Scrubber Notifications Issued in US ECAs Ahead of 2020

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According to a Safety4Sea report, the Office of Commercial Vessel Compliance issued CG-CVC Policy Letter 12-04 in 2012 asking for correspondence from flag administrations regarding equivalencies for exhaust gas cleaning systems (scrubbers) under MARPOL Annex VI Regulation 4.

Scrubber Notifications

As CG-CVC no longer requests this notification, flag administrations should continue to make appropriate notifications to the IMO regarding equivalencies issued under MARPOL Annex VI Regulation 4, in order to avoid control and enforcement action by the Coast Guard.

What is more, all operational exhaust scrubbers that are tested, surveyed, and verified under the MEPC 184(59) or MEPC 259(68) and are granted equivalencies by a flag administration are authorized to operate in the North American and U.S. Caribbean Sea Emission Control Areas.

Non Scrubber Fuel Use

According to the USCG, all non-emergency machinery not serviced by the exhaust scrubber are required to use compliant fuel of 0.10% or less sulfur content, in order to meet MARPOL Annex VI Regulation 14; such scrubbers must be operated in accordance with applicable state and local regulations. In fact, the CG-CVC Policy Letter 12-04 Change 1 has been adjusted in order to reflect this policy change. To find out more about this policy change, you can click for the PDF here.

Nonavailability of Compliant Fuel

In July, the USCG Office of Commercial Vessel Compliance launched a Marine Safety Information Bulletin, the ‘New Procedure for Shipping Industry to Notify the US Government of Non Availability of Compliant Fuel Oil.’

Who is it for?

In general, the notice concerns owners and operators of vessels operating in the North American (NA) or U.S. Caribbean Sea Emission Control Area (ECA), that are unable to acquire sufficient MARPOL Annex VI compliant fuel oil at a foreign or U.S. port may satisfy the MARPOL Annex VI Regulation 18.2.4 requirement to notify the competent authority of the relevant port of destination by notifying the cognizant U.S. Coast Guard Captain of the Port (COTP).

No FONAR Reports Acceptable

Effective June 30, 2019, the U.S. Environmental Protection Agency (EPA) would stop accepting Fuel Oil Non-Availability Reports (FONARs). Marine notice alerts that in possibility of failing to make the notifications required by MARPOL Annex VI, 18.2.4 may result in a vessel control, such as detention, and/or enforcement action.

Scrubbers in Line

Moreover, in light of the approaching IMO 2020 sulphur cap, Bloomberg has previously suggested that in the following years about 2,200 vessels are to install scrubbers, as if they don’t they will be banned. DNV GL states that putting all those vessels in a line, they’d stretch about 340 miles.

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Source: Safety4Sea

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