Annex VI entry into force immi
Although entry into force conditions for MARPOL Annex VI (air emissions) may be satisfied before the end of the year, it will not become enforceable until 12 months after that date, which in practice means the end of 2004 or early 2005.
The protocol requires that at least 15 states with not less than 50% of the gross tonnage of the world?s merchant shipping fleet have ratified the convention. To date, 11 countries representing just over 53% of shipping tonnage have become parties to Annex VI. Cyprus, Italy, Japan, the Netherlands and Spain have stated that their national procedures for ratification have reached the final stage and they would be able to deposit their instrument of ratification shortly.
Although the NOx regulations will not enter force until Annex VI comes into force, administrations are encouraged to issue interim certificates confirming conformity with the NOx technical code. The aim is to ensure that new or modified engines will already be compliant with the code until it enters into force.
Ship owners and engine builders must ensure their engines comply with the new NOx regulations on air pollution from ships
Annex VI of MARPOL, better known as the regulations for the ?prevention of air pollution from ships?, will, when it comes into force, require among other measures compliance with the technical code on control of emissions of Nitrogen Oxides (NOx) from marine diesel engines. This will affect diesel engines over 130 kW installed on ships built on or after 1 January 2000, together with any engines which have undergone a ?major conversion? after that date. This could potentially result in wide ranging implications on the flexibility of ship owners and managers as regards the maintenance of those engines.
The regulations demand that engine builders ensure that each of their engine types fall within the relevant limits of NOx emissions. This is generally measured on the test bed and is typically witnessed by classification societies acting as a ?recognised organisation? (RO) on behalf of the flag state of the ship onboard which the engine is to be installed. Subsequent engines of this type could be certified as being compliant without further emission testing provided that the duty, rating and NOx critical settings and components are within the scope of the ?engine group? definition as approved for the tested parent engine.
Mandatory records
For each engine requiring NOx certification, the engine builder prepares a technical file which includes the parent engine emission test report together with the permitted duty, rating and NOx critical settings and components of the engine. The technical file is approved by, or on behalf of, the flag state of the ship and must be supplied with the engine to the ship owner and contain the NOx certification. This file must be retained throughout the service life of the engine and is not to be subject to unauthorised amendments.
Additionally, the technical file must contain an approved onboard NOx verification procedure to verify compliance during onboard surveys. For those engines which are to be shown to be compliant by the ?parameter check? method of onboard verification (the universal case to date) the ship owner is required to maintain a record book of engine parameters. This record book may be supplied by the engine builder or may need to be drawn up by the ship owner.
However, it will be the responsibility of the ship owner to ensure that all changes and replacements to NOx critical settings and components are recorded in this book. Both the up-to-date technical file and engine record book are to be available at time of surveys in connection with MARPOL Annex VI. A failure in this respect would result in an inability to complete what will be a survey for a mandatory trading certificate with all the resulting problems for ships engaged in international trade.
To ensure that replacement parts are NOx compliant each engine builder is obliged to identify the critical components, usually with a code number, which will be detailed in the approved technical file. Any replacement parts must bear this number to maintain compliance of the engine and would typically include the piston, cylinder cover, liner, charge air cooler, turbocharger and the fuel injection system components.
This system is feasible in respect of expendable parts such as fuel equipment but could pose serious problems for operators of large bore two stroke engines. In this case key components such as pistons and cylinder covers are often reconditioned or exchanged rather than replaced by new parts from the licensee. The numbering system will potentially make this practice difficult.
There is some doubt whether spare parts from other licensees or even the licensor will have the same part number as the licensee who built the engine and drew up the technical file, which would mean that all spares would have to be acquired from the original source. It may also prevent operators from transferring components between ships in the same fleet. Components from pre-NOx engines may not bear the code number and will therefore be unacceptable for NOx compliant engines even though the parts may be identical.
Simple solution
One solution to this problem is being proposed by Diesel Marine International (DMI), a company which reconditions engine components and has been working on this issue for a couple of years in close co-operation with two major classification societies in their role as ROs. DMI tried to get some of its competitors involved but they preferred to await the outcome of this scheme.
DMI?s initiative led to the development of a simple alternative method of ensuring compliance while permitting the use of components which may have different code numbers, or no number at all, but are considered equivalent to the original component. This was achieved by appending to the engine record book, a set of approved simplified drawings of the NOx critical components by giving their principal dimensions. The onus is on the owner, together with the supplier, to demonstrate that the replacement component is equivalent to the original from the NOx emissions aspects.
It has to be noted, however, that acceptance of a simplified drawing by the ROs does not imply acceptance from the classification society responsible for maintaining that particular engine type. Also, under no circumstances can the class society use privileged information to endorse simplified drawings without the agreement of the OEM.
As it is in the interest of both DMI and ship owners not to be fully dependent on original engine manufacturers (OEM), it initially approached the two previously mentioned ROs in order to get their support. This was crucial in order to gain acceptance from other ROs in future to allow the use of simplified drawings while at the same time assisting ship owners to apply pressure on OEMs and licensed engine builders to include simplified drawings in the technical file. The technical departments of two major European container operators have already given DMI the necessary support while customers in the UK and Germany have already expressed their interest in this approach.
Subsequently, at future engine surveys in respect of MARPOL Annex VI, it would be demonstrated to the surveyor that, where NOx critical components had been replaced by unmarked or differently marked components, those replacement parts comply by means of comparison to the approved simplified drawings.
Through the application of the parameter check, the ship owner will be able to maintain flexibility in either sourcing new spares from a choice of suppliers, use reconditioned or exchange components and also retain the possibility of transferring components between ships.
