Exhaust Gas Cleaning Systems
Australia’s approach to exhaust gas cleaning systems
As a party to MARPOL Annex VI, Australia permits the use of EGCS to comply with the low sulphur fuel oil limit, provided the:
- system is approved by the ship’s flag State, or a recognised organisation appointed by the flag State
- system is operated in accordance with IMO requirements, including the IMO 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68))
- crew are trained on the use of the system and the system is kept in good working order, with maintenance up to date and monitoring devices fully operational
- EGCS approval documents, as well as operational and maintenance records for the EGCS are maintained on board the vessel and made available for inspection upon Port State Control Officer (PSCO) request
- following information is provided to AMSA at EGCS@amsa.gov.au before arrival at the first Australian port:
- Ship 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 Appendix 3 of the IMO 2015 Guidelines for Exhaust Gas Cleaning Systems.
- 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. Ships may be directed not to discharge wash-water from an EGCS in Australian waters if this data, or evidence that samples have been taken for analysis, cannot be provided to AMSA before arrival at the first Australian port.
Any EGCS found to be non-compliant with IMO guidelines in any respect (including but not limited to the wash water discharge criteria) may be prohibited from use in Australian waters.
Further information on Australia’s approach to the use of an EGCS to support compliance with the 2020 low sulphur limit can be found in Marine notice 5/2019—Requirements for the use of Exhaust Gas Cleaning Systems in Australian Waters and reporting to AMSA.
EGCS wash water
Further work is being undertaken through the International Maritime Organization (IMO) and by AMSA to research the potential long-term impacts of cumulative wash water discharges, including in areas with high shipping density and with poor tidal flushing.
Work by the IMO
The IMO 2015 Guidelines for Exhaust Gas Cleaning Systems outlines requirements for the testing, certification and verification of EGCS, including wash water discharge and monitoring criteria. An updated version is expected to be adopted by the IMO Marine Environment Protection Committee (MEPC) in late 2020 and will take effect six months after adoption. The 2020 Guidelines will only apply to new installations, existing EGCS approved in accordance with the 2015 Guidelines do not need to be approved again.
The IMO's Pollution Prevention and Response Sub-Committee (PPR) will also work to evaluate and harmonise rules and guidance on discharges from EGCS. This work aims to address concerns over the potential negative impact on the marine environment and the measures that have been put in place in some areas to prohibit wash water discharge. The scope of this work was agreed by PPR in February 2020, with a view to approval by the MEPC in late 2020. This work is anticipated to conclude in 2021.
Work by AMSA
AMSA considers that any prohibition on the discharge of EGCS wash water should be supported by sound scientific studies and evidence-based data.
Initial advice from the Commonwealth Scientific and Industrial Research Organisation (CSIRO) indicates that dilutions of wash water discharge by the receiving environment will adequately reduce all contaminant concentrations to below water quality guidelines applied in Australia and New Zealand.
AMSA is commissioning further research on the cumulative effects of EGCS wash water discharges to identify any potential long-term impacts for the Australian marine environment. The outcomes of this research will inform whether any future restrictions on the use of EGCS in Australian waters may be required.