Bahrain

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Bahrain’s 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. While regulation 4 also applies and approved EGCS can be used as an alternative means of compliance, discharges from open loop scrubbers are not permitted in port and anchorage areas.

While Bahrain has to date not ratified MARPOL Annex VI (click to view current status), Ministry of Transportation and Telecommunications Marine Notice PMA/03/2019 (click here to download) applies and section 5 paragraphs 1 through 4 are of particular relevance.

In Bahraini territorial waters and the exclusive economic zone (EEZ) EGCS discharges are permitted if in compliance with the IMO 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68) and there is no negative impact on marine ecosystems.

A permit to discharge must first be obtained from the Marine Safety & Environment Protection Directorate (MSEPD) at Ports and Maritime Affairs (PMA). The application for a permit must include results of washwater testing undertaken during commissioning of the EGCS and repeated every twelve months, as a minimum, for a period of two years. Ships may not be allowed to discharge washwater from an EGCS in Bahraini waters if this data, or evidence that samples have been taken for analysis, cannot be provided.

Section 5 paragraph 4 goes on to state that PMA strongly encourages the vessel to use the close loop mode (no discharge overboard) when it sails within Bahraini waters.

Marine laws, regulations and notices can be downloaded at the PMA website http://mtt.gov.bh/content/pma-law-and-regulation , although it should be noted that Marine Notice PMA/03/2019 is not listed.

South Africa

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South Africa’s 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 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.

Marine Notice No. 42 of 2020

This is is a supplement to and should be read in conjunction with Marine Notice No.8 of 2019 (see below). The Notice issued by SAMSA 7 September 20 can be viewed in full here.

It provides an “update on the country’s transitional position regarding the use of Exhaust Gas Cleaning System (EGCS) in South African waters, in line with the global implementation of the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI limit of 0.50 mass per cent concentration (0.50% m/m) sulphur content in fuel oil, for all ships, effective 1 January 2020.”

Statistics are given on the methods of compliance used by vessels at their first port of call in South Africa, between the period April 2020 and July 2020 (including the various scrubber configurations used).

The Notice confirms that South Africa continues to accept all type approved scrubbers. This position will be re-evaluated following completion of a South African University study on the impact of open loop system wash water discharge on the marine environment. The study is estimated to be finalised December 20.

Marine Notice No. 8 of 2019 and Marine Notice No.22 of 2019 confirm the following key points regarding EGCS:

MN8 (4 March 2019)

3.1 Open-Loop, Closed-Loop Or Hybrid Systems

The use of exhaust gas cleaning systems, also known as scrubbers, is a commercially available option for the shipping industry. Ships installed with scrubbers mean they can continue to burn high-sulphur bunker fuel from 2020 and comply with the 0.5% sulphur limit

The abatement technology works by spraying alkaline water into a vessel’s exhaust to remove sulphur and other unwanted chemicals, either via open-loop system, closed-loop system, or hybrid (open-and-closed loop) system.

The acceptance of exhaust gas cleaning systems (scrubbers) as an equivalent arrangement under Regulation 4 of MARPOL Annex VI for compliance with the sulphur limit is currently based on the criteria stipulated in the 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68)).

2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68)

UNTIL FURTHER NOTICE SOUTH AFRICA ACCEPTS ALL TYPES OF APPROVED SCRUBBERS

The notice can be downloaded from the SAMSA website here.

MN22 (24 December 2019)

Masters of all ships at their first call on any South African port are required to report to SAMSA in the MRCC PAN report, information regarding compliance of MARPOL, ANNEXE, VI (IMO 2020 Sulphur Cap).

There are various options available to a ship owner which will be acceptable to SAMSA

iii)          Ship is equipped with an approved, fully operational Exhaust Gas Cleaning System (Scrubber Unit) and operated in accordance with IMO requirements and guidelines (resolution MEPC.259(68))

Port State Control Officers (PSCO) will require to sight all relevant documents on type of Fuel Oil on board, documents pertaining to the EGCS, evidence that the ship’s personnel involved in the operation of EGCS are adequately trained and familiar with its operation. Such records shall be made available to PSCO’s on request.

Additional information on the EGCS i.e. Make and Type of EGCS installed (Open Loop, Close Loop or Hybrid), frequency and date of Wash Water testing is to be included in the PAN report to MRCC.

Any breakdown or malfunction of the EGCS, notification to be sent to SAMSA

The notice can be downloaded from the SAMSA website here.

All Marine Notices can be downloaded at the following address: http://www.samsa.org.za/Pages/Marine-Notices.aspx

Relevant acts and regulations can be downloaded at the following address:

http://www.samsa.org.za/Pages/Acts-and-Regulations.aspx

The Maritime Zones act defines the boundaries of South African waters

Egypt – Suez Canal Authority

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Egypt has to date not ratified MARPOL Annex VI (click to view current status), however:

SCA Circular No. 08/2019 states:

“In consideration of using fuel oil with low Sulphur content in accordance with MARPOL Annex VI during transit from Suez Canal,

” you are kindly advised that Suez Canal Authority puts no conditions or restrictions on fuel oil or Open-loop Exhaust Gas Cleaning Systems until ratification of MARPOL Annex VI by Arab Republic of Egypt.

“This is also in consistence with the obligation that Wash water resulting from exhaust gas cleaning systems shall not be discharged into water during vessels transit of Suez Canal.”

7 January 2020: Because the wording is seemingly ambiguous, EGCSA has sought further local advice.

EGCSA’s interpretation is that scrubber washwater should not be discharged during transit of the canal, which differs from that widely reported in the online maritime media and press. This has been confirmed by Gulf Agency Company in Egypt, who advise

“Since no restriction on high Sulphur using in Suez canal assume that the best is to not use the scrubbers during Suez Canal transit

“From SCA point of view to avoid any environmental rules breach no wash water to be discharge during transit.”

This has been subsequently confirmed in a communication from SCA, which can be downloaded here (courtesy NEPIA)

The original SCA circular can be viewed here.

Attention is also drawn to Suez Canal Authority Rules of Navigation Article 64 A.  which can be viewed here (search for the word ‘discharge’)

United Arab Emirates

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MARPOL Annex VI regulation 14 fuel sulphur limits for ships operating outside of Emission Control Areas apply in the United Arab Emirates, however

Fujairah – 22 January 2019

The Port of Fujairah Harbour Master has issued Notice To Mariners No. 252 (click to view), which simply states “… Port of Fujairah has decided to ban the use of open-loop scrubbers in its waters. Ships will have to use compliant fuel once the IMO 2020 sulphur cap comes into force.”

There is no other supporting information and there is no mention of the use of scrubbers operating in closed loop/zero discharge as an alternative method of compliance.

The latest Notices to Mariners are available at the Port of Fujairah website.