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Frequently

Asked

Questions

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I. SOLAS matters

1. Spare and/or repair equipment for fixed fire detection system

Question

Is there any requirement as to spare and/or repair equipment for fixed fire detection system in

SOLAS or FSS Code?

Answer

In accordance with Reg.2.5.2 of FSS Code chapter 9 as regard specific requirement on the number

of spare fixed fire detection system, it is described that “Suitable instructions and component

spares for testing and maintenance shall be provided”. However, the specific mandatory

requirement is not clearly stipulated in the SOLAS or FSS Code.

2. Noise level requirement for weather deck

Question

It is noted that there is no specific requirement relating to the Noise in weather deck in

accordance with Res.MSC.337(91). A case where the any other particular requirement on Noise

in weather deck is stipulated in the SOLAS Convention, what noise level should be applicable

criteria for weather deck in view of Noise Code (MSC.Res.337(91))?

Answer

1. If they are open deck workspaces that are not machinery spaces or open deck workspaces

where communication is relevant, they fall into section 4.2.1 of the Code, which requires 85

dBA as max. allowable noise level.

2. Otherwise, if it should be considered 'normally unoccupied spaces' specified in section 3.14.1

of the Code, max. allowable noise level could be 90 dBA.

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3. ECDIS Type Specific training

Question

Is the type specific training for ECDIS mandatory requirement?

Answer

There are three types of ECDIS training as follows;

1) ECDIS Generic training

In legal respect, generic ECDIS training to masters and officers serving on ships fitted with ECDIS

is not mandatory to until the date of enter into force(1st January 2017) of the 2010 Manila

Amendments to the STCW Convention and Code.

However, the evidence of generic ECDIS training based on IMO Model course(1.27) is being

checked and mandatorily requested during lots of Flag states’ inspections and/or oil major

inspections

Accordingly, it is highly recommend to carry out generic ECDIS training based on IMO Model

course(1.27) even though the date of enter into force(1st January 2017) of the 2010 STCW

Convention is not yet arrived.

2) ECDIS familiarization training

Companies should provide an appropriate training to ship’s personnel in accordance with the

section 6 of Part A/ ISM Code and STCW Code Part A / CHAPTER I / Section A-I/14, so ECDIS

familiarization training shall be provided in this respect.

3) Type specific training

It was noted and agreed at HTW 1st session during the discussion on the development of a

guideline on ECDIS familiarization training that a type specific training is not be considered as

mandatory. (Paragraph 5.6.6 of HTW 1/21)

Moreover, in accordance with the paragraph 27.5 of MSC.1/Circ.1503 (ECDIS – GUIDANCE FOR

GOOD PRACTICE), ECDIS manufacturers are encouraged to provide training resources including

type-specific materials so that these resources may form part of the ECDIS familiarization training.

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Having considered above, ECDIS type-specific training is not considered as a mandatory training

but type specific materials such as a CD or DVD can be used in a part of the ECDIS familiarization

training.

Notwithstanding above, some Flag states (e.g. U.K, Island, Bahama, Singapore and etc.) states by

its own instruction that “The ECDIS ship specific equipment training should relate to the make

and model of the equipment fitted on the ship on which a Master or Navigational Officer is

currently serving i.e. it will be necessary to complete training for each different system a Master

or Navigation Officer is expected to operate. This training should build on the approved ECDIS

generic training, and be delivered by the ECDIS manufacturer; the manufacturer’s approved agent,

or a trainer who has attended such a programme. A manufacturer’s computer based training

package can be accepted for this purpose. “Trickle down training” (i.e. one officer training

another) is not acceptable as, inevitably, it leads to incomplete knowledge of the equipment’s

capabilities, and especially the lesser used functions, being passed on.”

4. Periodical inspections/surveys for fire-fighting appliances by ship’s crew

Question

Is it possible to accept the periodical inspections/surveys for fire-fighting appliances by ship’s

crew?

Answer

There is no requirement in Convention which mandates periodical maintenance and inspection

of fire protection systems and appliances, but most Flag states mandatorily require such

periodical maintenance and inspection to their Flagged ships by issuing a flag instruction, which

was developed based on MSC.1/Cir.1432 and Resolution A.951(23).

Paragraph 3.1 of MSC.1/Cir.1432 states that certain maintenance procedures and inspections may

be performed by competent crew members who have completed an advanced fire-fighting

training course, while others should be performed by persons specially trained in the

maintenance of such systems (i.e. service provider). The onboard maintenance plan should

indicate which parts of the recommended inspections and maintenance are to be completed by

trained personnel.

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For instance, crew members in lieu of service provider can carry out two year line blowing test

for Fixed gas fire-extinguishing systems provided that crew members having competent on test

procedures are assigned as an entity for such testing according to the onboard maintenance

plan, and appropriate testing appliances for such testing are provided onboard.

With respect to the possibility of carrying out periodical inspections (e.g. annual, two year, five

year and 10 years) for fire protection systems and appliances in concert with the terms of the

HSSC convention survey, periodical inspection except items where the expression of “not

exceeding” is used such as ten year service of flexible hoses for fixed gas fire-extinguishing

systems, can be carried out in concert with annual or a periodical survey within 3 months before

or after each anniversary of the Convention surveys (e.g. Cargo Ship Safety Equipment Certificate). However, some Flag states (e.g. Panama) require that ship owner/operator should submit an

application for extension so that the period for each fire protection systems and appliances can

be extended by Administration.

5. Legal status of IMO Circulars (e.g. MSC, MEPC and etc.)

Question

What is the legal status of IMO circulars (e.g. MSC, MEPC and etc.)?

Are MSC Circulars mandatory? Then, when is the implementation of such circulars?

Answer

In accordance with Res.A.911(22), Uniform wording for referencing IMO instruments, IMO

instruments (e.g. MSC Circulars or Resolutions) which not appear in the authentic text of the

convention to be treated as recommendatory.

The most appropriate methods for referencing, in an IMO convention, instruments determined

to become mandatory under the parent convention is :

.1 to refer expressly to IMO instruments in the text of the relevant convention regulations;

.2 to provide expressly that future amendments to such instruments should follow the

amendment procedures laid down in the relevant article of the parent convention; and

.3 to prescribe expressly in the text of the relevant convention regulations that "such

requirements shall be treated as mandatory" in case the word "should" has been used in

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such instruments instead of "shall".

In principle, MSC Circulars or Resolutions, which referred in the footnote accompanying the

relevant regulations of the parent convention, should be treated as recommendations.

Notwithstanding above legal status of IMO instruments, lots of non-mandatory instruments,

especially Unified Interpretations or guidelines approved as a MSC Circular, are "de facto"

mandatory within the industry in the absence of Administration different instructions, and treated

as a minimum requirement for implementing IMO Convention.

6. Harmonization of annual service for liferafts with ships periodical surveys in

accordance with HSSC

Question

Is it possible to carry out the annual service of inflatable liferatfs in conjunction with HSSC (i.e.

interval of 18 months) in accordance with MSC/Circ.955 without any approval by the

Administration?

Answer

Ship's equipment are permitted to be serviced at the same interval with ship's periodical survey

(within 3 months before or after each anniversary date) after entering into force of HSSC.

However, in accordance with SOLAS Regulation III/20, inflatable liferafts, inflatable lifejackets,

marine evacuation systems and hydrostatic units shall be serviced at intervals not exceeding 12

months, which may be extended to 17 months where in any case this is impracticable, so it has

created inconvenience to ship operators.

In order to cope with this issue, Maritime Safety Committee, at its seventy-second session,

approved MSC/Circ.955 which permitting the servicing intervals of life-saving appliances in

concert with the terms of the HSSC(i.e. annual, periodical and renewal survey) in spite of the

relevant SOLAS regulations only for Administrations which are implementing the HSSC.

Some Governments including the Republic of Korea (e.g. Singapore, Marshall Islands, Liberia,

Bahama and etc.) have decided to implement MSC/Circ.955, hence life-saving appliances

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provided to ships under one of those flag States are permitted to be serviced at the same interval

with ship's periodical survey (within 3 months before or after each anniversary date).

7. Graphical symbol sticker for fire-fighting appliances

Question

Is the graphical symbol sticker for fire-sighting appliances in accordance with Res.A.952(23) to be

attached in the vicinity of each fire-fighting appliance stowage location?

Answer

In accordance with paragraph 2 of Res.A.952(23), the graphical symbols were developed with a

view to encouraging their use for the preparation of the shipboard fire control plans required by

SOLAS regulation II-2/15.2.4. Therefore, there is no mandatory SOLAS regulation to require

attaching graphical symbol stickers in the vicinity of each fire-fighting appliances.

However, it should be noted that most ships have provided and attached such symbolic

(fluorescent) stickers in the vicinity of each fire-fighting appliances as a practice, therefore some

inspectors may misunderstand such practice as mandatory requirements and would raise as a

deficiency.

Further, it should be also noted that some life-saving symbols shall be marked to indicate the

devices stowed in that location for that purpose in accordance with SOLAS regulation III/20.10.

8. Provision of damage control information (damage control plan, damage control

booklet)

Question

Which ships shall be provided with damage control plan and/or damage control booklets?

Answer

Regulations for the provision of damage control plan and/or damage control booklet by ship’s

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construction date and ship type are as follows;

1. Requirement for the provision of damage control plan/booklet

Application date (K/L date) SOLAS Reg. Applied ships

25 May 1980 – 31 Aug. 1984 74 Reg.II-1/20 (Damage Control Plans) Passenger ships1)

1 Sept. 1984 – 31 Dec. 2008 81 Amend. Reg.II-1/23

(Damage control plans in passenger ships)

Passenger ships2)

1 Feb. 1992 – 31 Dec. 2008 89 Amend. Reg.II-1/23-1

(Damage control in dry cargo ships)

Dry cargo ships3)

1 Jan. 2009 - 2006 Amend. Reg.II-1/19

(Damage control information)

cargo ships of 80 m in

length (L) and upwards

and to all passenger

ships4)

*(Note)

1) The plans shall be permanently exhibited. In addition, booklets containing the aforementioned

information shall be made available to the officers of the ship.

2) The plans shall be permanently exhibited. In addition, booklets containing the aforementioned

information shall be made available to the officers of the ship. (refer to MSC/Circ.919)

- For passenger ships, the damage control plan should be permanently exhibited on the navigation

bridge, as well as in the ship's control station, or equivalent.

3) The plans shall be permanently exhibited. In addition, booklets containing the aforementioned

information shall be made available to the officers of the ship. (refer to MSC/Circ.919)

- For cargo ships, the damage control plan should be permanently exhibited or readily available or the

navigation bridge. Furthermore, the damage control plan should be permanently exhibited or readily

available in the cargo control room.

4) The plans shall be permanently exhibited, or readily available on the navigation bridge. In addition,

booklets containing the aforementioned information shall be made available to the officers of the ship.

(refer to MSC/Circ.1245)

- For passenger ships, the damage control plan should be permanently exhibited or readily available on

the navigation bridge, as well as in the ship’s control station, safety centre or equivalent.

- For cargo ships, the damage control plan should be permanently exhibited or readily available on the

navigation bridge. Furthermore, the damage control plan should be permanently exhibited or readily

available in the cargo control room, all ship’s office or other suitable location.

2. Application by ship type

1) Passenger ship

Constructed 25 May 1980 – 31 Aug. 1984 : The plans shall be permanently exhibited

Constructed 1 Sept. 1984 – 31 Dec. 2008 : the damage control plan should be permanently exhibited on

the navigation bridge, as well as in the ship's control station, or

equivalent.

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Constructed on or after 1 Jan. 2009 : the damage control plan should be permanently exhibited or readily

available on the navigation bridge, as well as in the ship’s control

station, safety centre or equivalent.

2) Dry Cargo Ship

Constructed 1 Feb. 1992 – 31 Dec. 2008 : the damage control plan should be permanently exhibited or

readily available or the navigation bridge. Furthermore, the

damage control plan should be permanently exhibited or readily

available in the cargo control room.

3) All cargo ships, including dry cargo ships and tankers

Constructed on or after 1 Jan. 2009 : the damage control plan should be permanently exhibited or readily

available on the navigation bridge. Furthermore, the damage control

plan should be permanently exhibited or readily available in the cargo

control room, all ship’s office or other suitable location.

9. Requirement for the gaps on engine room funnel damper

Question

Is there any mandatory regulation that E/room funnel damper shall be of gastight type and the

light beam shall not come through the gaps between the damper flaps and its frame?

Answer

The above question has been asked for several years, in particular as a frequently raised deficiency

during PSC inspections in various countries, from our customers.

However, we couldn’t get clear information from PSC Officers, why such light beam should not

be seen, what will be caused by such deficiency nor what is the relevant SOLAS mandatory

regulation.

According to our interpretation, the reasons why ship’s funnel damper should be closed tightly

would be as follows;

1) In case of engine room fire, closed funnel damper would prevents additional inflow of

air and oxygen and prevent fire growth or spreads

2) When engine room fixed fire-fighting system activates, the closed funnel damper can

prevent leaking of fire extinguishing medium, and increase the efficiency of the fixed fire

fighting system (However, in case of fixed CO2 system, CO2 gas will sink due to its

heavier weight than air, and the CO2 gas leaking through the funnel damper would

hardly happen.

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According to above reasons, the gaps between flaps, and between funnel flap and frame should

be as narrow as possible, however, if the gap is required to be narrow enough to block out light,

the fire damper, which is normally made of metal, would not operate properly.

Therefore, considering such PSC tendency and also considering the need of proper operation of

such fire dampers, KR reflected followings in our form of PSC Checklist;

“5.3 E/R ventilator & E/R funnel damper

① Damper moving/corrosion

② Maintenance considering manufacturer’s gap standard (ref.: abt. 3~4mm on the basis

of new production)

③ Visual check the flap (especially calling AUS ports)”

According to above, we recommend that the gaps in fire damper, its flaps and frames are made

of metal, should be maintained as narrow as possible in accordance with the guidelines and

instruction of manufacturer.

Further, it may be impossible to require the fire damper to block light beam completely due to

its construction and manufacturing process, ship’s master or superintendent should provide clear

explanation to PSCO that such gap is essential for the operation of the fire damper.

And also, please note that operational trouble, or corrosion/holes on metal flap/frame were raised

as deficiencies in case of old existing ships.

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II. MARPOL matters

1. Application of NOx Approved Method(AM)

Question

Related to the Application of NOx Approved Method(AM)

1) How to deal with applicable diesel engines other than Wartsila and MAN B&W engine

which IMO circulars have been already issued?

2) How to deal with the case which are not available to complete application of Approve

Method within the time limit.

Answer

1) A marine diesel engine with a power output of more than 5,000 kW and a per cylinder

displacement at or above 90 litres installed on a ship constructed on or after 1 January

1990 but prior to 1 January 2000 shall comply with the emission limits by installation of

the certified Approved Method. Even though the engine is belonging to the applicable

engines, it is only possible to apply to the engines with certified AM established by

manufacturers. There are only two manufacturers established certified AM so far, i.e.

Wartsila and MAN B&W. Excepts above two cases, even though the engine is belonging

to the applicable engines, it has to be understood that there is no applicable AM exist,

therefore we should await until the manufacturers establish certified AM.

2) AM shall apply no later than the first renewal survey that occurs 12 months or more of the

issuance IMO circular to the applicable Wartsila and MAN B&W engines. If it is not available

to complete application of AM within the time limit, a shipowner demonstrate to the

satisfaction of the Administration that the AM was not commercially available despite best

efforts to obtain it, then it shall be installed no later than the next annual survey. Normally

shipowners contact to the engine manufacturer for purchasing AM retrofit materials few

months ago and install them within the time limit, however there are cases that the

Approved Method File could be issued few month later then it is not possible to complete

the AM application within the time frame. In this case, interim IAPP certificate could be

issued with the valid until the designated date by the Administration (ex) 6 months)

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2. Record formats for the Ozone Depleting Substances by flag administrations

Question

Are there any record formats for the Ozone Depleting Substances for each flag Administration?

Answer

1) The Ozone Depleting Substances Record Book may form part of an existing log-book or

electronic recording system. And refer to below by the flag Administrations.

- For Korean Flag ship, it shall be recorded on the form of “Ozone Depleting Substances

Record Book” in the Maritime Environment management regulation.

- For Panama Flag ship, it shall be recorded on the Oil Record Book Part III

- For other flag ships, no specified form of “Ozone Depleting Substances Record Book”

exist, it could be recorded on the engine log-book

2) In accordance with the regulation 12.5 and 12.6 of MARPOL Annex VI, a list of equipment

containing ODS and ODS record book shall be maintained on each ship. Therefore even

though there is no equipment containing ODS onboard, we would like to recommend

to maintain the list of equipment and record book in order to avoid unnecessary

argument during PSC inspection. For reference, there is a technical information issued

by KR (2010012/IMO) which provides sample of the ODS record book.

3. Recording to Panamanian Oil Record Book Part III

Question

Related to the Panama Oil Record Book Part III

1) How to record average of oxygen in the combustion chamber (range from 6% to 12%) for

Non-IMO type Incinerator? (Oxygen content meter is installed on an IMO Type Incinerator,

but not on a non-IMO Type Incinerator)

2) Is it required to record as Code B, Item 2 after every bunkering operation?

3) How to handle when a record has been missing? (ex) Incinerating record exists on garbage

record book, but it has been missing on the oil record book part III)

Answer

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1) Please refer to average oxygen contents in the incinerator if possible, otherwise refer to the

maker specification. If there is no any source for the oxygen contents at all, it is

recommended to put in “N/A” on the oil record book part III.

2) As you know, Panama Oil Record Book Part III is one of the indigenous requirement of Flag

state apart from the requirement of oil record book part I in accordance with the MARPOL

Annex I. It is recommended to keep recording after every bunkering operation by Flag state

inspectors in accordance with the Code B, regardless entry into SECA and receiving low

Sulphur fuel oil.

3) Any missing record could be recorded utilizing code “I” on the Oil Record Book Part I, but

there is no code for this purpose in the Panama ORB part III. Therefore we would like to

recommend to record the missing operation in the ORB part III according to the relevant

code, and put a remark on it describing when the operation implemented and missed thus

it is recorded on here now with signature of charging engineer, then it would be acceptable.

4. Transfer of the bilge generated in machinery space to deck slop tank

Question

Related to the transfer of Bilge generated in machinery space to Deck Slop Tank

1) The situation is that a subject ship has no fixed piping arrangement to transfer bilge

generated in machinery space to deck slop tank, thus flexible hose should be used

2) Bilge water or oil residues generated in machinery space could be transferred to slop tank

or residual tank in cargo space though additional independent piping arrangement such as

spool piece, then related transfer operation shall be recorded in oil record book. It is noted

that above transfer operation is being identified and allowed by adding a relevant phrase

‘Transfer to slop tank by non-permanent means of connection’ in the paragraph 3.2.3 of

supplement to IOPP certificate.

3) What is the procedures to transfer residues to slop tank as above? (note on IOPP Certificate)

4) How to record the related transfer operation in oil record book? (Code, etc)

5) Is it possible to discharge the residues through the ODME after transfer to slop tank? And

how to record this transfer operation in oil record book?

Answer

1) In order to transfer oil residues generated onboard machinery space to Slop Tank, a survey

to confirm that suitable facilities and arrangements were equipped onboard shall be carried

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out. In such a case, general piping arrangements cannot be connected to prevent the

transfer of residues generated cargo spaces to machinery space. A case where connection

of piping arrangements by non-permanent means such as Spool Piece is possible, the

phrase ‘Transfer to slop tank by non-permanent means of connection’ would be written in

paragraph 3.2.3 of supplement to IOPP Certificate.

2) Taking into account the example 23 and 24 of the Guidance for recording Oil Record Book

referred in MEPC.1/Circ.736, please refer to the applicable recording guidance for a case of

transfer of oil residues generated in machinery space to Slop Tank.

3) The residues which were generated in machinery space but transferred to Slop Tank shall

be regarded to cargo residues generated on cargo spaces. Those residues detected under

15ppm through ODME which is installed in Slop Tank can be discharged to sea area, but

the residues detected over 15ppm shall be discharged to port reception facility without any

exception. Therefore, the related operation on treatment of residues generated in cargo

spaces shall be recorded utilizing the applicable Code of cargo record book, accordingly.

5. Replacement of ODME for the carriage of Bio-Fuel Blends

Question

Related to the replacement of ODME for the carriage of Bio-Fuel Blends

1) It is noted that ODME type approved in accordance with Res.MEPC.240(65) shall be

retrofitted onboard existing oil tankers for the carriage of Bio-Fuel Blends as of 1 Jan’ 2016.

In this regard, is there a generic guidance or interpretation on the replacement of ODME

unit?

2) Are there any considerations when type of ship is changed or cargo is added according to

the carriage of Bio-Fuel Blends?

Answer

1) When carrying the Bio-Fuel Blends containing 75% or more of petroleum oil classified to

oil cargoes in accordance with MARPOL Annex I, ODME system shall be approved for the

operation and detection of these mixtures, and issued with type approval certificate in

accordance with Res.MEPC.240(65).

- A case where existing oil tankers are going to carry Bio-Fuel Blends, an ODME type

approved in accordance with Rres.MEPC.108(49) installed onboard could be retroactively

applied as follows:

.1 relevant computational program is only updated to existing ODME without any

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physical conversion;

.2 partially or completely replaced to existing ODME such as replacement of Oil Content

Meter or Control Unit only; or

.3 existing ODME is completely replaced to new ODME type approved in accordance

with Res.MEPC.240(65).

l Above modification can vary depending on type of systems, thus owners are invited

to sufficiently discuss with manufacturers prior to its application. After modification,

type approval certificate shall be delivered to the ships certifying that the newly

installed or updated ODME was type approved in accordance with

Res.MEPC.240(65).

- The relevant parts of ODME Manual shall be amended to be suitable for carriage of Bio-

Fuel Blends, and re-approved by this classification society.

2) Until 1 January 2016, Bio-Fuel Blends may be carried when the ship’s ODME is not in

compliance with paragraph .1 above provided that residues and all tank washings are to be

disposed to port reception facilities.

3) Furthermore, a case where oil tankers are going to carry Bio-Fuel Blends containing 75% or

more of petroleum oil classified to chemical cargoes in accordance with chapter 17 of IBC

Code, the type of ships shall be changed to oi/chemical tankers or chemical tankers issued

with IBC fitness certificate.

4) A case where oil tankers are going to carry Bio-Fuel Blends containing 1% or less of

petroleum oil classified to NLS cargoes in accordance with MARPOL Annex II, the type of

ships shall be changed to NLS tankers issued with NLS certificate.

5) A case where chemical tankers subject to IBC Code are going to carry Bio-Fuel Blends

containing 75% or more of petroleum oil, the type of ship shall be changed to oil tankers

or oil/chemical tankers issued with IOPP form B and statement of compliance which

specifying that the carriage of Bio-Fuel Blends containing 75% or more of petroleum oil is

suitable for the subject ship.

6) A case where chemical tankers subject to IBC Code are going to carry Bio-Fuel Blends

containing 1% or less of petroleum oil classified to NLS cargoes in accordance with MARPOL

Annex II, statement of compliance specifying that the subject ship can carry those cargoes

shall be issued.

7) A case where chemical tankers subject to IBC Code are going to carry Bio-Fuel Blends

containing more than 1% but less than 75% of petroleum oil as the additional cargoes,

technical reviews to add specific cargoes shall be carried out. Those cargoes can be listed

into the IBC fitness certificate on the understanding that the subject ship is suitable for

carriage of intended cargoes.

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6. Disposal of used cooking oil and guidance for entries in the relevant record book

Question

Inquiry regarding disposal of used cooking oil and guidance for entries in the relevant Record

book

- Possibility of whether the used cooking oil is transferred to sludge oil tank for retaining.

- If possible, how it should be described in Oil Record Book.

Answer

Cooking oil is classified as a garbage in accordance with MARPOL Annex V and it should be

treated in accordance with this annex.

[QTE]

Reg. 1.3 “Cooking oil” means any type of edible oil or animal fat used or intended to be used

for the preparation or cooking of food, but does not include the food itself that is prepared using

these oils.

Reg. 3.3 Except as provided in regulation 7 of this Annex, the discharge into the sea of cooking

oil is prohibited.

Therefore, transfer of cooking oil to oil residue tank and subsequent recording oil record book

are prohibited in principle. As a consequence, cooking oil shall be discharged to a port reception

facilities or incinerated, and then related entries in the Garbage Record Book shall be made on

the method for the disposal of cooking oil in accordance with the related regulation in MARPOL

Annex V.

7. Incineration of plastics

Question

Availability on incineration of plastics

Answer

In accordance with the 2012 Guideline for the implementation of MARPOL Annex V,

Res.MEPC.219(63), most garbage generated onboard is amendable to incineration with the

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exception of metal and glass and incineration conducted in a shipboard incineration can

significantly reduce the volume of garbage to easily store on board the ship.

However, the requirements for prohibition of incineration is specified in Reg.16.2 & 3 in annex VI

of MARPOL.

[QTE]

16.2 Shipboard incineration of the following substances shall be prohibited:

.1 residues of cargoes subject to Annex I, II or III or related contaminated packing materials;

.2 polychlorinated biphenyls (PCBs);

.3 garbage, as defined by Annex V, containing more than traces of heavy metals;

.4 refined petroleum products containing halogen compounds;

.5 sewage sludge and sludge oil either of which are not generated on board the ship; and

.6 exhaust gas cleaning system residues.

16.3 Shipboard incineration of polyvinyl chlorides (PVCs) shall be prohibited, except in shipboard

incinerator for which an IMO Type Approval Certificates* has been issued.

On the basis of above requirements, the incineration of PVCs such as a transparent plastic

container which is removed vinyl in the incinerator designed, constructed, operated and

maintained in accordance with the IMO Standards (Res.MEPC.59(33), 76(40), 244(66)) is available

to be undertaken by competent crew. However, any other plastics except PVCs shall not be

permitted to incinerate on the ship. The using of compaction is most practicable method to

reduce the volume of garbage generated onboard a ship.

8. EEDI calculation for ships installed with EGR, SCR

Question

1. For engines installed with EGR or SCR, the specific fuel oil consumption (SFOC) as indicated in

the NOx Technical File in Tier-III mode would be different from that in Tier-II mode. Which

one should be considered in EEDI calculation?

2. In addition there would be some minimal CO2 emission changes with SCR reactions or

washwater that should be taken under consideration in the EEDI calculation or should be

acknowledged as being ignored:

o SCR: There is a CO2 increase from urea consumption since urea is hydrolyzed into ammonia

(NH3) and carbon dioxide (CO2) over the SCR catalyst. Urea consumption contributes to

around 1% increase of the CO2 emissions of the engine.

o EGR: EGR with EGCS using freshwater with additional chemicals to neutralise the acids produced

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from scrubbing SO2 and this process could potentially remove CO2.

Answer

In accordance with a reference to MEPC 66-21, Annex 5, Page 16, Footnote 5:

“EEDI calculation should be based on the normal seagoing condition outside Emission Control

Area designated under regulation 13.6 of MARPOL ANNEX VI.”

Even though this footnote is referring to feff(i), we believe it is fair to apply this also to SFOC.

9. Calibration for 15 ppm bilge alarm at IOPP renewal survey

Question

Calibration for 15 ppm bilge alarm at IOPP renewal survey

For confirmation of the accuracy of the 15 ppm bilge alarms at IOPP renewal survey, we consider

that some options can be taken, taking into account difference between IOPP renewal survey

intervals and calibration intervals. For example, at IOPP renewal survey:

- Option 1 Check the validity of calibration certificate. If the validity remains for certain period

of time, it is not required to carry out the calibration at the IOPP renewal survey.

- Option 2 Irrespective of the validity of the calibration certificate, calibration at each IOPP

renewal survey is required.

We would like to know about KR’s survey practice, at IOPP renewal survey, on how to confirm

the accuracy of 15 ppm bilge alarm.

Answer

For the above regulation, KR applies the following IACS UI;

For application of resolution MEPC.107(49), the phrase ” The accuracy of the 15 ppm Bilge

Alarms should be checked at IOPP Certificate renewal surveys according to the manufacturers

instructions.” in 4.2.11 shall be interpreted as follows considering resolution A.1104(29):

a) The validity of calibration certificate should be checked at IOPP annual/intermediate/renewal

surveys.

b) The accuracy of 15 PPM bilge alarms is to be checked by calibration and testing of the

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equipment conducted by a manufacturer or persons authorized by the manufacturer and

should be done at intervals not exceeding five years or within the term specified in the

manufacturer’s instructions, whichever is shorter.

10. Storage of pollution response equipment and chemical on board

Question

Is there any requirements on the storage of pollution response equipment and chemical can, oil

sample onboard?

Answer 1) There is no specific requirement on the storage location of pollution response equipment, oil

and chemical in the MAROL/SOLAS convention.

Therefore, if there is no special requirements of flag state, pollution response equipment

should be retained in the designated place of the SOPEP as approved by Administration or

Authorized classification.

2) Regarding flammable liquids having a flashpoint of less than 60 degrees, it is recommended

to be located outside of machinery spaces of category A as mentioned in the regulation 4

of SOLAS Chapter II-2 “Probability of ignition”.

3) In addition, location for the oil sample should be placed in the following place as mentioned

in the regulation 18 of MARPOL ANNEX VI and Res.MEPC.182(59).

* Res.MEPC.182(59)

9 Retained sample storage

- 9.1 The retained sample should be kept in a safe storage location, outside the ship’s

accommodation, where personnel would not be exposed to vapours which may be released

from the sample. Care should be exercised when entering a sample storage location.

- 9.2 The retained sample should be stored in a sheltered location where it will not be subject

to elevated temperatures, preferably at a cool/ambient temperature, and where it will not be

exposed to direct sunlight.

- 9.3 Pursuant to regulation 18.8.1 of Annex VI of MARPOL 73/78, the retained sample should

be retained under the ship's control until the fuel oil is substantially consumed, but in any case

20

for a period of not less than 12 months from the time of delivery.

- 9.4 The ship's master should develop and maintain a system to keep track of the retained

samples.

11. Sewage discharge

Question

Please let me know the areas which are prohibited from discharging treated sewage and

alternative plan for disposal treated sewage on board.

Answer

1) According to the MARPOL Convention, it is possible to discharge sewage into the sea through

the IMO type approved treatment regardless of distance from the land. But, several countries

such as US water, Dubai, Turkey, Australia, Israel, has their own port regulations for prohibiting

discharging all sewage into the sea even it is treated by IMO type approved sewage treatment

plant or not.

2) Therefore, if sewage holding tank is not installed on board, it can be retained temporarily in

the After Peak Tanks or tanks in void space. In this case, for the proper transfer of treated

sewage, permanent and proper pipeline should be provided on board and approved by Ship’s

classification society.

For your reference, there is no convention requirement on the tanks for the purpose of

retaining treated sewage. Therefore, it is not required to be listed in the ISPP certificate

because it is not regarded as a sewage according to the definition of sewage in MARPOL

convention.

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III. Other convention matters (BWM, Ship Recycling)

1. BWM Convention

Question

Related to the Ballast Water Management Convention

1) Taking into account that due date for the installation of BWMS onboard existing ships is

designated to the first IOPP renewal survey after the date of entry into force of the

Convention, is it possible to carry out IOPP renewal survey other than other statutory

certificates before the date of entry into force of the Convention?

2) What are the possible problems when the IOPP renewal survey is carried out before the

date of entry into force of the Convention and renewal surveys associated with other

statutory certificates are carried out as scheduled?

3) Regardless of above 2 questions, are there any special requirements for Korean Government

or Recognized Organization in a case where the renewal surveys associated with all statutory

certificates are carried out more than 3 months before the expiry date of the existing

certificates?

Answer

1) The renewal survey can be carried out at anytime and anywhere as this survey is the highest

survey required by the Convention, But, in order to carry out the renewal survey associated

with IOPP certificate before the date of entry into force of the Convention for the purpose

of delaying the installation of BWMS onboard existing ships, the following should be

considered

- A case where the renewal survey associated with IOPP certificate other than other

statutory certificates is carried out, the designated survey cycle and expiry date for other

statutory certificates will be inconsistent, as a consequence, it would affect the

consistency between designated statutory survey cycle and expiry date in accordance

with the HSSC(Harmonized System of Survey and Certification) now in force.

- In addition, inconsistency of statutory survey cycle caused by differentially designated

expiry dates among the statutory certificates would also create the significant

administrative burden for ship owners as well. It is not an efficient way as there would

22

be a case where the statutory survey shall be carried out more than 2 times a year

2) After in-depth consideration of above, if ship owners wish to carry out the renewal survey

associated with IOPP certificate before the date of entry into force of the Convention, the

owners are kindly requested to get a permission from ship’s flag Administration and then

submit a written permission to our classification society. Please note that if there is no

technical justification on that permission, this classification society would not contact the

Administration on behalf of ship owners.

3) A case where the renewal survey associated with all statutory certificates is carried out more

than 3 months before the expiry date of the existing certificates, there would be no special

requirements for the Administration or RO. Please note that the same survey scheme such

as dry-docking, bottom survey and thickness check as the renewal survey associated all

statutory certificates will apply accordingly.

2. Ship owners who can take advantage of non-penalization with respect of BWM

roadmap

Question

Please define the details on non-penalization clauses and the applicable ships to which non-

penalization applies for the smooth implementation of BWM Convention.

Answer

MEPC 67 adopted Res.MEPC.253(67) – measures to be taken to facilitate entry into force of the

international convention for the control and management of ships’ ballast water management

and sediment 2004 that clearly indicated “Agrees that shiponwers that have installed type

approved BWMSs prior to the application of the revised G8 guidelines, should not be penalized”.

MEPC 68 continued its consideration and developed a “Road Map” as follows:

1. Ship owners who have installed, prior to the application of the revised G8 guidelines,

ballast water management system (BWMS) approved in accordance with the existing G8

guidelines, should not be required to replace these systems due to the application of

the revised G8 guidelines with systems approved in accordance with revised G8

guidelines;

2. Ship owners who have installed, maintained and operated correctly BWMS approved in

accordance with existing G8 guidelines should not be required to replace these systems,

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for the life of the ship or system, whichever comes first, due to occasional lack of efficacy

for reasons beyond the control of the ship owners and ship’s crew.

3. Early movers should not be penalized (sanctioned, warned, detained or excluded) solely

due to occasional exceedance of the D-2 standard following use of a BWMS approved

by the Administration under G8 guidelines if;

- The ship has a correctly installed BWMS approved in accordance with G8 guidelines;

- The approved BWM Plan is followed, including the operational instructions and the

manufacturer’s specification for the BWMS;

- The BWMS has been maintained in accordance with the manufacturer’s specifications

for the BWMS;

- The self-monitoring system of the BWMS indicates that the treatment process is working

properly

4. The port State control, flag State and ship owners should work together to agree on the

most appropriate solution to allow for the discharge of ballast water found to be non-

compliant.

5. But, for those decisions, the United States expressed their reservation. Thus, non-

penalizing clauses are not applicable for ships to which USCG BWM regulation applies.

3. Main difference between Hong Kong Convention(HKC) and EU Ship recycling

Regulation(SRR)

Question

What is the main difference between Hong Kong Convention (HKC) and EU Ship recycling

Regulation (SRR)?

Answer

24

The EU ship recycling regulation’s requirements are based on the respective requirements of the

Hong Kong Convention. Keeping an up to date Inventory on board a ship throughout the life

cycle of a ship is a key requirement set out both in the convention and EU Regulation. Moreover,

IHM development in accordance with the regulation must be complied taking into account the

relevant IMO guideline.

as aforementioned, the inventory should be developed on the basis on the standard format set

out in the IMO guideline (Res.MEPC.269(68)). However, in this format there should be a reference

stating that the IHM has been developed to cover also the requirements of SRR. This would be

entail that the inventory include the materials according to IMO guideline with the addition of

two hazardous materials (PFSO, HBCDD) as appropriate.

The main difference is that HKC is non-mandatory international convention because this

convention has not been ratified until now. On the other hands, ships register in EU member

states and ships flying flag third countries shall have IHM developed in accordance with guideline

from 2018 gradually. For more details, please refer to the following comparison table.

IHM

EU SRR

IMO HKC EU Ships Non-EU

Ships New ships Existing Ships

Date of Application 2015.12.31*

~ 2018.12.31 2020.12.31 2020.12.31 Not yet in force

PFOS ○ ○ N/A N/A

HBCDD ○ N/A N/A N/A

ODS ○ ○ ○

Include ODS but provides

for an exception of new

installations containing

HCFCs which are

permitted until 1 Jan 2020.

*This Regulation shall apply from the earlier of the following two dates, but not earlier than 31 December 2015.

- 6 months after the date that the combined maximum annual ship recycling output of the ship recycling facilities

included in the European List constitutes not less than 2.5 million light displacement tonnes.

- on 31 December 2018

25

IV. Coastal states or port regulations

1. Application of China ECA Regulation

Question

Related to the application of China ECA Regulation

1) Whether or not Anchoring, On Buoys, or Alongside are included

2) Availability of meeting the Sulphur contents limit by mixing of retained fuel oil (high Sulphur)

and newly received low sulphur fuel oil

3) Coordinates information of China ECAs

Answer

1) The China ECA regulation states the regulation applies to ships at berth but it is not

mentioning whether the regulation includes when the ships at anchor, on buoy, or alongside.

We have confirmed there are different interpretation between Chinese PSC by regionally. In

other words, some of them interpret the all above cases should be included, and others

interpret it applies only alongside. Therefore, the most safe operation of a ship without any

unnecessary arguments during PSC inspection would be using low Sulphur fuel at the all

above cases until firm interpretation of regulation is provided by China Administration.

2) Mixing of retained fuel oil (high Sulphur) and newly received low sulphur fuel oil may be

available if the fuels are same kinds, however there will be a problem if the fuel kinds are

different. This could be justified by more technical experts other than Classification Society,

therefore it would be recommended to contact to the refinery or fuel oil analysis industry

for clear justification case by cases.

3) The China ECA regulation defines the ECA is about 12 miles away from coastlines and islands

within the areas, but no exact coordinates is designated. We will provide relevant information

upon receive further coordinates information.

2. USCG BWM 규정

Question

Related to the USCG Ballast Water Management regulation

1) USCG BWM regulation requires all ships to which this regulation applies to install a BWMS

26

at first dry-docking on or after 1 January 2016. In this regard, is there specific definition for

the dry-docking?

2) It is noted that under water survey can be carried out in lieu of dry-docking according to

the conditions for shell plates of the ships. Is under water survey included in the scope of

dry-docking referred in the USCG BWM regulation?

Answer

1) In all cases, a vessel’s ‘first scheduled dry-docking’ date is the date when vessel enters a

dry-dock. For example, if a vessel enters dry-dock on or before 31 Dec’ 2015 and does not

leave dry-dock until after 1 January 2016, this is not considered the ‘first scheduled dry-

docking after 1 Jan’ 2016’ for the purpose of compliance.

2) A dry-docking begun after the date specified in either 33 CFR Part 151.1215(b) and

151.2035(b), as applicable, which is necessary for emergency repairs is not considered the

first scheduled dry-docking. However, if this dry-docking satisfies the Administration for

endorsing the Certificate of Inspection, passenger ship safety certificate, cargo ship safety

certificate, or cargo ship safety construction certificate as the required survey of the bottom

of the ship, this dry-docking date is considered the first scheduled dry-docking.

3) A scheduled dry-docking begun after the date specified in either 33 CFR Part 151.1215(b)

and 151.2035(b), as applicable, to satisfy a statutory bottom survey requirement or to

accomplish planned work (such as a dry-docking to install exhaust gas cleaning equipment

or to install a new bottom coating system), as apposed to emergency work, is considered

the first scheduled dry-docking.

4) An underwater survey in lieu of dry-docking is not considered the ‘first scheduled dry-

docking’; instead:

- For vessels that undergo one underwater survey in lieu of dry-docking for statutory

purposes every five years, the first scheduled dry-docking is the first dry-docking

conducted for statutory purposes after the date specified in either 33 CFR 151.1215(b)

and 151.2035(b), as applicable;

- For vessels that do not routinely undergo dry-dockings, their original compliance date

is 1 Jan’ 2014 or 1 Jan’ 2016, depending on the vessel’s ballast water capacity.

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3. Use of non-EALs for ship installed stern tube air seal

Question

If the ship is installed with stern tube air seal, is it possible to use mineral lub.oil instead of

Environmentally Acceptable Lubricants(EALs) to Stern tube or equipment cease being an oil-to-

sea interface?

Answer

If a stern tube seal such as the air seal can fully eliminate the oily discharge, then the lubricated

stern tube would be much like a seawater lubricated stern tube in terms of having no potential

for oily discharge, and use of an EAL would not be required. And if ship is installed air seal and

mineral oil, she should have manufacturer service letter clearly state that there is no risk of oil

leakage to sea during normal operation.

4. Application of EALs to deck crane and launching appliance etc. for ships applied by

VGP regulations

Question

In case of a ship to which VGP regulation applies, is deck crane and launching appliance to be

applied with Environmentally Acceptable Lubricants (EALs) ?

Answer

If the machinery or equipment are subject to immersion during normal operation, the vessel

owner/operator must use an EALs to a part of that.

[For example]

1. emergency towing wire for oil tanker: shall be applied EALs

2. Deck Crane: should be applied EALs or mineral lub.oil