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Scrubbers are an accepted equivalent measure from compliance with thee IMO 2020 sulphur cap. Scrubbers have divided the shipping industry, while ports around are analyzing their impact in their waters.


In the latest development, MPA Singapore will ban the discharge of wash water from open-loop scrubbers, as from January 1, 2020. The ban is part of the MPA’s attempt to prepare the port ahead of the 2020 sulphur cap.


In order to facilitate the implementation of the ban, Singapore will provide facilities to collect the residue generated from the operation of scrubbers.


As of now, several ports and regions have stated that they will not allow the discharge of wash water from scrubbers.

According to the North Club, the following ports have or will prohibit the use of scrubbers, or have placed conditions on their use:


  • Belgium: Belgium states that discharge is only allowed in coastal and open seawaters when at least 3nm off coast. Discharges must not violate EU Water Framework Directive objective, while Flemish regional law also confirms that discharge is not allowed in ports or inland waters.


  • Germany: EGCS discharge is not allowed in inland waterways, canals and ports within inland waterways.


  • Ireland: EGCS discharge is not allowed in Dublin.


  • Latvia: Here the information are not clear. According to the European Commission Report in 2016, EGCS discharge is allowed. But national authorities are of the position that open-loop scrubber discharge should be prohibited in territorial waters and ports. What is more, an ABS report from 2018 says that the discharge is prohibited in port waters. Nevertheless, Pandi Balt Ltd advised in 2018 that discharges are currently allowed under regulations but they could be prohibited in future.


  • Lithuania: The situation here resembles Latvia’s. Lithuanian authorities are examining whether scrubbers wash water discharges have serious impacts on the marine environment or not. When results will be clear, conclusions will be provided.


  • US: EGCS discharge is not allowed in Californian Ports and waters; and Connecticut Ports and waters. The discharge is allowed under conditions in Hawaii Ports and waters.


  • UAE: EGCS discharge is allowed under conditions at Abu Dhabi Ports.


  • Singapore: EGCS discharge is not allowed.


  • China: International sources report that China is possible to ban open-loop scrubbers along its rivers.



A recent Malaysian Marine Department declaration foresees an alteration to the Port Limits for Johore Bahru Port, extending the limits of the port in its southernmost state and encroaching the territorial waters of Singapore. In response, MPA of Singapore said it does not recognise the Port Limits published and reminded operators that Singapore’s territorial waters extend westward of Singapore’s current port limits around Tuas and vessels operating in this area are to continue to comply with applicable Singapore regulations.







Namely, the Gazette Notification, by the Attorney General’s Chambers of Malaysia is to extend the port limits for Malaysia’s Johor Bahru Port in a way which encroaches into Singapore’s territorial waters and approaches to the Port of Singapore off Tuas. Accordingly, MPA does not recognize the port limits published in the Gazette Notification.  


The Swedish Club informs that by 1 January 2019 there will be a supplementary IMSCB (International Maritime Solid Bulk Cargoes Code) for coal. Namely, coal will not only be categorized as a chemical hazard cargo (Group B) but will also fall into Group A (liquefaction).

For a Group A cargo TML and FMP always need to be established by the shipper and provided to the vessel according with the Code before loading.

However, if the particles are large enough to prevent liquefaction, then they will not be a Group A cargo. Nevertheless, it may be difficult to get within the exception. In fact, no more than 10% can be less than 1 mm and no more than 50% can be less than 10 mm. For this reason, both criteria must be met.

Additionally, without a cargo certificate showing particle distribution that meets the criteria, then operators would return to the starting point of coal automatically being a Group A cargo, requiring TML and FMP to be established for safe loading.

This means that the ship should:

  • Either receive (i) a cargo certificate that meets the criteria for the exception; or
  • Be handed a ‘TML certificate’.

Without one of the two documents, loading cannot begin. In addition to time being lost, ships could stay on-hire, and the Time Charterers could claim against Voyage Charterers and they will in turn claim against Shippers. In order to testing coal for TML, the use of a modified Proctor/Fagerberg procedure is needed.


Along with a major focus on the regulatory scoping exercise for autonomous ships, the landmark 100th session of IMO’s Maritime Safety Committee (MSC 100) held on 3-7 December, pushed further regulatory work on shipping safety, with the adoption of amendments to the SPS Code and the STCW Code, as well as the approval of draft amendments and guidelines.

Adoption of amendments


The MSC adopted Amendments:


  • To the Code of Safety for Special Purpose Ships (SPS Code), including a revised chapter 8 on life-saving appliances; a requirement for special purpose ships to comply with the provisions of chapter IV of SOLAS; and a revised Form of Safety Certificate for Special Purpose Ships and Record of Equipment for Special Purpose Ship Safety Certificate (Form SPS).


  • To sections B-V/a, B-V/b, B-V/c, B-V/d, B V/e, B V/f and B-V/g of the STCW Code, which relate to consequential amendments following earlier amendments to the STCW Convention and Code relating to the Polar Code.


Draft amendments to the 2011 ESP Code forwarded to MSC 101


The Committee decided to hold in abeyance the adoption of amendments to update the International Code on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers, 2011 (2011 ESP Code), pending further work on the new consolidated Code by the Sub-Committee on Ship Design and Construction (SDC 6), which is expected to be adopted by the IMO Assembly at its 31st session.



Approval of draft amendments


The MSC also approved draft amendments:


  • To the International Code for the Construction and Equipment of Ships carrying Dangerous Chemicals in Bulk (IBC Code), with a view to subsequent adoption. The draft amendments include draft revised chapters 17 (Summary of minimum requirements), 18 (List of products to which the Code does not apply), 19 (Index of products carried in bulk) and 21 (Criteria for assigning carriage requirements for products subject to the IBC Code), as well as draft new paragraph 15.15 (Hydrogen sulphide (H2S) detection equipment for bulk liquids). Further amendments are consequential to draft amendments to MARPOL Annex II. Associated amendments to the BCH Code were approved for adoption in conjunction with the adoption of the above IBC Code amendments.
  • To forms C, E and P of the appendix to SOLAS 1974, for consistency throughout the forms contained in the appendix.
  • To the International Life-Saving Appliance (LSA) Code regarding manual launching of a rescue boat (paragraph having a mass not more than 700 kg in fully equipped condition and which is not one of the ship’s survival craft, allowing manual hoisting from the stowed position and turning out to the embarkation position by one person so that persons can be safely embarked.
  • To the LSA Code regarding a lifeboat with two independent propulsion systems (paragraph providing a flexibility for the requirement of sufficient buoyant oars and their related items to make headway in calm seas.
  • To paragraph 2.2 of chapter 15 of the FSS Code, aiming to provide a unified understanding of arrangements for inert gas lines and related indicators and alarms for monitoring the pressure of the inert gas mains.
  • To the International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code).


Approval of guidance and guidelines


The MSC approved:


  • 1/Circ.1430/Rev.1 on the Revised guidelines for the approval of fixed water-based fire-fighting systems for ro-ro spaces and special category spaces (to update the guidelines in MSC.1/Circ.1430). The revision relates in particular to the position of sprinklers or nozzles, to ensure adequate performance, and to reliable control of fixed water-based fire-fighting systems.
  • Instructed relevant sub-committees to consider relevant parts of the draft interim guidelines for the safety of ships using methyl/ethyl alcohol as fuel prepared by CCC 5. The detailed interim guidelines provide requirements for the arrangement, installation, control and monitoring of machinery, equipment and systems using methyl/ethyl alcohol as fuel to minimize the risk to the ship, its crew and the environment, taking into account to the nature of the fuels involved.
  • Interim guidelines on the application of high manganese austenitic steel for cryogenic service. The interim guidelines are aimed at ensuring the safety of ships carrying or fueled by LNG, by specifying the requirements for the utilization of high manganese austenitic steel in the design and fabrication of cargo and fuel tanks complying with the International Gas Carrier (IGC) and IGF Codes.
  • Interim guidance for conducting the refined MHB (CR) corrosivity test related to draft amendments to section of the IMSBC Code concerning test for metals.
  • New Global Counter Piracy Guidance, updated Gulf of Guinea Guidance, and BMP 5, and issued the suite of guidance as a new MSC circular on Revised Industry Counter Piracy Guidance.

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