The IMO has taken a lead through MARPOL and other regulatory instruments to enhance energy efficiency and reduce greenhouse gas emissions from shipping. In July 2011, the Marine Environment Protection Committee (MEPC) of the IMO concluded its sixty-second session with the adoption of new requirements on CO2, including making a SEEMP mandatory for new and existing ships above 400GT irrespective of flag from1 January 2013. A SEEMP provides a structured approach for monitoring and improving ship and fleet efficiency performance over time, and encourages the ship-owner to consider new technologies and practices at each stage of the plan. The SEEMP is not subject to pre-approval by flag states or recognised organisations, but a vessel-specific SEEMP must be on board at the time of survey. Chapter 4 of the MARPOL Annex requires under Regulation 22 that “each ship shall keep on board a ship-specific Ship Energy Efficiency Management Plan (SEEMP) … (which) shall be developed taking into account guidelines adopted by the (IMO).”
While it is certainly possible for any operator’s energy manager or senior superintendent with energy efficiency duties to write a compliant SEEMP, many vessel operators opt to have the SEEMP for their vessels created by professional experts on marine energy management.
There are various reasons for this, e.g.:
- Learning from industry best practice
- Resource limitations – avoid wasting the superintendent’s time on formulating compliant text
- Compliance is ensured
When developing / revising a SEEMP, the process should follow a cyclical process (Plan-Do-Check-Act):
PLANNING includes ship- and company-specific measures, human resource development and goal-setting, while bearing in mind the need to minimise on-board administration.
Important considerations: This is the most crucial phase of the SEEMP development and should reference company goals and processes, ship-specific features in technical and operational spheres, training, competence and timelines.
IMPLEMENTATION includes attention to establishing an appropriate system that allows for each selected measure to be rolled out according to the plan.
Important considerations: Any ‘system’ can involve a mix of tools, processes and record keeping that, when combined, will enable the implementation of specific energy efficient initiatives. A communication plan that identifies who is responsible for each step in the process will both increase awareness and the likelihood of sustainable activity.
The SEEMP may be part of the vessel’s Safety Management System mandated by the ISM Code. It can form the cornerstone of a broader energy management initiative, or it can be kept separate, focusing on compliance only.
MONITORING describes the establishment of a system utilising various tools, existing and new, that can provide a qualitative and quantitative basis for self-evaluation and subsequent performance review.
Important considerations: This is perhaps the hardest area to activate in a consistent manner. The interaction of the right tools, systems and processes is crucial for measuring achievement and ensuring sustained improvement. Many organisations collect data from a wide range of sources, but not all manage this information systematically so that they know how well they are performing or whether they are on track.
SELF-EVALUATION, IMPROVEMENT AND REVIEW complete the continuous improvement cycle by assessing the effectiveness of implemented energy efficiency actions, identifying ways to improve associated processes and formerly reporting to stakeholders.
Important considerations: Plan to communicate both ‘good’ and ‘not so good’ news to interested parties. This will increase awareness and build trust in the programme and activities. In addition, seek regular feed-back from others via meetings, presentations and emails to check and validate plans as they unfold.
The SEEMP is just the beginning
In our opinion, an SEEMP is a crucial first step towards the comprehensive energy management of any fleet. Based on rigorous analysis of trading patterns, vessel speeds over time, actual vs. desired fuel consumption and so forth, a fully-fledged energy efficiency programme should be started and maintained that will encompass technical and operational measures, both on board and in the office, together with training and a goal-driven continuous improvement process.