IMO 2020 sulphur cap: Restrictions for discharging washwater from Scrubbers
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.
ASIA
China
China’s Ministry of Transport (MOT) issued its ‘Notice on Regulating the Implementation of Supervision and Management of Ship Air Pollutant Emission Control Areas’ which states that from 1 January 2019 discharge of washwater from scrubbers is prohibited in the county’s inland emission control areas (ECAs), port water areas of coastal domestic ECAs and Bohai Bay waters. The document also states that a ban in the entire coastal domestic ECA will be announced in due course. Our local correspondent, Huatai, has published a useful circular on China’s ban on scrubber washwater discharge, which can be accessed here. China MOT recently circulated a draft recommending that the ban on the discharge of washwater be extended to within 12nm of all coastal areas and regions near the southern island province of Hainan.
Hong Kong
If a ship intends to use scrubbers in Hong Kong waters, to meet the sulphur cap requirements, application must be made to the Hong Kong authorities requesting for an exemption from using compliant fuel. The exemption application must be made at least 14 days prior to a ship’s first visit to Hong Kong after 1st January 2019. For details of the exemption application process, please refer to Sections 7 to 11 of the new ‘Air Pollution Control (Fuel for Vessels) Regulation’.
Singapore
According to the Maritime and Port Authority of Singapore (MPA), discharge is prohibited in Singapore port waters from 1 January 2020. MPA has published useful guidance on IMO’s 2020 Sulphur limits which can be accessed here. The document advises ships fitted with open loop scrubbers to ‘carry out the switch to either closed-loop mode or to compliant fuel well in advance of the vessel’s arrival at the port waters’. Residues from scrubbers have been classified as toxic industrial waste under Singapore’s Environmental Public Health (Toxic Industrial Waste) Regulations. It can only be collected by licensed Toxic Industrial Waste Collectors.
India
In DG Engineering Circular 05 of 2018, India seems to indicate that scrubber washwater discharges are allowed if the criteria set out in MEPC.259(68) are met. However, this is qualified with a requirement that local regulations should also be followed. As of now, it is not clear if local restrictions will be imposed in some areas.
UAE
Abu Dhabi: In 2013 Abu Dhabi authorities issued ‘Vessel Discharge and Maintenance Guidelines For Owners, Masters And Agents’. It states that scrubber washwater can be discharged in port waters if free form pollutants whilst scrubber sludge should be discharged from the vessel to an Abu Dhabi Ports Company (ADPC) licensed waste disposal contractor.
Fujairah: As per notice to mariners no. 252, Harbour Master of Fujairah has announced that use of open loop scrubbers will be banned in port waters. The circular can be found here.
Belgium
The European Commission’s 2016 note on discharge of scrubber washwater, bans the discharge in ports and inland waters. Relevant legislation is ‘Wet van 26 maart 1971 op de bescherming van de oppervlaktewateren tegen verontreiniging (Vlaams Gewest)’.
Germany
Discharge is not allowed in inland waterways and the Rhine, pursuant to Articles 1 and 3 of the CDNI Convention (Convention on the Collection, Deposit and Reception of Waste Produced during Navigation on the Rhine and Inland Waterways).
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