Port State control and GHG emissions

Captain Sukhjit SinghTechnical Head, MTCC Caribbean

What is Port State Control (PSC) and its legal basis

• It is an inspection of foreign ships in national ports by an authorized inspector of the Maritime

Administration.

• Objective

• To check if the ship is in compliance with International Conventions (e.g. SOLAS , LL (Load Lines),

MARPOL, STCW (Standards of Training, Certification and Watchkeeping ).

• The ship is manned and operated in compliance with applicable international laws

• Authority for carrying out PSC comes from:

• International treaties and Conventions

• Bilateral / multilateral agreements

• National Laws

• Many IMO conventions include provisions that give rights to undertake PSC including - MARPOL

Convention:

• Article 5 - Certificates and special rules on inspection of ships

• Articles 6 - Detection of violations and enforcement of the Convention

• MARPOL Annex VI regulations 10 and 11

Role of PSC in Elimination of Substandard Shipping

Safer & Cleaner Shipping

Flag State

Coastal State

Port State

Article 217 -Enforcement by flag StatesStates shall ensure that vessels flying their flag

or of their registry carry on board

certificatesrequired ……, and do periodically

inspection.

Article 218 -Enforcement by port StateWhen a vessel is voluntarily within a port or at an off-shore terminal of a State, that State

may undertake investigations and, where the

evidence so warrants, institute proceedings

against that vessel.

Resolution A.1138(31)Adopted on 4 December 2019- Procedures for Port State Control

• 1.2.2 “Ships of non-Parties should be given no more favourable treatment”.• MARPOL article 5(4) With respect to the ship of non-Parties to the

Convention, Parties shall apply the requirements of the present Convention as may be necessary to ensure that no more favourable treatment is given to such ships.

• 1.2.4 “When exercising port State control, Parties should only apply those provisions of the conventions which are in force and which they have accepted”.

SHIPS BELOW CONVENTION SIZE

– Example from Caribbean

CCSS Code Certification – up to 499 GT

MARPOL Annex VI Certification ≥ 400 GT

SCV Code Cert. – Length < 24 M

Factors impacting emissions

• SOX – Fuel type and Quality

• NOX – Combustion Quality

• CO2 - Combustion chamber quality and Fuel quantity

MARPOL Annex VI

• Chapter 1 – General

• Chapter 2 – Survey, certification and means of control

• Chapter 3 – Requirements for control of emissions from ships

• Chapter 4 – Regulations on Energy Efficiency on ships

• Chapter 5 – Verification of compliance with the provisions of this annex

Vessels and Engines

Manufacturer Certification Operation Fuel quality

PSC - MARPOL Annex VI

Init

ial i

nsp

ecti

on Checking Required

Certificates and Documents

Operational aspects of various required equipment

Cle

ar g

rou

nd

s Certificates missing or invalid

Absence or malfunction of equipment or arrangements specified in certificates or documents

Presence of equipment not specified in certificates or documents

Non familiarity of master or crew

Substandard quality of fuel,

Det

aile

d in

spec

tio

n Depends on what areas or aspect need to be inspected

It is further investigation by PSCO

Det

ain

able

def

icie

nci

es Absence of valid certificates or documents.

A marine diesel engine on board that does not comply with regulations.

The sulphur content of any fuel used or found on board exceeds 0.5% m/m (or 0.1% while in ECA SOx

The master or crew are not familiar with essential procedures of operation of air pollution prevention equipment

Port State Control for Nitrogen Oxides (NOx) (Regulation 13)

Initial inspection

• IAPP and EIAPP certificates

• NOx Technical file and related documents

• Crew familarisation and awareness

Detailed Inspection

• Has there been any major conversion?

• Is emergency generator used for non-emergency?

• Are there any additional engines on board?

• Are main components such as injectors, turbochargers are conforming to NOx Technical File?

PSC for SOx and sulphur compliance (Regulations 14 and 18)

Initial inspection

• Fuel Changeover procedure

• Bunker Delivery Note

• Bunker Samples

• Exhaust Gas Cleaning System

• Crew familarisation and awareness

Detailed Inspection

• ORB, BDN’s, FONAR as applicable

• Physical Examination of Fuel

• EDGC Compliance checklist

• Remedial action in case of malfunctioning of equipment

IMO GUIDANCE

• RESOLUTION MEPC.259(68) (adopted on 15 May 2015) - 2015 Guidelines For Exhaust Gas Cleaning Systems

• MEPC.1/Circ.883 21 May 2019 Guidance On Indication Of Ongoing Compliance In The Case Of The Failure Of A Single Monitoring Instrument, And Recommended Actions To Take If The Exhaust Gas Cleaning System (EGCS) Fails To Meet The Provisions Of The 2015 EGCS Guidelines (resolution MEPC.259(68))

• RESOLUTION MEPC.321(74) (adopted on 17 May 2019) 2019 Guidelines For Port State Control Under MARPOL Annex VI Chapter 3

Port State Control for Energy Efficiency MARPOL Annex VI – Chapter 4

Initial inspection

• IEE Certificate

• Ship Record of Construction (annex to IEE Certificate).

• EEDI Technical File, its contents and validity

• SEEMP part I and II

• Statement of Compliance – Fuel Oil Consumption Reporting

• Crew familarisation and awareness

Detailed Inspection

• Record of Construction for Energy Efficiency

• Review of Fuel Oil Consumption Reporting

• Verification of Data collection system

• Application of SEEMP principles in operations

Other relevant documentation to MARPOL Annex VI

• The copy of the type approval certificate of applicable shipboard incinerator (resolutions MEPC.76(40) or MEPC.244(66))

• The Ozone Depleting Substances Record Book (regulation VI/12.6)

• The VOC Management Plan (regulation VI/15.6)

Key Considerations

Building capacity within Maritime Administrations to conduct PSC inspections targeting emissions from ships

Need for regional approach – uniformity in enforcing compliance and consequences

Infrastructure investments to support the regulatory compliance in line with Initial IMO GHG strategy

mtcc@utt.edu.ttwww.u.tt/mtcc-caribbean