Items with Most Common Deficiency

Requirements / Guidance to the Owners/ managers

Technical files and if applicable, monitoring manual (MARPOL Annex VI/Reg. 13)

Each diesel engine which is certified to NOx Tier I, II or III must be issued an Engine International Air Pollution Prevention (EIAPP) Certificate and a NOx Technical File approved by the vessel’s RO on behalf of the Administration. The EIAPP and NOx TF are to be maintained on board the vessel.

The IMO ID number of fuel injection nozzles and other spare parts are to match those in the NOx technical file.

If an engine uses the Direct Measurement and Monitoring method, this is to be documented in an Onboard Monitoring Manual, approved by the vessel’s RO on behalf of the Administration.

Record book of engine parameters (MARPOL Annex VI/Reg. 13 and NOx Technical Code/6.2.2.7))

A ship equipped with a marine diesel engine requiring to undergo an Engine Parameter Check method is to maintain on board:

1.  A Record Book of Engine Parameters;

2.  An engine parameter list of an engine’s designated components and settings and/or the documentation of an engine’s load-dependent operating values approved by the Administration; and

3.   Technical documentation of engine component modification when such a modification is made to any of the engine’s designated engine components.

Record book of engine parameters (NOx Technical Code/6.2.2.8)

A record of the component identification numbers of engine parts that affect NOx emissions are to be made in the "Record book of engine parameters" and ensure they match the official "NOx Technical File" and "EIAPP Certificate".

Key components include fuel injectors, pumps, camshafts, charge air coolers, pistons, and turbochargers, all of which need to be logged with their original and replacement ID numbers when a change is made.

Approved method (MARPOL Annex VI/Reg. 13.7.1 to 13.7.5)

A marine diesel engine with a power output of more than 5,000 kW and a per cylinder displacement at or 90 L installed on a ship constructed on or after 1 January 1990 but prior to 1 January 2000 shall comply with the Tier I emission limits standards, provided that an approved method for the engine has been certified by an Administration of a Party and notification of such certification has been made to IMO.

Section 2.2.1 of vessel’s IAPP Supplement is to be completed appropriately depending on the ship-specific application of this regulation.

1.  Meet the EGR bleed-off water discharge standards.

2.   Have on board a manual for EGR bleed-off discharge system and EGR Record Book approved by the RO on behalf of the Administration.

3.    Have on board certificates of type approval and operating and maintenance manuals of oil content meters (15 ppm alarm).

EGR or Selective Catalytic Reduction (SCR)(MARPOL Annex VI/Reg. 13)

Fuel Sulphur Content and Fuel Oil change-over procedure and SOx Records (MARPOL Annex VI/Reg. 14)

The Sulphur content of any fuel oil carried for use on board a ship when operating outside a designated SOx ECA shall not exceed 0.50% m/m.

The Sulphur content of any fuel oil used on board ships when operating within a designated Sox ECA shall not exceed 0.10% m/m. Current ECA’s are North American, United States Caribbean Sea, the Baltic Sea, the North Sea, and the Mediterranean Sea, and on 01 March 2026, the Canadian Arctic and the Norwegian Sea.

The maximum Sulphur content of marine fuels for use while at berth in EU ports is 0.10% m/m.

Vessels using separate fuel oils when entering or leaving an ECA must carry a written procedure showing how the fuel oil change-over procedure will be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable Sulphur content prior to entry into an ECA. The use of a “fuel oil change over calculator” is one way of ensuring the change-over is done in time.

The volume of low Sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an ECA or commenced after exit from such an area, are to be recorded in the engineering log book or in a record book or log book in electronic format (electronic record book) approved by the Administration.

Alternative arrangements (SOx) - EGCS (MARPOL Annex VI/Reg. 14)

An exhaust gas cleaning system (EGCS) used as an equivalent or alternative arrangement to achieve the relevant Sulphur limit must be approved by the Administration.

Ships operating with EGCS shall have on board an EGCS record book approved by the vessel’s RO on behalf of the Administration.

Shipboard incinerators are to be approved by the vessel’s RO on behalf of the Administration and issued with a Type Approval certificate.

Incinerators are to be provided with a manufacturer’s operating manual which is to be retained on board the vessel and which specifies how to operate the incinerator within its applicable limits.

Details of fuel oil delivered to and used on board ships are to be recorded by means of a Bunker Delivery Note provided by the supplier, which may be in electronic format.

The BDN is to include, among other things, Sulphur content (% m/m), flashpoint (°C) specified in accordance with acceptable standards, or a statement that the flashpoint has been measured at or above 70ºC, and a declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulation 18.3 of MARPOL Annex VI and that the Sulphur content of the fuel oil supplied does not exceed the applicable regulatory limit or the purchaser’s specified limited value.

IEEC & Statement of Compliance

Ensure that there is a valid Statement of Compliance related to fuel oil consumption reporting and operational carbon intensity rating, and International Energy Efficiency Certificate and a Ship Energy Efficiency Management Plan on board.