The project vessels are existing operating vessels that carry cement and bulk cargo from port to port. In light of this, the project company’s activities are not likely to have risks and impacts which will have to be managed in accordance with PS5: Land Acquisition and Involuntary Resettlement; PS7: Indigenous Peoples; and/or PS8: Cultural Heritage.

A description of the principles and procedures that the project companies  currently use to address and manage E&S risks for their business activities and how these will be modified in some instances to ensure that the project companies activities comply with IFC’s PSs, has been provided below in the PS1 section of this review.                                                   

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability. The project vessels are existing operating ships. The key risks and impacts will therefore be limited, few in number, and largely reversible. Any adverse impact can be minimized, avoided or mitigated by adhering to generally recognized international industry performance standards, guidelines, or design criteria. Accordingly, the key E&S issues related to the project and reviewed at appraisal are: E&S management systems as applied to project vessels; vessels’ inspection and certification status; capacity to operate, maintain and decommission/dismantle/recycle project vessels in accordance with the IMO conventions, International Safety Management Code (ISM code), IFC PSs and national requirements; working conditions and OHS for employees and contractors; compliance with MARPOL; emergency, oil and chemical spill management; shipboard petroleum product and chemical storage and handling; vessel’s waste management; crew community interaction during shore leave; security; and management of any impacts on sensitive coastal and marine environment.

IFC will require that the project companies, within a timeframe to be agreed with IFC, adopt and implement an upgraded ESMS that has been outlined in the sections below.                                                   

 Environmental and Social Assessment and Management System - Policy

PSL has an ISO 14001 certified and integrated Security, Quality & Environment Management System (IMS) which includes management measures for health and safety, human resource management, environmental impacts and emergency preparedness and response. The IMS includes policies for: Health, Safety & Environment Protection; Drug and Alcohol Abuse; and Integrated Quality Management System. The IMS meets the requirements of IMO conventions and Indian laws. PSL’s IMS is applicable to the project companies and project vessels and the IMS has been systematically implemented in the project companies and project vessels. The project companies will, as mentioned at ESAP # 1, incorporate compliance with IFC PSs and alignment with  good international  industry practice (GIIP) as reflected in the applicable and relevant parts of the WBG General EHS Guidelines and WBG EHS Guidelines for Shipping in their respective IMSs.

The project vessels have certifications for: Safety Management; International Ship Security; Maritime Labor; Cargo Ship Safety Construction; Cargo Safety Equipment; International Air Pollution Prevention; Compliance with ship energy efficiency management (SEEM); International Load Line; Cargo Ship Safety Radio; International Oil Pollution Prevention; International Sewage Pollution Prevention; International Anti-Fouling System; International Ballast Water Management; Inventory of Hazardous Materials; and Vessel Classification.

Identification of Risks and Impacts

PSL’s IMS has an environmental aspects assessment procedure to evaluate all its activities. The assessment procedure identifies all the operational activities that could lead to potential environmental impacts (e.g. marine pollution, air pollution, waste generation among others) and health and safety (H&S) risks. The procedure assesses risks taking into account impact magnitude, likelihood of occurrence and impact significance.

Aspects, impacts and risks of the project vessels operation have been assessed as part of IMS development. However, the procedures for the assessment and management of certain social, environmental, and H&S risks and impacts, particularly those related to final waste disposal by subcontractors, worker safety during shore leave, community health and safety during shore leave, gender aspects and biodiversity, are insufficient or lacking. The project companies will, as mentioned in ESAP # 2, upgrade the environmental aspect assessment matrix by incorporating risks and impacts, including the ones related to final waste disposal by subcontractors, worker safety during shore leave, community health and safety during shore leave, gender aspects, ship recycling policy and biodiversity..

Management Programs

PSL’s IMS includes procedures for: aspect, impact and risk identification and significance determination; implementation of mitigation measures and operational controls based on the outcome of the aspect, impact and risk assessment process; compliance with regulatory requirements; setting objectives and targets; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; responsibility and resource allocation; training and awareness; stakeholder engagement ; contractor management; monitoring, recording, reporting and documentation of environmental, health and safety performance; periodic third party and internal audits; and management review.

The IMS includes plans, procedures and documentation for: compliance with legal and other requirements; identification and recording of significant environmental aspects; safety management; shipboard standard operating procedures (SOP); fleet memoranda; shipboard oil pollution emergency management; garbage management; cargo securing; ballast water management; SOLAS training; evacuation preparedness; ship security; major casualty and contingency; ship energy efficiency; inventory of hazardous material maintenance; and COVID-19 management.

PSL undertakes environmental screening of contractors including port operators (piers, berths and jetties as relevant), onshore waste management contractors, dry docks and contractors that undertake maintenance or certification activities on vessels. PSL reviews contractor’s asbestos-free declarations, environmental management system, ISO 14001 certificates, qualifications/certification to work on a class of vessel, minimum packaging practices of contractors besides undertaking contractors’ evaluations.

The project companies will, as mentioned at ESAP # 2, incorporate in the IMS procedures related to the management of the following: E&S management of contractors  according to IFC’s PS requirements, final waste disposal by subcontractors, worker safety during shore leave, crew and community health and safety during shore leave, labor working conditions for contractors, gender aspects, biodiversity; and will develop and include relevant Key Performance Indicators (KPIs) to monitor all significant E&S aspects. 

The project companies will, as mentioned at ESAP # 6, further strengthen the contractor screening and oversight procedure to include labor and working condition requirements of PS2 for contractor; duty of care verification that final waste disposal during dry dock is aligned with PS3, particularly in relation to the removed hull coating; oversight of final waste treatment and disposal by waste management contractor; and specific clauses in the contractual agreements requiring compliance with IFC requirements.

Organizational Capacity and Competency

The corporate team has nine senior staff members whose responsibilities specifically include E&S responsibilities as well. Further, on each of the project vessels, three senior crew members (the Master, Chief Engineer, Chief Officer) and those in supervisory positions, have specific E&S responsibilities as part of their job responsibilities.

The IMS includes competence & training requirements for corporate personnel and crew members. In-house familiarization training and briefing is conducted for all staff (serving at shore office as well as on vessels) and training records maintained. There is a structured staff and crew training process in place including: pre-joining training checklist; training matrixes; an on-board familiarization process; on-board training videos; induction training; provision of pocket safety book; on the job evaluations; training record/documentation; and training feedback recording. Staff are also sent for external training.

Monitoring and Review

Several monitoring and reporting tools are being systematically implemented at the corporate and the project level including daily and weekly monitoring and inspection procedures, internal audits, external certification audits, yearly data analysis, non-conformity reports (NCRs), and near misses reporting. The data collected by the vessels is compiled and assessed by the company. One area for improvement identified during the review was that the IMS does not clearly outline how monitoring and reporting KPIs are selected and how these relate to key company risks, to the applicable legal and/or contractual obligations and regulatory requirements. The project companies will, as mentioned at ESAP # 3, put in place procedures to: develop a systematic approach and criteria for selection of KPIs; ensure that KPIs capture the management measures required in the IMS for significant E&S risk; and include additional KPIs for gender aspects, labour and working conditions aspects, and environmental aspects to ensure all risks and performances are captured, consistent with IFC’s PSs.

The periodic monitoring, inspection, auditing, control and reporting measures in place in the project vessels include: daily monitoring by the Master or Chief Engineer, including near misses and incidents/accidents, cargo activities, and security activities; weekly inspections including accommodation and emergency equipment; quarterly H&S inspection ; monthly inspection of measuring and testing equipment; monthly monitoring of the status and validity of the vessel’s certificates; monthly safety committee meetings and shore committee meetings; monthly reporting through the master’s monthly report; non-conformances and near misses are documented and reported using a specialized software for shipping companies.

Annual internal audits are undertaken on board by PSL corporate and external audits of the vessels are conducted by classification societies.  The E&S performance of each vessel is evaluated through NCRs and Near Miss records and reported to PSL, where the vessel level data is analyzed through annual review meetings.  PSL publishes annually a sustainability report and an annual report.                                                  

Human Resources (HR) Policies and Procedures

The IMS includes requirements on labor conditions in the Seafarer’s Employment Manual which includes policies and procedures on: recruitment, job description, employment agreement, working age, working/rest hours, wages and benefits, leaves, H&S, medical treatment, repatriation, performance management,  code of conduct, disciplinary procedures, and separation among other procedures. The Seafarer’s Employment Manual commits to complying with Standards of Training, Certification and Watchkeeping for Seafarers (STCW) and ILO Maritime Labor Convention (MLC). There are procedures and checklists to ensure compliance with MLC requirements. The Seafarer’s Employment Manual is available to all crew aboard the project vessels.

Women staff outnumber men staff in PSL’s corporate office, women are well represented in management positions and there is equal representation of women and men on the company’s Board of Directors. PSL’s seafarers are recruited only from Thailand and India; they have fixed term contracts of between six and nine months, and on average, employees work for the company for over 10 years. After contract expiration, seafarers can decide to join back and sign a new fixed period contract. Typically, there are  25 crew members deployed on board each of the project vessels. There are no female crew members in PSL’s fleet.

The project companies will, as mentioned at ESAP # 3, develop and monitor KPIs to track additional labor and working conditions indicators including seafarers’ statistics, pre-employment medical examinations, drug and alcohol tests, sickness, and other relevant parameters.

Working Conditions and Terms of Employment

All workers have written contracts specifying duration, port of engagement, wage, terms of employment and working conditions, minimum wage as per the Singapore Maritime Officer’s Union and Singapore Organization of Seamen collective bargaining agreement, premature termination of contract, transfer to another vessel, medical, misconduct and disciplinary action and injury/fatality compensation among other aspects. The project vessels/project companies maintain evidence of compliance with requirements related to minimum safe manning, wage and payments, age, insurance, collective agreement and MLC among other aspects. Amenities and facilities provided in the project vessels meet requirements and GIIP in relation to drinking water, food, toilets, pantry, laundry, resting areas, recreational areas, dining area, safe working conditions, galley and accommodation.

Workers’ Organization

Project companies enter into a collective agreement with Singapore Maritime Officers Union and Singapore Organization of Seamen. Terms of the employment contract for the project vessel crew comply with the requirements of this collective agreement. Further, some Indian crew members on the project vessels are members of the National Union of Seafarers of India (NUSI).

Non-discrimination and Equal Opportunity

PSL has gender non-discrimination commitments for recruitment and a zero-tolerance policy towards gender discrimination, although non-discrimination commitments are not specifically included as part of the Seafarers Employment Manual. The project companies will, as mentioned at ESAP # 4, include in the Seafarers Employment Manual a policy indicating that no person will be subject to any discrimination in employment including hiring, compensation, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, social group or ethnic origin.

Further, besides the commitment to prevent gender discrimination, there are no specific management measures to prevent and address gender discrimination and gender-based violence and harassment. PSL’s corporate Code of Conduct and the Code of Conduct on Board do not have a specific anti-harassment policy and there are no specific management measures to prevent and address gender-based violence and harassment. PSL’s staff have not been trained on Gender Based Violence and Harassment (GBVH) prevention and response, policies and codes. There are no KPIs in place to measure progress on gender aspects.

Accordingly, PSL will, as mentioned at ESAP # 5, put in place procedures for prevention and redress of gender discrimination and GBVH including: ensuring an explicit commitment to equal opportunities and to creating a safe working environment for women in recruitment advertisements; inclusion of female interviewers in the interview panels; training and awareness building of all staff and vessel crew on prevention and redress of gender discrimination and GBVH; a procedure to redress GBVH incidents including coercion, sexual harassment, bullying, intimidation and/or any form of discrimination; adapt training facilities and vessels for female trainees and female seafarers through provision of at a minimum, safe working environments, privacy, lockable and separate toilets, availability of female hygiene products, hygienic and safe sanitation disposal facilities and welcoming social and recreational spaces; regular consultation with female employees about the suitability of the facilities and required improvements; and development, monitoring and reporting of KPI’s to track gender aspects.

Grievance Mechanism

The project companies have in place a seafarer’s grievance mechanism with procedures for time bound grievance resolution and appeal process. Chief Engineer of the Project Vessels is the seafarers’ welfare officer designated on board. A copy of the on-board grievance procedure is provided to all the seafarers including contact details from the Company, Marine Department and Country Flag. The grievance procedure commits to non-retaliation but does not provide for lodging grievances anonymously and confidentiality protection. The project companies will, as mentioned at ESAP # 4, incorporate procedures in the Seafarer’s Employment Manual to enable anonymous filing of grievances with confidentiality protection.

However, there is a Whistleblowing Policy, which PSL staff can use to report any misbehaviors on a confidential basis without fear of retaliation.

Protecting the Work Force

The Seafarers Employment Manual establishes that no one below the age of 18 is to be recruited or trained by PSL. The policy also includes measures to prevent forced labor and exploitation. It indicates that no fees are to be charged to seafarers for recruitment or employment (except for medical certificates and visas) and that procedures are to be implemented to ensure that seafarers are not subject to exploitation.

Occupational Health and Safety

The IMS includes requirements on H&S as part of Seafarer’s Employment Manual and COVID-19 Management Manual. The project vessels have obtained certifications for ship security, safety management, MLC, ship safety equipment, ship safety construction, registered pharmacist inspection, ship sanitation, and cook competence. The vessels maintain records and documentation related to MLC compliance, H&S inspection, safety officer’s inspection, SOLAS, safety committee meetings, permits-to-work, pre-boarding health declaration, training, PPE usage, water quality monitoring, voyage planning and passage planning.

Safety statistics are reported regularly and include near misses, incidents/accidents, injuries, first aid, fatalities, grievances, and seafarers trained in HSE and analysis of incident trends. The number of incidents in PSL’s fleet (e.g., fire, explosion, serious injury or death of crew members, collisions, groundings, etc.) has declined steadily from 2015 onwards, and in 2020 only one incident was registered for the entire company fleet, which involved the death of a crew member due to natural causes. All the crew members undergo pre-employment medical checkup and are trained in first aid. The Master and the Officers receive more advanced medical training and the company also has a doctor on call in India and in Thailand, who have medical data from each of the crew members and can provide medical advice and follow up to the seafarers in their native language.

Workers Engaged by Third Parties

As indicated above, screening of contractors is undertaken by PSL. The project companies will, as mentioned at ESAP # 6, further strengthen the contractor screening and oversight procedure to include labor and working condition requirements of PS2 for contractor.                                                   

Resource Efficiency

The IMS includes relevant management measures to improve resource efficiency and Environmental Objectives. PSL has set several measurable environmental objectives which are monitored and records maintained including reductions in fuel and energy consumption, increased sludge disposal to shore facilities (instead of incineration), reductions in electricity and paper consumption in PSL’s offices, and minimization of vendor packaging.

Some of the measures being implemented to achieve these objectives include: voyage planning (improved voyage planning, weather routing, speed optimization, just-in-time, optimized shaft RPM); optimized ship handling (optimum trim, optimum ballast, optimum propeller consideration, optimal use of autopilot); hull maintenance (periodic hull and propeller cleaning as required; improved cargo handling, switch off power if idling); engine maintenance (optimum fuel inlet temperature and use of advance technology like improved fuel injection valves); energy management (optimum power utilization, run shaft generator only or one generator at sea, maximized use of waste heat recovery, steam wastage avoidance, steam traps adjustment); sludge disposal to shore facilities; other measures to reduce fuel and to minimize energy and waste footprint of PSL’s facilities; and crew training and awareness on resource efficiency. Such measures are described in the company’s annual report.

Greenhouse Gases and Air Emissions

The average fuel consumption of one vessel in 2020 was about 2650tons HFO and 16400 tons of MDO/MGO, amounting to about 62,000 tCO2e per vessel per annum. For the four cement carriers, the average CO2 emission was 27.584 grams CO2 per tonne-nautical mile and for Supramax (which includes APD), the average CO2 emission was 9.524 grams CO2 per tonne-nautical mile.  

The project vessels comply with relevant IMO requirements related to air emissions, have International Air Pollution Prevention Certificate, use low or very low sulfur fuel , use CO2 fire extinguishers (instead of halon) and have measures in place to minimize spills and dust generation during loading and unloading of cargo.

Waste and Wastewater Management

The averaged quantity of oil sludge disposed ashore per vessel in 2020 was about 38 m3, and the total food waste disposed (into the sea) per vessel was about 7 m3. The project vessels dispose of food waste, ballast water sediments, domestic waste, incinerator ashes, electronic waste, operational waste and plastic to onshore contractors.

In addition to the certifications listed above, the project vessels have in place procedures, equipment and facilities that meet IMO requirements related to: ballast water management;  garbage management; sewage treatment and disposal; sludge management; safe use of pesticides; prevention of pollution from oil and noxious liquids; hull and propeller cleaning; and anti-fouling system. Waste is segregated at source, hazardous waste is kept on board and disposed of ashore to licensed hazardous waste disposal facilities, and sewage is treated and effluent discharged at sea. Oil residues are disposed ashore to petrochemical recycling facilities.

The project vessels monitor and maintain records of: ballast water exchanges; bunker delivery; biofouling management; loading and unloading operation videos; hull and propeller cleaning; waste quantities; waste incineration; waste discharges; delivery to external facilities; sludge management and disposal. The project vessels have measurable environmental objectives including reductions in waste disposal at sea, reductions in food waste generation, increase in food waste and sludge disposal at port, and avoidance of excess provision inventory.

The project companies will, as mentioned at ESAP # 2, develop and implement duty of care procedures to verify and document how onshore contractors treat or dispose of all waste streams using chain of custody forms to be signed / stamped at the final disposal / treatment facility.

Ship Recycling

The project vessels maintain an inventory of hazardous materials (IHM), that meets the requirements of the ‘Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships’ (Hong Kong Convention), and IMO Guidelines. Three of the project vessels are also compliant with the EU Ship Recycling Regulation whilst the remaining two will become so after their next annual survey. Additionally, the company’s IMS includes procedures to prohibit/restrict the use of specific hazardous materials at the ship construction stage.

The inventory of hazardous materials is exhaustive and identifies the predefined hazardous materials that are contained in a ship’s structure or equipment, their location and approximate quantities. When end-of-life ships are sold for dismantling, the IMS requires that the recycling yard will prepare a ship recycling plan, based on the inventory of hazardous materials on board.

The project vessels are between six and nine years old. Accordingly, the project companies do not have any plans to send any of the project vessels for recycling. However, as mentioned at ESAP # 2, the project companies will articulate a policy and put in place procedures to ensure that if any of the project vessels are sent for recycling during the period of IFC’s loan, it will be sent to a shipyard that complies with the requirements of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.                                                   

 Shore Leave and Interaction with Communities

Project Vessel’s crew have to comply with a code of conduct for shore leave which specifies requirements related to drugs, pornographic material, offensive weapons, molestation and stalking, shoplifting, and possession or trading of wildlife products, but gender related aspects are not included. Further, guidance on H&S risks for crew members during shore leave is not included as part of the Seafarer’s Employment Manual.

Typically, port agents provide to the crew specific information regarding crew safety, cultural aspects and community health & safety risks during shore leave. The port agents are selected from a panel of agencies approved by the by the port authority. However, the communication with port agents is inconsistent in form and content and is not under a systematic procedure. In light of the above, the project companies will, as mentioned at ESAP # 2 and 7: update the code of conduct requirements in relation to shore leave to include local cultural gender norms; include general advice on H&S risks for crew members during shore leave as part of the Seafarer’s Employment Manual; and establish a systematic procedure to request information from port agents on potential risks to the crew during shore leave and potential community health and safety risks associated with shore leave, requesting specific information on risks for the crew related to criminality levels, robbery, kidnapping, violence, political conflicts, cultural sensitivities, gender sensitivities, STDs, harassment, drugs, alcohol, religious celebrations, etc.

Communicable Diseases

Seafarers undergo pre-employment health exams and awareness training is provided to them through safety videos related to communicable diseases. The project companies have instituted specific measures to minimize risks associated with COVID-19 pandemic including among other measures: pre-boarding screening (14 days of self-quarantine and COVID-19 negative test); online briefing prior to joining back; contingency measures and health care provisions in the vessels; ship-shore personnel exchange restrictions; training courses on epidemic prevention and control.

Emergency Preparedness and Response

The project companies and project vessels have in place plans and procedures for: distress and emergency situations; vessel contingency; shipboard oil pollution emergency; major casualty; and evacuation preparedness. The emergencies for which plans and procedures are in place include oil pollution, grounding/stranding/beaching, collision, fire and explosion, extreme weather, abandon ship, man overboard, medical emergencies and casualties, piracy, rescue actions in enclosed spaces, and machinery damage or loss of steering. The plans and procedures define roles, responsibilities, response equipment and materials to be used, emergency contact details as well as procedures for notification and reporting actions. Emergency drills are conducted periodically as per a drill and training schedule and records are maintained.

Security Personnel

The IMS includes a ship security plan and security procedures as per ISPS code that describe the response to foreseeable situations including stowaways and refugees. On some routes at risk of piracy, security contractors are hired and armed security guards embark in the ship. This is only applicable to one of the project vessels, the bulk carrier (APD). The project companies, prior to appointing a security contractor, confirm that the policies, procedures and training of the security contractor and personnel reflect the requirements of the International Code of Conduct (ICOC) for Private Military Security Companies, which are in line with UN Basic Principles on the Use of Force and Firearms and UN Voluntary Principles on Security and Human Rights. The project companies will, as mentioned at ESAP # 10, develop and implement a systematic screening procedure for security contractors which documents evidence that ICOC policies and procedures are being followed and that guards are trained in the UN Basic Principles on the Use of Force and Firearms and UN Voluntary Principles on Security and Human Rights.

In line with the IMS requirements, stowaways are not allowed to work on-board and their health and welfare is assured. Stowaways are though required to participate in emergency drills. Refugees are given food and water and their position is reported to the nearest Coastal State.                                                  

To minimize impact on marine environment, the project vessels implement IMO compliant anti-fouling systems, ballast water management, hazardous materials and waste management practices including adhering to restrictions on waste disposal in special areas. The project vessels have wake conditioning devices in place and hull cleaning and propeller cleaning are currently undertaken by the project companies to minimize underwater noise and this action will continue.

Protected Areas

The project vessels comply with IMO and protected area requirements in relation to marine protected areas (MPAs) and designated Particularly Sensitive Sea Areas (PSSAs). There are no PSSAs within Arabian Sea and near west coast of India. Hence, no MPAs or PSSAs are impacted by the routes of four cement carriers, that regularly ply on a route close to west coast of India. The bulk carrier (APD) follows different international routes based on demand, and therefore it could potentially cross PSSAs or MPAs.

Critical Habitat

A review of the Important Marine Mammal Areas (IMMAs) and Important Coastal and Marine Areas (ICMBAs) indicates that there are sixty-two ICMBAs that have been identified along the west coast of India including National Park, Wildlife Sanctuary, Conservation Reserve and Community Reserve. Sindhudurg-Karwar is the only IMMA located along the regular routes of the cement carriers. Sindhudurg-Karwar IMMA supports populations of Indian Ocean humpback dolphin [VU] and Indo-Pacific Finless porpoise [VU]. This IMMA is one of the top 10 IMMAs globally where target species are potentially at risk from bycatch, but it is not considered to be a high risk from merchant traffic. Also, the 62 ICMBAs are located right at the coast (mostly estuarine environments).

The regular routes of the cement carriers come close to the Sindhudurg-Karwar IMMA, but the IMMA is not impacted by the vessels, as it is parallel to the coast and the ships operate in deeper waters. Also, the 62 ICMBAs are not impacted by the project vessels as their regular routes do not cross the ICMBAs.

The bulk carrier travels on international routes on demand. Some of the routes it has taken in the past have crossed several IMMAs, including the Southern Gulf and Coastal Waters IMMA, the Oman Arabian Sea IMMA, the North East Arabian Sea IMMA and the South West to Eastern Sri Lanka IMMA. The presence of the species Balaenoptera musculus (blue whale) and Sousa plumbea (Indo-pacific humpbacked dolphin), and the Arabian Sea Humpback Whale (Megaptera novaeangliae) which are categorized as endangered by the IUCN, has been detected in these IMMAs.

The cement carrier project vessels will, as mentioned at ESAP # 8, maintain a 5 nautical miles (nm) buffer distance with the Sindhudurg-Karwar IMMA, and other IMMA as feasible, if weather and navigation conditions allow it. Further, as mentioned at ESAP # 8, the bulk carrier (APD) shall put in place plans and procedures (with roles and responsibilities) to: report collisions with whales to the International Whaling Commission (IWC), in line with the recommendations of the IWC-66; identify potentially sensitive areas, and the mandatory measures, recommendations and specific measures when crossing sensitive marine areas (e.g. IMMAs, slope of continental shelf and other such areas); reduce speed to 11.5 knots or less if individuals of threatened marine mammal species are identified within  2 km of the ship; training including annual refresher training of current and any new crew for monitoring and reporting sightings of marine mammals including preparation of specific materials to aid seafarers in the identification of marine mammals by members of professional marine mammal professional association; at least 2 trained crew members must be present on each voyage and present on the bridge; provision of infra-red binoculars (to be used by staff trained to observe marine mammals ); development of a reporting system to share information with non-governmental organizations (NGOs) and other conservation organizations studying marine mammals, such as, for example Global Biodiversity Information Facility; optimize route to minimize impacts on the sensitive areas; no discharge of waste within MPAs, PSSAs and sensitive areas; and, in sensitive areas, avoid to the extent possible, taking into account retention capacity and hygiene consideration, disposal of food waste.

When sensitive marine areas are identified, project vessels will adhere to the relevant legal obligations and guidelines, which may include a combination of the following:

1. Permanent routing measures through the designation of Areas to be Avoided (ATBA), Traffic Separation Schemes (TSS) or port approach routes.
2. Seasonal routing measures through the designation of Areas to be Avoided, Traffic Separation Schemes or port approach routes.
3. Voluntary routing measures through the designation of Areas to be Avoided, Traffic Separation Schemes or port approach routes.
4. Short term and dynamic routing measures implemented in response to observations of whale aggregations or Voluntary Dynamic Management Areas (DMAs), which are temporary protection zones triggered when three or more whales are sighted within 2-3 miles of each other outside of active Seasonal Management Areas and vessels are encouraged to avoid these areas or reduce speeds to 11.5 knots or less while transiting through them.
5. Permanent, seasonal or dynamic management areas for speed restrictions.
6. Rapid reporting network of whale sightings or acoustic detections to alert vessels transiting an area.