This guide provides information on the use of an Exhaust Gas Cleaning System (EGCS) as a method for meeting the fuel sulphur limit of 0.50% m/m, as required by both MARPOL Annex VI and Australian law.
Australian Legal Framework and Approval
In Australia, the use of an EGCS for compliance is permitted under the Protection of the Sea (Prevention of Pollution from Ships) Act 1983. To be used, the system must have been approved by the vessel’s flag State Administration or a Recognised Organisation designated by that state. Furthermore, it must be operated in accordance with the International Maritime Organization (IMO) requirements, specifically the 2021 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.340(77)).
Discharge Water and Residue
Discharge water from all types of EGCS (open-loop, closed-loop, and hybrid) is permitted in Australian waters, provided it meets the quality criteria set out in the IMO Guidelines. This applies even within Australia’s Particularly Sensitive Sea Area and the Great Barrier Reef Marine Park. While permitted, it is recommended that vessels contact specific port authorities, as some may encourage vessels to refrain from discharging within port limits.
Sludge and residues from the EGCS must be disposed of at port reception facilities and are strictly prohibited from being discharged at sea or incinerated on board.
Operational and Maintenance Requirements
Vessels operating an EGCS must adhere to several operational requirements. Crew members must be proficient in the system’s operation, and the system must be kept in good working order with up-to-date maintenance. All monitoring devices must be fully functional. The vessel must also keep and be able to provide records upon inspection by a Port State Control Officer (PSCO), including the EGCS approval documents and its operational and maintenance logs.
Malfunction Procedures
In the event of an EGCS malfunction, immediate action is required. If the issue is a one-off and can be resolved within an hour, no report is necessary. However, if the malfunction lasts for more than an hour or occurs repeatedly, the vessel must switch to compliant fuel and report the incident to both the flag State Administration and the Competent Authority of the destination port.
If the vessel does not have enough compliant fuel to reach its destination, this must be included in the report. The report should also outline a proposed course of action, such as bunkering compliant fuel at the next port or carrying out repairs, for agreement by the flag State Administration and Competent Authority. For Australian vessels or foreign vessels in Australian waters, this report must be emailed to reports@amsa.gov.au.
Consequences of Non-Compliance
Any EGCS that fails to comply with the IMO Guidelines, including discharge water quality criteria, may be prohibited from use in Australian waters.
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