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BIMCO - MEPC74 LOOKS AT SCRUBBER WASHWATER AND ECGS FAILURE IMPLICATIONS

Monday, May 20, 2019 

BIMCO has reported back from the latest meeting of the IMO Marine Environmental Protection Committee (MEPC74), which examined the controversy surrounding exhaust gas cleaning systems (EGCS - scrubbers) in detail.

The sub-committee on Pollution Prevention and Response (PPR) has been tasked to look into the discharge from open-looped scrubbers, in particular the environmental impact of the washwater. Several delegations to MEPC74 had expressed fundamental concerns whether a scrubber system could constitute a more favourable treatment of ships, compared to ships using compliant fuel.

Today, the industry is faced with many new national or regional rules on the water discharges from scrubbers. These rules are increasingly restricting - or even prohibiting – ships from discharging scrubber washwater certain sea areas - such as ports, estuaries and coastal areas. Hence, as part of the work, PPR is tasked to evaluate and possibly harmonise the rules and guidance on the discharge of washwater from scrubbers.

BIMCO believes that preliminary results from scientific studies modelling the accumulative effect of scrubber discharge in port shows very limited effect when compared to the EU water quality standards. This is not an issue that will be decided soon, as finalisation is not expected until 2022.

MEPC additionally considered the question of failure of the EGCS. If this happens, and the ship is thus no longer in compliance with the sulphur-rules, the ship should change over to compliant fuel oil, if the EGCS cannot be put back into a compliant condition within one hour. The failure should also be properly reported in the EGCS Record Book. The reason for a failure could be a system error or a failure of a monitoring instrument, where the system malfunction cannot be rectified.

If the ship does not have compliant fuel oil or sufficient amount of compliant fuel oil on board, the ship should communicate a proposed course of action to the relevant authorities (including the ship’s administration), in order to bunker compliant fuel oil or carry out repair works. The authorities need to sign off on this course of action. BIMCO adds that any troubleshooting procedure may vary according to scrubber design and EGCS manufacturer. MEPC is to issue guidelines as a Circular shortly.

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