cThe Club has learnt that Paris MOU, Tokyo MOU, Indian Ocean MOU and Black Sea MOU port state control (PSC) regimes have agreed to focus on the prevention of air pollution by ships during their forthcoming concentrated inspection campaigns (CICs) - 1 September 2018 and 30 November 2018. The Port State Control Officers (PSCOs) will pay particular attention to visiting ships’ compliance with MARPOL Annex VI.
It is believed that the CIC checklist/questionnaire to be used by attending PSCOs will be published in August 2018. However, as some PSC regimes have recently announced that they will take enforcement of the new 2020 global 0.5% sulphur cap seriously from commencement of the new regulation, the CIC might well focus on this to create awareness on the forthcoming requirements. Ship operators should therefore expect to be asked to confirm the sulphur content of the fuel on-board as part of the CIC. This could include a review of documents, such as bunker delivery notes, oil record books, fuel logs and fuel changeover procedures, as well as the taking and analysis of fuel samples at short notice. However, SOx is not the only pollutant governed under the convention and therefore vessels should ensure they comply with limits to NOx, Ozone Depleting Substances (ODS) & shipboard incineration waste material.
Members are encouraged to familiarise themselves with the relevant MARPOL Annex VI regulations and CIC criteria well before 1 September 2018. As with previous CICs, it is assumed that the questionnaire will focus on the maintenance and working condition of relevant equipment, such as the incinerator, but will mainly contain operational questions aimed at verifying the Ship’s Company familiarity with the ship-specific equipment and procedures. It should not be forgotten that compliance with MARPOL Annex VI requires significant recordkeeping. As such, ensure that that all MARPOL Annex VI documentation is complete and up-to-date prior to entry into any port.