MARPOL Annex VI sets limits on sulphur- and nitrogen oxide emissions from ship exhausts and prohibits deliberate emissions of ozone-depleting substances and volatile organic compounds.

The main objectives of this CIC are to:

  • establish the level of compliance with the requirements of MARPOL Annex VI within the shipping industry;
  • create awareness amongst ships’ crew and ship owners with regard to the importance of compliance with the provisions of MARPOL Annex VI and the prevention of air pollution;
  • send a signal to the industry that prevention of air pollution and enforcement of compliance with applicable requirements is high on the agenda of both MoU member States; and
  • underline the responsibility of the Port State Control regime with regards to harmonised enforcement of compliance with the requirements of MARPOL Annex VI, thus improving the level of compliance and ensuring a level playing field.

Namely, the CIC Questionnaire examines the following items:

Q1: Are bunker delivery notes, with details of fuel oil for combustion purposes, kept available on board for the required period of 3 years? (Annex VI, regulation 18.5 and 18.6)

Q2: Do bunker delivery notes indicate that fuel oils delivered and used on board is not exceeding the maximum allowed Sulphur content, as appropriate? (Annex VI, regulation 14.1.2 and 14.4.3)

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? (Annex VI, regulation 14.6)

Q4: Are alternative arrangements, (e.g. scrubbers) installed on board according to regulation 4.1 approved by the flag State? (Annex VI, regulation 4.1)

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? (Annex VI, regulation 14.6)

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?(Annex VI, regulation 12.6)

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? (Annex VI, regulation 13.7.1.1)

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?(Annex VI, regulation 16.8)

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? (Annex VI, regulation 15. 6)

Q10: Does the ship keep on board a Ship Energy Efficiency Management Plan (SEEMP) (Annex VI, regulation 22 paragraph 1)

Q11: Is the ship detained as a result of this CIC?

Ship managers are advised to get prepared and address all items as appropriate; in this context, SQE MARINE has prepared a best practice guidance which analyses each question of  CIC Questionnaire, recommending actions in order to assist operators comply with the requirements.

A ship will be subject to one inspection under this CIC during the period of the campaign. Port State Control Officers (PSCOs) will use a list of 11 questions to assure that equipment carried onboard complies with the relevant statutory certificates, the master and officers are qualified and familiar with operations and that equipment is properly maintained and functioning.

The questionnaire for the CIC was approved during Paris MoU's 51st Committee meeting in Cascais, Portugal, in early May, where members also agreed to an information campaign by issuing a “Letter of Warning” starting 1 January 2019, to encourage timely compliance ahead of the new maximum limits for sulphur in ships fuel oil, entering into force on 1 January 2020.

If deficiencies are found, actions by the port State may vary:

--> from recording a deficiency and instructing the master to rectify it within a certain period of time
--> to detaining the ship until the serious deficiencies have been rectified.

It is expected that the Tokyo and Paris MoUs will carry out approximately 10,000 inspections during the CIC. The results of the campaign will be analysed and findings will be presented to the governing bodies of the MoUs for submission to the IMO.

In a joint statement, Secretary Hideo Kubota and Secretary General Richard Schiferli note:

Effective and uniform enforcement is a prerequisite for ensuring cleaner air and the full environmental impact of the regulation. In practice, this requires a high priority on enforcement and strong and effective cooperation between national port State control authorities.

Similar CICs on MARPOL VI will run in the Black Sea MoU and the Indian Ocean MoU on 1 September-30 November, to check compliance with air pollution prevention requirements and to boost awareness of the 2020 sulphur cap.

The questionnaire may be found herebelow: