Merchant Shipping Notice 161
Notice to Ship-owners, Ship Operators, Managers, Masters, Owners’ Representatives and Recognized Organizations
The Directorate wishes to remind all concerned of the requirements set out in MARPOL Annex VI and Directive (EU) 2016/802 limiting the sulphur content of marine fuels to 0.1% whilst operating in emission control areas, and the global sulphur limit of 0.5%, that became effective from 1 January 2015 and 1 January 2020 respectively; as well as regulating the use of exhaust gas cleaning systems.
Resolution MEPC.259(68) specifies the requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for discharging exhaust gas cleaning washwater into the sea.
Notwithstanding the above, it is important to note that a number of coastal States and ports have implemented local regulations with more stringent requirements that restrict or even completely prohibit the discharge of washwater from open loop exhaust gas cleaning systems in waters falling under their jurisdiction.
It is imperative that owners/managers ensure that their crews are familiar with the emissions and discharge limits in force in their trading areas. Furthermore, since the regulatory enforcement strategy may differ from one region/port to another, crews must be provided with clear procedures and guidance on this matter well in advance of the vessel’s intended area of operation and port of call.
For vessels trading in areas where the discharge of scrubber washwater is not permitted, two options are available in order to ensure compliance with the sulphur limits, either to switch over to closed loop mode of EGCS operation in case of hybrid systems, or changeover to compliant fuel. Any changeover should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place. Early changeover is highly recommended as this may help in identifying any operational issues that may arise and to take corrective actions in a timely manner.
To this effect, it is recommended that shipowners and operators of Maltese registered ships undertake the necessary actions to ensure that the systems are in compliance not only with the relevant IMO instruments but also with the regulations and the limits in force in their trading areas. This should be done at the earliest opportunity to avoid the risk of any detentions or unnecessary delays.
Merchant Shipping Directorate
02 September 2020