Italy

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Italy is a member of the European Union, Directive(EU) 2016/802 therefore applies and a maximum of 0.10% sulphur fuel is to be used in port. As Italian waters are outside of the Emission Control Areas defined under MARPOL Annex VI Regulation 14 (and the EU Directive) a fuel sulphur limit of 0.50% applies to vessels outside of ports from 1 January 2020.

Ministry of Infrastructure and Transport Coast Guard Headquarters, Safety of Navigation Department circular “Navigation Safety” No.132/2017/Rev.1, as amended 19 December 2019, (click to view) confirms that EGCS can be used as an alternative method of compliance if approved, have appropriate documentation and are operated as per MEPC.259(68) Guidelines for Exhaust Gas Cleaning Systems.

Coast Guard circulars can be viewed here: https://www.guardiacostiera.gov.it/normativa-e-documentazione/Pages/circolari.aspx

Ports of Livorno and Piombino

EGCSA has been advised the above circular will be applied by the local Maritime Authorities (Harbour Master offices) in Livorno and Piombino (also in the province of Livorno)  and that as of the date of advice there are there are no specific restrictions regarding the use of open-loop scrubbers as an alternative to closed-loop or hybrid systems.

It should however be noted that the document  Agreement for the Environmental Sustainability of the Port of Livorno – Livorno Blue Agreement states that if ECCS are used as a method of compliance, the systems must be operated in closed loop if a fuel of greater than 3.50% sulphur is in use. (This is in line with Directive(EU) 2016/802).

The Livorno Blue Agreement can also be viewed here.

Information compiled with contributions kindly provided by Thomas Miller in the UK / Vincenzini-Batini in Italy

Kenya

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Kenya’s waters are outside of IMO MARPOL Annex VI Emission Control Areas. Under Annex VI regulation 14 the maximum fuel sulphur limit of 0.50% applies from 1 January 2020. Regulation 4 also applies and EGCS be used as an alternative means of compliance if at least as effective in terms of SOx emissions reduction as the fuel sulphur limit.

However the National Guidelines on Implementation of IMO2020: MARPOL Annex VI Requirement for Marine Fuel Oil, December 2019, confirms the following key points regarding use of EGCS:

7.0 SCRUBBER WASHWATER DISCHARGE

7.1 The discharge of wash-water from open-loop scrubbers is prohibited in the Kenyan Ports limits. This is to٠maintain the standard of Kenya marine water quality.

7.2 While in the port of Mombasa, ships fitted with hybrid type of scrubbers shall switch to the closed-loop mode of operation. Ships fitted with open-loop scrubbers shall switch over to compliant fuel oil.

7.3 It is advisable to carry out the switch to either closed-loop mode or to compliant fuel oil well in advance of the vessel’s arrival at the port waters, so that any operational issues can be identified and dealt with promptly prior to entering Kenya port limits. For ships fitted with open-loop scrubbers and calling into ports where discharge from open-loop scrubbers is prohibited, appropriate procedures in the safety management system should be established to ensure that the changeover to compliant fuel oil is carried out safely. Such procedures should take into consideration the mode of engine operation, traffic density, and duration of passage etc., including identifying locations where such changeover to compliant fuel is to be carried out. The company’s Safety Management System (SMS) should also ensure that the ship’s crew is properly trained

Click here to view the Guideline.

Further information on the IMO 2020 implementation can be found at the Kenya Maritime Authority (KMA) website – https://kma.go.ke/implementation-of-imo-sulphur-limit/

Information sourced with kind assistance of Thomas Miller in UK and Protecting and Indemnity (K) Ltd in Kenya

Republic of Korea (South Korea)

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Republic of Korea (South Korea) Ministry of Oceans and Fisheries has announced that SOx Emission Control Areas (SECA) will be implemented in and around a number of major ports under Article 10(1) of The Special Act on the Improvement of Air Quality in Port Areas.

The ports are:

  • Incheon (including Kyongin Port)
  • Pyeongtaek-Dangjin
  • Yeosu
  • Gwang-yang (including Hadong port)
  • Busan
  • Ulsan

Korean Register Technical Information notice No.: 2020-ETC-06 Date: 9th July, 2020, gives geographic coordinates and maps of the areas. (Click here to view)

  1. From 1st September 2020, ships at berth or at anchor will be required to use fuel with sulphur content not exceeding 0.10%. Fuel changeover is to be within 1 hour of completing anchoring/mooring and compliant fuel must continue to be used until 1 hour before heaving anchor/deberthing.
  2. From 1st January 2022, changeover to 0.10% low sulphur fuel is to be completed at entry into the SECA and use of compliant fuel must continue while the vessel remains inside the SECA.
  3. Alternatively, EGCS (Exhaust Gas Cleaning Systems) compliant with MARPOL requirements can be used providing the reduction in SOx emission is as least as effective as using 0.10% sulphur fuel. There are no restrictions on overboard washwater discharges from open-loop scrubbers.

The Korean Register publication also gives further details on information to be logged if a compliant fuel or alternatively EGCS is to be used and confirms that a written changeover procedure is mandatory if 0.10% sulphur fuel rather than EGCS is the method of compliance.

Downloads of Korean Register rules and technical information can be found in both Korean and English languages at https://www.krs.co.kr/eng/Exclusive/Tech_ETC.aspx?MRID=546&URID=539&TechCode=7

 

Brazil

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Brasil Directorate of Ports and Coasts (DPC) Circular No 7/2019, 22 November 2019, confirms that all ships in Brazilian territorial waters and national ports must comply with the MARPOL Annex VI requirement to use fuel with a sulphur content no greater than 0.50% from 1 January 20 (paragraphs 3.1 and 3.2). EGCS are allowed as an alternative method of compliance (see paragraphs 3.3 and 3.4), provided the equipment is approved, has documentation and is operated as per MEPC.259(68) Guidelines for Exhaust Gas Cleaning Systems. (Click here to view circular)

DPC circulars can be viewed at https://www.marinha.mil.br/dpc/circular

It should be noted that there have been reports by P&I club corresponents in Brazil (e.g. https://proinde.com.br/news/brazilian-maritime-authority-changes-position-on-open-loop-scrubbers/) that discharges from open loop EGCS were or were to be prohibited in Brazilian waters, however it appears that the advice of regulators has been changing and there is no formal notice to this effect, so Circular No.7/2019 still applies.

A number of sources also cite a statement by Vale S.A. dated 20 December 19 recommending that to comply with Brazilian environmental law ships only use Low Sulphur Fuel Oil within 24 nautical miles of the Brazilian Coast. Also that EGCS wash water should not be discharged overboard within Brazilian waters or while inside the Vale S.A. ports and terminals of (i) Ponta da Madeira, (ii) Tubarão & Praia Mole Complex and (iii) Ilha Guaiba. Owners/Masters may be asked to provide written confirmation of compliance while inside Vale’s ports and terminals. Non-compliance could result in berthing being rejected and owners being responsible for associated costs.

Vale port regulations can be found at https://www.vale.com/logistics (click on the port name). It should be noted that the above Vale statement regarding no EGCS discharges appears not to be in any of the regulation documents.