Kostas Vlachos, Chief Operating Officer, Consolidated Marine Management Inc., addressed the “Challenges on the implementation of the EU MRV” from the Ship Manager Perspective at the 2017 GREEN4SEA Conference. Mr. Vlachos focused on the preparation of the Monitoring Plan and suggested that a Risk based approach is certainly required. He further presented the required Data Flow Activities for the control of data and referred to issues concerning the Quality assurance and Reliability of IT along with the required Internal Reviews and Validation of data.
Ship operators are currently facing many challenges with the implementation of the EU MRV plan which takes into consideration the EU Regulation about the MRV and requires assessment by an accredited verifier until August 31st, 2017.
Our opinion is that the EU MRV plan is a new complete management system because:
- New Detailed and prescriptive procedures and records are required with new roles duties and responsibilities
- Documentation control for amendments and new versions and storage of records of MP system are required
- Development of Risk Assessments for a Flow Chart of Activities
- New Maintenance and calibration processes are established for instruments that in the past they were not in the maintenance plans of the company
- Internal and external assessment and verification is required
- Periodical Management Review is required
- New Document of compliance covering vessel and company is issued.
In fact, we believe that new bureaucratic system is created with new meanings for shipping such as Materiality, Uncertainty, Inherent Risk, Control Risk, Detection Risk, completeness, accuracy, Consistency, transparency and relevance of information as per ISO 14064. It brings additional administrative workload to the ship personnel putting at risk the safety of the ship and the personnel onboard. The MP compromises the real controls for restriction of emissions and pays a special attention to the system rather to the human and the environment. Also, we believe, that the MP contains grey areas and introduces a verification process with complex levels of verification such as the independent reviewer.
Its contents are divided into six main sections:
A. Revision record sheet
B. Basic Data
C. Activity Data
D. Data Gaps
F. Further Information
Regarding the Monitoring of fuel consumption, the following issues are important:
- Methods used to determine fuel consumption of each ES;
- Procedures for determining fuel bunkered and stock takes in FT
- CROSS –CHECKS between BDN and stock takes;
- Description of measurement equipment involved;
- Procedures for recording, retrieving, transmitting and storing information regarding measurements;
- Method for determination of density;
- Level of uncertainty associated with fuel monitoring;
- Procedure for ensuring quality assurance of measuring equipment
- Method for determining and recording the FC on laden voyages
Also, you will need to declare in the MP which of the following methods you will follow in order to determine the fuel consumption for each emission source:
- Bunker Fuel Delivery Note (BDN) and periodic stock takes of fuel tanks;
- Bunker fuel tank monitoring on board;
- Flow meters for applicable combustion processes;
- Direct CO2 emission measurements
The level of uncertainty is something new and its verification is very important. In particular, the EU MRV Legislation states “The Company should complete and document an uncertainty assessment for each method selected”. The factors that may affect the uncertainty are the Equipment, the Processes, the People, the Material, the Environment and the Management systems that you apply.
Also companies have the obligation to report the voyages and should develop procedures for the list of voyages coming under the monitoring scheme. Software based on noon reports, departure and arrival reports shall make an extract of the required voyages. The department and the person in charge shall be reported. Attention is needed the voyage to cover berth to berth and not pilot to pilot. Also, validation of the data is required as well as control of risks related of potential errors, omissions or misrepresentation and processes for collecting, processing, consolidating and reporting List of voyages and information.
The table herebelow compares the EU MRV and the IMO system for CO2 ship emissions.
|EU MRV||IMO Fuel Data Collection System|
|Monitoring||Ships 5000 GT and above for per Voyage to/from EU port monitoring and on an annual basis |
EU Monitoring Plan
Starting 1st January 2018
|Ships 5000 GT and above|
Annual basis for ALL voyages
Updated SEEMP (Part II)
Starting 1st January 2019`
|First monitoring period||2018||2019|
|Exemptions||Warships, naval auxiliaries, fish-catching / processing ships, ships not propelled by mechanical means and government ships used for non-commercial purposes||TBD|
|Parameters||Amount and emission factor for each type of fuel consumed|
CO2 emitted per voyage falling in EU MRV/per annum
Total Transport work
Total Distance travelled
Total Time at sea & in port
Average Energy EFFICIENCY
|Total Annual Fuel consumption |
Distance travelled over ground (O/G)
|Reporting||All the above parameters|
Port of Registry
Name of Shipowner
Name of company with address, email and details of contact person
EEDI or Estimated Index Value (EIV)
Identity of verifier
Ice class if applicable
|All the above parameters|
EEDI if applicable
Ice class if applicable
|Verification||EU accredited verifiers|
ISO standard procedures for the assessment of MP and verification of ER
|Flag Administration/ recognized organisations|
|Reports to||European Commission||Flag state|
|Certification||Document of Compliance (June 2019)||Statement of Compliance|
|Publication||Distinctive public database||Anonymous public database|
- A very heavy NEW management system is created, if someone develops well and in depth
- Challenged areas for the shipping with new procedures and meanings (don’s underestimate the meanings)
- A great attention should be given to the determination of uncertainties and data gaps;
- A thorough risk assessment should develop with the aim to identify and control the inherent, the control and detection risks and minimize the uncertainties;
- A detailed flow chart of activities should be prepared for better control;
- Validation of the data is needed, including any predetermined materiality thresholds, especially for IT software
- Operational and control procedures shall be implemented to ensure the quality, integrity and security of the information.
- A well competent verifiers with a good experience on business activities is required to be selected by EU
Above text is an edited article of Kostas Vlachos presentation during 2017 GREEN4SEA Conference & Awards
You may view his presentation video by clicking here
|Click here to view all the presentations of 2017 GREEN4SEA Conference & Awards|
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
Kostas Vlachos, Chief Operating Officer, Consolidated Marine Management Inc.
Kostas Vlachos is Mechanical / Electrical Engineer graduated from Technical University of Athens in 1981. From 1982 to 1996 he served in the Merchant Ships Inspectorate of the Greek Ministry of Merchantile Marine in various positions with the most important that of MARPOL Convention department head and ISM implementation department head. In the same period he was a Member of the Greek delegation in IMO as well as in various EU committees and subcommittees in Maritime Safety Committee and MEPC (Marine Environment Protection Committee). In 1997 he joined the Consolidated Marine Management Inc. as DPA/DMR and as Marine, Safety & Quality Manager.In February 2005 he assumed the duties of the COO/Managing Director of the Company having full control and responsibilities on all activities and dpts of the Company. He is a member of ABS, DNV, LRS, technical committees. In 2013 was elected Chairman of Intertanko Hellenic Mediterranean Panel & Council member. Since 2014 he is a member of the executive committee of Intertanko, and ISTEC member.