Japan will not impose any restrictions on international ships discharging scrubber wash water in its ports, according to a senior representative of the country’s Ministry of Land, Infrastructure, Transport and Tourism.
Naohiro Saito, deputy director for international affairs in the ministry’s maritime bureau, gave that assurance to ShipInsight during discussion following a presentation of a study into the impact of discharges from open-loop scrubbers to the first technical conference organised by the Clean Shipping Alliance (CSA 2020) in London on Thursday (21 February).
Assisting with that presentation was Shinichi Hanayama, a manager at Class NK’s research institute. In conversation with ShipInsight later, he said that individual Japanese ports could apply different requirements for domestic shipping “but it almost never happens.”
Explaining Japan’s decision, Mr Saito told the meeting that the government had assessed the potential risk to the marine environment from discharged scrubber water and concluded that it did not cause unacceptable effects on either marine organisms or on seawater quality. “Therefore Japan’s position is that there is no scientific justification to prohibit the use of open-loop scrubbers as long as the IMO discharge criteria are met,” he said.
In his conclusions he went as far as to suggest that the impact on human health of a ship burning 3.5% sulphur fuel but using an open-loop scrubber is less than that of a ship burning 0.5% sulphur with its exhaust going into the atmosphere. This is because a proportion of the polycyclic aromatic hydrocarbon (PAH) emissions from the scrubbed exhaust are absorbed by the seawater rather than released into the atmosphere. PAHs generally result from unburned fuel.
The conference took place while the sixth meeting of IMO’s Sub-Committee on Pollution Prevention and Response (PPR 6) was in progress, where the Japanese findings had been presented the day before to a large audience. Mr Saito told ShipInsight that some IMO delegations had commented to him that the report would be useful in making their own decisions about scrubbers and he believed that some jurisdictions had banned scrubbers “as a precautionary approach” without investigating the science of scrubber discharges.
Reacting to the Japanese position during the CSA 2020 meeting, Hamish Norton president of Star Bulk, which operates over 100 bulk carriers, told ShipInsight that the company operates into Japan “to some extent” and welcomed the Japanese data and analysis. But he also stressed its wider implications, saying that, as a major operator, Star Bulk “can hopefully take that information and analysis and help communicate it” to ports worldwide “so they can make decisions based on actual information.”
Further support for scrubbers came from a report presented at the conference by Simon Mockler, head of maritime advisory services at DNV GL. The class society had reviewed test results from 281 wash water samples taken over three years from 53 Carnival cruise ships fitted with scrubbers and assessed them against 54 test parameters based on a variety of ISO water quality standards used in other industry sectors.
ShipInsight has published a preliminary account of that study, which Mike Kaczmarek, Carnival’s senior vice president for marine technology, described during the conference as “a long-missing piece of the discussion related to the quality of wash water and exhaust gas cleaning systems.” He said that hitherto there has been a lack of data or evidence so “nobody really seems to have any real basis on which to base their speculations,” making this data significant.
In presenting his report, Mr Mockler said that when compared to point-source discharge standards for land-based industries, the concentrations of the parameters being tested for are within those limits. These samples “also compare very favourably” to the other water quality standards, which have “significantly stricter criteria than for point-source industrial discharges,” he added. For many of the parameters he reported, the amounts present in the water samples had been too small to register on the measurement equipment, his report showed.
Scrubbers had been a significant topic at PPR 6, with discussion centred around two presentations, one from the European Commission and one from Germany. As a result, IMO decided that more research should be conducted in relation to open-loop scrubbers.
One panellist at the CSA 2020 conference, Chris Fee, general manager for the environment and sustainability at Oldendorff Carriers, was critical of those two papers, saying that they were based on “the preliminary results of an incomplete study” and that they “really should not have been submitted.” But Mr Kaczmarek acknowledged that “the literature is thin” in relation to scrubber-related data so, “considering all the controversy in the past six-eight months, it is a natural discussion to have,” he said. He welcomed IMO’s call for research, predicting it would verify the Carnival/DNV GL findings.
Despite his commitment to scrubbers, however, he is concerned about the availability of HFO in the future. ShipInsight put it to him that, since only a minority of ships are expected to fit scrubbers, bunker suppliers might not stock it as widely as at present. “There is a lot of discussion [with distributors] among all the companies in this alliance” on that point, he confirmed.
HFO prices are predicted to fall in the future as demand falls, one audience member said, which he suggested will also deter suppliers from stocking fuel, creating logistical difficulties for scrubber-equipped vessels. Kaczmarek confirmed that this was also a point that must be taken into account. Unless a ship is operating on a scheduled route with predictable bunkering locations, “then it becomes more of a challenge,” he said. There is no perfect answer to that question he said, “but I know that everyone is working on it.”