The Australian Maritime Safety Authority (AMSA) has published a Marine Notice to address the risks associated with the use of engine power limiters (EPL) and similar power restriction systems on ships.
The notice provides essential guidance for ship operators, masters, navigational officers, and AMSA-licensed coastal pilots to ensure that these systems do not compromise the safety and maneuverability of vessels in these critical waters. The notice also outlines regulatory requirements and best practices for managing these power-limiting systems to support both safe navigation and compliance with international energy efficiency standards.
SOLAS Chapter V, Regulation 34, via the cascading requirements found in IMO Resolution A.893(21), requires voyage planning to take into consideration:
- Ship maneuvering characteristics
- Known navigation hazards
- Environmental conditions
Accordingly, engine-limiting devices should be considered as part of the voyage planning appraisal, including when considering:
- Frequency of course
- Speed changes necessary
- Duration of transits in restricted waters
- Whether an override may be required during operation in confined waters
Operators of ships with an engine-limiting device installed are expected to indicate this in their:
- Pilot cards
- Wheelhouse poster
- Maneuvering booklet
It is also a requirement under the International Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code) that a risk assessment is in place that would consider immediate access to override an EPL when the ship’s full maneuverability is required to ensure safe passage. Hence, AMSA’s expectation is that such a risk assessment be in place and available upon request when navigating through the Australian coastal pilotage areas.
Masters and OICNW should be familiar with any load-limiting or automatic acceleration-limiting devices fitted onboard the ship and be familiar with the operation of their overrides. Ships are expected to be able to answer all engine and helm commands provided by a pilot at all times while underway in a coastal pilotage area.
Pre-boarding Requirements for Coastal Pilots and Pilotage Providers
Pilots should be familiar with the changing environment in which they operate. The addition of ShaPoLi or EPL to ships means that pilots may need to adapt their approach to coastal pilotage.
Pilotage providers should ensure that their Master-Pilot Exchange (MPX) process specifically includes a requirement for the pilot to verify the existence (and potential limitations) of any EPL (or similar power limitation arrangement) onboard, prior to the pilot taking the con.
Pilotage providers should obtain (at least) the following information as part of the pre-boarding communication with the ship/operator:
- Is the ship equipped with an engine or shaft power limiter? If yes, is the limiter mechanical or software-based?
- If the ship is equipped with a mechanical limiter, will it be removed or disabled prior to the pilot boarding the ship?
- If the ship is equipped with a software-based limiter, will the ship’s crew be able to override it immediately at the request of the pilot?
- Can the main engine(s) attain the posted maneuvering power (RPMs) without delay?
- Are the master and all bridge navigational watchkeepers familiar with the override feature for the EPL (if fitted)?
- Does the vessel have a risk assessment with appropriate control measures in place for immediate access to the EPL when full maneuverability is needed for safe passage?
Based on the responses to the questions above, the pilotage provider and the assigned pilot should decide if they need to conduct a targeted risk assessment of the planned passage before boarding. This will determine if the ship’s maneuverability presents a significant risk to the conduct of a safe passage, noting the expected environmental factors and the scheduled timing of the passage.
If the pilotage provider’s risk assessment indicates the ship’s maneuverability presents a significant risk, the provider should consider implementing extra control measures like weather, tidal, and/or timing restrictions to address the risk.
The pilotage provider should notify AMSA immediately (via email to [email protected]) if:
- The pilot card onboard the ship does not reflect the existence of an EPL (or similar arrangement), where such a system exists; and/or
- Any additional controls are intended to be implemented after a risk assessment is conducted for any particular voyage.
