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A joint Concentrated Inspection Campaign regarding MARPOL Annex VI announced by Paris and Tokyo MoU. Black sea and Indian MoU will also take part to this CIC in accordance with relevant press releases. This inspection campaign will be held for a period of three months, commencing from 1 September 2018 and ending 30 November 2018.

Aim of CIC

The aim and scope of the CIC is 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 harmonized enforcement of compliance with the requirements of MARPOL Annex VI, thus improving the level of compliance and ensuring a level playing field

Questionnaire

The questionnaire that issued and adopted for the CIC is an eleven items questionnaire checking of MARPOL Annex VI regulations implementation. For information on the items that the PSC inspectors will be especially looking into, please refer to Annex 1 with the questionnaire that they will be referring to report the results of the inspection.

Actions required

Ship managers should be prepared for the questionnaire and address all items as appropriate. As the fuel oil requirements is the base of air emission then the fuel oil handling, use, documentation, sampling and other operations should be addressed.

Some issues related to MARPOL Annex VI may include also the EU MRV compliance and the IMO data collection issues as all of them include fuel oil handling requirements.

 

Annex 1: MARPOL Annex VI CIC Questionnaire
  1. 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)
  2. 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)
  3. 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)
  4. Are alternative arrangements, (e.g. scrubbers) installed on board according to regulation 4.1 approved by the flag State?
    (Annex VI, regulation 4.1)
  5. 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)
  6. 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)
  7. 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)
  8. 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)
  9. 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)
  10. Does the ship keep on board a Ship Energy Efficiency Management Plan (SEEMP)?
    (Annex VI, regulation 22 paragraph 1)
  11. Is the ship detained as a result of this CIC?
Annex 2: Best Practice Guide

1. Are bunker delivery notes, with details of fuel oil for combustion purposes, kept available on board for the required period of 3 years?

BDNs provided by bunker suppliers should be in accordance with MARPOL annex VI requirements, including all relevant parts, dully signed and stamped and must be kept on board for 3 years. A specific file is suggested to be part of Fuel Oil Management Plan or stand alone in order to file all related bunkers documentation, numbered by the date /port /supplier.

2. Do bunker delivery notes indicate that fuel oils delivered and used on board is not exceeding the maximum allowed Sulphur content, as appropriate?

BDN (as per MARPOL Annex VI) is to include the % Sulfur content of delivered fuel. In case this exceeds the maximum allowed Sulfur vessel has to notify, Company, Bunker provider, Flag administration and classification society issuing the relevant letters of protests as per Safety Management System and Fuel Oil Management Plan. Samples received to be used for sulfur content verification.

3. 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?

In order to comply with ECA or other Local requirements (eg. EU Ports, China’s ECA, Hong Kong and Taiwan ports low sulfur requirements, Turkish ports etc), vessel have to change the fuel used in main fuel consumers with applicable fuel with sulfur % content not exceeding the requirement (0.1% in ECAs or Local). The changeover procedure should be engine specific and step by step in order to provide safe transition from one fuel type to other. Temperature and viscosity are some of the main concerns of the process and detailed guidance should be provided on such issues in order to protect Fuel Pumps and other machinery from failure. The time of completing each change over should also be taken into account as when reaching the limit of area (ECA or Local) vessel should be operated with fuel with the appropriate % sulfur content.(see also Question No 5)

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

In case of scrubber installations, these should be approved by Flag Administration for compliance with MARPOL Requirements.

5. 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?

Vessels have to complete change over procedure PRIOR entering restriction Area (ECA or Local). As the time for change over depends (e.g. number of settling and service tanks used), appropriate entries on logbooks (bridge/Engine room) are to be made. Starting and ending positions (latitude-longitude) and relevant times to be marked as required. Such entries are subject to PSC inspection for MARPOL Annex VI compliance.

6. 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?

Vessels using rechargeable systems containing Ozone Depleting Substances, should have a detailed ODS record book in order to enter the onboard quantity used by different systems and any maintenance / modification to such systems. Leak test that conducted to ensure the safe storage and leakage avoidance are to be recorded also.

7. 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?

Any modification (for NOx compliance) based on regulation MARPOL Annex 13.7, should be approved in accordance with IMO MEPC.1/Circ.743 17 February 2011. All related information and records should be available for inspections and IAPP supplement should include same.

8. 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?

As incineration is part of Garbage handling a detailed Garbage management plan should be onboard and describe the incineration procedure. Personnel involved with incineration should be familiar with the used of equipment and the restrictions for garbage categories to be incinerated along with the area restrictions for incineration. Training records to be available for inspection.

9. 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?

This manual is applicable to crude oil carriers. The purpose of this plan is to ensure that the operation of the vessel prevents, or minimizes VOC emissions to the extent possible, as well as to provide written, ship-specific, operational procedures for the crew in order to minimize VOC emissions during the following operations:

  • Loading
  • Carriage of relevant cargo (transit)
  • Crude Oil Washing

VOC emissions can be prevented or minimized by optimizing operational procedures to minimize the release of VOC emissions and using devises, equipment or design changes to prevent or minimize VOC emissions.

The plan should be approved by Flag Administration (or Recognized Organization on behalf of it).

10. Does the ship keep on board a Ship Energy Efficiency Management Plan (SEEMP)?

A Ship Energy Efficiency management Plan should be available on board. The SEEMP has been divided to two parts.

PART I: Includes all related procedures for Energy Efficiency Inspection, Monitoring, Review, Objectives, Targets and Action Plans. Responsibilities and relevant KPIs should also be included. PART I is NOT SUBJECT to approval by flag administration.

PART II: Cover the requirement for IMO data collection regarding fuel consumption. The calculation method and the reporting methods are to be included in this part. PART II is subject to Flag Administration (or Recognized Organization on behalf of it) APPROVAL. All vessel subject to MARPOL Annex VI regulation 22A should have an approved SEEMP Part II on board up to 1st January 2019 in order to start collecting data for IMO Data Collection System.

You may also find further information on MARPOL Annex VI CIC at SAFETY4SEA

See also our related products

SQEMARINE can provide guidance and further information on CIC requirements and implementation issues. Please refer to Annex 2 for item by item best practice guide. Additionally, a Fuel Oil Management Plan is recommended to be on board in order to provide guidance and implementation solutions to crew members. Other products related to MARPOL Annex VI are: SEEMP (Part I&II), EU MRV Plan, VOC Management Plan & Ozone depleting Substances Record Book.