A policy paper released by Pacific Environment reveals that there is a huge body of scientific work and studies that show that Exhaust Gas Control Systems (ECGS) – otherwise known as scrubbers – are detrimental to the marine environment, wildlife and people’s health.
As informed, recent scientific studies show that scrubber discharge is extremely toxic to marine life at very low concentrations, and scrubber discharge may have a serious impact on the populations of key species of marine food webs. Pacific Environment has compiled 26 recent studies showing the breadth and depth of new and substantial data, making the case for why the U.S. Environmental Protection Agency must ban scrubber discharge.
The Biden administration and the U.S. Environmental Protection Agency should respond to these increasing environmental threats and lessen health risks by banning scrubber discharges in U.S. waters, as they finalize pending regulations under the Vessel Incidental Discharge Act (VIDA). VIDA requires the EPA to develop national standards of performance for incidental discharges. The EPA issued a Notice of Proposed Rulemaking in October 2020, but the rule has not yet been finalized.
Significant impacts to the environment
- Use of scrubbers on ships burning heavy fuel oil (HFO) leads to even greater marine pollution and air emissions than use of HFO without scrubbers due to the additional energy demand and concentrated marine pollution.
- Additionally, scrubber discharge is still not well characterized and understood relative to marine and environmental impacts from PAHs derivatives and downstream compounds formed; thus the testing regime is even more limited as to not understanding the impacts of these compounds.
Substantial data has been published since EPA’s 2020 initial consideration to regulate scrubbers. This new information documenting the harms to our marine environment and wildlife compels action now. More than 90 jurisdictions across the globe have enacted scrubber discharge bans and restrictions — and the United States should follow their lead.
…Kay Brown, Arctic Policy Director, Pacific Environment, said.
In a summary of restrictions on discharges from Exhaust Gas Control Systems, dated August 11, 2020, EPA concluded that “insufficient data exist at this time to warrant prohibiting these discharges under the Clean Water Act. Technical committees at the IMO (International Maritime Organization) are currently revisiting the need to perform additional assessments of environmental impacts from EGCS discharges, and EPA will continue to monitor the availability of research findings compiled in connection with these discussions.”
Substantial data has been published since EPA’s 2020 consideration of regulating scrubbers and this new information documenting harms justifies and compels action now. In addition, the IMO has essentially ceded the opportunity for near-term regulation of scrubbers to nations, regions and local authorities.
Background
In September 2023, Pacific Environment and Ocean Conservancy, in partnership with our allies, submitted a letter with 45 signatories to the Biden administration that includes seven specific recommendations, including a call to phase out and ban the use of sulfur scrubbers on ships in U.S. waters. In June 2024, we added 23 signatories for a total of 68 signatories, including industry groups and non-governmental organizations.
