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Collaborating on an Underwater Code

Published on 20 September 2021

Nadine Robinson, Technical Adviser, Environmental Sustainability, International Marine Contractors Association (IMCA) presents a new voluntary IMCA Code that promotes environmental stewardship. 

Working with its members IMCA has reached a significant landmark with its recently published ‘Recommended Code of Practice on Environmental Sustainability’ (IMCA ES 001), making it the first membership organisation in the industries IMCA serves to produce such a document. Reaction amongst members, and their clients, has already proved very positive, with one oil major representative declaring the IMCA Code has applications for other industries. 

As a leading international trade association with some 700 member companies, IMCA represents the vast majority of marine contractors and the associated supply chain in the worldwide offshore marine construction industry. The association has a strong reputation for setting leading industry standards of technical and operating guidance; and is fully engaged in the energy transition to a sustainable, low carbon future, collaborating to advance environmental sustainability.  

Through its ‘Code of Conduct for Members’, launched in 2018, all IMCA members commit to, and sign up to, adhering to applicable laws and complying with accepted standards of ethical and responsible business conduct, including those related to environmental protection. 

In the new Code, we put pen to paper for the first time on what environmental sustainability means for our industry, identifying industry-specific material topics and highlighting some preliminary steps that can be taken to make progress, and signposting additional related resources available. It is a marker in the sand – a foundation document on which to build. 

IMCA ES 001 sets expectations on our industry to manage key environmental and climate topics associated with offshore marine construction. Naturally IMCA members are at different stages of their environmental sustainability journey, but there are some common actions all members can take in principle and in practice. These are detailed in the Code. 

As IMCA’s CEO, Allen Leatt writes in the foreword to IMCA ES 001: “Championing environmental sustainability and reducing our carbon footprint are fundamental to long-term value creation for not only our industry, but also for the wider public good. This Recommended Code of Practice on Environmental Sustainability is a first step in the right direction and to building resilience.”  

As he explained in launching the voluntary Code in late May: “IMCA started its environmental sustainability journey with its members four years ago. Since then, a great deal of groundwork has been accomplished and I would like to thank all our committee members for their sustained effort in the past year in developing this Code, which although voluntary is strongly encouraged for our membership.” 

The dedicated Environmental Sustainability Committee (which became an IMCA core committee in September 2020 having previously been a subcommittee reporting to the HSSE Committee) is chaired by Peter de Bree, Director of Strategy and Technology at Heerema Marine Contractors.  The Environmental Sustainability Committee draws on members from 13 member companies. It brings together environmental and climate change experts from marine contractors operating around the world, and provides a forum for discussion, exchange of experiences and good practices, and sharing of knowledge to help achieve individual and collective goals. Its work is ongoing, IMCA ES 001 is just the start of the journey – much lies ahead. 

Getting down to work 

In producing the new Code to promote environmental stewardship an overall workgroup, involving members from 10 countries, was formed and so too were sub-groups under the auspices of the Environmental Sustainability Committee. As with all IMCA committees they were led by members. All IMCA guidance is produced by members for members. Member companies instrumental in developing the Code included DeepOcean, DEME Offshore DOF, Fugro, Global Maritime, Heerema Marine Contarctors, McDermott, Saipem, SBM Offshore, Subsea 7 and TechnipFMC. 

The sub-groups covered greenhouse gas emissions reduction; energy efficiency and management; the circular economy; supply chain engagement; and reporting and disclosure. We called on additional experts to assist with our section, on managing life below water and environmental impacts which will be of particular interest to readers of ‘World Pipelines’.  

The final step was a consultation process with comments received assessed by the Review Committee. Like all IMCA documents the Code will be regularly reviewed and revised to take account of key regulatory and market developments, new technologies, stakeholder demands, adoption rates and changes in industry practice. IMCA’s Board has closely followed the Code’s development and welcomes its publication. 

The meetings and production of the Code was all achieved during the pandemic. We are immensely grateful for the time and expertise of the dedicated experts in our membership who convened to develop and write the Code during this challenging time. 

Principles and practice 

Every two years IMCA holds a member survey and the one carried out in 2021 clearly emphasised the importance of environmental sustainability and the energy transition. Almost 80% of respondents said environmental sustainability was critical or very important in IMCA’s strategy and more than four-fifths acknowledged their client base was increasingly using environmental sustainability in evaluating contractors and suppliers; so, our timing for providing them with signposts by means of the new Code is impeccable.  

IMCA’s ‘Environmental Sustainability at a Glance’ document, readily available for wide dissemination from the IMCA website, provides a bird’s eye view of the Code; and identifies several principles for possible adoption by members, as well as good practices, Throughout the Code we highlight around 50 suggestions as ‘recommended’ or ‘good practices’, we want to encourage members to consider recognising that each of them will have their own objectives, and create ambition throughout the industry: 

  1. Developing Paris Agreement aligned marine emissions reduction strategies, consistent with the International Maritime Organization’s (IMO) 2018 initial Greenhouse Gas Strategy.  It is suggested in the Code that Members should, where possible, develop Paris-aligned GHG emissions strategies and set specific, measurable, achievable, realistic and time-bound (SMART) targets consistent with the IMO’s initial strategy.  Members can review their decarbonisation roadmap regularly, taking into account advances in technologies, adoption rates, economics, and regulatory and other developments. 
  1. Committing, prioritising and planning for sustained energy efficient operations.  Key practices in this area include establishing a baseline for energy consumption and recording and consolidating of data at regular intervals. Members are encouraged to keep abreast of technological advancements that may enhance vessel energy efficiency and consider these in the overall strategy to improve energy performance.  Various operational and technical measures for enhancing energy management are noted in the Code.  For example, operational measures include optimising operational modes (without compromising safety), preventive asset management and optimised voyage planning.  Technical measures to promote energy efficiency could include more efficient vessel power systems, greater energy efficiency through use of digitalisation and, where feasible, use of shore power. 
  1. Managing the process of protecting life below water (the 14th United Nations’ Sustainable Development Goal (SDG 14)) and other environmental impacts associated with offshore construction.  Marine contractors operating offshore need to carefully manage the process of protecting life below water and other environmental impacts (e.g. underwater noise or invasive species).  Members are encouraged to adopt good practices, such as implementing environmental management systems (EMS) and environmental management plans (EMP), which outline commitments, responsibilities and mitigation measures in place for specific activities.  
  1. Applying the principle of circularity and adopting a circular economy approach to asset lifecycling, and waste and resources management.  The Code offers strategies of how this approach may be applied to both waste management and End-of-Life (EOL) assets, drawing on the internationally recognised 9Rs Framework of the MacArthur Foundation.  This concept can also be promoted within the supply chain.   
  1. Collaborating with and cascading environmental objectives to the supply chain, and considering collaborating with others, for example through participation in relevant multi-stakeholder initiatives.  Engagement with the supply chain, including undertaking due diligence, is key to helping advance environmental sustainability across the offshore marine contracting industry, although it is recognised that the nature and level of engagement will vary across the IMCA membership and will be dependent on the supplier level of criticality.  To be successful in our shared environmental journey will also require learnings from others.  In this respect, several multi-stakeholder initiatives, in which Members are engaged, are noted such as the United Nations Global Compact, the Seabed 2030 Project, and the Oil and Gas Climate Initiative.   
  1. Raising awareness and advancing competence of key environmental issues within our industry.  It will be increasing important for Members to deliver on their responsibility to respect and protect the environment.   This is not only the right thing to do but is also governed by regulation to varying degrees.  To do so effectively, requires an informed and engaged workforce and supply chain.  IMCA will engage further with Members and Committees to explore what support is needed, including any further guidance, awareness-raising, and training.   
  1. Measuring, disclosing and self-assessing progress on environmental sustainability.  Members are encouraged to report progress on the most material environmental aspects through their chosen disclosure vehicle and to regularly self-evaluate or reflect on how to improve their environmental performance.  Multiple international frameworks and standards are included in the Code to help Members communicate environmental performance in a consistent, comparable and decision-useful way.  

Managing life below water 

The entire Code has relevance to the pipelaying, and O&M community however, as mentioned in point 3 above members involved with pipelines have an important role to play in supporting the achievement of SDG14 by demonstrating good environmental stewardship in the marine environment in which they operate.  

Members recognise that the world is facing not only a climate, but a biodiversity crisis. October 2021 sees the UN Convention on Biodiversity (UN CBD 15) taking place in China. It is expected that the world will agree on a post-2020 global biodiversity framework including related targets. 

For example, Members may encounter marine mammals and other biodiversity in operating their vessels. The associated potential impacts vary dependent on the environmental characteristics and ecosystems where the activity is taking place, and on the engineering solutions delivered. The Code dives into much fuller details on these points. 

The Code adds: It is also important to distinguish between the impact of members on ‘life below water’ (e.g. through ballast water, on hulls and in intakes/outlets, oily water discharge, hydraulic spills from thrusters and hoses, and underwater noise from machinery, etc. Fuller information is given)) and the much larger impact, made on behalf of clients (e.g. seabed disturbance through dredging, ploughing, trenching and rock installation; chemical discharge through Ready for Operations (RFO) on pipelines, drill cuttings from drill rigs; underwater noise from piling and seismic activities).   

It should be recognised that many of these activities are conducted under the client’s environmental plan and associated requirements and approvals. Where practicable, members should adopt “Best Available Techniques” and ALARP principles, even in areas where client or government requirements are not stringent. 

What comes next? 

Publication of the Code is just a first step on IMCA’s environmental sustainability journey. Guidance documents on specific aspects figure in the Environmental Sustainability Committee’s work programme as does ensuring all relevant existing IMCA documents are updated to include salient points.  

Developing a self-assessment tool so members can reflect on the ‘asks’ in the Code and determine how they are doing, both individually and as an organisation, is high on the action list. It is too early for benchmarking, but the time will come. 

On 28 September a technical and motivational seminar will be held to disseminate the Code; with external speakers homing in on specific topics to provide a different lens and view. We are eager to raise awareness throughout the industries we and our members serve.  We have also produced a related podcast and broadcast.  

In many ways, the process of producing the Code was as important as the Code itself. Members have come together, developed a relationship and a network which has cemented the Environmental Sustainability Committee and are looking forward to the next steps in making progress on environmental sustainability across our industry.  

Author information:  

Nadine Robinson: Technical Adviser – Environmental Sustainability 

Nadine joined IMCA as Technical Adviser in May 2020. She leads IMCA’s environmental sustainability strategy and related programme of member engagement on a global level. 

Nadine brings a wealth of experience to IMCA having held positions as Technical Director (Climate Disclosure Standards Board in CDP), as an Environmental Consultant, Environmental Policy Lecturer (Birkbeck College), Economic Advisor on Climate Change (Commonwealth Secretariat), Shipping Finance Solicitor (Allen & Overy).  

She has also held various policy and research roles in Government and UNDP advising on environment, climate finance, energy, the green and blue economy, and sustainable development. 

Nadine holds a BA Honours (McGill University) and an MA (York University, Canada) in Geography.