1 More stringent EU requirements ozone depleting substances (11-24)
According to EU Regulation 2037/2000, EU flagged ships are not allowed to use HCFK (R-22) for service and maintenance from the 1st of January 2015 anymore. For non EU ships HCFK (R-22) is not allowed in ships contructed on or after the 1st of January 2020, according to MARPOL Annex VI Reg 12.
It is expected that old ships with large reefer installations using R-22 such as reefer ships / trawlers / passenger ships will change flag to a non EU state in order to continue their services.
Shipowners with a ship with R-22 installations have the following options:
- Continue with the use of R-22, but leakages should be minimized as much as possible. Only applicable for installations in the final stage of use.
- Retrofit to be considered and replace the R-22 filling by another HFK refrigerant. However, these replacement refrigerants often are green house gasses. Furthermore their efficiency is significantly lower than that of R-22 and problems have occurred in installations already retrofitted.
- Replace the complete installation. Very costly but for the long term it should be considered.
The ROs are requested to pay attention to these more stringent EU regulations (5 years earlier then IMO MARPOL) and arrange for a memo in the vessel survey database for timely implementation.
2 Logbook ozone depleting substances (13-14)
According to MARPOL Annex VI every ship >400GT shall have an ozone depleting substances logbook. For ships flying the flag of The Netherlands also ships < 400GT shall have such a logbook when the content of the refrigerating equipment is more than 3 Kg. Additional for ships flying the flag of The Netherlands the logbook needs to be on board in case greenhouse gasses are used in refrigerating systems with a content of more than 3 Kg.
The same requirement is in force for fishing vessels.
3 Diesel generator set irt emission requirements (13-23)
Referring to Marpol Annex VI Chapter 1 Regulation 2 paragraph 12:
12. Installed means a marine diesel engine that is or is intended to be fitted on a ship, including a portable auxiliary marine diesel engine, only if its fuelling, cooling, or exhaust system is an integral part of the ship.
A fuelling system is considered integral to the ship only if it is permanently affixed to the ship. This definition includes a marine diesel engine that is used to supplement or augment the installed power capacity of the ship and is intended to be an integral part of the ship.
For the temporary placed containerized diesel generator it has to be confirmed that the fuelling, cooling and exhaust gas system is not considered an integral part of the vessel and therefore, according to Marpol annex VI definition Ch 1 Reg. 2 par 12, the diesel generator set is excluded from the emission requirements of Marpol annex VI, The Netherlands flag confirmed that the above Marpol VI definition applies for Dutch flag vessels and that for temporary installed engines which are not covered by above definition verification of Marpol VI emission standards or equivalent standards is not mandatory but recommended.
4 Application Annex VI and Sulphur Directive during sea trials (15-03)
The Netherlands Shipping Inspectorate allows the use of High Sulphur heavy fuel during sea trials in the Netherlands Exclusive Economic zone of ships flying the flag of The Netherlands but the use of high Sulphur Fuel shall be restricted as much as possible and only serve the testing of engines. For example dredging trials, manoeuvring trials, etc. shall be performed on low sulphur fuel.