SOLAS damage stability, EU MRV and IMO DCS and MARPOL ANNEX
VI: To prepare and comply with what you need to know.
2019 is a busy year with the adoption of the International Maritime Organization (IMO)
regulation with the forthcoming SOLAS amendments, significant milestones for the data
collection system for fuel oil consumption (DCS) along with the EU regulation on monito
ring, reporting and verification (MRV) and the entry into force of the MARPOL Annex VI
Global Sulphur Limit in January 2020.Here is why these regulations are important to
ship-owners and operators.
Amendments to SOLAS Chapter II-1 on damage stability
Chapter II/1of the SOLAS amendments to harmonize the damage stability of cargo and p
assenger ship came into force in 2009.This made probabilistic damage stability the main
method for calculating the damage stability for passenger vessels and general cargo ves
sels. Once the amendments came into use, the need for a number of revisions became
apparent, so the IMO undertook a major review of the subdivision and damage stability
requirements in Chapter II-1 of SOLAS. Significant changes include, amongst others:
- Requiring limiting stability information to include trim.
- Modifying the required subdivision index, R, for passenger ships.
- Amending the calculation for S factor.
- Providing limits on the distance between small wells and the keel line unless a
damage stability check is made and introducing a minimum limit for the vertical
damage extent. Permitting a butterfly valve at the collision bulkhead on cargo
- Requiring testing of watertight hatches.
- Requiring air pipes which terminate in a superstructure to be considered
unprotected openings unless fitted with a watertight means of closure.
- Removing the possibility of leaving watertight doors open.
These amendments need to be taken into account in the design of ships contracted from
1 January 2020.
Monitoring and reporting of fuel oil consumption and CO 2 emissions
2019 brings significant milestones in both the EU’s MRV regulation and the IMO’s fuel
oil consumption DCS requirements under MARPOL Annex VI. For EU MRV, the first year
of monitoring ended in 2018 and the first reporting is taking place in early 2019. For
IMO DCS, 2019 is the first monitoring period. In order to comply with the IMO DCS
requirements, each affected existing vessel’s Ship Energy Efficiency Management Plan
(SEEMP) will by now have been updated with a new Part II to provide the ship-specific
methodology and processes to be followed for the data collection. New ships will need
to have this upon delivery. After verified data has been reported, it will be transferred to
the IMO Ship Fuel Oil Consumption Database where it will be kept anonymised. This will
help the IMO to produce annual reports and evaluate the need for further technical and
operational measures for enhancing the energy efficiency of international shipping.
For ships subject to the EU MRV regulation, the first monitoring period has now finished
and the collected monitoring reports need to be submitted for verification. For LR
clients, all documentation (monitoring plans and emission report evidence packs),
except emission reports, should be submitted to CO2 Verifier. The regulation requires
that clients submit emission reports directly to THETIS-MRV, which is operated by the
European Maritime Safety Agency (EMSA). As the accredited verification body, LR will
then retrieve the reports from THETIS-MRV for verification and upload them to CO2
Verifier along with related LR deliverables.
Global fuel sulphur limit reduction to 0.50% and associated carriage ban
From 1 January 2020, MARPOL Annex VI will require all new and existing ships to
comply with the new global 0.50% sulphur limit using the most appropriate method for
that ship. The options include low sulphur fuels and alternative fuels, or alternative
arrangements such as an exhaust gas cleaning system (also known as scrubbers). The
global limit means that this applies to all areas outside of Emission Control Areas
(ECAs). Unless a ship has an alternative arrangement such as a scrubber, shipowners
and managers will need to consider debunkering any high sulphur fuel oil that is not
used up before 1 January 2020. The IMO has also adopted a requirement to prohibit
ships from carrying fuel oil with a sulphur content above 0.50% if its purpose is for
combustion for propulsion or operations on board, unless the ship has an approved
equivalent arrangement in place. This is to help support full global compliance. Due to
the IMO procedural requirements for amendments to MARPOL, this will enter into force
on 1 March 2020, but it is worth clarifying that this does not change the sulphur limit