The International Chamber of Shipping (ICS) is encouraging the Paris Memorandum of Understanding on Port State Control (PSC) to ensure that a harmonised approach to PSC inspections has been developed in advance of the 1 January 2015 deadline with respect to the implementation of the 0.1% Sulphur Emission Control Areas (SECAs), established in accordance with Marpol Annex VI.
ICS has underlined the shipping industry’s commitment to full compliance with the IMO sulphur ECA requirements from January 2015. However, ICS is concerned that information collected by its member national ship owners’ associations suggests that many governments are not yet prepared to implement the requirements in a uniform manner, to ensure the prevention of a potentially serious market distortion.
PSC Inspection Issues
A number of PSC inspection issues have been raised by ICS with respect to Marpol Annex VI on which the organisation believes it is vital that a harmonised approach is developed and agreed by the Paris MOU in advance of the implementation date. These issues include:
- Whether – as ICS believes should be the case – the principal method of inspection will only involve looking at the bunker delivery note (BDN), with further sampling/analysis of fuel only normally taking place when examination of the BDN suggests clear grounds to
- suspect non-compliance, or when there is a previous history of non-compliance with Marpol Annex VI;
- The procedures to be followed, with reference to applicable IMO Guidelines, in the event that sampling or analysis is undertaken during PSC inspections;
- The procedures that might be followed with respect to ships that transit an ECA without calling at a Port State located within an ECA;
- The extent to which a consistent approach will be shown with respect to any discretion for minor technical violations (e.g. those that might arise from fuel switching when a vessel enters an ECA) as opposed to deliberate use of the wrong grade of fuel, or with respect to any discretion that might be applied for a limited period after January 2015;
- And the criteria to be applied during PSC inspections with respect to alternative compliance measures such as Exhaust Gas Cleaning Systems (‘scrubbers’) or LNG.
Issues with respect to scrubbers that ICS believes require a harmonised approach include the acceptability of "closed loop" and "open loop" systems, and the extent to which overboard discharges will be subject to inspection by reference to the relevant IMO Guidelines.
It is hoped that the Paris MOU will consider these issues at the next meeting of its Management Advisory Board.
