Estonia
February 2021
2019 advice below remains valid following confirmation from the Estonian Maritime Administration:
“Using open-loop exhaust gas cleaning systems in Estonian ports are not prohibited, but their washwater must comply with the requirements of the IMO resolution MEPC.184(59).
“In addition, Estonian domestic law specifies (Annex 9 to Regulation No. 73 of the Minister of the Environment):
“Washwater from exhaust gas cleaning systems using chemicals, additives, preparations or relevant cemicals created in situ, as referred to in MEPC.184 (59) paragraph 10.1.6.1, shall not be discharged into the sea, including closed ports, unless the shipowner demonstrates that the discharge of such washwater into the sea does not have a significant adverse effect on or endanger human health or the environment. If the chemical compound used is sodium hydroxide, it is sufficient that the washwater meets the criteria set out in MEPC.184 (59) and has a pH of not more than 8,0”
The last paragraph typically applies to closed loop scrubbing, however this is not specifically mentioned and so it is assumed that discharges from closed loop scrubbers remain prohibited as per the circular below
A copy of the email (contact details removed) courtesy of the Clean Shipping Alliance can be viewed here.
October 2019
Circular No. 4 21.10.19, Clarification of Exhaust Gas Cleaning System (EGCS) operations in territorial waters and ports
of Estonia can be downloaded from the Estonian Maritime Administration website here.
Other circulars can be found at https://www.transpordiamet.ee/en/safety-and-supervision/maritime-safety/estonian-transport-administrations-circulars
The circular confirms advice received from the Adminstration in July 2019 in response to a request for information from an EGCSA member:
“Thank You for the inquiry. Estonian Maritime Administration will make public the official information concerning EGCS (Exhaust Gas Cleaning System) operations in territorial waters and ports of Estonia in due time. With the regulation no. 73 by Minister of Environment Annex 9 the open-loop EGCS is not prohibbited if the systems comply with resolution MEPC.184(59) and other appropriate international regulatory requirements including MARPOL Annex VI. Also it is important that the port authorities will issue approval of using open-loop EGCS in the port area.”
The communication with contact details redacted can be viewed here.
It should be noted the circular ends with the following regarding closed loop scrubbers:
“The use of closed-loop EGCS is permitted in the territorial waters and ports of Estonia, provided that it meets the relevant requirements and is certified. Discharging of washing water from closed-loop EGCS is not permitted.“
