Scrubbers Could Harm People Through Food Chain Per IMO Report
What’s worse, air pollution or pollution pumped into the ocean that could make the seafood you eat toxic?
The transition to the new IMO 2020 regulation that requires a sulfur emissions cap of 0.5% on ships’ fuel has been very smooth so far. Of course, with the regulation having just gone into effect on January 1st, it is still too soon to know how well ocean carriers around the world are actually following the new regulation. But one of the biggest things for making the transition so smooth has been the allowance of carriers to retrofit ships with scrubbers, fuel cleaning systems, in order to continue to use higher-sulfur-content fuels.
Where Do Pollutants Go When Scrubbers Remove Them from Emissions?
The idea seems genius. Instead of having to buy more expensive, cleaner fuel all the time, carriers invest a one-time cost (yes, there will be maintenance costs here and there) in basically an onboard treatment plant inside a ship to remove harmful gasses from its engines and exhausts. However, we all know those pollutants don’t just disappear. Critics of the scrubbers plan from the beginning have said scrubbers will dump the pollutants into the ocean rather than burning them into the air.
Despite this concern, carriers have moved forward with spending billions of dollars to install scrubbers on thousands of ships. What’s crazy is the International Maritime Organization (IMO) compiled an internal report that says the use of scrubbers to comply with its IMO 2020 regulation “could harm humans by contaminating fish and crustaceans with toxins,” according to the Guardian, which obtained the report.
“Could” is a big word in that sentence. The IMO is uncertain about whether or not scrubbers dumping toxins into the ocean will harm our food chain because there just hasn’t been enough testing done to know for sure. In its article on the topic, the Guardian says:
In the report the IMO, the United Nations agency responsible for regulating shipping, says that there is insufficient “toxicity data” to be able to assess the risk to humans caused by the increased use of exhaust gas cleaning systems, which are also known as “scrubbers”.
Some of the pollutants deemed most concerning by experts that are pumped into the sea by scrubbers are polycyclic aromatic hydrocarbons (PAHs), which have been linked to skin, lung, bladder, liver and stomach cancers.
Dangerous To Allow Scrubbers When We Don’t Know How Harmful They Are
The obvious question is if critics have been saying from the start that scrubbers will dump toxins in the ocean — especially toxins linked to various cancers — why haven’t scrubbers been properly tested before being approved for a means of compliance for IMO 2020. Well, maybe they have. We’ll get to that later, but here’s something of an answer from the IMO that was in the Guardian’s article:
In its report, the IMO says “carrying out a preliminary risk assessment [on the PAH emissions from scrubbers] was not possible considering the available information” and warns that “secondary poisoning (via consumption of seafood) had been mentioned as a likely exposure route for humans”.
Critics say IMO member states should have conducted thorough risk assessments before deciding to allow the use of scrubbers under the new legislation.
This criticism seems especially true with as many ships installed with scrubbers are hitting the ocean. In the lead-up to IMO 2020, we posted a blog about the world fleet not appearing ready for the regulation implementation that included the stat that 3,000 ships were scheduled to have scrubbers installed by this year. The installation of scrubbers has been slower than anticipated, so many of those ships are not yet out on the water with a new scrubber system yet.
I’m not an environmental activist or anything, but I, for one, think the use of scrubbers should be reassessed before any more of those ships do hit the water, and the many, many ships using scrubbers that are already in the water should be assessed for levels of pollution. That might not be a popular thing for someone in the international shipping industry to say as there are billions and billions of dollars at stake here, and such a move would be negatively impactful for ocean freight carriers and raise freight rates for shippers.
While those in the shipping industry are probably not saying what I just voiced, I’m obviously not alone in this opinion. The Guardian gathered a couple such opinions in its article:
Lucy Gilliam, a campaigner for the Brussels-based NGO Transport & Environment, says the IMO should stop the use of scrubbers until it can answer key questions about how discharges may affect health.
“Ships should not be allowed to use scrubbers if the IMO has no idea what the consequences will be for human health and food chain contamination,” she said.
“The surge in scrubber use means that increasing amounts of PAHs will accumulate in sediment over time, and no one knows what the impact on human health will be.
“It is going to have an impact on the food chain and, as things stand, we have no reliable information about when safe threshold limits will be breached.”
Christopher Elliott, a professor at the Institute for Global Food Security at Queen’s University Belfast, believes the effect of bioaccumulation of PAHs in the food chain is a worrying issue.
“Any increase in PAHs at the bottom of the food chain can have a negative impact on human health over the long term, damaging immune systems and potentially increasing susceptibility to cancer,” he said.
Testing of Scrubbers
Of course, those opinions are expected from a campaigner for cleaner environmental practices in transport and from someone of an institute dedicated to protecting global food. There is also the other side of the argument, coming, as expected, from the ocean freight and cruise line industries. The Guardian article also gives this side of the argument from shipping companies, actually more from cruise lines than shipping lines, who say they have done rigorous studies to test the discharge of scrubbers and found that say the cleaning systems have “limited impact on water quality” and are “safe and effective.”
Here are a couple quick highlights shared by CE Delft, an independent research company Cruise Lines International Association hired to do a study on scrubbers:
Ships that use Exhaust Gas Cleaning Systems (EGCSs) to comply with the IMO sulphur regulations have a small impact on the water quality in ports, when compared to future EU standards for priority substances in water. This is the main conclusion of a new study carried out by CE Delft, with support from Deltares.
…The study is unique as it uses empirical data from almost 300 EGCS washwater samples, the most extensive dataset of this kind analyzed in this manner, and because it employs the MAMPEC-BW model to calculate equilibrium concentrations in ports. MAMPEC-BW is a model that is widely used in a regulatory context, e.g. for the approval of ballast water management systems and antifouling agents.
The other study mentioned in the Guardian article is one that came from Carnival Cruise Line. The cruise line hired a two-year, third party study done on wash-water samples from 53 Carnival Corporation ships installed with scrubbers. Here’s a quick highlight from Carnival:
Specific to IMO wash-water requirements, the study confirmed results from previous studies showing the quality of the water used in the Advanced Air Quality Systems process was always far below the IMO monitoring limits for polycyclic aromatic hydrocarbons (PAHs) and the annual limits for nitrates. In fact, when measured against IMO standards, the average wash-water test results in this study were over 90 percent lower than maximum allowable levels. In many cases, the materials were completely undetectable in the laboratory testing process.
Additionally, the report compared the samples to selected national and international water quality benchmark standards, including the German Waste Water Ordinance, the EU Industrial Emissions Directive and the Surface Water Standards of the EU’s Water Framework Directive. The World Health Organization’s (WHO) drinking water guidelines were also evaluated. The Advanced Air Quality Systems test results compared favorably with all of these major benchmark standards, demonstrating that the composition of the water was not only consistently below, but in most cases, significantly below the most stringent limits.
Are Ship-Line-Commissioned Studies Enough?
Carnival’s study findings sound good. However, would these results remain constant testing ships not owned by Carnival? Specifically, those owned by shipping lines rather than cruise lines? Are all scrubbers equal or installed equally?
Thinking back on all I’ve read about scrubbers over the last couple years, and I’ve read a great many articles on the subject, I don’t remember seeing any scrubber studies like the ones mentioned above that were instead released by ocean freight carriers. Ocean freight carriers are known for their lack of transparency, so maybe they’ve been testing away and not telling anyone. Of course, if ocean carriers were conducting studies with positive findings, why keep that opaque? How concerned are they with pollution from scrubbers? Did they decide to just let the cruise lines pay for studies and go with those findings? Or did I just miss container shipping companies’ studies?
I’m not a huge regulation guy, but I would think it appropriate to require testing of every scrubber system in use to make sure it is not releasing high toxicity levels into the oceans and seas. Frankly, I want more than the study results I’ve seen reported before thousands of scrubbers release wash water into the seas.
I don’t mean to impugn these cruise lines or the research companies they’ve hired — in fact, I applaud them for putting resources into testing the environmental impact of scrubbers — but I’d also like to see such studies that were not commissioned by companies with so much interest in a positive outcome from said studies.
Ocean pollution is not even the only risk that comes along with scrubbers. In October of last year, we posted an article in Universal Cargo’s blog about other dangers that come with scrubbers. You can read that article to learn about corrosive waste from scrubbers as well as shoddy workmanship from shipyards installing the scrubbers creating risk of danger for ships and their crews.
A "scrubber malfunction" on a VLOC. Reports of high corrosion levels in these units. pic.twitter.com/ylzzbAremD— Sam Eckett (@Sam_Eckett) September 17, 2019
To go back to the question posed at the beginning of this post, I’d rather not choose between A) polluted air and B) poisoned seafood when there is an option C) out there. Obviously, that C) option is cleaner fuel. Unfortunately, choosing C) isn’t exactly an option (not that there aren’t ships using cleaner fuel instead of fuel cleaning systems) when carriers have already chosen scrubbers and invested billions in that choice.
My hope is that ship lines, whether cruise companies or ocean freight companies, are right that the waste put in water by scrubbers is negligible. It’s unlikely all the scrubber-utilizing ships already in the water and that are being added to the world fleet are going to be stopped anytime soon. It will certainly give me pause the next time I think about going to Red Lobster. Maybe I’ll just fill up on their unlimited Cheddar Bay Biscuits and skip the entrée altogether.