Web-Alert: Verification of emission control measures by China MSA

Further to the club’s update on Yangtze River Delta ECA, the China Maritime Safety Administration (MSA) has issued a Notice on Enhancing Supervision and Administration of ECA to specify the requirement for ships calling ports within ECAs, and to provide guidance to local MSA offices on supervision and administration of ECAs.

Ships using low-sulphur fuel

Ships using low-sulphur fuel within ECAs in line with relevant requirements are required to record the switching date, time, vessel’s location (latitude & longitude), oil specification and operator for change-over in the engine book. A written fuel change-over procedure must be kept on board as part of a ship’s Safety Management System.

Ships should keep bunker delivery notes on board for 3 years, and keep a fuel sample for at least 1 year until the fuel has been used up.
 
China MSA will verify relevant records/documents such as the engine log, bunker delivery notes, fuel change-over procedures, engine room logbook records, and fuel oil sampling & analysis (in accordance with Resolution MEPC.96(47) and Appendix VI of MARPOL Annex VI); and will conduct fuel sampling and analysis if breaches are found during the document check or if the authorities deem it necessary.

Ships using fuel oil that doesn’t meet with the relevant standard or requirements are subject to one or more of the following:

1. Warning education;
2. Correction of breaches;
3. Detention;
4. Penalty ranging from RMB10,000 to RMB100,000 according to article 106 of Air Pollution Prevention Law of PRC.

Ships failing to keep the fuel supply document and fuel sample as requested are subject to a penalty ranging from RMB2,000 to RMB10,000 according to article 63 of 'Regulation on the Prevention and Control of Vessel-induced Pollution to the Marine Environment'.

Ships using alternative measures

For ships intending to use shore power, appropriate arrangements with the port should be checked and confirmed in advance. The recording of date, time and operator in the engine log book is required.

For ships using clean energy (such as liquefied gas) or emissions reduction technology, the MSA will carry out verification of the International Air Pollution Prevention (IAPP) Certificate/Record.

Ships using dual fuel are required to record the usage amount of each fuel, date and time of switching fuel, the ship’s location (latitude & longitude) and operator in the engine log book.

Ships using after-treatment equipment as replacement measures should hold an exhaust after-treatment certificate issued by ship survey organizations and should also put remarks in the IAPP certificate. The recording of date, time, ship’s location (latitude & longitude) and operator in the engine book is required.

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.

MSA will verify relevant records/documents and conduct an onsite inspection when ships are using alternative measures in accordance with the Notice. If ships are using alternative measures that do not meet with the relevant standards or requirements, the maritime authorities are subject to:

1. Warning education;
2. Correction of breaches;
3. Detention.

Breaches under Special Situations

If ships are unable to comply with the ECA requirements 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.

Members are advised to ensure compliance with the requirements in order to avoid any unnecessary delays or fines whilst navigating in Chinese ECAs.

For more details, please refer to the Huatai Insurance Agency & Consultant Service Ltd circular no. 1602.