2/2021—Requirements for the use of exhaust gas cleaning systems in Australian waters and reporting to AMSA
The purpose of this marine notice is to advise vessel owners, operators and masters of Australia’s requirements for the use of Exhaust Gas Cleaning Systems (EGCS) to support compliance with the sulphur limit of 0.50 mass per cent concentration (m/m) in fuel oil as required by the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI and Australia’s domestic law.
This notice is issued as general guidance only and should be read in conjunction with MARPOL Annex VI and associated guidelines, relevant Acts, and Marine orders.
The 0.50 per cent m/m sulphur limit
As of 1 January 2020, the sulphur content of fuel oil used for propulsion or operation on board a vessel has been limited to 0.50 per cent m/m or less.
Vessel owners and operators have three options to comply with the 0.50 per cent m/m fuel oil sulphur limit:
- use of fuel oil with a sulphur content not exceeding 0.50 per cent m/m, or
- use of alternative fuels that have a sulphur content of 0.50 per cent m/m or less, or
- use of an EGCS, approved and operated in accordance with International Maritime Organization (IMO) requirements1.
Approval and operation of Exhaust Gas Cleaning Systems (EGCS)
The EGCS must be approved by the vessel’s flag State Administration, or a recognised organisation appointed by the flag State. The EGCS must also be operated in accordance with IMO requirements, including the IMO 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68)).
Crew members must be properly trained in the use of the EGCS and the system must be kept in good working order, with maintenance up to date and monitoring devices fully operational. The EGCS approval documents, as well as operational and maintenance records for the EGCS must be maintained on board the vessel and made available for inspection upon Port State Control Officer (PSCO) request.
Wash water discharges
AMSA is currently investigating the potential impacts of EGCS wash water discharges on Australian port environments and has commissioned a study to assess the potential cumulative impacts of wash water discharges from open-loop EGCS over time.
This investigation will inform whether any future restrictions on the use of EGCS in Australian waters are needed. While the discharge of wash water from EGCS is currently permitted in Australian waters, vessel owners, operators and Masters are encouraged to avoid discharging wash water within Australian port limits.
Notification to AMSA before arrival at the first Australian port
The master, owner or operator of a vessel using an EGCS is requested to notify AMSA before the first arrival at an Australian port after installation and approval of the EGCS, and provide the below information to EGCS@amsa.gov.au.
A vessel should only need to provide the above information to AMSA once, prior to their first arrival at an Australian port. There
is no need to notify AMSA for subsequent voyages to Australia unless the information provided to AMSA has changed. Any changes to this information should be provided to EGCS@amsa.gov.au.
- Vessel name (in email subject title)
- IMO number
- Arrival port
- Arrival date
- EGCS Scheme A or Scheme B approval
- Make and Model of EGCS
- Open-loop, closed-loop or hybrid-type system
- Results of all wash water testing that has been undertaken in accordance with 2015 Guidelines for Exhaust Gas Cleaning Systems.
For h), wash water testing should be conducted upon commissioning of the EGCS and repeated every twelve months, as a minimum, for a period of two years.
Vessels may be directed not to discharge wash-water from an EGCS in Australian waters if this data cannot be provided to AMSA.
If there is an EGCS malfunction2, action must be taken as soon as possible to identify and remedy the malfunction. Any EGCS malfunction that lasts more than one hour, or repetitive malfunctions, should be reported to the flag State Administration and Competent Authority of the port State of the vessel's destination. The report should include an explanation of the steps that are being taken to address the failure.
If the vessel’s EGCS cannot be returned to a compliant condition within one hour, the vessel must then change over to compliant fuel oil. If the vessel does not have sufficient compliant fuel oil to reach the next port of destination, the vessel will need to make a report to the relevant authorities, including the vessel’s flag State Administration and the Competent Authority for the next port of destination. The report must outline the vessel's proposed course of action, which might include bunkering compliant fuel oil at the next port or carrying out repair works. Where this occurs on an Australian Vessel or a Foreign Vessel within Australian waters, this report should be sent to email@example.com.
Any EGCS found to be not in compliance with IMO guidelines in any respect (including but not limited to the wash water discharge criteria) may be prohibited from use in Australian waters.
Ship owners and operators should refer to Marine Notice 04/2019 for a summary of requirements relating to MARPOL Annex VI. Detailed requirements can be found in MARPOL Annex VI, the Protection of the Sea (Prevention of Pollution from Ships) Act 1983 and Marine Order 97.
This document does not constitute legal advice and is not a substitute for independent professional advice.
Deputy Chief Executive Officer
30 April 2021
Australian Maritime Safety Authority
GPO Box 2181
CANBERRA ACT 2601
1. Refer to resolution MEPC.259(68) for further information.
2. Refer to resolution MEPC.1/Circ.883 for further information.