SQE MARINE recommends best practices to check compliance with the applicable requirements of the MARPOL Annex VI for the forthcoming CIC which will be held for a period of three months by Paris, Tokyo, Black Sea and Indian MoUs.
The CIC questionnaire has been recently released featuring eleven items related to MARPOL Annex VI which sets limits on SOx and NOx emissions from ship exhausts and prohibits deliberate emissions of ozone-depleting substances and volatile organic compounds.
In this regard, ship managers are advised to get prepared and address all items as appropriate and the following guidance could assist toward that end as it analyses each Question, recommending actions to help operator comply with the CIC requirements. High attention is required to comply with all appropriate fuel oil requirements such as fuel oil handling, use, documentation, sampling and other related operations.
In addition, some issues related to MARPOL Annex VI may include also the EU MRV compliance and the IMO data collection issues as all of them include fuel oil handling requirements, SQE MARINE notes, recommending a Fuel Oil Management Plan to be on board in order to provide guidance and implementation solutions to crew members. Other items related to MARPOL Annex VI are: SEEMP (Part I&II), EU MRV Plan, VOC Management Plan & Ozone depleting Substances Record Book.
Best Practice Guide
Analysing each item of the CIC questionnaire to be used in the forthcoming Concentrated Inspection Campaign ( Sept 1 – Nov 30, 2018), SQE MARINE recommends the following in order operators to comply with MARPOL Annex VI requirements:
Q1: Are bunker delivery notes, with details of fuel oil for combustion purposes, kept available on board for the required period of 3 years?
BDNs provided by bunker suppliers should be in accordance with MARPOL annex VI requirements, including all relevant parts, dully signed and stamped and must be kept on board for 3 years. A specific file is suggested to be part of Fuel Oil Management Plan or stand alone in order to file all related bunkers documentation, numbered by the date /port /supplier.
Q2: Do bunker delivery notes indicate that fuel oils delivered and used on board is not exceeding the maximum allowed Sulphur content, as appropriate?
BDN (as per MARPOL Annex VI) is to include the % Sulfur content of delivered fuel. In case this exceeds the maximum allowed Sulfur vessel has to notify, Company, Bunker provider, Flag administration and classification society issuing the relevant letters of protests as per Safety Management System and Fuel Oil Management Plan. Samples received to be used for sulfur content verification.
Q3: Do ships which are using separate fuel oils to comply with the maximum sulphur content of 0.1% m/m in fuel oil while operating in SOx emission control areas, have a written procedure showing how fuel oil change-over is to be done for achieving compliance with the above requirements when entering SOx emission control areas?
In order to comply with ECA or other Local requirements (eg. EU Ports, China’s ECA, Hong Kong and Taiwan ports low sulfur requirements, Turkish ports etc), vessel have to change the fuel used in main fuel consumers with applicable fuel with sulfur % content not exceeding the requirement (0.1% in ECAs or Local). The changeover procedure should be engine specific and step by step in order to provide safe transition from one fuel type to other. Temperature and viscosity are some of the main concerns of the process and detailed guidance should be provided on such issues in order to protect Fuel Pumps and other machinery from failure. The time of completing each change over should also be taken into account as when reaching the limit of area (ECA or Local) vessel should be operated with fuel with the appropriate % sulfur content.(see also Question No 5)
Q4: Are alternative arrangements, (e.g. scrubbers) installed on board according to regulation 4.1 approved by the flag State?
In case of scrubber installations, these should be approved by Flag Administration for compliance with MARPOL Requirements.
Q5: Do ships which are using separate fuel oils to comply with the maximum sulphur content of 0.10% m/m in fuel oil and entering or leaving SOx emission control areas, record detailed information showing that the ship has completed/initiated the change-over in the logbook prescribed by the Administration?
Vessels have to complete change over procedure PRIOR entering restriction Area (ECA or Local). As the time for change over depends (e.g. number of settling and service tanks used), appropriate entries on logbooks (bridge/Engine room) are to be made. Starting and ending positions (latitude-longitude) and relevant times to be marked as required. Such entries are subject to PSC inspection for MARPOL Annex VI compliance.
Q6: Do ships which have rechargeable systems containing ozone depleting substances (refer to the supplement to the IAPP Certificate, item 2.1), have the ozone-depleting substances record book maintained?
Vessels using rechargeable systems containing Ozone Depleting Substances, should have a detailed ODS record book in order to enter the onboard quantity used by different systems and any maintenance / modification to such systems. Leak test that conducted to ensure the safe storage and leakage avoidance are to be recorded also.
Q7: Where an Approved Method in accordance with Annex VI, regulations 13.7.1-13.7.5 (refer to the supplement to the IAPP Certificate, item 2.2.1) is installed, has such an installation been confirmed by a survey using the verification procedure specified in the Approved Method File, including appropriate notation on the ship’s International Air Pollution Prevention Certificate of the presence of the Approved Method?
Any modification (for NOx compliance) based on regulation MARPOL Annex 13.7, should be approved in accordance with IMO MEPC.1/Circ.743 17 February 2011. All related information and records should be available for inspections and IAPP supplement should include same.
Q8: For ships equipped with a shipboard incinerator or thermal waste treatment device installed as an alternative arrangement, is the ship’s crew responsible for the operation of the equipment familiar with, properly trained in, and capable of implementing the guidance provided in the manufacturer’s operating manual?
As incineration is part of Garbage handling a detailed Garbage management plan should be onboard and describe the incineration procedure. Personnel involved with incineration should be familiar with the used of equipment and the restrictions for garbage categories to be incinerated along with the area restrictions for incineration. Training records to be available for inspection.
Q9: Are the master and crew familiar with essential shipboard procedures in the approved VOC Management Plan relating to the prevention of air pollution from ships?
This manual is applicable to crude oil carriers. The purpose of this plan is to ensure that the operation of the vessel prevents, or minimizes VOC emissions to the extent possible, as well as to provide written, ship-specific, operational procedures for the crew in order to minimize VOC emissions during the following operations:
- Loading
- Carriage of relevant cargo (transit)
- Crude Oil Washing
VOC emissions can be prevented or minimized by optimizing operational procedures to minimize the release of VOC emissions and using devises, equipment or design changes to prevent or minimize VOC emissions.
The plan should be approved by Flag Administration (or Recognized Organization on behalf of it).
Q10: Does the ship keep on board a Ship Energy Efficiency Management Plan (SEEMP)?
A Ship Energy Efficiency management Plan should be available on board. The SEEMP has been divided to two parts.
PART I: Includes all related procedures for Energy Efficiency Inspection, Monitoring, Review, Objectives, Targets and Action Plans. Responsibilities and relevant KPIs should also be included. PART I is NOT SUBJECT to approval by flag administration.
PART II: Cover the requirement for IMO data collection regarding fuel consumption. The calculation method and the reporting methods are to be included in this part. PART II is subject to Flag Administration (or Recognized Organization on behalf of it) APPROVAL. All vessel subject to MARPOL Annex VI regulation 22A should have an approved SEEMP Part II on board up to 1st January 2019 in order to start collecting data for IMO Data Collection System.
