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Open Loop Scrubbers

We recently had an inquiry from an owner that has a vessel scheduled to arrive with an open-loop scrubber system installed. To ensure compliance of all local regulations and in anticipation of additional requests of a similar nature we reached out to both Transport Canada and the Vancouver Harbour Master. The vessel in question is fitted with an open-loop EGCS scrubber system with no holding tanks available. Relevant certificates relating to the system were sent to the authorities as well.

Transport Canada’s clarification on the matter as follows –

“Inquiry with respect to Air emission/ EGCS.

As of January 1st 2020, all vessels operating outside Emission Control Areas (ECA) will be required to meet the sulphur emission requirements which will be 0.5% maximum sulphur content. It can be achieved by either burning Marine Fuel Oil of up-to 0.5% sulphur content or emission control system such Exhaust Gas Cleaning System (EGCS) commonly known as scrubber system.

Within ECA area, strict emission requirements are already enforced by maximum sulphur content of 0.1%.  Vessels installed with an approved EGC system are allowed to use marine fuel oil of higher sulphur of 0.1% content, provided ECG system is able to clean the exhaust gas and provide record that sulphur content is 0.1% sulphur or less in the ECA area.

Vessel with ECG systems are required to operate the system as per manufacturer instructions and Flag States / Class approval procedures. Maintain the logbooks of ECG operation and monitoring alarms.

If the vessel is installed open loop ECG system, then master should also check with local harbour and port authorities for wash water discharge requirements. *

Vessel installed with an approved ECG system and operated as per requirements then there is no requirement to report unless system have malfunctioned or not operational.

Also please see following received from HQ:

Are Scrubbers Allowed? (Yes or No)

YES

If Yes, which manufacturers allowed?

ALL – ASSUME THAT THE IAPP REFLECTS THIS INFORMATION AND IT HAS BEEN SIGNED OFF BY THE RO OR THE FLAG STATE.

If Yes, then Open, Closed, Hybrid Systems?

ALL – RECOGNIZING THAT SOME PORT AUTHORITIES MAY PROHIBIT THE USE OF OPEN LOOP SCRUBBERS – SHIP OPERATOR SHOULD ALWAYS CHECK.

IMPLEMENTATION START DATES (will the ports start implementing these IMO rules at 0000 on 1st Jan 2020 or from a date in 2019 as many ships now have scrubbers onboard and could use them in 2019 and are likely to in the last days of 2019)

STARTS 0:00 JAN 1 2020, BY 0:00 MARCH 1, 2020 VESSELS WILL BE PROHIBITED TO CARRY FUEL GREATER THAN 0.5% SULPHUR ONLY IF IT’S BEING USED IN CONJUCTION WITH A SCRUBBER.”

Per Transport Canada’s above guidance, we followed up with the Port of Vancouver Harbour Master’s office which provided the following statement on the matter –

“VFPA currently has no restrictions at this time for the use of scrubbers, either open or close loop, in the port waters. Please ensure Transport Canada & VFPA is notified of any scrubber operation before use.

** This may change pending 2020 IMO fuel changes**”

The Port of Prince Rupert has also confirmed their use although each system will be evaluated on a case by case basis pending valid certification.

It is important that all vessels calling the West Coast of Canada notify their agents if scrubber systems are installed so that the proper authorities can be notified accordingly. Should you have any questions regarding these regulations please contact us for further clarification.