- IMO considers exhaust gas scrubbers to reduce vessels’ sulphur emissions.
- It specifies requirements for verification, testing, survey, and certification of scrubber systems.
- It also sets out the criteria for discharging scrubber wash water into the sea.
- Vessel operators have two options to choose to ensure compliance with the sulphur limits.
- They can switch to a closed-loop scrubber or compliant fuels.
- The vessels must maintain proper records of such a changeover.
According to an article published in Gard, the IMO considers exhaust gas scrubbers to be an acceptable means of reducing vessels’ sulphur emissions and ensuring compliance with MARPOL Annex VI.
Local exhaust guidelines released
A separate guideline, Resolution MEPC.259(68), specifies the requirements for the verification, testing, survey, and certification of scrubber systems and sets out the criteria for discharging scrubber wash water into the sea.
Summary and recommendations
Although exhaust gas scrubbers are an accepted abatement technology to meet IMO’s SOx emission rules for 2020, their use is not accepted globally in all states. If a members’ vessel is trading in the area(s) where the discharge of scrubber wash water is not permitted, vessel operators have two options to choose from to ensure compliance with the sulphur limits:
- switch over to a closed-loop mode of scrubber operation, in which case it will be necessary to convert currently installed open loop scrubber systems to closed-loop or hybrid systems, if not already done; or
- the changeover to compliant fuel.
Changeovers to be carried out in advance
Any changeover should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place, and proper records should be maintained of such changeover.
The early changeover will help in identifying operational issues, if any, after the changeover, and will allow for sufficient time to rectify such before the vessel enters the area. Owners’ and managers’ safety management procedures should contain guidelines on how to carry out the changeover safely and outline the recordkeeping requirements. It is also recommended that a vessel’s passage plan incorporates information on when to carry out the changeover, taking into account things such as duration of passage, the time needed for the changeover, the density of traffic, proximity to hazards, etc.
Members urged to alert the crew
We advise Members and clients to monitor the situation closely and ensure that crew members onboard vessels fitted with open-loop scrubbers are made aware of any relevant local discharge requirements in force.
In general, vessels with any kind of scrubber installed should check with local authorities whether there are any applicable regulations in relation to the use of scrubbers, such as wash water discharge restrictions, and requirements to seek permission from authorities to use scrubbers.
You can read more about the restrictions from here.
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Source: Gard
