Updates and Reminders on the Use of Exhaust Gas Scrubbers in US Waters (IMO 2020 sulphur cap)


(www.MaritimeCyprus.com) The USCG issued an update to their policy letter, CVC Policy Letter 12-04, to remove a request for correspondence from Flag administrations on granted equivalencies. The USCG will instead be verifying this information through the IMO's Global Integrated Shipping Information System (GISIS).

  • Provided the systems are tested, surveyed, and verified in accordance with MEPC 184(59) or MEPC 259(68) and are appropriately granted equivalencies by a flag administration, exhaust gas scrubbers may be used to meet the ECA requirements in the US.
  • Foreign flagged vessels using an exhaust gas scrubber to meet the North American and U.S. Caribbean Emission Control Area (ECA) requirements do not need to make a separate notification to USCG prior to arrival in US waters.
  • US flagged vessels planning to use an exhaust gas scrubber must submit an equivalency request to USCG in accordance with Section 5(b)(i) of CVC Policy Letter 12-04.

Reminder: Additional Vessel General Permit (VGP) Requirements for Scrubber Washwater

Vessels using an open-loop or hybrid system that will generate an exhaust gas scrubber washwater discharge within 3nm of the US, are subject to additional monitoring and effluent limitations under the 2013 VGP. An excerpt of the exhaust gas scrubber requirements from the 2013 VGP is included below.

  • While the requirements are generally similar to those in MARPOL Annex VI, the pH limit is more stringent under the VGP.
  • Analytical monitoring must be carried out and reported to EPA as part of the vessel’s Annual Report.
  • If the washwater can be contained and is not discharged within VGP waters, these requirements do not apply.
  • The discharge of any scrubber washwater is prohibited in Connecticut State waters. Vessels calling ports in Connecticut, may not operate an open-loop scrubber while in State waters.

Reminder: Research Exemption Required for Use of Exhaust Gas Scrubber in California

Use of exhaust gas scrubber systems are not authorized to meet the California fuel oil requirements unless a special research exemption is granted by the State. More information on applying for an exemption is included in the References section below. If an exemption is not obtained from the State, vessels using an exhaust gas scrubber will need to switch to compliant fuel prior to entry within California Regulated Waters (24nm from the baseline).

Required Actions

If you are planning to use exhaust gas scrubbers for your vessels operating in the US, please ensure your Masters and appropriate crew and familiar with any additional requirements or restrictions that may apply.


CG-CVC Policy Letter 12-04 CH-1, November 7, 2019 – Guidelines for Compliance and Enforcement of the Emission Control Areas Established within the United States Jurisdiction as Designated in MARPOL Annex VI Regulation 14.

2013 Vessel General Permit, Section 2.2.26 – Exhaust Gas Scrubber Washwater Discharge Requirements

California Marine Notice 2017-01, August 2017 – Guidance for the Use of the Temporary Experimental or Research Exemption in the California Ocean-Going Vessel Fuel Regulation.

U.S. Coast Guard Maritime Commons, November 18, 2019 – Exhaust Gas Scrubbers on Foreign Ships in North American and U.S. Caribbean Sea Emission Control Areas

Source: Witt O'Brien's

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