What MEPC75 means for tanker operators

 Tanker operators will be keen to know exactly what they need to do to comply with MEPC 75 – if they will be able to keep a certain vessel in compliant operation until 2030 just through slow steaming, and when they need to consider switching to LNG fuel.

At a webinar organized by DNV GL about MEPC 75 on November 26, 2020 stated.

“You need to consult with your trusted classification society and see how they can help you with specific vessels. It depends on age, trade profile, investment willingness. There are a lot of factors playing into what is the most appropriate solution for each individual ship.”

Although “we think you can achieve 40 per cent improvement in efficiency with the toolkit we have available today. It won’t always be cheap, but it can be done.” In other words, we can manage until 2030 without new fuels.

“Getting to the absolute reduction levels of 2050 is a different ballgame - there we need other options.”

The MEPC 75 meeting was held online over November 16-20. Because people were attending

from their home countries, rather than travel to the IMO building in London, and all working in different time zones, the decision was made to restrict discussions to 3 hours a day, so 15 hours in total for the meeting.

The online format also did not allow as much interaction as usual. Many items were postponed to the next meeting (MEPC 76). Since the MEPC 75 meeting was originally planned for April 2020, it means some items are being postponed for a year. MEPC 76, planned for 2021, is also likely to be virtual, and so have a constrained agenda, and some issues may slide into MEPC 77.

A planned revision of guidelines for Exhaust Gas Cleaning Systems was pushed to MEPC 76.

Correspondence groups have been established to look at licensing fuel oil suppliers, a shaft power limitation concept, and interim minimum power guidelines.

The work to agree a definition of Phase 4 of EEDI was “deprioritized”. Phase 4 will apply to newbuilds of a number of ship types from 2022, and anticipated to come into force after 2025, so not considered urgent to discuss now.

Agreements at MEPC 75

At the November 2020 meeting, approval was given to the 4th IMO greenhouse gas study, by a consortium led by CE Delft, which counted emissions from shipping in 2018 of 1056 MT CO2 equivalent, up 9.6 per cent from 2012.

Methane and nitrous oxide emissions were included (and converted to a CO2 ‘equivalent’ amount). This study says that shipping’s share of global emissions was calculated to be 2.89 per cent in 2018, up from 2.76 per cent in 2012.

The study says that the overall “carbon intensity” of shipping decreased by either 21 per cent or 32 per cent over the period 2008 to 2018, depending on how it is calculated – 21 per cent if calculated by “capacity mile” or based on voyages, and 32 per cent if calculated by “tonne mile” (cargo carried). Carbon intensity is a measure of how much carbon is emitted per “transport work”.

If no additional policies are adopted to decarbonize, emissions are projected to end up growing by between 90 and 130 per cent by 2050, relative to 2008.

The focus of the MEPC work is to get emissions to a peak as soon as possible, and then reduce “carbon intensity” by 40 per cent by 2030, compared to 2008. (Note, 21 to 32 per cent reduction has already been achieved).

On the technical side, MEPC75 approved plans for an EEDI (Energy Efficiency Design Index) rule on existing ships, known as the “EEXI” (Energy Efficiency Existing Ship Index).

This is described in more detail below.

On the operational side, it approved plans to ask shipping companies to write a “SEEMP” (Ship Energy Efficiency Management Plan), showing how they will reduce their operational emissions. It is based around a Carbon Intensity Indicator – CII. This is also described in more detail below.

Each member state is encouraged to develop its own national action plan, an example being Norway’s Green Shipping Program.

MEPC75 considered a proposal from a number of shipping industry associations, including the International Chamber of Shipping, World Shipping Council, Intertanko and the International Parcel Tankers Association, to raise money for research and development of fuels, levied on fuel purchases.

The meeting also did not discuss plans to set GHG / carbon intensity guidelines for other fuels, also including emissions made in producing the fuels and delivering them to vessels (“well to tank”), methane slip, nitrous oxides, and emissions from VOCs.

So, for now, the regulations only relate to the amount of CO2 you emit per the amount of cargo tonne miles you make.

EEXI

EEXI is what will concern tanker operators the most. It follows EEDI, the “Energy Efficiency Design Index”, which says that new ships being built over 2025 to 2030 must have a 30 per cent improvement in energy efficiency compared to a baseline, calculated as the average efficiency for ships being built between 2000 and 2010.

Under EEXI, existing tankers need to achieve a “delta”, or improvement, of 15 to 20 per cent, compared to the baseline, with the same time periods as for EEDI for achieving the improvement and the base line. The delta is different for different ship types. Cruise ships and LNG carriers must get 30 per cent, gas carriers must get 20 to 30 per cent.

So, this should get existing ships “on par” with what is required for new ships, under EEDI phase 2 or 3. Ships need to comply with EEXI by early 2024. Specifically, the deadline is the “first annual, intermediate or renewal IAPP (International Air Pollution Prevention) survey after 1 Jan 2023.” So, by early 2024 - all ships which are in scope need to comply with EEXI.

The index is calculated by a complex formula which takes ship’s emissions, capacity and speed into account, with the speed based on that calculated in the sea trial, after the vessel was launched, or by other methods.

The way to reduce the score involving the least financial investment is probably to reduce the speed. The engine can be “de-rated”, so it operates at a slower speed, or you can set a “virtual” limit on engine power, basically an agreement that you will only operate the vessel with a certain power level. You are only allowed to exceed it in an emergency.

Shipping companies need to put all of this in a technical file, which is verified and approved in the first IAPP survey after Jan 2023.

SEEMP

All ships above 400 GT need to develop a “Ship energy efficiency management plan (SEEMP), by Jan 1, 2023.

A rating system will be designed by IMO so that if all ships are C or better, by 2030 shipping will reach its 40 per cent target of improving carbon intensity.

It will probably be calculated in emissions per deadweight mile. The threshold for reaching “C” will get more stringent in time. Cargo and cruise ships above 5000 GT need to achieve rating “C” in their Carbon Intensity Indicator, every year from 2023, their SEEMP should show their plan to achieve this. The plan should also have a continuous improvement focus.

Any ship scoring “D” for 3 consecutive years, or an E, will need to implement corrective actions, which will be included in their SEEMP, and need to be approved, for a vessel to receive its annual statement of compliance. Offshore vessels, passenger vessels (not cruise ships or ROPAX) will not have any index. The reason is that these vessels are very diverse, so it is very hard to calculate how one vessel compares to others in its ‘class’. Although they are still required to collect and report data.

The policy will be reviewed by Jan 2026, looking at strengthening the enforcement mechanism and corrective actions.

IMO’s 2050 target is that CO2 emissions should be reduced by 70 per cent compared to 2008, counted as CO2 emissions per transport work, and total GHG emissions from the industry should be reduced by 50 per cent, compared to 2008.

The company’s CII may become public, since it is included on the vessel’s “statement of compliance”, which is a public document in many jurisdictions. This means the data may be included in the various online vessel rating schemes.

The verification and audit will be done by the organizations accredited as “recognized” by flag states – mainly the classification societies.

IMRDB

There is a proposal from industry bodies, including ICS, World Shipping Council, BIMCO and Intertanko, to set up a research fund to develop zero carbon technologies, paid for with a levy per tonne of fuel purchased, proposed at $2 per tonne for all ships above 5,000 GT, building a purse of $5bn over the lifetime of the program.

A full day of the MEPC 75 meeting (3 hours) was taken up by discussing this. IMO members were talking about it as a “market based measure”, although the industry had been careful not to present it as a “market based measure”, saying that the money would be for research only, not to make certain fuels more viable.

There were inconclusive discussions about whether IMO could take on the responsibility of making this a legal mandate, Mr Longva said. “IMO agreed to invite further comment, so discussion will come back in MEPC 76.”

Other amendments

Other amendments made by IMO are changes to MARPOL Annex VI stating that you need to have a sampling point in your fuel system, either fitted or “designated”, for inspectors to sample and verify sulphur content. This needs to be approved by the first IAPP survey after April 2023. “There’s either technical or bureaucratic work to take care of,” Mr Nyhus said.

There are new verification procedures for how samples are to be analyzed and what kind of bandwidth is acceptable on sampling results.

Also, at MEPC 75 the International Convention on the Control of Harmful Anti-fouling Systems on Ships was amended to ban the biocide cybutryne.

There was a ban on use and carriage of heavy fuel oil in the Arctic from July 1, 2024, with exemptions for tanks with a double hull, or for Arctic coastline states which want to exempt their own ships in their own waters until 2029. This was a compromise agreed with certain Arctic states to get the ban passed. Audience poll Audience members were polled to find out what they anticipated their main measure would be to comply with EEXI.

21 per cent chose engine power limitation, 16 per cent retrofit energy efficiency devices, 17 per cent operational improvements, 25 per cent alternative fuels, 19 per cent said “I have not started looking into this.”

Useful reference links

https://www.imo.org/en/MediaCentre/MeetingSummaries/Pages/MEPC-75th-session.aspx

https://www.ukpandi.com/news-and-resources/legal-content/legal-articles/mepc-75-16_20-november-2020_summary-of-outcome/

https://www.imo.org/en/OurWork/Environment/Pages/Anti-fouling.aspx

https://www.iomshipregistry.com/media/1403/msn-047-anti-fouling-systems-convention.pdf

TSB Canada investigation: Collision of two bulk carriers after dragging anchor

TSB Canada issued an investigation report on the collision of the bulk carriers Golden Cecilie and Green K-Max 1 in the Plumper Sound, British Columbia, in March 2020. The Golden Cecilie suffered dragging anchor due to heavy winds, the report reveals, stressing that the crew did not follow established procedures to ready the vessel for impending adverse weather conditions.

The incident

On 30 March 2020, the bulk carrier Golden Cecilie was anchored at Anchorage C in Plumper Sound, British Columbia, with 20 people onboard, when it collided with the bulk carrier Green K-Max 1 anchored at Anchorage B, after reporting a dragging anchor due to gusting wind.

Following the collision, both vessels’ anchor chains became entangled. With the direction of a pilot on each vessel, and the assistance of two tugs, the anchor chains were disentangled and the two vessels returned under their own power to their respective anchorages and were secured in place. There were no injuries or pollution reported, but both vessels sustained damage to their hulls as a result of the incident.

 Key findings

The Golden Cecilie had an SMS manual that included guidance and recommendations on how to mitigate the risk of dragging anchor.

The investigation established that the crew did not collect the daily local weather forecast for the day of occurrence from the VHF radio, weather fax, medium frequency-high frequency broadcast, nor did the crew obtain an up-to-date weather warning from local authorities, such as Environment and Climate Change Canada (ECCC) or Marine Communication and Traffic Services (MCTS). As a consequence the crew did not follow established procedures to ready the vessel and crew for impending adverse weather conditions. As well, factors that impact dragging an anchor had not been taken into consideration as per the SMS, and the emergency preparedness to respond to adverse weather was inadequate, ...the report reads.

 Actions taken

Following the occurrence, the Golden Cecilie’s operator took the following safety action:

• The anchoring and anchor watch checklist was amended on 01 May 2020 to indicate that the master should be informed immediately if the barometric pressure drops by 3 mb during watch or if the wind speed exceeds 21 knots (force 5 on the Beaufort scale). In such circumstances, the engines are to be placed on standby and the deck watch is to monitor the anchor position.
• The checklist was also amended to specifically indicate the engine notice period as per the master’s instruction. A notice was sent to the vessels informing them that they should be documenting the engine notice period, the state of readiness, and the position of the second anchor in the bridge log book.
• A “Safety Flash” bulletin was circulated to all vessel crew members stressing the importance of proper anchor watches and compliance with the SMS.
• Bridge resource management refresher training was arranged for bridge watch officers.

Safety messages

When vessels are at anchor, crews need to:

• collect weather forecasts from all available sources in a timely manner;
• be aware of the risk factors that can lead to dragging anchor, in particular excessive freeboard and inadequate ballasting; and
• ensure that the main engines, anchors, and deck machinery are ready so that corrective action can be taken at the first sign of dragging anchor.

Between January 2015 and March 2020, a total of 102 dragging anchor occurrences along the BC coastline were reported to MCTS.

Full report may be downloaded at

https://safety4sea.com/wp-content/uploads/2021/02/TSB-Canada-DRAGGING-ANCHOR-AND-SUBSEQUENT-COLLISION-2021_02.pdf

Charterers Terms and Conditions 2021

With an ever changing Insurance market, it becomes even more important to have a clear set of Terms and Conditions dedicated to our Charterers Members.
The Charterers Terms and Conditions 2021 reflects the latest developments in the market

whilst continuing to provide comprehensive cover as accustomed from the UK P&I Club. Although the majority of the changes are minor and are there to further increase the readability of the clauses, we would like to highlight some material changes to our Charterers Terms and Conditions 2021.  

The CTC 2021 will apply to all Charterers Members with covers attaching with effect from 20th February 2021. A digital copy can be found below, as well as on our Charterers & Traders page. Limited hard copies will be printed and made available to Members, same can be ordered by filling out the following online form.

Copy may be downloaded at https://www.ukpandi.com/-/media/files/uk-p-and-i-club/rules/2021/charterers-terms-and-condition-2021.pdf

Bunker supply contracts – key considerations for the buyer

Regardless of whether a buyer purchases fuel directly from physical suppliers or via brokers or traders and whether sale is under a global framework agreement or ad hoc on a port by port basis, a common feature is that the seller’s terms generally

On 1 January 2020, the lower sulphur limit imposed pursuant to IMO 2020 regulations came into effect. The new regulations have been written about extensively by Gard and others in the shipping and insurance industries.  However, the terms upon which bunkers are purchased is perhaps not given the consideration it deserves

Sellers' terms often incorporate fixed (often low) limits on sellers’ liability, exclusions for certain types of loss (e.g. loss of time, profit, indirect or consequential loss), short time bars for buyers’ claims, and evidential and law and jurisdiction clauses in sellers' favour. There have been moves to try and work towards standard bunker purchase contracts with BIMCO introducing BIMCO Bunker Purchase Terms in 2015 which were updated in 2018. These contracts are more balanced than typical sellers' standard terms, and representatives from owners, charterers and bunker companies were all involved in the drafting process.

From a commercial bargaining perspective, it may be easier to negotiate more balanced terms if they are agreed in advance as part of a worldwide framework agreement to buy bunkers from a single or small number of sellers.

Taking the BIMCO Terms as a starting point buyer may try to negotiate on some of the following checklist key items:

Bunker supply contracts – key issues checklist

·     Due diligence with respect to the seller: consider market reputation and financial standing of sellers, in terms of financial standing and insurance position (see below) and involvement in previous supply issues. Are they also a physical supplier or only an intermediary? How do they verify the quality of the fuel supplied? What are their supply chain quality management procedures?

·        Due diligence with respect to the fuel: consider what information you need about the fuel and its origin.  Are there any special parameters regarding storage, handling, treatment and use of the fuel on board? Do you require specific information in the Certificate of Quality?

·   Fuel specification: the contract should identify the correct specification of the fuel - for example by expressly stating the relevant ISO specification. For residual fuels, the most widely used specification is ISO 8217 Table 2.  The Table 2 specification for sulphur content is stated as per “statutory requirements” and, since 1 January 2020, the global MARPOL sulphur limit is 0.50% with lower limits set for SECAs. ISO 8217 is periodically revised and the industry guidance recommends the most recent version, ISO 8217 2017. Check whether the fuel specified in your bunker supply terms complies with IMO 2020 and that this also accords with charterparty requirements so it is back-to-back. A further point to consider adding is an express term that the fuel is free of contaminants, is fit for purpose and complies with MARPOL. 

·        Sampling and quality testing: the contract should specify the agreed sampling and quality testing regime, including for sulphur content. Ideally, a sample from each of the bunker supplier and the vessel should be analyzed as opposed to only the supplier's sample.  Again, insofar as possible, sampling and testing requirements need to match the charterparty so the buyer is not exposed to different test standards. Ideally, the sampling process should be set out in detail in the contract together with the agreed analysis regime that is to be used. Consideration should also be given as to whether preferred accredited labs for testing should be identified in the contract. In the event there is a dispute about the quality or characteristic of the particular stem, inability to agree to a lab for testing may complicate and delay resolution. 

·        Quality claims time bar: the contract should ideally include a quality claim time bar that allows sufficient time for quality testing to be performed, taking into consideration that testing might need to take place at an accredited lab located at a place other than the place of supply. In our experience, bunker contract time bars are normally far too short, especially given that bunkers may not be immediately used (for example bunker test results may be required under the charter before the bunkers are in fact used) and even when used promptly problems may not manifest themselves immediately. We have seen cases where the bunker recourse claim against the supplier is time barred before the bunkers have been used. It is recommended to link any time bar to 14 days after use of the bunkers or alternatively to have a much longer time bar period, for example 45 days.

·   Limitation of liability: standard bunker supply contracts usually include a low mutual limitation of liability figure (usually one or at most two times the invoiced value of the fuel). Consider negotiating increased limitation of liability sums to reflect the fact that losses arising from loading or consumption of off-specification fuel can be very high in value. It is suggested that at least twice the value of the fuel or more should be targeted where possible. An alternative option is to include reference to both a specific amount and at least twice the value of the fuel provision, with the highest of the two applying. Lastly, make sure that any limitation agreed applies mutually to both parties (rather than just the sellers).

·        The "OW Bunkers" issue: if buying direct from a physical supplier there is less risk, but if purchasing via a broker or trader there is a risk they may not have paid their counterpart for the bunkers which could, in the event of their insolvency, lead to competing payment demands and the risk for the buyer of having to pay twice.  It is sensible to include provisions under which the sellers warrant they have paid for the bunkers and the buyer has a right to request evidence from the sellers that they have paid any third parties for the bunkers before the buyer is required to pay the sellers' invoice, such that if no evidence is provided the buyer may withhold payment/hold sellers in breach.

It is further prudent to include a term that in the event of bankruptcy of the sellers, the buyer will be entitled to withhold payment for the fuel until the relevant court/tribunal determines whether sellers or the physical suppliers or any third parties have a claim directly against the buyer/vessel. If there is such a determination, the contract can also provide that payment to a party other than sellers for the fuel, as determined by the relevant court/tribunal, shall be deemed to subordinate the claim to the rightful party in order to safeguard the buyer from having to pay more than one party (and more than once!) for the fuel.

Consider also making the contract subject to the Sale of Goods Act 1979, so as to make the contract a contract of sale (thus bringing in the Act's protection so far as fitness for purpose and quality are concerned, and the requirement that the Sellers also have good title to the fuel at the time of sale to the buyer).  

·     Insurance: sellers should ideally have insurance in place and should be required to produce evidence of this. Such insurance may for example include credit, professional indemnity and product liability insurance.

·     Local rules and regulations: most standard term contracts incorporate local rules and regulations into the bunker supply contracts. Local rules and regulations can bring about surprises that the parties to the contract might not be aware of at the time of contracting. Consideration is accordingly recommended to be given to the exclusion of local rules and regulations either in their entirety or to limit their applicability to fuel sampling only.

·        Uniform bunker supply terms: ideally the same supply terms should be used across the board with all suppliers so as to have certainty over the risk allocation and to avoid the use of ad hoc supplier friendly terms. In effect, have a framework agreement/standard terms agreed with major suppliers.

·        Lien: try and avoid provisions that give the sellers a lien over the vessel or any rights of action against third parties (e.g. the owner if the charterer is the buyer) as this can cause serious issues under the charterparty. A further point to consider, is to add an express provision that the sellers must hold the buyer harmless and indemnify the buyer in the event that a third party asserts a lien or encumbrance on the vessel in relation to the fuel purchased from the sellers. Similarly, a clause can also be included by which the sellers warrant that no third party has any right to claim against the buyer in relation to the fuel, or exercise any right of lien, charge, encumbrance or arrest over the vessel or any sister vessels in respect of the fuel. Lastly, consider including a provision that if such a claim nevertheless arises, the sellers shall co-operate to allow interpleader proceedings. See also our comments on the OW Bunkers issue above.

·        Exclusions: consider whether you wish to exclude indirect or consequential loss (as this could extend to loss of time). Be careful of broad term exclusions that are usually found in bespoke sellers' contracts. Make sure that any exclusions apply mutually to both contractual parties if they are agreed.

·        Law and Jurisdiction: avoid the application of US law (due to maritime lien rights) and agree on a neutral law/jurisdiction that is not necessarily the sellers' choice.

These suggestions come from our experience in disputes and litigation involving bunker quality. It is important for buyers to understand the consequences of accepting sellers' terms and well worth the effort to attempt to negotiate a more balanced contract. Even when the terms are not negotiable, risks can be mitigated by exercising due diligence before selecting the seller.

 

 

MAIB UK Investigation Reports / Lessons Learnt (02/2020)

 1-ECDIS is not an Alarm Clock

Narrative

It was a fine summer night and a live fish carrier was on passage; the bridge was manned by the OOW and an AB lookout. It was still dark at 0430 when the AB left the bridge to prepare painting materials for the next watch.

Thereafter, the OOW was alone and sitting in the bridge chair. The OOW did not feel tired but must have drifted off to sleep as he was suddenly woken by the ECDIS safety depth alarm indicating that the water depth was less than 10m.

The OOW applied astern power and turned to port in an attempt to avoid shallow water. But it was too late, and the vessel was still underway at 4kts when it grounded (see figure). The master was called to the bridge, and an initial assessment found no internal damage. The crew refloated the vessel using its own power around 30 minutes after the grounding and headed for harbour. Once the vessel was within mobile phone range, the coastguard was informed. An inspection by divers found some minor damage and the vessel proceeded to dry dock for repairs.

The Lessons

1. An alarm is only of value if it provides sufficient warning for the OOW to make sense of what is wrong and take action accordingly. In this case the depth alarm came too late to be effective as the seabed shelved steeply around the island and the water depth decreased rapidly. Neither the ECDIS off-track alarm, which would have alerted the OOW to the missed course alteration, nor the BNWAS, which would have alerted the crew to the inactivity on the bridge, had been set. Had either alarm sounded there might have been sufficient time to avoid the grounding.

2. There have been many incidents caused by lone watchkeepers falling asleep on the bridge. After a previous grounding incident under similar circumstances, the company involved in this case had required that a lookout be posted in the hours of darkness. When the lookout left the bridge to perform other duties while it was still dark the OOW was left alone and vulnerable to falling asleep.

3. Fatigue can creep up on you. Even if you do not feel tired it is important to recognize that falling asleep is a real risk when working at night, particularly in the pre-dawn hours where circadian rhythms mean the body is most primed for sleep.

4. Alerting the coastguard should be one of the first actions after an incident – not the last. Although the vessel was refloated without assistance, an early call to the coastguard would have been invaluable had the situation escalated. The ship was within VHF coverage and could easily have communicated with the coastguard without delay.

2-A Splash of Danger

Narrative

The crew of a cargo vessel were preparing for departure from their regular port, and a tug was connected at the bow and waiting to assist. All the mooring lines were still fast and the bosun was preparing to single up the forward lines, which would have included releasing the mooring winch brakes. However, instead of releasing the mooring winch brakes, the bosun released the port anchor windlass brake, inadvertently freeing the port anchor, which dropped into the water extremely close to the tug (Figure 1). There was no damage to either vessel, and the departure proceeded without further incident after the port anchor had been retrieved.

The Lessons

1. The brake release handles for the mooring winch and anchor windlass were next to each other (Figure 2). Tis arrangement is not unusual but does introduce the risk of inadvertent release of the wrong handle. On this vessel, the crew had painted the anchor release red to assist with distinguishing between the handles. Nevertheless, when preparing to depart from harbour the bosun operated the wrong handle, resulting in the accidental release of the anchor. This occurred because in all other respects the anchor was ready for letting go, removing any safety barrier to prevent inadvertent release.

2. The bosun was experienced and familiar with the mooring and anchor arrangements; it was daylight, good weather conditions and the crew were rested, so fatigue was not a factor. Therefore, there were no clearly identified causal factors for the bosun’s erroneous action. Events like this can happen, and it highlights the need for carefully following procedures, teamwork and maintaining high levels of supervision when working on deck. 

3. The anchor fell extremely close to the waiting tug. Had the tug been directly underneath the anchor with crew on deck, this accident could have had severe consequences. Tis serves as an excellent reminder of the hazards that exist for tugs, workboats or line handling boats when operating in close proximity to larger vessels.

 

Use of MARPOL Electronic Record Books.

From 1 October 2020, IMO amendments to MARPOL Annexes I, II, IV and V (and the NOx Technical Code, 2008)* will permit the use of electronic record books (in lieu of hard copy records).

Record Books Covered
 
The IMO amendments and guidelines apply to the following record books:

• Oil Record Book, parts I and II (MARPOL Annex I)
• Cargo Record Book (MARPOL Annex II)
• Garbage Record Book, parts I and II (MARPOL Annex V)
• Ozone-depleting Substances Record Book (MARPOL Annex VI)
• Recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI)
• Record of Fuel Oil Changeover (MARPOL Annex VI)
• Record Book of Engine Parameters (NOx Technical Code, 2008)

Approval of New and Existing Electronic Record Books

To be used to comply with these record keeping provisions, new and existing installations of electronic record books shall be approved by the flag Administration, or LR (Lloyd's Register) where authorised by Flag, to the IMO’s Guidelines for the Use of Electronic Record Books under MARPOL. Where LR is carrying out the approval, it will consist of type approval of the software and a subsequent installation survey on board.
 
Ship's Installation
Any ship choosing to use MARPOL electronic record books is required to carry a ship-specific Declaration, that confirms the installation meets the requirements of the IMO guidelines. The Declaration may be issued by the flag Administration, or where authorised by flag may be issued by LR following an installation survey on board.

During MARPOL surveys or Port State Control inspections, the absence of such a Declaration means an electronic record book (and the records it contains) may not be accepted as fulfilling the record-keeping provisions of MARPOL and the NOx Technical Code, 2008.

Type approval
Where requested by electronic record book manufacturers, LR can type approve their software applications, in accordance with the IMO guidelines.

Further information

file:///C:/Users/User/Downloads/LR_Class_News_17_2020.pdf

List of jurisdictions restricting or banning scrubber wash water discharges

Last updated 18 August 2020 

The MARPOL convention allows for the use of Exhaust Gas Cleaning Systems1 (EGCS, more commonly referred to as scrubbers) as an alternative means of complying with the 2020 low sulphur regulations. However some jurisdictions have imposed local regulations which restrict or prohibit the discharge of wash water from scrubbers within their waters. The list below includes countries and ports where such restrictions are currently understood to be in place based on information received by the Association at the time of publication. However, the list should not be seen as necessarily complete and is for guidance only, in particular noting that local legislation can be subject to change at short notice. It is therefore important that Members monitor the current situation closely and always contact their local agent/representative prior to arrival. This should include seeking confirmation of the latest situation regarding any applicable requirements relating to the operation of scrubbers and any permission required from the relevant local authorities for their use.

Download pdf at,

https://britanniapandi.com/wp-content/uploads/2020/08/List-of-scrubber-discharge-restrictions-and-bans-Britannia-LP-08-2020-1.pdf