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As previously advised through PHRS NL 166/17 of 30 January 2017, the IMO fuel oil consumption data collection system (IMO DCS) came into force on 1 March 2018, further to MARPOL Annex VI amendments adopted in October 2016 by virtue of IMO Resolution MEPC.278(70).
Summarizing the MARPOL Annex VI amendments (with additional information) :
• Under new Regulation 22A of MARPOL Annex VI, from January 1st, 2019, ships of 5.000 GT and above will have to start collecting data on fuel consumption and transport work for each calendar year according to a Methodology set out in the Ship Energy Efficiency Monitoring Plan (SEEMP).
• From 2020 onwards, aggregated data on fuel consumption and transport work concerning the previous calendar year (e.g. 2019 data) will be reported to the ship' Flag Administration or a Recognized Organization (RO) nominated by the Flag in the form of annual reports of specific format.
The submitted ship fuel oil consumption data shall be verified by the Administration or the nominated RO according with Regulation 22A.7 of MARPOL Annex VI based on procedures established by each Administration, taking into account guidelines developed by the Organization [ MEPC.292(71) ]. Upon verification of the submitted data, by 31st of May of each calendar year (starting from May 2020) the Administration or the nominated RO will issue to the ship a Statement of Compliance related to fuel oil consumption, valid for 1 year. Finally, the Administration will submit aggregated data to the IMO, which will maintain and publish an anonymized IMO Ship Fuel Oil Consumption Database.
From 1 March 2018, Regulation 5.4.5 of amended MARPOL Annex VI requires Administrations to ensure that the Ship Energy Efficiency Management Plan (SEEMP) of ships of 5,000 GT and above complies with Regulation 22.2 of MARPOL Annex VI, for preparing the ships to collect the required data. The updated SEEMP shall include a description of the methodology that will be used to collect the data required pursuant to Regulation 22A of MARPOL Annex VI and the processes that will be used to report the data to the ship’s Administration or any organization duly authorized by it. This shall be done prior to collecting data under Regulation 22A of MARPOL Annex VI in order to ensure the methodology and processes are in place prior to the beginning of the ship’s first reporting period from 1 January 2019.
Therefore, shipping companies, from March 1st, 2018 must update their ships' SEEMP according to the 2016 Guidelines for the Development of a Ship Energy Efficiency Monitoring Plan (SEEMP) adopted with Resolution MEPC.282(70) which superseded the 2012 SEEMP Guidelines; the updated SEEMP must be submitted to the Flag Administration or a RO for review/verification well before the end of 2018. Confirmation of SEEMP' compliance shall be provided to the ship and retained on board.
Click here for the IMO Resolution MEPC.282(70) - 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP).
Click here for Resolution MEPC.292(71) - 2017 Guidelines for Administration verification of ship fuel oil consumption data.
Ships flying the flag of a non-Party State to MARPOL Annex VI will still be required to demonstrate compliance with these requirements.
Phoenix Register of Shipping (PHRS) is undertaking the necessary steps for being nominated by the Administrations for which acts as RO/RSO to provide following services related to the IMO DSC:
• Review of the Ship Energy Management Plan (SEEMP);
• Verification of the reported data on fuel consumption and transport work;
• Issuance of the Statement of Compliance.
The nomination process is expected to be concluded as soon as possible and relevant notification will be released.
In the meantime, ship-owners and operators should consider and determine the means for collecting the fuel oil consumption data that is most appropriate for each ship and update the SEEMPs of their ships. Following this, they should submit each SEEMP Part II to Phoenix Register of Shipping (PHRS) for approval, after PHRS will be nominated by the Administrations.
For more information regarding the issue please do not hesitate to contact us.
April 18th , 2018 – PHRS Head Office
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