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MARINE ENVIRONMENT PROTECTION COMMITTEE 62nd session Agenda item 7

MEPC 62/7/86 May 2011

Original: ENGLISH

INTERPRETATIONS OF, AND AMENDMENTS TO, MARPOL AND RELATED

INSTRUMENTS

Minimum requirements for IMO circulars related to notification of the certification of an Approved Method (MARPOL Annex VI, regulations 13.7.1 and 13.7.2)

Submitted by the International Association of Classification Societies (IACS)

SUMMARY

Executive summary: Under the provisions of MARPOL Annex VI, regulations 13.7.1 and 13.7.2, two types of Approved Methods have been certified, one by the Danish Administration and the second type by the German Administration, and the relevant IMO circulars MEPC.1/Circ.738 and MEPC.1/Circ.743 were issued. However, the information contained in these circulars is considered insufficient for implementing the relevant survey. Therefore, in order to improve the situation, IACS proposes a clarification of the information to be included in the relevant IMO circular notifying the certification of an Approved Method.

Strategic direction: 7.3

High-level action: 7.3.1

Planned output: 7.3.1.1

Action to be taken: Paragraph 13

Related documents: MEPC.1/Circ.738 and MEPC.1/Circ.743

Background 1 In accordance with MARPOL Annex VI, regulations 13.7.1 and 13.7.2, marine diesel engines with a power output of 5,000 kW or above and a per cylinder displacement at or above 90 litres, installed on a ship constructed on or after 1 January 1990 but prior to 1 January 2000, are to comply with Tier I NOx emission limits using an Approved Method, provided that an Approved Method for that engine has been certified by an Administration. 2 In accordance with the provisions of regulation 13.7.1, once an Approved Method has been certified by an Administration, that Administration is to submit the notification to IMO, which then publishes the relevant IMO circular.

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3 In accordance with the provisions of regulation 13.7.2, installation of the Approved Method and the relevant survey are to be completed no later than the first renewal survey that occurs 12 months or more after deposit of the notification in paragraph 2 above. 4 In line with the aforementioned procedure, so far, IMO circulars related to the Approved Methods certified by the Danish Administration (MEPC.1/Circ.738: Approved Method for MAN B&W S70MC engines) and the German Administration (MEPC.1/Circ.743: for Wärtsilä RTA engines) have been issued. In accordance with these IMO circulars, application and the relevant survey of the Approved Methods shall be completed no later than the first renewal survey that occurs on or after 6 October 2011 for the MAN B&W S70MC engines and 5 February 2012, for the Wärtsilä RTA engines respectively. 5 However, IACS considers that sufficient information needed to implement the application of the Approved Methods was not contained in MEPC.1/Circ.738 and MEPC.1/Circ.743. Consequently, IACS Members are now confronted with difficulties in implementing the relevant survey appropriately. To improve the situation, IACS proposes a set of minimum requirements regarding the information to be included in the relevant IMO circulars. Issues that need to be solved for implementation of the relevant survey 6 IACS Members, which are in the position of performing the relevant surveys, recognize the following issues, which makes it difficult to implement the relevant survey:

.1 given the information contained in the IMO circulars, the Administration/RO responsible for the survey in question is unable to clearly identify diesel engines to which the Approved Method is to be applied; and

.2 the Approved Method files required by section 7.4 of the NOx Technical

Code (NTC), 2008 were not publicly made available; therefore, it is unclear what kind of on-board survey procedure should actually be applied.

7 The issues briefly touched upon in paragraph 6 above, are discussed in more detail in the following paragraphs 8 and 9. 8 The specific circumstances and the views of IACS on the issue referred to in paragraph 6.1 above are as follows.

.1 In MEPC.1/Circ.738, only the following information was included: the model type, the power output and speed range of the marine diesel engines subject to the Approved Method.

.2 However, according to information received from the Danish Administration

that certified the Approved Method, the data provided in MEPC.1/Circ.738 is not sufficient enough to identify diesel engines to which the Approved Method is to be applied, and further information such as fuel valve nozzle type, shop trial results, etc., is necessary for the identification. Therefore, applicability of the Approved Method to individual diesel engines needs to be judged by the engine manufacturer one by one upon application from the shipowners.

.3 IACS is concerned about unnecessary confusion which could be caused by

the circumstance whereby parties responsible for the relevant survey and certification cannot identify the diesel engines to which the Approved Method is to be applied just by referring to the information provided in the IMO circulars.

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.4 In addition, even if the engine manufacturer judges the applicability of the Approved Method to individual diesel engines as mentioned in paragraph 8.2 above, since the technical background of the certification of the Approved Method is unknown to any person/organization other then the Administration that certified the Approved Method, the Administration/RO in charge of the survey does not have the ability to readily verify the manufacturer's judgement.

.5 In order to solve the aforementioned issues, IACS considers the relevant

IMO circulars should include all the necessary information for the concerned parties to clearly identify the diesel engines to which the Approved Method is to be applied. Alternatively, a list of the subject diesel engines should be provided as an attachment to the IMO circular.

.6 In addition to the above, clarification is necessary in the event that a

modification has been made on the subject diesel engine. In such a case, since the NOx emissions may not be reduced as expected due to the modification, applicability of the Approved Method should be determined individually by the Administration which certified the Approved Method upon request from the shipowner. In cases where the Administration determines that the modified diesel engine is exempted from application of the Approved Method, the exemption should be duly documented by the Administration, and the document should be retained on board the ship for evidence.

9 The specific circumstances and the views of IACS on the issues regarding Approved Method files referred to in paragraph 6.2 above are as follows.

.1 In section 7.4 of NTC 2008, it is specified that the Approved Method for achieving compliance with regulation 13.7 shall include a copy of the Approved Method file that is required to accompany the engine throughout its life on board ship. In addition, in section 7.6 of NTC 2008, it is also specified that, after installation of the Approved Method, a survey shall be conducted in accordance with the Approved Method file.

.2 IACS understands the procedures for certification of the approved method

file and the subsequent survey referred to in paragraph 9.1 above are as follows:

.1 Any Administration which certifies an Approved Method is also

required to certify a relevant approved method file. .2 Each diesel engine subject to installation of an Approved Method

is required to be provided with a copy of the Approved Method file certified by the Administration responsible for certification of the Approved Method, and the file is to be kept on board the ship. (Since the technical background of the certification of the Approved Method is unknown to any person/organization other then the Administration which certified the Approved Method, the Administration/RO in charge of the survey cannot certify the relevant approved method file for the individual diesel engine).

.3 The Approved Method file which has been certified (i.e. the

relevant Administration's official seal, etc., is affixed) is made available to the Administration/RO in charge of the survey.

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.4 Relevant surveys after installation of an Approved Method are to be performed in accordance with the procedure described in the Approved Method file.

.3 In the cases of MEPC.1/Circ.738 and MEPC.1/Circ.743, the Approved

Method files were not attached to the IMO circulars. Therefore, details of the survey in question were not made available to the shipowners or Administrations/ROs responsible for actually performing such surveys until the time when the first application of the Approved Method will be made to a diesel engine concerned. This may delay the whole process of application of the Approved Method and the subsequent on-board survey, and consequently lead to non-compliance with the regulatory requirements.

.4 The aforementioned issues could be minimized if the Approved Method file

certified by the Administration responsible for the certification of an Approved Method would be made available as an attachment to the IMO circular.

Proposals 10 In order to address the issues explained above, IACS proposes that the following information should be included as a minimum in the relevant IMO circulars:

.1 a clear explanation of the details of the Approved Method; .2 all the relevant conditions necessary to identify diesel engines to which the

Approved Method is to be applied (including sufficient information to allow third parties to make such identifications); or alternatively, a list of the diesel engines;

.3 if possible, a list of ships known to be equipped with diesel engines to

which the Approved Method is to be applied; and .4 a copy of the Approved Method file which has been certified by the

Administration responsible for the certification of the Approved Method. 11 If there is any doubt regarding the applicability of the Approved Method for an individual diesel engine, e.g., in cases where a modification had been made on the diesel engine, the Administration responsible for certification of the Approved Method should determine the applicability of the Approved Method one by one upon request from the shipowner. Additionally, in cases where the Administration determines that the modified diesel engine is exempted from application of the Approved Method, the exemption should be duly documented by the Administration, and the document should be retained on board the ship as evidence. 12 Considering the current circumstances related to both MEPC.1/Circ.738 and MEPC.1/Circ.743, it is difficult to properly implement the relevant surveys due to the issues described in paragraphs 8 and 9 above. Therefore, for practical reasons, IACS proposes that both circulars be withdrawn until such time as the necessary information specified in paragraph 10 above is made available. Action requested of the Committee 13 The Committee is invited to consider the above comments and proposals and take action as appropriate.

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