035/16/Gen.Inf. Statutory Alert: Guidelines on verification of ECA emission control measures issued by China Maritime Safety Administration

Applicability: Ships navigating, anchoring, berthing or operating in the China ECAs, except military, recreational and fishing vessels

China Maritime Safety Administration (MSA) has issued Guidelines on Implementation and Supervision of Ship Emission Control Areas (ECAs) that detail how compliance with emission control measures will be verified in the China ECAs.

The Guidelines detail how the MSA will verify use of both low-sulphur fuel and alternative measures, as follows.

Ships using low-sulphur fuel
For ships using low-sulphur fuel, the MSA will carry out verification of:
• bunker delivery notes

• fuel change-over procedures

• engine room logbook records (to include the following information about each fuel change-over: start/end dates and times; ship latitude/longitude; fuel oil sulphur content; quantity of low-sulphur fuel oil; and ship operator), and

• fuel oil quality (including fuel oil sampling as considered necessary, in accordance with Resolution MEPC.96(47) and Appendix VI of MARPOL Annex VI, and analysis carried out by a laboratory recognised by Chinese state authorities).
Penalties will be imposed for non-compliance, including warnings, instructions to rectify violations, detention of ships, and/or monetary fines as per the Law of the People’s Republic of China on the Prevention and Control of Air Pollution, Article 106.

Ships using alternative measures
For these ships, the MSA will carry out verification according to whether shore power, ‘clean energy’ (for example, liquefied natural gas) or emissions reduction technology (for example an exhaust gas cleaning system) is used, as follows:
• Shore power
Verification of engine room logbook records (to include the shore power start/end dates and times and the ship operator).

• Clean energy
Verification of the International Air Pollution Prevention (IAPP) Certificate/Record that shows the ship is allowed to use clean energy

Verification of engine room logbook records (to include the following information about each change-over from fuel oil to clean energy for dual-fuel powered ships: start/end dates and times; ship latitude/longitude; quantity of clean energy and fuel oil; and ship operator).

• Emissions reduction technology
Verification of the IAPP Certificate/Record that shows the ship is allowed to use emissions reduction technology

Verification of the relevant approval certificate

Verification of engine room logbook records (to include the reduction technology start/end dates and times; ship latitude/longitude; and ship operator).
If any of the above documentation is unsatisfactory, an on-site inspection of the shore power arrangement, clean energy fuel system, or emissions reduction technology will be carried out.

Ships that are unable to comply
If ships are unable to comply with the ECA requirements (for example, in order to protect the safety of the ship, carry out the rescue of life at sea, or in case of damage or failure of the ship and its equipment) the ship should report the situation immediately to the nearest MSA authority, and record all relevant information in the ship’s logbook.

SOURCE: LR

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Thank you & Best Regards,

Eng. Dimitrios Nikolaos Spanos
Principal Maritime Auditor / Lead QMS Auditor
Principal Surveyor / Flag Inspector
Member of IRCA, IIMS, ELINT, HELMEPA & Nautical Institute

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