During the meeting, a number of delegations expressed some concerns regarding whether a scrubber system could be a more favourable treatment of ships equipped with a scrubber system, in comparison to ships using compliant fuel.


Commenting about the upcoming regulations in the industry, BIMCO said that they are increasingly restricting ships from discharging scrubber washwater certain sea areas, like ports, estuaries and coastal areas. For this reason, PPR has the responsibility to evaluate and harmonize the rules and guidance on the discharge of washwater from scrubbers.

Initial results from scientific studies modelling the accumulative effect of scrubber discharge in port shows very limited effect when compared to the EU water quality standards.

This is not an issue that will be decided soon, as finalization is expected in 2022

BIMCO stated.

In addition, MEPC 74 agreed on guidance for a malfunctioning scrubber. Namely, in case the scrubber fails, and the ship no longer complies with the sulphur-rules, it must change over to compliant fuel oil, if the scrubber cannot be put back into a compliant condition within one hour. The failure should also be properly reported in the EGCS Record Book.

The reason for a failure could be either a system error or a failure of a monitoring instrument, where the system malfunction cannot be rectified.

As BIMCO informed:

If the ship does not have compliant fuel oil or sufficient amount of compliant fuel oil on board, the ship should communicate a proposed course of action to the relevant authorities (including the ship’s administration), in order to bunker compliant fuel oil or carry out repair works. The authorities need to sign off on this course of action

The committee discussed, and agreed, on a full set of guidance on ECGS failure. The guidelines will be issued as an MEPC Circular shortly.

Overall, the Committee approved the subject Guidance as MEPC.1/Circ.884, applicable for those ships that will operate an exhaust gas cleaning system (EGCS) which will provide guidance to the attention of Administrations, port State control authorities, industry, relevant shipping organizations, shipping companies and other stakeholders concerned on how they should handle unexpected issues during the operation of an EGCS such as:

  • System malfunction that leads to emission exceedance;
  • Short-terms exceedances of the applicable Emissions Ratio;
  • Interim indication of on-going compliance in the case of sensor failure.