Q: What does it mean to be a Performance & Environmental Compliance Manager?
Environmental compliance means adopting and implementing environmental requirements – national and international environmental rules, laws, and regulations. Environmental concerns have raised compliance standards across the globe. Especially in the Shipping industry, more Regulations regarding Sustainability and Environmental protection are being enforced, whilst Regulators and other Stakeholders in the maritime industry are intensifying their efforts to reduce greenhouse gas (GHG) emissions from shipping.
In this fast-evolving period for shipping regulation, the protection of the environment and the increasingly stringent measureds designed to achieve the goals of the IMO have made this role of utmost importance.
An Environmental Compliance Manager is responsible for managing an organisation’s environmental performance, and ensuring that the company complies with environmental laws & regulations. Part of the role is to assess the organisation’s current business practices and to develop strategies that improve and meet environmental targets. Some common daily tasks are to perform environmental audits and assessments, develop environmental strategies and policies. The role lies with Technical and Operations departments, validates the information, corrects as necessary and transmits it in a format compliant to local and international regulations.
Q: What are the biggest challenges that you face in your role?
In many ways, managing environmental compliance is like trying to hit a moving target – and doing so while working under pressure and major time constraints. Regulations are constantly changing, but the deadlines are unforgiving. The main challenge for shipping companies today, and the industry as a whole, relates to the implementation of these new regulations.
Recently, a number of important decisions have been adopted by the IMO. In view of these decisions, various questions have been raised – how will we manage and implement these new requirements within the specified time limits. What will be the impact on shipping’s decarbonisation targets? Will deadlines have to be delayed? How is port state control going to deal with the enforcement of these regulations under current restrictions? And how will regulators move forward with the ‘new normal’?
Sometimes it feels like you’re stuck in a never-ending cycle of falling behind… however, you know that it’s also imperative to get things done.
Q: What is your sustainability strategy at Eurobulk? What are you aiming to accomplish?
We are committed to protecting the environment – and this commitment is reflected in our Environmental Protection, Safety and Quality Policy. We seek to minimise the impact of our operations on both air quality and the marine environment.
To support our policy, we have an environmental management system in place, incorporated in our HSEQ manual, defining our objectives, action plans, strategic ambition, and the corresponding deadlines for our work – all in an effort to reduce potential negative impacts on the marine environment.
Moreover, we recently created a Compliance department which handles all the issues concerning environmental challenges and the necessity of meeting relevant regulations. This department is concurrently keeping abreast of IMO announcements, the new regulations, market developments, and technology improvements. We are also continually educating our company’s employees on the new and forthcoming regulations, the environmental challenges, how the performance and design of ships might be affected, and what needs to be done in order to ensure compliance whilst minimising service disruption.
Q: What steps is Eurobulk taking to ensure that it meets these goals?
Eurobulk is a member of the Hellenic Marine Environmental Protection Association (HELMEPA) since 2012, in order to support its environmental efforts, and to be part of a community which provides training and other benefits to our crew and shore-based employees.
Our priority is to minimise CO2, NOx and PM emissions from our ships’ engines, and to reduce the export of aquatic organisms by fitting our ships with ballast water management plants. Amongst other plans, we have implemented a program to renew our fleet with modern, more efficient, tonnage- either by contracting new buildings or by replacing older ships with newer eco vessels. We are confident that we will achieve our goal to support the SDG 13 of the 2030 UN targets and the IMO’s Greenhouse Gas Strategy for the reduction of carbon intensity.
The bottom line is that any action to reduce emissions per mile-sailed improves a ship’s rating. Both technical and operational improvements should be considered when considering how to achieve this goal.
Q: How is technology assisting you in reaching your energy efficiency and vessel/fleet performance goals?
In an effort to accurately monitor our fleet’s performance and emissions, we have introduced a number of performance software modules – alongside a specialised team to evaluate their effectiveness.
Most of our vessels are equipped with digital mass flowmeters, and we are gradually installing telemetric equipment for high-frequency data collection – allowing us to better monitor the fleet’s fuel consumption and improve overall digitalisation. DeepSea helps us in this direction – it specialises in vessel performance monitoring and optimisation utilising artificial intelligence, and provides us with the appropriate equipment to collect and analyse our vessel data. We use DeepSea to track the performance of our vessels, calculate our ships’ emissions, and compare the actual condition of each ship against design condition in real-time. Monitoring each ship’s performance and consumption trends, and performing timely hull cleaning, is one way to keep our CII in check.
Moreover, we are committed to continuing our sustainability journey and playing our part in the decarbonisation of shipping. Energy efficiency technologies will continue to play a crucial role in this mission, and we believe that collaborating more closely with DeepSea will not only lead to fuel savings and emissions reductions across our fleet, but also that sustainable growth will create additional value for our stakeholders in the mid- and long-term.
Q: How do you measure ROI and success?
To monitor the impact of vessel improvement projects we use both qualitative and quantitative KPIs. Regarding the quantitative KPIs, a vessel’s performance is always considered over time – i.e. against the performance achieved during previous quarters or on similar legs. Improvement in fuel consumption, CO2 emissions and speed performance are key indications of current status. As far as the qualitative aspects are concerned, the ability to fully monitor a vessel remotely, without human intervention, allows the performance manager and operator/superintendent to quickly identify and solve any issues. For example, we can understand if our generator engines are properly loaded and equally shared over time. This allows us to better plan overhauling intervals. Certainly, “performance” is not just about monitoring hull fouling.
Q: Should environmental & performance compliance only concern senior management, or does the entire workforce play a role in it? In what ways?
“Green shipping” is the concept of sustainable development applied to the shipping sector – incorporating both environmental and social responsibility. Environmental & performance compliance is, for sure, not only a concern for senior management – but it is certainly where it begins. The roadmap for environmental & performance compliance consists of six vision areas – Oceans, Communities, People, Transparency, Finance, and Energy – each with its own set of objectives, desired outcomes and interrelated milestones.
We understand that to achieve long-term sustainability, companies must continuously improve the environmental performance of their vessels to comply with the latest regulations. This requires cooperation between several departments – and of course between shore personnel and crew – in order to collect and maintain all the necessary information to achieve compliance in this new era. In my position, I do my best to ensure our fleet meets the environmental objectives whilst remaining responsible stewards of the environment.
In order to achieve this, the Performance & Environmental Compliance department arranges a series of trainings throughout the year. We collect data over time, and validate all information collected from vessels on a quarterly basis. We arrange meetings with the involved departments prior to the submission of results. We keep Masters and Chief Engineers engaged throughout the whole process of environmental compliance, helping them to understand the importance of being accurate, aware and responsible regarding the new challenges and demands coming from the IMO.
Q: What advice would you give to your peers regarding setting a sustainability strategy?
A sustainability strategy is not one-dimensional, but multidimensional. It takes into consideration both current and future challenges.
The need for rapid decarbonisation by 2050, the increased scrutiny and pressure from financial stakeholders, and the labour and human-rights risks faced by seafarers worldwide (as highlighted by the ongoing crew change crisis) all need to be taken into consideration.
There is no ‘silver bullet’ for environmental compliance. Often, shipowners and operators must tailor their approaches and solutions to specific vessel types, sizes or fleets. It is clear that, to comply with all these challenges, team-work, cooperation, stakeholder collaboration and energy are necessary.
While new technological advancements have created more compliance options, shipowners and operators must carefully evaluate which solutions make the most sense for their business model. Whichever technology is chosen, it must ensure a measurable efficiency improvement across the fleet.
Also, shipowners, ship-builders and operators must stay on top of the numerous regional, domestic and international environmental requirements and understand the impact of these requirements on maritime transport. Proper reporting, evaluation and monitoring of fuel consumption is now of paramount importance. Optimisation and correct monitoring can improve vessel ratings at the same time as maximising the competitive advantage for commercial operators. The Carbon Intensity Indicator will also have a direct impact on competitive advantage. Vessels in the better-performing categories (A and B) may see commercial benefits. Vessels in the middle of category C represent the Required Annual Operational CII – effectively the acceptable baseline of the regulation and the market. Vessels in the D and E categories will have to demonstrate improvements promptly, moving progressively towards category C – if they are to stay compliant and market-viable.
Marilena Apostolidou, Eurobulk Ltd.
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