marpol annex vi - verification of compliance from

MARPOL Annex VI - Verification of

Compliance from Operators Perspective

Captain Sukhjit SinghMaster Mariner, MS International Management (Oil and Gas)Post Graduate Diploma (Maritime Energy Management)Deputy Director & Technical Head, MTCC Caribbean, The University of Trinidad and Tobago

The most challenging areas regarding MARPOL Annex VI

2/13/2020The Project is Funded by the European Union and

implemented by the International Maritime Organization 2

Total Inspections during CIC

Tokyo MoU: 6,604 Paris MoU: 4,311 India MoU: 1,007 Black Sea: 1,298

Basic Checks PrescribedBunker delivery notes

• To be kept on board for three years

• To be stored readily available for inspection

• Correct format of BDN as amended

Quality of fuel

• The fuel quality is also subject for inspection

• Delivery of fuel to be accompanied by representative fuel samples

• Fuel samples are to be sealed and signed by supplier and crew representative

• To be kept on board for 12 months from delivery

A fuel changeover (FCO) procedure must be in place

• Fuel oil service system to be fully flushed through, enabling the crew to calculate the starting time

Crew to be trained to handle challenges and manage risks

• Incompatibility of fuel oils / filter problems

• Low viscosity of distillate fuel / fuel pump failure and injection valve problems



Requirements• the International Air Pollution Prevention Certificate (IAPP Certificate) (regulation

VI/6), including its Supplement;

• the Engine International Air Pollution Prevention Certificate (EIAPP Certificate)

(paragraph 2.2 of the NOX Technical Code) including its Supplement, for each

applicable marine diesel engine

• the Technical File (paragraph 2.3.4 of the NOX Technical Code) for each applicable

marine diesel engine

• the bunker delivery notes (BDNs) and representative samples or records thereof

(regulation VI/18)

• the approved documentation relating to any installed Exhaust Gas Cleaning System

(EGCS) or equivalent means, to reduce SOX emissions (regulation VI/4)



Requirements• the copy of the type approval certificate of applicable shipboard

incinerator (resolutions MEPC.76(40) or MEPC.244(66));

• the Ozone Depleting Substances Record Book (regulation VI/12.6);

• the VOC Management Plan (regulation VI/15.6);

• any notification to the ship's flag Administration issued by the master

or officer in charge of the bunker operation together with any

available commercial documentation relevant to non-compliant

bunker delivery, regulation VI/18.2; and

• if the ship has not been able to obtain compliant fuel oil, the FONAR

• SEEMP Part I and Part II



If Clear Grounds Exists PSCO may inspect

• the master or crew are familiar with fuel oil bunkering procedures in connection to the respective bunker delivery notes and onboard records including the Oil Record Book Part 1 and retained samples as required

• the master or crew are familiar with the correct operation of an EGCS or other equivalent means on board together with any applicable monitoring and recording, and record keeping requirements

• the master or crew are familiar and have undertaken the necessary fuel oil changeover procedures, or equivalent, associated with demonstrating compliance within an Emission Control Area

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Bunker Delivery Note

• The Bunker Delivery Note (BDN) is the only legal document in case there is a bunker quantity and quality dispute, be it with the bunker supplier or the charterers.

• This is also the document that is used by external authorities to determine compliance with emission regulations. Hence, it is critical that the data entered in this document is verified prior to signing.

Why sample the fuel? • Bunker fuel oil quality testing is important as it helps reduce the risk of engine problems and forewarns the operator of any specific issues.

• It is important that the samples are representative of the bunkered fuel for the analysis results to be truly helpful. Prior to the commencement of bunkering, there should be an agreement on the location of the sampling point.

• Preferably this should be carried out at the ship’s manifold. The collection of the sample will be by continuous dripping and witnessed by all parties.

• Only those sample bottles whose filling was witnessed, should be sealed and the seal numbers recorded in the BDN.

• The analysis report should be available prior to the newly bunkered fuel being used and therefore sufficient reserves should be available on board.

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This is generic name. Not appropriate for orb entries.Need to check the msds if it is reflecting hsfoif not then must reject during pre bunkering meeting

Too high a temperature to load bunker.• Need to consider if vessel was loaded or in

ballast.• If loaded what was the cargo• Does the cargo have any temperature

restriction

Safe access is a requirement under SOLAS and ILO . The vessel is responsible for safe access under bunkering contract.Such comments may go against the vessel under charter party terms and BIMCO shipman agreement to demonstrate due diligence by the chief engineer to protect owner’s interest

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FONAR• Failure to make the notifications required

by MARPOL Annex VI, 18.2.4 may result in a vessel control (e.g., detention) and/or enforcement action.

• Consistent with MARPOL Annex VI, Regulation 18.2.1, the ship owner or operator should be prepared to present a record of the actions taken to achieve compliance, including evidence that they attempted to purchase compliant fuel oil in accordance with the vessel’s voyage plan.

• FUEL OIL NON-AVAILABILITY REPORT (FONAR)http://www.imo.org/en/OurWork/Environment/PollutionPrevention/Documents/Resolution%20MEPC.320%2874%29.pdf#page=12



http://www.imo.org/en/OurWork/Environment/PollutionPrevention/Documents/Resolution%20MEPC.320%2874%29.pdf#page=12

Before filing a FONARThe following should be observed by the ship/operator:

A fuel oil non-availability report is not an exemption. According to regulation 18.2 of MARPOL Annex VI, it is the responsibility of the Party of the destination port, through its competent authority, to scrutinize the information provided and take action, as appropriate.

In the case of insufficiently supported and/or repeated claims of non-availability, the Party may require additional documentation and substantiation of fuel oil non-availability claims. The ship/operator may also be subject to more extensive inspections or examinations while in port.

Ships/operators are expected to take into account logistical conditions and/or terminal/port policies when planning bunkering, including but not limited to having to change berth or anchor within a port or terminal in order to obtain compliant fuel.

Ships/operators are expected to prepare as far as reasonably practicable to be able to operate on compliant fuel oils. This could include, but is not limited to, fuel oils with different viscosity and different sulphur content not exceeding regulatory requirements (requiring different lube oils) as well as requiring heating and/or other treatment on board.



NON-AVAILABILITY OF COMPLIANT FUEL OIL CLAIMED

The master/owner may provide evidence as below to support their claim (not exhaustive):

• a copy (or description) of the ship's voyage plan, including the ship's port of origin and port of destination

• the time the ship first received notice it would be conducting a voyage involving transit/arrival in the port and the ship's location when it first received such notice

• a description of the actions taken to attempt to achieve compliance, including a description of all attempts that were made to locate alternative sources of compliant fuel oil, and a description of the reason why compliant fuel was not available (e.g. compliant fuel oil was not available at ports on the "intended voyage", fuel oil supply disruptions at port, etc.)

• the cost of compliant fuel is not considered to be a valid basis for claiming non-availability of fuel

• include names and addresses of the fuel oil suppliers contacted and the dates on which contact was made

• in cases of fuel oil supply disruption, the name of the port at which the ship was scheduled to receive compliant fuel oil and the name of the fuel supplier that is reporting the non-availability of compliant fuel oil

• the availability of compliant fuel oil at the next port-of-call and plans to obtain that fuel oil

• if applicable, identify and describe any operational constraints that prevented use of compliant fuel oil, e.g. with respect to viscosity or other fuel oil parameters

If, despite best efforts, it was not possible to procure compliant fuel oil the master/owner must notify the port State control authorities in the port of arrival and the flag Administration (regulation VI/18.2.4). 2/13/2020 13

Open Loop Scrubber Units

WASHWATER DISCHARGE CRITERIA AND MONITORING

• pH CRITERIA

• PAHs (Polycyclic Aromatic Hydrocarbons)

• Turbidity/Suspended Particle Matter

• Nitrates

• Washwater additives and other substances

2/13/2020The Project is Funded by the European Union and implemented by the

International Maritime Organization 14

Wash water Discharge not permitted from Open Loop Scrubbers



SCHEME A – EGC SYSTEM APPROVAL, SURVEY AND CERTIFICATION USING PARAMETER AND EMISSION CHECKS

SCHEME B – EGC SYSTEM APPROVAL, SURVEY AND CERTIFICATION USING CONTINUOUS MONITORING OF SOX EMISSIONS

Carriage Ban• The complementary amendment (Carriage ban on

HSFO) will enter into force on 1 March 2020.

• The complementary MARPOL amendment prohibits the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship - unless the ship has an exhaust gas cleaning system ("scrubber") fitted.

2/13/2020The Project is Funded by the European Union and implemented by the

International Maritime Organization 16

• It is intended as an additional measure to support consistent implementation and compliance and provide a means for effective enforcement by States, particularly Port State control.

• Carriage ban is not applicable to vessels fitted with an approved exhaust gas cleaning system or when the fuel is being carried as cargo.

• Fuel can be debunkered to another vessel to be carried as cargo or to an appropriate shipboard or land-based facility.

Guidelines to ensure a consistent implementation of the 0.50% sulphur limits for fuel oils:



• Resolution MEPC.320(74) Guidelines for consistent implementation of the 0.50% sulphurlimit (including the Fuel Oil non-Availability Report)

• Resolution MEPC.321(74) Guidelines for port state control (including how to handle nonavailability claims)

• MEPC.1/Circ.882 Guidance for port state control on contingency measures for addressing noncompliant fuel oil MEPC.1/Circ.883: Best Practice for member and coastal states

• MEPC.1/Circ.864/Rev.1 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships

• MEPC.1/Circ.884 Guidelines in case of failure and recommended actions for Exhaust Gas Cleaning Systems (EGCS)

• MSIB 005-19, New Procedure For Shipping Industry To Notify The US

Thank You !

[email protected]

www.mtcc-Caribbean.com