ABS: 3 key steps for compliance with CII

ABS has issued a regulatory update to remind that on November 1st, 2022, amendments to MARPOL Annex VI will enter into force and set the stage for the implementation of the Carbon Intensity Indicator (CII) beginning 1 January 2023.

In that regard, operators need to revise the existing Ship Energy Efficiency Plan to include a Part III for Carbon Intensity Indicator (CII), calculation and rating in order to conform with the revised MARPOL Annex VI accordingly.

There is limited time remaining to prepare for compliance with this new regulatory scheme aimed at limiting and reducing the operational carbon intensity of specific vessel types, and pushing operators to make choices that optimize fuel efficiency

…ABS highlighted and suggested the following three key steps for compliance:

#1 Step: Submissions for Technical Review
Submit SEEMP Part III for review and verification. A verified SEEMP Part III and its corresponding Confirmation of Compliance must be provided onboard prior to 1 January 2023.

#2 Step: Preparation for Company Audits
Prepare for company audits in accordance with MEPC.347(78). These periodical company audits may include annual audits of the company (company audits) and verifications on board the ship (shipboard audits) which may coincide with ISM Code audits

#3 Step: Maintaining Compliance
If future vessel modifications affect the SEEMP Part III, then re-verification is required. Regardless of the above, re-verification of the SEEMP Part III will be required every 3 years due to the update of the 3-year CII implementation plan.

With regards to SEEMP Part III the following should be included:

1) a description of the methodology that will be used to calculate the ship’s Attained Annual Operational CII and the processes that will be used to report this value to the ship’s Administration;

2) the Required Annual Operational CII for the next three years;

3) an implementation plan documenting how the Required Annual Operational CII will be achieved during the next three years; and

4) a procedure for self-evaluation and improvement.

Furthermore, ABS notes that the three-year implementation plan should be SMART (Specific, Measurable, Achievable, Realistic, and Timebound) to the extent feasible and it should include:

List of measures with time and method of implementation for achieving the required operational CII
How the required operational CII will be achieved considering the combined effect of the measures
The personnel responsible for:
o the three-year implementation plan
o monitoring and recording performance throughout the year
o reviewing the effectiveness of the implementation plan
Identification of possible impediments to the effectiveness of the measures, including possible
contingency measures

The SEEMP Part III must receive verification and be placed onboard each ship prior to 1 January 2023. Upon successful completion of the technical review, the vessel will be issued a new Confirmation of Compliance (CoC) to document the verification. This will be issued separate from the SEEMP Part II Confirmation of Compliance (related to the IMO Data Collection System on fuel oils). The SEEMP Part III CoC is to be retained onboard and will remain valid until any revisions are necessary for the SEEMP Part III, in which case the document must be resubmitted for verification.

With regards to CII regulation, a review is to be completed by 1 January 2026 by IMO to assess:

1. the effectiveness of the regulation in reducing the carbon intensity of international shipping;
2. the need for reinforced corrective actions or other means of remedy, including possible additional EEXI requirements;
3. the need for enhancement of the enforcement mechanism.
4. the need for enhancement of the data collection system
5. the revision of the Z factor and CIIR values

EXPLORE MORE AT ABS Regulatory Update