Technical Circular No: 033/2022

Subject: IMO Circular on Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the Exhaust Gas Cleaning System (EGCS) fails to meet the provisions of the EGCS Guidelines.

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1. The Marine Environment Protection Committee vide Circular – MEPC.1/Circ.883/Rev.1 has approved the Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the Exhaust Gas Cleaning System (EGCS) fails to meet the provisions of the EGCS Guidelines (2009 EGCS Guidelines adopted vide MEPC. 184(59), 2015 EGCS Guidelines adopted vide MEPC.259 (68) & 2021 EGCS Guidelines adopted vide MEPC. 340(77)).

2. An EGCS unit may be deemed to be faulty when its emissions and discharges exceed the standard as prescribed in the applicable EGCS Guidelines.

3. Any malfunction that lasts for more than one hour or in case of repetitive malfunctions, in pursuant to regulation 5.6 of Annex VI of the MARPOL Convention, it is imperative that such a situation is reported to the flag Administration of the vessel and to the relevant port State’s Administration, along with an explanation of the steps the ship operator is taking to address the failure.

4. An EGCS malfunction event is to be duly recorded in the EGCS Record Book including the date and time the malfunction began, the duration of the malfunction and, if relevant, how it was resolved, the actions taken to resolve it and any necessary follow-up actions.

5. Short term temporary exceedances of the applicable emissions ratio and discharge parameters that occur as a result of EGCS dynamic responses due to sudden changes in the exhaust gas flow rate and/or wash water flow characteristics, do not necessarily mean that the system is malfunctioning. There are various parameters being monitored and recorded that are normally interrelated. Hence if the value of one parameter changes, this will result is a corresponding change in one of the other parameters. Such interrelation of parameters will provide an indication as to whether the EGCS is faulty or it is only a failure of one of the sensors.

6. The ship operator should follow the process to identify and remedy the malfunction in the approved Exhaust Gas Cleaning System – Technical Manual (ETM) that is approved at the time the EGCS is certified or in other documentation provided by the EGCS manufacturer. Typical operating conditions that may result in such short term temporary exceedance would be specified in the ETM Manual.

7. A EGCS malfunction that cannot be rectified is regarded as a breakdown. The ship should then change over to compliant fuel oil if the EGCS cannot be put back into a compliant condition within a maximum of one hour. If the ship does not have compliant fuel oil or sufficient amount of compliant fuel oil on board, a proposed course of action, in order to bunker compliant fuel oil or carry out repair works, is to be communicated to relevant authorities including the ship’s Administration and relevant Port State, for their agreement.

8. Ship Owners/ Operators and masters are advised to be guided by above.

9. This Technical Circular supersedes and revokes earlier Technical Circular No. 074/2020, dated 05 May 2020.

Enclosure:

Disclaimer:

This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority. 

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