page 1/23 What has to be checked upon a revised MARPOL Annex VI survey? F318AE (or TRON report) covers all relevant aspects of the revised MARPOL Annex VI. By completing F318AE (or TRON report), you will have checked all necessary items to verify whether or not the ship complies with the revised MARPOL Annex VI. The following guidance provides support for filling form F318AE (or TRON report), and you will find additional information that might be helpful. Revised MARPOL Annex VI, SURVEY REPORT F318AE 1 Ozone depleting substances Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.
page 2/23 1. Applicable regulation: Reg. 12, Ozone-depleting substances : The regulation applies only to ships with rechargeable systems and equipment containing ozonedepleting substances. The regulation does not apply to permanently sealed equipment containing ozone-depleting substances where there are no refrigerant charging connections or potentially removable components containing ozone-depleting substances (reg. 12,1). 1.1 Deliberate emissions of ozone-depleting substances are prohibited. In case of maintenance of such systems, the substances must be taken to reception facilities (Reg. 12, 3.1, 12.4). 1.2 In new installations, ozone-depleting substances are prohibited from 2005-05-19, except for HCFCs, which are prohibited in new installations on or after 2020-01-01 (Reg. 12.3, 1+2) 1.3 Each ship with an IAPP Certificate shall maintain a list of ozone-depleting substances (Reg. 12.5). 1.4 Each ship that has rechargeable systems which contain ozone-depleting substances shall maintain an ozone-depleting substances record book. The record book may form part of an existing record book or electronic recording system as approved by the Administration (reg. 12,6). 1.5 Entries shall be made in terms of mass (kg) upon recharge of equipment, repair and maintenance of equipment, and discharges of ozone-depleting substances. (Reg. 12.6 + 12.7) Entries shall be recorded on each occasion: - recharge, full or partial, of equipment containing ozone depleting substances - repair or maintenance of equipment containing ozone depleting substances - discharge of ozone depleting substances to the atmosphere, deliberate, and non-deliberate - discharge of ozone depleting substances to land-based reception facilities; and - supply of ozone depleting substances to the ship 2 Instruction: 2.1 Ozone-depleting substances are substances which deplete the ozone-layer. Ozone-depleting substances contain usually chlorine or bromine. They can usually be found as cooling agents or agents in fire-fighting equipment in older ships (our category 1+2 below). Newer ships usually use alternative agents without chlorine or bromine, which are not considered ozone-depleting. If substances are used which are NOT considered ozone-depleting, they are NOT to be listed in the survey report or the certificate. (e.g. R290, R134a, R32, R404a, R407a to c, R410a, R413, R417, R507, R600, R717, CO2, NOVEC1230). In this case, items 1.2 to 1.5 are not applicable (= in this case, no ozone-depleting substances record book needs to be kept, no list of equipment required). Frequently used ozone-depleting substances Cat. 1 Cat. 2 Halon R21 to R22 R11 to R13 R31 R111 to R115 R121 to R124 R211 to R217 R131 to R133 R141 to 142 R151 R221 to R226 R231 to R235 R241 to R244 R251 to R253 R261 to R262 R271 R401
page 3/23 2.2 Restrictions for categories: R409a - Cat. 1) Prohibited in new installations on or after 2005-05-19, but old installations may remain in use - Cat. 2) Prohibited in new installations on or after 2020-01-01, but old installations may remain in use 2.3 If there are ozone-depleting substances used in the equipment installed on board, items 1.2 to 1.5. are applicable. If any item is answered with 0, please enter a deficiency. - Item 1.2: Documentation has to be on board showing that no deliberate emissions of ozone-depleting substances have occurred. This can be seen e.g. from the entries in the ozone-depleting record book. If entries of original quantity and quantity of recharge and discharge add up to the quantity currently listed, one would assume that no deliberate emissions have occurred. If these do not match, and no proof is given that these have been taken to a reception facility, this would be reason for a deficiency. - Item 1.3: The list of equipment shall match the supplement of the IAPP Certificate, section 2.1. - Item 1.4: A record book shall be provided on board. The form is not prescribed. If you find the record book acceptable, i.e., if you do not make any remarks in the survey statement in this regard, the record book is considered approved by the Administration. The record book does not have to be submitted to GL Head Office. Note: Panama requests the use of its own record book ( Oil Record Book and Emissions ), a combination of oil record book and air pollution record book. If not found on board, this is NOT reason for a deficiency, just comment it to the person in charge, please and inform them that they should use the official book for Panama.
page 4/23 - Item 1.5: Entries shall be made in the ozone-depleting substances record book about each recharge, discharge or upon maintenance and repair of system. These quantity added or taken out shall add up to the quantity currently listed. The above applies only to ships with rechargeable systems and for equipment containing ozone-depleting substances (e.g. not for alternative substances like R404A). The above does not apply to permanently sealed equipment containing ozone-depleting substances where there are no refrigerant charging connections or potentially removable components containing ozonedepleting substances [(e.g. not for domestic refrigerators] (reg. 12,1). The above does not apply if no ozone-depleting substances are used on board. In order to avoid further inquiries, GL recommends that ship owners keep delivery notes of substances which are not considered ozone-depleting when using them in above-mentioned equipment and systems. 2.4. Data entry in certificates: - Systems of category 1 to be entered under item 2.1.1 - Systems of category 2 to be entered under item 2.1.2 2.5. What happens if the crew cannot provide you with the data which you require for your survey? If the crew does not provide you with the data about system and equipment containing ozone-depleting substances, the survey cannot be completed. The item will have to be put on part held. The client should be informed in the survey statement that the data about system and equipment containing ozone-depleting substances has to be provided for completion of the survey. If the crew cannot show you the required ozone-depleting substances record book or list of equipment, a deficiency is to be imposed. The client should be informed in the survey statement that the ozone-depleting substances record book or list of equipment has to be presented to a surveyor in order for the deficiency to be deleted. If the crew cannot provide plausible proof - from the entries in the ozone-substances record book - that no deliberate emissions of ozone-depleting substances have been occurred, a deficiency is to be imposed. The client should be informed in the survey statement that the respective entries have to be presented to a surveyor in order for the deficiency to be deleted. If the surveyor is not satisfied with the entries in the record book upon resurvey, the crew shall be advised to send an explanation about the entries to engine.environmental@glgroup.com. The deficiency should not be deleted at this time, but only after satisfactory clarification.
page 5/23 2 Emissions from diesel engines Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.
page 6/23 1 Applicable regulation: Reg. 13, Nitrogen oxides (NOx) : 1.1 The regulation applies to every marine diesel engine with more than 130 kw. This reg DOES NOT APPLY to - engines with a power output (name plate) of 130 kw and less - engines only used for emergency purposes - engines installed on a ship which only trades in the waters of the ship s flag state ONLY IF such engines are subject to an alternative NOx control measure established by the Administration. 1.2 There are 3 emission limits: Tier I, II, and III (Reg. 13, 3, 13.4, 13.5.1) 1.3 The following requirements apply: NO emission limit: - applies to engines installed on a ship keellaid before 2000-01-01 UNLESS the engine underwent a major conversion and UNLESS for an engine with more than than 5,000 kw power output and 90 litres per cylinder displacement on a ship keellaid on or after 1990-01- 01 and 2000-01-01 an Approved Method exists. NOTE: This applies also to ships keellaid before 2000 and finished after 2000 if the ship is sailing with her original engines, and provided the NOx-relevant part/adjustments of the engines were not substantially modified. It applies even if those engines were manufactured after 2000. Example: Keellaying of ship = 1998, completion = 2007. Engines built and installed 2007, before completion of the ship. NOx-relevant part/adjustments were not substantially modified. Engines are not required to have EIAPP Certificates / Approved NOx Technical Files. TIER I: - applies to engines installed on ships constructed (keel laid) on or after 2000-01-01 and before 2011-01-01 - applies to installation of additional engines or non-identical replacement on or after 2000-01- 01 and before 2011-01-01, even if the keel laying date of the ship was earlier. - applies to substantial modification of engine installed on ships keellaid before 2011-01-01 - applies to engines with a power output of more than 5,000 kw and a per cylinder displacement of more than 90 litres, installed on ships constructed on or after 1990-01-01 and before 2000-01-01, provided that an Approved Method (NOx reduction method) for that engine exists. Approved Method means that the engine manufacturer has submitted the NOx reduction method for approval to an Administration or Classification Society, the method has been certified, the certification was notified to IMO, and the Approved Method is commercially available. In this case, carriage of an approved method file is required. Alternatively, the engine can prove compliance with Tier I through an EIAPP certificate and approved IMO NOx technical file (Reg. 13.7.1). TIER II: - applies to engines installed on ships constructed on or after 2011-01-01 - applies in the case of installation of a non-identical replacement engine or additional engine on or after 2011-01-01 - applies to substantial modification of engines installed on ships keellaid on or after 2011-01- 01. - applies when Tier III does not apply because the replacement engine cannot comply with Tier III (Reg. 13.2.2)
page 7/23 - applies when Tier III does not apply because the combined propulsion power of the ship is less than 750 kw and it is demonstrated to the satisfaction of the Administration that the ship cannot comply with the standards of Tier III because of design or construction limitations of the ship (reg. 13.5.2.2). - applies when Tier III does not apply because the ship has a length of less than 24 metres and is used solely for recreational purposes (reg. 13.5.2.1). Tier III: Applies in ECAs only - applies to engines installed on ships constructed on or after 2016-01-01 and in ECAs only. - applies in the case of installation of a non-identical replacement engine or additional engine on or after 2016-01-01, in ECAs only. - applies to substantial modification of engine installed on ships keellaid on or after 2016-01- 01 and in ECAs only. 1.4 On the following page, you will find a flow chart for checking if an engines has to comply with reg. 13, and if so, which emission tier it has to comply with: Flowchart by MaZe Item 2.10: All changes made to settings and components have been recorded: Applicable regulation: NOx Technical Code 2008, 6.2.2.7.1: The shipowner or person responsible for a ship equipped with a marine diesel engine required to undergo an engine parameter check method shall maintain on board the following documentation in relation to the on-board NOx verification procedures: 1. a record book of engine parameters for recording all changes, including like-for-like replacements, and adjustments within the approved ranges made relative to an engine s components and settings
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page 9/23 2 Instruction: 2.1 In the checklist, please enter all diesel engines installed on board with more than 130 kw rated power (name plate). ALSO FOR SHIPS KEELLAID BEFORE 2000-01-01 Date of installation: In general, this should be completion of the survey on which the engines were surveyed with satisfactory result for the first time. In case of original engines, this is usually the newbuilding survey. 2.2 Please enter the use of the engine ACCORDING TO THE ACTUAL USE ON BOARD (not according to EIAPP Certificate) - E3= Main propulsion FPP or propeller law operated aux. - E2= Main propulsion CCP or diesel electric - D2= Aux. constant speed - C1=Aux. variable speed, variable load 2.3 Please enter the applicable regulation for the engine (Tier I, II, III for details see 1.3). 2.4 Please enter if the EIAPP Certificate including supplement is available (in cases where required) and give the EIAPP certificate number. If the certificate including supplement is not available on board the ship, this is to be noted in the survey report. A deficiency has to be imposed. Form of EIAPP Certificate: Generally, if the ship holds an IAPP Certificate; for the engines, EIAPP Certificates have to be available on board, and if the ship holds an APP DoC; for the engines, EAPP DoCs have to be on board (or sometimes you might find EAPP SoCs on behalf of the flag state, some classifications societies issue these instead of DoCs). Reissuance of EAPP DoCs/SoCs as EIAPP Certificates after ratification of flag state: Flag states like Antigua and Barbuda, Malta or India did not ratify the MARPOL Annex VI convention in the beginning, hence you might find APP DoC and EAPP DoCs (or sometimes EAPP SoCs if they were e.g. issued by another classification society) on board. Antigua and Barbuda and also Malta and India have ratified the MARPOL Annex VI convention in the meantime. Upon renewal survey, the APP DoC and the EAPP DoCs will have to be issued as IAPP and EIAPP Certificates. If the EAPP DoCs/SoCs were issued by another classification society, copies of both the EAPP DoCs/SoCs and Technical Files will have to be submitted to dept. MC-PE so that the reissuance can be done. 2.5 Please enter if the approved IMO NOx Technical file for the engine is available on board. The Technical File is needed for the on-board verification of the engine. It the Technical File is not available on board, a deficiency has to be imposed. 2.6 Please enter if the EIAPP Certificates comply with the applicable emission limit. There are 3 emission limits, Tier I (Reg. 13.3), Tier II (Reg. 13.4) and Tier III (Reg. 13.5.1). This is stated under item 1.9.5 of the EIAPP Certificate (supplement): 2.7 Please check if power and speed: is the same as on engine name plate + EIAPP Cert. If not, please enter a deficiency. 2.8 Please check if IMO numbers of emission relevant components (e.g. valve, piston, cylinder, turbo charger):is the same on engine (spare) parts + NOx Tech File chapter on-board verification. If not, please enter a deficiency. 2.9 Please check the items 2.7 + 2.8 at least for one engine per engine model number. This is the minimum MARPOL Annex VI requirement (See also box below On-board-verification). The check is required upon each survey, and also before a new engine can be entered into the IAPP Certificate.
page 10/23 On-board-verification: The on-board verification procedure (OVP) is an instruction on how to verify whether or not an engine is compliant with the applicable NOx emission limit: The OVP shall be used to verify that the engine components/parameters coincide with those stated in the Technical File. The OVP is to be performed as follows: You will find, in the Technical File, a section OVP. NOx relevant components and settings and allowable adjustments which influence the emission of nitrogen oxides are listed. Please use it as reference for the counter check with the actual engine. In most cases drawings are included showing you where to find the identification numbers on the engine components. The surveyor has the option of checking one or all of the identified components, settings or operating values. The survey should be completed for at least one cylinder and/or one engine in a family or group. The engine log book should be checked for changes. If engine components, settings, adjustments or software revision nos. are different from the specification given in the Technical File, the ship s person in charge is to be informed that these components have to be replaced by such components which are stated in the Technical File. A deficiency is to be imposed. As a general guideline: No data to be entered in table 2.2.1 if the previous certificate listed no engines and if no changes have occurred. (Examples: Emergency engines, original engines installed in ships keellaid before 2000-01-01 if no approved method is required, new engines installed in ships keellaid before 2000-01-01 if the new engine was built before 2000-01-01 + did not have a major engine modification on or after 2000-01-01 + was installed before 2011-07-01). In all other cases, please enter: Manufacturer, model, serial number: self explanatory Date of installation: For original engines = completion date of the newbuilding survey. For engines installed later: completion date of survey which documents that the installation of the engine was completed. Use: according to Instructions item 2.2 Power output/rated speed: As per nameplate Exempted by regulation 13.1.1.2: (Only to be used for identical replacements since 2010-07-01. For more info, please see below). Exempted by regulation 13.1.1.2: 1. This concept did not exist before 2010-07-01, and the regulation at the time of replacement remains valid. Therefore, engine replacements before 2010-07-01, even if identical, are not to be listed as Exempted by regulation 13.1.1.2 in the supplement to the interim IAPP Certificate. Replacements before 2010-07-01 are either a major conversion (if date of build on or after 2011-01-01, or if changes to NOx relevant parts on or after 2011-0-101, or if increase in rated power of more than 10% on or after 2000-01-01). Then, they should be entered in table 2.2.1, and the date of the major conversion should be entered either under According to reg. 13.2.2 (in case of new engine, even if the replacement engine is identical) or under According to reg. 13.2.3 (in case of change of NOx relevant parts, or increase of rated power of more than 10%). Or, the replacements are no major conversion (if date of build was before 2011-01-01 and if no changes to NOx relevant parts on or after 2011-0-101 or increase in power of more than 10% on or after 2000-01-01). Then the engine should not be entered at all in the supplement to the interim IAPP Certificate. 2. Exempted by regulation 13.1.1.2 means that a) an engine was installed as replacement for another engine on or after 2010-07-01 b) is completely identical to the one it is replacing (maker, model, specification/configuration, power, speed)
page 11/23 c) the requirement from reg. 13.2.2 (engine has to comply with emission limit in force at the time of the replacement, currently Tier II) is not valid for this engine. Instead, the replacement engine has to comply with the same regulation which applies to the engine it is replacing. Example: Identical replacement installed in March 2011. Previous engine had to comply with Tier 1, so the identical replacement has to comply with Tier 1. Example: Identical replacement installed in April 2011. Previous engine did not have to comply with any emission limit (no EIAPP Certificate, no approved IMO NOx Technical File). So the identical replacement does not have to comply with any emission limit (no EIAPP Certificate, no approved IMO NOx Technical File). Tier I: Tier II: Tier II: Tier II: Tier III: Reg. 13.3: If Tier I is applicable and the ship is equipped with the respective EIAPP certificate (or equivalent) and approved IMO NOx technical file Reg. 13.4: If Tier II is applicable and the ship is equipped with the respective EIAPP certificate (or equivalent) Reg. 13.2.2: If replacement engines cannot comply with Tier III Reg. 13.5.2: If engines cannot comply with Tier III and ship is less than 24 metres long and used only for recreational purposes Reg. 13.5.1.1: If Tier III is applicable and the ship is equipped with the respective EIAPP certificate (or equivalent) and approved IMO NOx technical file Emergency engines do not have to comply with any emission limit. No EIAPP Certificate and approved IMO NOx Technical File required. Emergency engines also used for harbour use (in general: connected to the main switchboard), are to be treated like an auxiliary engine. Reporting: a) identical replacements: - the engine is to be listed in the survey report - the engine is to be listed in the supplement to the IAPP Certificate. The box "exempted by regulation 13.1.1.2" is to be checked. b) emergency diesel engine: - the engine is to be listed in the survey report (for our records) - the engine is not to be listed in the supplement to the IAPP Certificate. Item 2.10: All changes made to settings and components have been recorded: As stated in our respective customer information, most Technical Files contain empty pages where the respective entries can be made. However, shipowners are free to record the changes in any other way, e.g. in an engine record book, an engine maintenance program, or separately. Even a folder with receipts and additional remarks might do. However, the surveyor has to check the records when doing the on-board verification procedure. In order to accelerate the process it is recommended that the records display the engine-specific changes at a glance. Emission relevant parts are parts regarding the - combustion chamber geometry, e.g. piston, connecting rod, cylinder liner, cylinder head - fuel system, e.g. nozzle, fuel pump, camshaft, software, injection timing - aspiration, e.g. turbo charger, charge air cooler, valve timing Emission relevant parts and settings are listed in the Technical File of the relevant engine. All changes made to these parts or settings must be recorded. All emission relevant parts and settings must be identified (usually by their IMO number) in the approved IMO NOx Technical File, section on-board-verification.
page 12/23 2.5. What happens if the crew cannot provide you with the data which you require for your survey? If there is no name plate on the engines which shows the necessary engine details, the survey cannot be completed. The item should be put on part held. If the survey cannot be completed, a remark is to be made in the survey statement that the survey will be completed upon provision of all necessary engine details. For engines which do not require an EIAPP Certificate or DoC/SoC, the name plate is still required. On these name plates, if a detail is missing which can be proven in a plausible way through documentation on board, this is acceptable. If the EIAPP Certificates in their required form or if the IMO NOx Technical Files are not available on board, or not complete or correct, or if there is a discrepancy between engine data found on board and the documentation, a deficiency should be imposed stating what exactly is not in order. The deficiency can be deleted after the surveyor has seen all data on board as required and has been able to perform the necessary engine check against the documentation. 1 Applicable regulation: Reg. 13.7.1 1.1 An approved method is a method for a particular engine, or a range of engines, that, when applied to the engine, will ensure that the engine complies with the applicable NOx limit. (NOx Technical Code 2008, 1.3.17). 1.2 An approved method shall be installed no later than the first renewal survey that occurs 12 months or more after an Administration or classification society has notified IMO about the certification of the Approved method (Reg. 13.7.1). Alternatively, the engine can be equipped with an EIAPP Certificate if the engine owner decides to prove that the engine complies with regulation 13 without Approved Method (Reg. 13, 7.2). 2 Instruction: 2.1 Please enter the Approved method file number if available. Approved Method is available for the following engines: Engine specification MAN B&W S70MC with 2,530 2,810 MCR per cylinder (kw/cyl) and rated speed 81-91 rpm Wärtsilä Switzerland Ltd. RTA52 RTA52U RTA58T RTA62 RTA62U RTA72 RTA72U Approved method has to be available on board for Renewal Surveys carried out on or after 6 October, 2011 5 February, 2012
page 13/23 RTA84C RTA84CU RTA84M RTA84T-B RTA96C MAN B&W S50MC with 1,160-1,430 MCR per cylinder (kw/cyl) and rated speed 114-127 rpm 12 August, 2012 2.2 A respective instruction to surveyor was entered into the SIS/ Fleet Online. By checking the instruction for the relevant ship, you will be able to see if an approved method should be installed for the engine of this ship. Please note 1.2 above. If you see from the ItS that an approved method should be installed, and if this was not done in the legal time frame, a deficiency shall be imposed unless the ship owner proves that despite best efforts to obtain it, the Approved Method was not commercially available. If the ship owner proves this, the box Approved Method not commercially available is to be checked. The Approved Method shall in this case (=if Approved Method not commercially available was checked) be installed no later than the next annual survey after it has become commercially available. If, at this date, it is not installed and no proof is submitted that the Approved Method is still not commercially available, a deficiency is to be imposed. 3 Data entry in certificate: If an Approved Method is available for this engine type, entry in the certificate should be as follows: - Approved Method exists: Please see item item 2.2 above - Approved Method not commercially available: Please see item item 2.2 above - Approved Method installed: If Approved Method is installed. - If an approved method for this engine type is not available, these boxes are not to be checked 4 What happens if the crew cannot provide you with the data which you require for your survey? If there is no name plate on the engines which shows the necessary engine details, the survey cannot be completed. The item should be put on part held. If the survey cannot be completed, a remark is to be made in the survey statement that the survey will be completed upon provision of all necessary engine details. For engines which do not require an Approved Method File, the name plate is still required. On these name plates, if a detail is missing which can be proven in a plausible way through documentation on board, this is acceptable. If the Approved Method File is not available on board, or not complete or correct, or if there is a discrepancy between engine data found on board and the documentation, a deficiency should be imposed stating what exactly is not in order. The deficiency can be deleted after the surveyor has seen all data on board as required and has been able to perform the necessary engine check against the documentation.
page 14/23 1 Applicable regulation: Reg. 13, 2.1, 2.2., 2.3: A major conversion with regard to reg. 13 of MARPOL Annex VI consists of either one of the following: 1. replacement with identical engine (engine to comply with standards of the engine it is replacing) 2. replacement with non-identical engine (engine is to comply with the Tier in force at the time of installation of replacement engine) 3. installation of additional engine (engine is to comply with the Tier in force at time of installation of replacement engine) 4. substantial modification /increase in rating over 10% (engine is to comply with Tier I if ship was keellaid before 2000, else it is to comply with the Tier in force at the time the ship was keellaid). 2 Instruction: 2.1 In case of major engine conversions, please enter the type of conversion according to the above box 2.2 Please also enter the date of conversion (=completion date of survey which documents that the installation of the engine was completed). For the date of the major conversion, please see the IACS UI MPC98: The date of installation is either the contractual date (see contract) or the date of delivery (see delivery receipt). If installation is on or after 2016-01-01, the date is the date of the actual check on board (classificatory or emission testing, whichever is earlier). 3 Data entry in certificate: - Date of major conversion accord. to Reg. 13. 2.2 (= in case of replacement or additional engine) - Date of major conversion accord. to Reg. 13. 2.3 (= substantial modification of an installed engine). Substantial modification = change of emission-relevant parts/adjustments. 4 What happens if the crew cannot provide you with the data which you require for your survey? If there is no name plate on the engines which shows the necessary engine details, the survey cannot be completed. The item should be put on part held. If the survey cannot be completed, a
page 15/23 remark is to be made in the survey statement that the survey will be completed upon provision of all necessary engine details. For engines which do not require an EIAPP Certificate or DoC/SoC, the name plate is still required. On these name plates, if a detail is missing which can be proven in a plausible way through documentation on board, this is acceptable. If the EIAPP Certificates in their required form or if the IMO NOx Technical Files are not available on board, or not complete or correct, or if there is a discrepancy between engine data found on board and the documentation, a deficiency should be imposed stating what exactly is not in order. The deficiency can be deleted after the surveyor has seen all data on board as required and has been able to perform the necessary engine check against the documentation.
page 16/23 3 Sulphur oxides (SOx) (regulation 14) / Fuel oil quality (regulation 18) Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI. 1 Applicable regulation: Reg. 14, 18; sulphur oxides (SOx) and particulate matters 1.1 In general, the sulphur content must not exceed the following limits: - for fuel used before 2012-01-01: 4.5% m/m - for fuel used on or after 2012-01-01 and before 2020-01-01 = 3.5% m/m - for fuel used on or after 2020-01-01 0.5% m/m (Reg. 14.1) 1.2 The fuel used in the ECAs must not exceed the following limits: - on or after 2010-07-01 and before 2015-01-01 = 1.0% - or or after 2015-01-01 = 0.1% (Reg. 14.4) 1.3 Ships using different fuels shall carry a written procedure showing how the fuel oil change over is to be done. (Reg. 14.6) 1.4 The fuel change over shall be recorded in a log book, stating volume of low sulphur fuel oil in each tank, time date and position of ship (Reg. 14.6) 3.1 Emission Control Area NEW: NORTH AMERICAN ECA as of 2011-08-01. MEPC.1/Circ.723 Ships operating in the North American ECA are exempted from the requirements for SOx and particulate matter during the first twelve months after entry into force (MEPC.1/Circ.723 item 5). This means: No fuel with sulphur content below 1.0 % required until 2012-08-01 (3.5% ok), no bunker delivery notes which confirm sulphur content below 1.0% required until 2012-08-01 (3.5% ok), no written fuel change over procedure required until 2012-08-01.
page 17/23 2 Instruction: 2.1 Please check the bunker delivery notes with regard to sulphur content of the fuel. The sulphur content must be stated on the bunker note. If the sulphur content stated in the bunker delivery note exceeds the applicable limit (for details, pls see info below), please enter a deficiency. 2.2 Please check if the fuel oil used in ECAs does not exceed the applicable limit, by checking the bunker delivery notes. If the ship does not currently trade in ECAs, the question can either be answered as not applicable: the respective boxes in the certificate will be left blank. If the ship should ever go to such an area, this item will have to be resurveyed and the certificate will have to be changed. Alternatively, if the owner s representative can confirm now that only fuel which does not exceed the applicable sulphur limit will be used when trading in an ECA, the question can be answered with yes, and the boxes in the certificate can be checked. The owner s confirmation is documented through the signature on the survey statement (or signature of the survey report in case the paper version is used). Info regarding item 3.1 - Bunker note issued before 2012-01-01 = 4.5% m/m - Bunker note issued on or after 2012-01-01 and before 2020-01-01 = 3.5% m/m - Bunker note issued on or after 2020-01-01 = 0.5% m/m Info regarding item 3.2 - Date of trading in ECA before 2010-07-01 = 1.5% m/m - Date of trading in ECA on or after 2010-07-01 and before 2015-01-01 = 1.0% - Date of trading in ECA on or after 2015-01-01 = 0.1% 2.3 A written procedure is required if: - The ship enters and leaves an Emission Control Area. - The ship uses separate fuels in order to comply with sulphur limits inside and outside an Emission Control Area (reg. 14, 6). The procedure is considered approved if the GL surveyor does not enter any remarks during the survey. It is not necessary to submit the procedure to GL HO. 2.3.1 For surveys between 2012 and 2020, the second box is the box that will have to be ticked in order for the certificate to remain valid. If you tick the first box, this value is not valid anymore, if you tick the third box, this value is not valid yet. 2.3.2 For surveys between 2012 and 2015, the first box is the box that will have to be ticked in order for the certificate to remain valid. If you tick the second box, this value is not valid yet. In these cases, the following shall be recorded in a log book: The volume of low sulphur in each tank and the date, time and position of the ship when a change over is completed before entry or started before leaving an Emission Control Area. 3 Data entry in certificate: If the ship representative presents the fuel oil samples and bunker delivery notes confirming the currently valid sulphur limit, in the certificate under item 2.3.1 and 2.3.2, please tick boxes for currently valid sulphur limit only. Please do not tick all boxes.
page 18/23 4 What happens if the crew cannot provide you with the data which you require for your survey? If the required bunker delivery notes and fuel oil samples are not on board, or if they do not show compliance with the required sulphur limit, a deficiency should be imposed. In the deficiency, please state that the bunker delivery notes and fuel oil samples have to be presented to a GL surveyor on board for inspection. Upon satisfactory result, the deficiency will be deleted. If the fuel change-over procedure is required and not available on board, or if it is not found satisfactory, a deficiency is to be imposed. In the deficiency, please state that the fuel changeover procedure has to be presented to a GL surveyor on board for inspection. Upon satisfactory result, the deficiency will be deleted.
page 19/23 4 Volatile organic compounds (VOCs) (regulation 15), for tankers only Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI. 1 Applicable regulation: Reg. 15 Volatile organic compounds (VOCs) : 1.2 A tanker which is required to carry a vapour collection system because of port requirements shall have a vapour emission collection system approved on the basis of IMO document MSC.585 and use this system during the loading of relevant cargoes. 1.3 A tanker carrying crude oil must have on board and implement a VOC management plan approved by the Administration. NOTE: This is only applicable to ships which really carry crude oil. 1.4 The VOC management plan must provide written procedures for minimizing VOC emissions, give consideration to the additional VOC generated by crude oil washing and identify a person responsible for implementing the plan. For ships on international voyages, the plan shall be written in English, French or Spanish or include a translation into one of these languages if the working language is not English, French, or Spanish. 2 Instruction: 2.1 If the ship has a vapour collection system in accordance with IMO document MSC.585, the respective box shall be checked with 1/yes. This is not mandatory according to MARPOL Annex VI. Therefore, if not available, this is NO reason for a deficiency. 2.2 If the ship has a VOC management approval plan, please check the box and enter the reference number. If a tanker which carries crude oil does not have an approved VOC management plan, a deficiency has to be imposed. 3 Data entry in certificate: Self-explanatory 4 What happens if the crew cannot provide you with the data which you require for your survey? If the crew does not provide you with the data about the vapour collection system, the question: The tanker has a vapour collection system installed which complies with MSC Cird. 585 should be answered with No. If the crew of a tanker which carries crude oil does not show you the approved VOC management plan, a deficiency should be imposed.. In the deficiency, please state that the VOC management plan has to be presented to a GL surveyor on board for inspection. Upon satisfactory result, the deficiency will be deleted.
page 20/23 5 Incinerator Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI. 1 Applicable regulation: Reg. 16 Incinerators 1.1. Shipboard incineration is only allowed in an incinerator. Exception: Shipboard incineration of sewage sludge and sludge oil generated during normal operation of a ship may also take place in the main or auxiliary power plant or boilers, but in those cases shall not take place inside ports, harbours and estuaries. 1.2 Shipboard incineration of PVCs is prohibited. Except in shipboard incinerators for which IMO Type Approval Certificates have been issued. 1.3 Incinerators installed on a ship constructed on or after 1 January 2000 or incinerator installed on board a ship on or after 1 January 2000, shall be approved according to MEPC.76(40). 1.4 Incinerators subject to item 3 above shall be provided with a manufacturer s operating manual 1.5 The staff responsible for operation of the incinerator subject to item 3 above shall be trained and capable of implementing the guidance of the manufacturer's operating manual. 1.6 For incinerators subject to item 3 above, the exhaust gas outlet temperature shall be monitored at all times.
page 21/23 2 Instruction: 2.1 Please check if an incinerator is installed. 2.2 If so, please enter the year of installation of incinerator. 2.3 Please check for one of the following and mark the survey report accordingly 2.3.1 Incinerator complies with MEPC.76(40). This is mandatory if the ship is keellaid on or after 2000-01-01 or if the incinerator was installed on or after 2000-01-01. If the incinerator does not comply, a deficiency has to be entered. In order to check compliance, a copy of the approval certificate has to be on board. 2.3.2 Incinerator complies with MEPC.59(33) For an incinerator which was installed on or after 2001-01-01, please check if: - the exhaust gas outlet temperature is monitored and - the manual is available on board. - The personnel responsible for operation of the incinerator is trained and capable of implementing the guidance of the manufacturer's operating manual If this is not the case, a deficiency is to be entered. 3 Data entry in certificate: Please check the respective box. In cases of incinerators installed before 2000-01-01, there is no box to check in the IMO Certificate for incinerators which are not compliant with reg. 76.(40) or 59.(33). GL HO will submit a letter together with the new full term IAPP Certifcate, stating that there is an incinerator installed which is not compliant with reg. 76.(40) or 59.(33), and which must not be used for shipboard incineration of polyvinyl chlorides (PVCs) according to regulation 16.3 of the revised MARPOL Annex VI (2008). 4 What happens if the crew cannot provide you with the data which you require for your survey? If there is no name plate on the incinerator which shows the necessary details, the survey cannot be completed. The item should be put on part held. If the survey cannot be completed, a remark is to be made in the survey statement that the survey will be completed upon provision of all necessary details. If the required type test certificate or other evidence showing that the incinerator is approved according to the applicable regulation are not available on board, or not complete or correct, or if there is a discrepancy between engine data found on board and the documentation, a deficiency should be imposed stating what exactly is not in order. The deficiency can be deleted after the surveyor has seen all data on board as required and has been able to perform the necessary check against the documentation. If the incinerator is not required to comply with a regulation (installation before 2000-01-01), no deficiency is to be imposed.
page 22/23 6 Equivalents Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI. 1 Applicable regulation: Reg. 4.1 Equivalents The Administration may allow any fitting, material, appliance, and apparatus to be fitted in a ship [ ] if such fittings, materials, appliances, and apparatus are at least as effective. 2 Instruction: Please state if the ship uses equivalents en lieu of the systems or equipment intended by MARPOL Annex VI. An equivalent is any equipment which leads to the results required by MARPOL Annex VI. Example: The sulphur limit in the fuel can be met by using fuel with a low sulphur content (intended for use by MARPOL Annex VI). It can also be met by using a scrubber. If the scrubber is approved, it can be entered under 06.20. The approval number is required in this case. The Approved Method (items 2.8 and 2.9) is not an equivalent, but (if applicable) a MARPOL Annex VI requirement. Alternative cooling agents (cat. 3) are no equivalents, as their use is required in new installations where HCFCs are no longer allowed. They are not to be entered in the certificate, no approval no. necessary. 3 Data entry in certificate: Self-explanatory
page 23/23 7 Remarks: