Paris MoU: How PSCOs can ensure compliance with MARPOL ANNEX VI

Regarding ship inspections, Paris MoU guidelines detail crucial steps in the process. For instance, upon pre-boarding preparation the PSCO should ascertain the date of ship construction and the date of installation of equipment on board which are subject to the provisions of the Annex, in order to confirm which regulations of the Annex are applicable.

On boarding and introduction to the master or responsible ship’s officer, the PSCO should examine various parameters, including -but not being limited to- the following documents:

1. The International Air Pollution Prevention Certificate (IAPP Certificate, regulation VI/6), including its Supplement.
2. The Engine International Air Pollution Prevention Certificate including its supplement, for diesel engines on 130 KW after 1 of January 2000, with the exception of emergency diesel engines installed in lifeboats and any device or equipment intended to be used solely in case of emergency.
3. The Technical File for each applicable marine diesel engine.
4. Depending on the method used for demonstrating NOx compliance for each applicable marine diesel engine:
   a) the Record Book of Engine Parameters for each marine diesel engine demonstrating compliance with regulation VI/13 by means of the marine diesel engine parameter check method; or
   b) documentation relating to the simplified measurement method; or
   c) documentation related to the direct measurement and monitoring method;
5. The approved documentation such as SOx Emission Compliance Certificate where issued, EGC SOx Technical Manual, Onboard Monitoring Manual , SOx Emission Compliance Plan and relating to any installed Exhaust Gas Cleaning System or equivalent means, to reduce SOx emissions (regulation VI/4).

Deficiencies warranting detention

In order to assist the PSCO in the use of these Guidelines the following list describes situations of such, a serious nature, taking regulation VI/3 into account, that they may warrant the detention of the ship involved:

1. Absence of valid IAPP Certificate, EIAPP Certificates or Technical Files, if applicable
2. A marine diesel engine, with a power output of more than 130 kW, which is installed on board a ship constructed on or after 1 January 2000, or a marine diesel engine having undergone a major conversion on or after 1 January 2000, which does not conform to its Technical File.
3. A marine diesel engine, with a power output of more than 5,000 kW and a per cylinder displacement at or above 90liter, which is installed on board a ship constructed on or after 1 January 1990 but prior to 1 January 2000.
4. On ships not equipped with equivalent means of SOx compliance, the sulphur content of any fuel oil being used or carried for use on board exceeds the applicable limit required by regulation VI/14.
5. On ships equipped with equivalent means of SOx compliance, absence of an appropriate approval for the equivalent means, which applies to relevant fuel combustion units on board.
6. Non-compliance with the relevant requirements while operating within an Emission Control Area for SOx and particulate matter control
7. An incinerator installed on board the ship on or after 1 January 2000 does not comply with requirements contained in appendix IV to the Annex, or the standard specifications for shipboard incinerators developed by the Organization.
8. The master or crew are not familiar with essential procedures regarding the operation of air pollution prevention equipment.

Reporting

Any deficiency found should be recorded as an individual deficiency. If an inspection indicates that a ship has emitted any of the substances covered by the Annex, in violation of the provision of the Annex, a report shall be forwarded to the Administration for any appropriate action, taking into account the requirements of regulation VI/11.

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