IMO Circular MEPC.1/Circ.795
At its 64th session, the IMO’s Marine Environment Protection Committee (MEPC) agreed on a number of Unified Interpretations (UI) seeking clarification of the terms “new ships” for Phases 1, 2 and 3, “major conversion” in regulation 2.24 of MARPOL Annex VI, and also clarification for the timing for existing ships to have on board a Ship Energy Efficiency Management Plan (SEEMP).
The UIs are given in MEPC.1/Circ.795 and the reasons for seeking clarifications are summed up as follows:
Definition of “new ships” for Phase 1, 2 and 3
The UI was required for practical reasons, namely that it is common commercial practice to place a single building contract with several ships of the same type to be delivered over a period of time. Since the attained Energy Efficiency Design Index (EEDI) for each ship depends on the basic design of the lead ship, it would be required to retain the longest period for each phase, unless the definition allows.
Definition of “major conversion”
The UI was necessary in order to actually better define the meaning of the term “substantial” in the context of a change an existing ship should undergo as to be considered going through a major conversion with regard to compliance with the EEDI regulations.
The interpretation in the attached document includes some examples for the meaning of the term “substantial” as an indication to the flag administrations which should make the decision.
UI for timing for existing ships to have onboard a SEEMP
The UI was necessary to clarify whether a SEEMP is required onboard existing ships as from 1 January 2013. The UI indicates that, for existing ships, an SEEMP is not required until its date of verification applies, namely the first intermediate or renewal survey after 1 January 2013.
SEEMP should be established in a working language or languages understood by the seafarers on board.
Source: INTERTANKO
