IMO 2020 sulphur cap: Restrictions for discharging washwater from Scrubbers (update)

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(www.MaritimeCyprus.com) 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. 

Readers are aware that in addition to using compliant fuel to meet the 0.50% sulphur requirement that entered into force on 1 January 2020, there also exists the option to use “equivalent” compliance mechanisms in accordance with Regulation 4 of MARPOL Annex VI, one of which is the use of Exhaust Gas Cleaning Systems (EGCS) commonly known as Scrubbers.  

 

In this regard the ICS Secretariat had circulated MC(19)04 that contained an initial list, which has been most recently revised in MC(20)54 that contained updates to the list of ports around the world that were identified as prohibiting the discharge from open loop scrubbers by ships visiting these ports. 

 

Based on further related information received from the Clean Shipping Alliance, the ICS Secretariat has updated the list as provided below.  

Country

Port/Sea area

Additional information

Albania

All ports

 

Australia

Port of Hastings

 

Belgium

All ports and inland sea areas

 

Belize

  

Bermuda

  

Brazil

Terminal of Ponta da Madeira

All ports owned by Vale

 

Complex of Tubarao e Praia Mole Ports

 
 

Terminal of Ilha Guaibe

 

Canada

Port of St John

 
 

Port Cartier

 

China

Inland River ECA's

 
 

Waters of ports in Coastal ECA's

 
 

Bohai Sea waters

 

Columbia

 

Internal waters, territorial sea area, and the contiguous Colombian zone

Croatia

Port areas

 

Egypt

Suez Canal

 

Finland

Port of Porvoo

 

France

Cannes

Restriction applies to cruise ships only

 

Marseille

 
 

Le Havre

 
 

Cherbourg

 
 

Reunion

 
 

Dunkirk

 

Georgia

  

Germany

Port of Hamburg

 
 

Port of Rostock

 
 

River Elbe

 

Ghana

  

Gibraltar

  

Ireland

Port of Dublin

 
 

Port of Waterford

 
 

Port of Cork

 
 

Port of Bantry

 
 

Shannon Foynes Port

 

Kenya

Within port limits

 

Malaysia

 

Within 12 nautical miles of land

Mauritius

 

Within 12 nautical miles of land

Mozambique

Nacala Port

 

Norway

The World Heritage Fjords

 
 

Port of Eidfjord

 
 

Port of Stavanger

 

Oman

  

Pakistan

Port of Karachi

 
 

Port of Bin Qasim

 

Panama

Panama Canal

 

Portugal

Port of Aveiro

 
 

Port of Leixoes

 
 

Port of Lisbon

 
 

Port of Sines

 

Qatar

  

Romania

Within port limits

 

Singapore

Within port limits

 

Slovenia

  

South Korea

Incheon (including Kyongin Port)

* Restrictions also apply to all ships at anchor in all ports

 

Pyeongtaek-Dangjin

 
 

Yeosu

 
 

Gwang-yang (including Haodng port)

 
 

Busan

 
 

Ulsan

 

Spain

Port of Cadiz

 
 

Port of Algeciras

 
 

Port of Cartegena

 
 

Port of Huelva

 
 

Port of Barcelona (at berth)

 
 

Canary islands ports

 
 

Port of Gijon

 

Sweden

Port of Stenungsund

 
 

Port of Trellebord

 
 

Port of Gothenburg

 
 

Port of Oxelosund

 
 

Port of Petroport

 

Turkey

  

United Arab Emirates

Port of Fujarah

 
 

Port of Dubai

 

United States of America

Ports of Conneticut

 
 

Port of Seattle

Restriction applies to passenger cruise ships at berth in port terminals only

 

Recommendations

Various other coastal states and ports are discussing enforcing similar bans citing the adverse effects of scrubber washwater on the marine environment. It is therefore likely that the above list of states/ports which currently regulate open loop scrubber discharges in their waters will grow over time. In those areas where the discharge of washwater is not permitted, vessel operators have two options to choose from to ensure compliance with the sulphur limits:

  • use compliant fuel instead of open loop scrubbers; or
  • switch over to closed loop mode of operation, in which case it will be necessary to convert currently installed open loop systems to closed loop or hybrid systems, if not already done.

Any changeover should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place. This 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.

The above list is intended to aid ships fitted with open loop scrubbers to plan in advance accordingly. In any case, companies are recommended to obtain further clarifications from relevant authorities before their ships visit these ports.  There is information of hefty fines being imposed on ships that do not follow individual port requirements on this issue. 

Source: ICS

 

For more IMO 2020 sulphur cap related guidance click here.

 

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