Ship Managers Raise Concerns Over IMO’s GHG Regulations, Advocate For Fairer Liability

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Ship managers are raising concerns about the IMO’s upcoming net-zero framework. They are proposing specific changes to enhance the effectiveness of these regulations, reports InterManager. 

Third-Party Managers

InterManager, representing global ship managers, has submitted a proposal to the IMO’s MEPC83 meeting, advocating for changes to the current greenhouse gas (GHG) proposal.

The submission expresses concern that the existing proposal does not adequately consider the role of third-party International Safety Management (ISM) Managers.

It highlights that approximately 20% of the global fleet is managed by third-party technical ship managers, emphasizing the necessity for refinement to ensure practical applicability and prevent potential legal challenges.

The proposal argues that ship managers have limited influence over a ship’s GHG intensity compared to charterers and shipowners. They lack control over engine type or the installation of alternative energy systems, which are decisions made solely by the shipowner.

Increasing Liability

InterManager’s submission clarifies that ship managers have no input on fuel procurement or supply, which is negotiated between shipowners and charterers in charter party agreements. They also have no control over speed and consumption, key factors affecting a ship’s GHG intensity.

The current proposed amendments to MARPOL Annex VI, however, would make ship managers solely responsible for GHG emission penalties. InterManager argues that this wrongly identifies them as the polluter, potentially leading to legal disputes.

Furthermore, assigning liability for compliance fees would force ship managers to seek financial security from shipowners, tying up significant capital and hindering growth and investment.

InterManager President Sebastian von Hardenberg emphasizes that while ship managers are committed to decarbonization, they have no decision-making power regarding factors that materially impact a ship’s GHG intensity. He likened their role to “Facility Managers, not the Factory Owners.”

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Source: InterManager