Key results
During the period from September 2018 to November 2018, a total of 13,220 inspections conducted as follows:
- Tokyo MoU: 6,604 Inspections
- Paris MoU: 4,311 Inspections
- India MoU: 1,007 Inspections
- Black Sea: 1,298 Inspections
Given that only 13 vessels were detained during the CIC period for non-compliance with related regulations, the status of MARPOL Annex VI performance is considered to be very good. Namely, the following detentions were recorded:
- Tokyo MoU – 4 detentions
- Paris MoU – 8 detentions
- Indian MoU- 1 detention
The most common deficiencies were related to Bunkering Delivery Notes, Sulfur content compliance, Ozone depleting Substances and Incinerator Use.
The main categories of detainable deficiencies were:
The most challenging areas regarding MARPOL Annex VI, are considered to be the ECA compliance (fuel changeover and sulfur content), combined with bunkering procedure and especially the Bunkering Delivery Note compliance.
How to avoid such deficiencies
#1 Focus on procedures
Clear procedures should be provided through SMS or other onboard document covering the following sections;
- When and how to conduct the changeover procedure
- Preparations and actions prior-during and post bunkering
- Use of incinerator and limitations
- Written instructions for record keeping (Logs, Checklists etc)
#2 Focus on documentation
All required documentation should be available and especially:
- Ozone Depleting Substances Log
- Change over log
- Bunkering Plan (approved by Company)
- Technical files for all related equipment
- Maintenance and test records
- Calibration tests and results
#3 Focus on Training
All the above should be supported by an adequate training and familiarization program which should be periodically reviewed for effectiveness. Company’s superintendents should provide such training in every opportunity, in order to enhance crew competence regarding MARPOL Annex VI requirements.
