12 Dec '17 How to ensure compliance with the EU’s MRV rules during a one-time voyage to Europe
Do you have a ship that might make a one-off trip to Europe in the future? If you do, then you run the risk of failing to comply with the region’s MRV regulations that come into force as of 1 January 2018.
From that date, any ship operator with vessels on voyages to or from a European port will be required to start recording CO2 related data for those voyages, along with other data relating to the vessel’s cargo.
The EU rules apply to every voyage to or from a European port, and apply to virtually any commercial vessel over 5,000 gt. Operators with ships calling to EEA ports have already been required to prepare a mandatory monitoring plan by 31 August 2017, which must be verified by 31 December 2017.
What should an owner do when a vessel is sent to a European port on a one-off voyage after 1 January 2018?
The vessel will not have a monitoring plan that has been verified and it is unlikely that the crew and shore staff will have been collecting the required data. What can be done about the data that is required to be collected during the voyage?
In short, part of the answer is written into the EU regulation itself. Any owner, or operator responsible for making sure that a ship remains compliant with regulations, has two months, after the first call at a European port, to comply with the requirement to submit a monitoring plan.
This is what the regulation states:
“For ships falling under the scope of this Regulation for the first time after 31 August 2017, the company shall submit a monitoring plan to the verifier without undue delay and no later than two months after each ship’s first call in a port under the jurisdiction of a Member State”.
Clearly, voyage monitoring may have started before the approval of a monitoring plan, but approval certainly needs to be obtained prior to the verification of the report, which will be annual, regardless of how many voyages are made.
What needs to be monitored?
Under the rules, these are the items that need to be monitored:
- Ports of call
- Amount, and emission factors, of each type of fuel consumed during the relevant voyage
- CO2 emitted
- Distance travelled
- Time spent at sea
- Cargo carried
- Transport work
The Master has ultimate responsibility for monitoring a ship’s bunker consumption and for reporting the data to the office, as set by the company’s procedures. The Chief Engineer is responsible for overall bunker operations, including the verification of bunkers received, the sounding of the bunker tanks and calculation of the exact quantity of bunkers on board.
The data, like the monitoring plan, must be verified by an approved body, and then sent to the database of the EMSA. For the 2018 reporting period, this needs to be done in the first months of 2019.
It is also important to remember that the systems used to record the required data must be verified, approved, and entered into the report, even if you are making a one-off voyage.
This is just one of the many reasons why it makes sense to use an approved system from Marorka for your routine voyage optimization. Marorka’s systems can also be used as part of your ad-hoc MRV compliance requirements, and for the IMO’s own data collection needs which will start in a little over a year.
Automation can ease, simplify and optimize across the board.