serious and unreasonable threat of harm to the marine environment, then the
detention of the ship may be warranted. The following deficiencies are listed in
sec. 2.3.2 of MEPC.181(59) as indicative grounds for detention:
• Absence of a valid IAPP Certificate, EIAPP Certificates or Technical Files;
• A marine diesel engine that is not compliant with the NOx emission limit;
• A marine diesel engine (more than 5000 kW and a per cylinder displacement at or
above 90 L), with certified Approved Method, but for which an Approved
Method is not installed;
• A marine diesel engine that is not compliant with the SOx limit;
• Non-compliance with SOx and particulate matter control requirements while in
an ECA;
• A non-compliant incinerator installed on board ship; and
• Master or crew unfamiliar with essential procedures regarding operation of air
pollution prevention equipment.
65
In Appendix 2, Resolution A.1119(30) adds the following two to this indicative
list:
• Absence of a valid IEEC (International Energy Efficiency Certificate); and
• Absence of a Ship Energy Efficiency Management Plan (SEEMP).
66
To provide a focused demonstration of how Annex VI might be implemented by
port state authorities, the Paris MoU on Port State Control and the Tokyo MoU on
Port State Control held the Joint Concentrated Inspection Campaign (CIC) on
MARPOL Annex VI from 1 September to 30 November 2018. The CIC set out to
determine the level of MARPOL Annex VI compliance within shipping, increase
awareness in the industry as to the importance of compliance, inform shipping of the
significant position that the matter occupies on the agenda of member states of both
MoUs, and “underline the responsibility of the Port State Control regime with
regards to harmonised enforcement of compliance with the requirements of
MARPOL Annex VI, thus improving the level of compliance and ensuring a level
playing field.”
67
While the Paris MoU has yet to release the preliminary results of their part of the
joint CIC, the Tokyo MoU has already some of theirs. Of the total of 6604 ships
inspected by Tokyo MoU member states during the CIC some 176 ships (2.14%)
ended up being detained, whereof 4 (0.06%) were a direct result of the CIC.
Panamanian ships made up 1817 or 27.51% of the inspections, while there were
649 Hong Kong ships (9.86%), 620 Marshall Islands ships (9.39%), and 620 Liberian ships (9.39%). The most notable deficiencies found during the campaign were
related to maintenance of the ozone-depleting substances record book (121 deficiencies, i.e., 1.83%), availability of bunker delivery notes (118 deficiencies, i.e.,
65 IMO (2009).
66 IMO (2017).
67 Paris MoU on PSC & Tokyo MoU on PSC (2018).
538
M. Q. Mejia, Jr.
detention of the ship may be warranted. The following deficiencies are listed in
sec. 2.3.2 of MEPC.181(59) as indicative grounds for detention:
• Absence of a valid IAPP Certificate, EIAPP Certificates or Technical Files;
• A marine diesel engine that is not compliant with the NOx emission limit;
• A marine diesel engine (more than 5000 kW and a per cylinder displacement at or
above 90 L), with certified Approved Method, but for which an Approved
Method is not installed;
• A marine diesel engine that is not compliant with the SOx limit;
• Non-compliance with SOx and particulate matter control requirements while in
an ECA;
• A non-compliant incinerator installed on board ship; and
• Master or crew unfamiliar with essential procedures regarding operation of air
pollution prevention equipment.
65
In Appendix 2, Resolution A.1119(30) adds the following two to this indicative
list:
• Absence of a valid IEEC (International Energy Efficiency Certificate); and
• Absence of a Ship Energy Efficiency Management Plan (SEEMP).
66
To provide a focused demonstration of how Annex VI might be implemented by
port state authorities, the Paris MoU on Port State Control and the Tokyo MoU on
Port State Control held the Joint Concentrated Inspection Campaign (CIC) on
MARPOL Annex VI from 1 September to 30 November 2018. The CIC set out to
determine the level of MARPOL Annex VI compliance within shipping, increase
awareness in the industry as to the importance of compliance, inform shipping of the
significant position that the matter occupies on the agenda of member states of both
MoUs, and “underline the responsibility of the Port State Control regime with
regards to harmonised enforcement of compliance with the requirements of
MARPOL Annex VI, thus improving the level of compliance and ensuring a level
playing field.”
67
While the Paris MoU has yet to release the preliminary results of their part of the
joint CIC, the Tokyo MoU has already some of theirs. Of the total of 6604 ships
inspected by Tokyo MoU member states during the CIC some 176 ships (2.14%)
ended up being detained, whereof 4 (0.06%) were a direct result of the CIC.
Panamanian ships made up 1817 or 27.51% of the inspections, while there were
649 Hong Kong ships (9.86%), 620 Marshall Islands ships (9.39%), and 620 Liberian ships (9.39%). The most notable deficiencies found during the campaign were
related to maintenance of the ozone-depleting substances record book (121 deficiencies, i.e., 1.83%), availability of bunker delivery notes (118 deficiencies, i.e.,
65 IMO (2009).
66 IMO (2017).
67 Paris MoU on PSC & Tokyo MoU on PSC (2018).
538
M. Q. Mejia, Jr.