Answer
A –
Decoupling – basically means decoupling of IOPP renewal from HSSC.
All new vessels after 8 Sept 2017 were supposed to comply with D 2 standards.
For existing vessels-
1stlOPP renewal after 8 Sept 2017, shall comply with D 2 after their 1st IOPP renewal.
IOPP renewal survey comes under HSSC.
HSSC is a guideline where Admins can give a leeway.
Since during the panic phase -2016 to 8 Sept 2017, either equipment were not available or were not efficient because on which Admins allowed ‘Decoupling’ of IOPP renewal from HSSC i.e.- forced IOPP renewal survey was carried out during this phase so that vessels could comply till next IOPP renewal i.e.2022.
DG Circular 2 of 2016- allowed for
1.Statement of Compliance- for Indian Flag vessels equivalent to IntI BW MC certificate. 2.Decoupling for Indian Flag ships.
Recoupling-
Decoupling was a loophole that was exploited by shipowners to delay the compliance of D 2.
Hence, MEPC 71 accepted an amendment, formally adopted in MEPC 72 to make a compromised formula (one formula for all). The leeway was decided for all and not left to the satisfaction of admins.
1stIOPP renewal bet 8 Sept 2017- 8 Sept 2019, shall comply after their 2nd IOPP renewal.
1stlOPP renewal after 8 Sept 2019, shall comply after their 1st IOPP renewal.
This led to the decoupled shipowners’ loss as now they had to comply with D 2 by 2022, whereas if they did not decouple, they could have complied by 2024.
So, the shipowners who decoupled as per DG Circular 2 of 2016 bet Dec 2016 to 8 Sept 2017 were allowed to recouple IOPP with HSSC regime formerly being done by the to its original dates.
The IOPP surveys conducted during panic phase would be considered as annual/ intermediate as applicable.
Q- Why BWM Certificate coupling with IOPP certificate, even though BWM is a separate convention?
A – Marpol Annex1& 2 is mandatory for all contracting states, hence BWM certificate was coupled to IOPP certificate for implementation of D 2 standards. Since BW is ship transported waste and not ship generated waste, it does not qualify to be annex of Marpol. Hence BWM is kept as a separate convention and no included in Marpol. Out of Annex 1 and 2, Annex 1 has wider range of applicability, hence it is coupled with IOPP certificate.