Feedback and experience sharing are expected from INTERCARGO members on PSC inspections.
- PSC on air emission
Last year, four (4) PSC MoUs (Paris, Tokyo, India and Black Sea) jointly carried out CIC on compliance with the MARPOL Annex VI. As advised via INTERCARGO circular 0301-F-1973 on 1 Mar 2019, findings on the most common deficiencies included:
- Bunkering Delivery Notes,
- Sulphur content compliance,
- Ozone depleting Substances, and
- Incinerator Use.
- PSC on BWM
The IMO’s Procedures for Port State Control, 2017, as adopted by res A.1119(30) on 6 Dec 2017, include the following to guide PSC officers to carry out inspections.
2.1 Documents to be checked during the inspection include:
- International Ballast Water Management Certificate (IBWMC) (BWMC Art 9.1(a) and reg.E-2);
- Ballast Water Record Book (BWRB) (BWMC Art 9.1 (b) and reg.B-2).
- Ballast Water Management Plan (BWMP) (BWMC reg.B-1)
2.2 PSC officers are expected to refer to, as attached for your reference:
- 252(67) on Guidelines for port State control under the 2004 BWM Convention
- 2/Circ.42/Rev.1 on Guidance on ballast water sampling and analysis for trial use in accordance with the BWM Convention and Guidelines (G2)
We hope that through experience sharing and feedback from members, we are able to share with members a simple, focused list of items on BWM to assist the crew onboard in receiving PSC inspection, something like the CIC Questionnaire.
- Guidelines for PSC inspections under the revised MARPOL Annex VI
It is expected that the draft 2019 Guidelines for port State control under MARPOL Annex VI would be adopted at IMO’s MEPC 74 to be held on 13-17 May 2019. Please let us know should you like to have a copy of the draft 2019 Guidelines for reference now.
IMO is developing another set of draft guidance for port State control on contingency measures for addressing non-compliant fuel oil. It is expected that MEPC 74 would receive concrete proposals and have extensive and detailed discussion on actions that port State control could take to enforce the provisions of regulation 14 of MARPOL Annex VI including the carriage ban on non-compliant fuel oil.
It is also expected that following PSC guidelines would be approved later in 2019:
- Amendments to Guidelines for PSCOs on the ISM Code
- Certification of seafarers, manning and hours of rest
- Use of electronic record books
It is not directly related to PSC but worth of noting following development at IMO:
- MEPC 73 had adopted resolution MEPC.307(73) on the 2018 Guidelines for the discharge of exhaust gas recirculation (EGR) bleed-off water, as attached for reference;
- MEPC 74 is expected to adopt/approve:
- the 2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI
- A MEPC Circular on 2019 guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships, as amended
- A joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers
- Review of the 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC 259(68)): draft amendments to the 2015 EGCS Guidelines is expected to be finalised in 2020.
- Sulphur limit in ECAs – increased risk of PSC deficiencies and detentions
It is useful to refer to the DNVGL guidance on Sulphur limit in ECAs – increased risk of PSC deficiencies and detentions at its webpage https://www.dnvgl.com/news/sulphur-limit-in-ecas-increased-risk-of-psc-deficiencies-and-detentions-142911?utm_campaign=MA_19Q1_TRN_No%2002%20-%20external&utm_medium=email&utm_source=Eloqua.
One member shared their communication with Singapore’s MPA recently as follows: MPA confirmed that currently, there is no requirement to change over to low sulphur fuel when calling Singapore, including the anchorages. Guidance for ships calling Singapore at the following URL: https://www.mpa.gov.sg/web/portal/home/singapore-registry-of-ships/about-srs-and-what-new/IMO-2020-Fuel-Oil-Sulphur-Limit.
