadequacy Reports Received by INTERTANKO Jan 2011 to June 2013:
||Number of Alleged PRF Inadequacy Reports received by INTERTANKO (2011-2013)
||Number of Reports also uploaded to IMO PRFD
||Number of INTERTANKO Members submitting reports
||Number of different Flag Administrations sent reports
||Number of different Port States
||Number of reports submitted to the Port/PRF in question
||Number of responses from Port/PRF in relation to 6a
Members are encouraged to file Alleged Inadequacy Reports with their Administration and copy the report to the INTERTANKO (email@example.com). The IMO reporting form can be downloaded here. This allows INTERTANKO and the flag administrations to build a stronger case for action at the IMO and Port State level.
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