New EGCS Guidelines

The 2021 EGCS Guidelines (MEPC.340(77)) were adopted at this meeting, thereby closing the discussion surrounding them. The new rules will enter into force six months later, around 26 May 2022, and will apply to all newbuild and retrofit installations. They will also apply when an installation is changed to such a degree that the EGCS Technical Manual needs to be amended. So, except in the latter situation (major conversion), the 2021 EGCS Guidelines apply to new installations and do not impact existing installations.

Significant changes from the previous guidelines include:

• When a zero-discharge area prevents the immediate discharge of cleaned bleed-off water, the tanks used to for temporary storage of the water must meet a strict PAH limit at the tank discharge point. The new limit is 50 µg/L, independent of discharge flow rate and engine load.
• The discharge water monitoring and logging frequency have increased from 0.035 Hz to 0.0111 Hz, which is around every 90 seconds.
• There are several changes that impact the logging system and scrubber documentation, but not EGCS function as we know it today.
• Mandatory daily spot-checks are now required for Scheme A scrubbers.

New MEPC Circular

The Committee approved an MEPC circular, MEPC.1/Circ.883/Rev.1, which applies to all EGCS, old or new. It provides updated guidance for indicating compliance if a single monitoring instrument fails, as well as recommended actions to take if the EGCS fails to meet the provisions of the EGCS Guidelines.

Fortunately for owners and operators, the majority of IMO member states did not approve the suggestion that ships with a scrubber installed should carry compliant fuel for a full voyage. This had been suggested as a redundancy measure to cover any EGCS malfunction, and it would have removed the possibility for ‘indication of ongoing compliance’ in the event of a single monitoring instrument failure.

Harmonization of discharge water regulations

The scope of work for harmonizing discharge water regulations was accepted during MEPC 77. This means the work will be initiated and finalized at PPR 9 in April 2022. The scope is as follows:

• Agree on a text to change MARPOL
• Finalize a guideline for conducting risk assessments
• Finalize a guideline for conducting impact assessments
• Develop a guideline for scrubber sludge disposal ashore
• Establish a database of substances identified in the discharge water

Once the guidelines above are established, a government can apply for its waters to become a ‘scrubber sensitive area’. (It remains unclear whether this includes only territorial waters or extends to the EEZ boundary of 200 nautical miles.) An assessment of risk and impact will then be conducted, and following approval the government can ban scrubber discharge in the body of water defined.

To clarify, this is a harmonization of the regulatory structure, which will result in all member states having the same definitions and guidelines for conducting impact and risk assessments. In other words, they will be aligned on what is considered harmful. Shipowners will still face a patchwork of regulations, however, in the sense that not all ports or coastal areas will have the same regulations.