Oman

Omani ports and 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 approved EGCS can be used as an alternative means of compliance. However overboard discharges are prohibited as per Maritime Notice 09/20 issued by the Directorate General of Maritime Affairs, effective date 01 November 2020 :

  1. Ships that use open-loop ship exhaust gas- cleaning systems is prohibited from discharging washing water into Omani ports and territorial waters
  2. Ships that use hybrid exhaust gas cleaning systems must switch from the open loop mode to the closed loop mode when they reach the
    territorial waters and keep the washing residues on board and dispose of them in the designated facilities at the port
  3. Ships using closed-loop exhaust gas cleaning systems must be keep the washing residues onboard when they reach territorial water and dispose of it at designated facilities at the port.

The full notice can be read here. EGCSA would like to thank Gulf Agency Company in Oman for its kind assistance in obtaining this notice

 

Kenya

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

Qatar

Qatar has to date not ratified MARPOL Annex VI (click to view current status) however Qatar Petroleum MIC [Mesaieed Industrial City] Port Information and Regulations Guide January 2020 Edition, Section 6.73 states:

“As per the International Convention for the Prevention of Pollution form ships (MARPOL) Annex VI, Reg.14 which came into force on 01/01/2020, all ships to meet the new requirements of LSFO (0.5% m/m) on and after the date of enforcement by using low Sulphur in marine “fuel oil used on board”.

“Mesaieed Port recommends all vessel to use compliant fuel (LSFO) while in Qatari territorial waters.

“Also, as per Qatari Environmental Law, wash water originated from the open loop scrubbers, containing chemicals and /or metals are PROHIBITED to be discharged in Qatari waters.”

Click here to view

Ras Laffan port rules can be found here. It should be noted that regulations on this page are 2017 edition (as of August 2020) and do not mention scrubbers.

Mwani Qatar port laws and regulations can be found here. It should be noted that Hamad and Al Ruwais regulations on this page are 2021 editions and also do not mentions scrubbers.

Saudi Arabia

Under Maritime Transport Sector, TGA Circular No. (14) 2019 (distributed as Circular No. (21) 2019 by Mawani Saudi Ports Authority), MARPOL Annex VI regulation 14, 0.50% fuel sulphur limit applies to ships in Kingdom of Saudi Arabia waters. EGCS are permitted as an alternative method of compliance.

However Mawani Saudi ports authority has subsquently published Circular No. (55) 2020 “Preventing ships’ exhaust wash water discharges by (EGGS) system designed as open loop into Saudi ports”. Click here to view

It should be noted that Circular No. (55) 2020 does not explicitly state that open loop EGCS cannot discharge into Saudi territorial waters, however the prohibition in ports is based on “instructions that we [Mawani] received from General Authority of Meteorology and Environmental Protection “GAMEP” about the mechanism of the exhaust wash water discharges, which includes preventing the ships disposal of that water into the territorial water of the Kingdom of Saudi Arabia.

Mawani circulars in arabic with an english translation can be accessed here (note up to date circulars are only available on the arabic language page – for reference hovering over the document download icon shows the number of the circular in the link address).