The IMO considers
exhaust gas scrubbers to be an acceptable means of reducing vessels' sulphur emissions and ensuring compliance with MARPOL Annex VI. A separate guideline,
Resolution MEPC.259(68), specifies the requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for discharging scrubber washwater into the sea.
However, some coastal states and ports have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of washwater from open loop scrubbers or prohibit the use of scrubbers. We are currently aware of the following
regions/states/ports with local regulations that have an effect on the discharge of exhaust gas scrubber washwater, although the list should not be considered as complete.
Summary and recommendations
Although exhaust gas scrubbers are an accepted abatement technology to meet IMO’s SOx emission rules for 2020, their use is not accepted globally in all states. If a members’ vessel is trading in area(s) where the discharge of scrubber washwater is not permitted, vessel operators have two options to choose from to ensure compliance with the sulphur limits:
switch over to closed loop mode of scrubber operation, in which case it will be necessary to convert currently installed open loop scrubber systems to closed loop or hybrid systems, if not already done; or
changeover to compliant fuel.
Any changeover should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place, and proper records should be maintained of such changeover. Early changeover will help in identifying operational issues, if any, after the changeover, and will allow for sufficient time to rectify such before the vessel enters the area.Owners’ and managers’ safety management procedures should contain guidelines on how to carry out the changeover safely and outline the recordkeeping requirements. It is also recommended that a vessel’s passage plan incorporates information on when to carry out the changeover, taking into account things such as duration of passage, time needed for changeover, density of traffic, proximity to hazards etc.
We advise Members and clients to monitor the situation closely and ensure that crew members onboard vessels fitted with open loop scrubbers are made aware of any relevant local discharge requirements in force. In general, vessels with any kind of scrubber installed should check with local authorities whether there are any applicable regulations in relation to the use of scrubbers, such as washwater discharge restrictions, and requirements to seek permission from authorities to use scrubbers.
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