AUTORIDAD MARÍTIMA DE PANAMÁ F-410
(PANAMÁ MARITIME AUTHORITY) (DCCM)
DIRECCIÓN GENERAL DE MARINA MERCANTE V.00
(GENERAL DIRECTORATE OF MERCHANT MARINE)
DEPARTAMENTO DE CONTROL Y CUMPLIMIENTO
(DEPARTMENT OF CONTROL AND COMPLIANCE)
Merchant Marine Notice
Summary on Local Restrictions available
for Discharging Washwater From Exhaust Gas Cleaning System
No.: MMN-09/2019 November, 2019
1. Purpose
To advise ship-owners/operators, company security officers, legal representatives of Panamanian
flagged vessels, Panamanian merchant marine consulates and recognized organizations and other clients
to monitor the situation closely and ensure that crews’ onboard vessels fitted with open loop scrubbers
are made aware of any relevant local discharge requirements in force. As a precautionary measure, it is
advised that vessels with open loop scrubbers installed, approach the local agents for detailed up to date
requirements on the discharge of scrubber washwater as part of a vessel’s voyage planning.
2. Summary
According to MARPOL Annex VI regulation 4, exhaust gas cleaning systems may be allowed by
flag Administrations as compliance methods acceptable as alternative to reduce vessels’ sulphur
emissions and ensuring compliance with MARPOL Annex VI regulation 14. Therefore a separate
guideline, Resolution MEPC.259(68), indicate the requirements for the verification, testing, survey
and certification of EGCS and sets out the criteria for discharging its washwater into the sea.
Some coastal and ports states have implemented more stringent requirements contained in local
regulations restricting or completely prohibiting the discharge of washwater from EGCS open loop
type or prohibit its use at all. Some of these regions/states/ports with local regulations are as
follows:
Country Policy Summary
Australia Discharge of washwater from open
loop scrubbers have not been imposed
by any state.
Belgium The European Prohibit the discharge in ports and
Commission’s 2016 note on inland waters.
discharge of scrubber
washwater.
Bermuda Environmental Policy for Open loop EGCS not permitted nor
Ships washwater and residues. Use of
closed loop EGCS required
permission from the authorities
China ‘Notice on Regulating the From 1 January 2019 discharge of
Implementation of washwater from EGCS is prohibited
Supervision and Management in the county’s inland emission
of Ship Air Pollutant control areas (ECAs), port water
Emission Control Areas’ areas of coastal domestic ECAs and
From China’s Ministry of Bohai Bay waters.
Transport (MOT) From 1st January 2020, the wash
water of open-loop exhaust gas
cleaning systems should not be
discharged into waters of DECAs.
Ban on the discharge of washwater
be extended to within 12nm of
baseline of China´s territorial sea and
regions near the southern island
province of Hainan.
Germany Articles 1 and 3 of the CDNI Discharge is not allowed in inland
Convention (Convention on waterways and the Rhine.
the Collection, Deposit and
Reception of Waste Produced
during Navigation on the
Rhine and Inland
Waterways).
Hong Kong For details of the exemption Hong Kong authorities shall be
application process, please requested for an exemption from
refer to Sections 7 to 11 of the using compliant fuel. The exemption
new ‘Air Pollution Control application must be made at least 14
(Fuel for Vessels) days prior to a ship’s first visit to
Regulation’. Hong Kong after 1 January 2019.
India DG Engineering Circular 02 EGCS washwater discharges are
of 2019, allowed if the criteria set out
in MEPC.259(68) are met.
Local restrictions will be imposed in
some areas, please verify prior
arrival.
Ireland
Dublin Notice No. 37 of 2018 form Discharge of washwater is prohibited
The Irish authority in waters under Dublin port
jurisdiction. Dublin port jurisdiction
includes waters from the Matt Talbot
Memorial Bridge eastwards to a line
from the Baily Lighthouse through
the North and South Burford buoys
and through Sorrento Point.
Waterford ‘Prohibition on the Discharge EGCS washwater discharge is
of Exhaust Gas Scrubber prohibited in port limits from the
Wash Water’ from Port of start of January 2019.
Waterford
Cork No. 15 of 2018 – Port Notice Discharge of scrubber washwater is
prohibited in port waters.
Latvia European Commission’s 2016 Discharge is not allowed in territorial
note and port waters.
Lithuania European Commission’s 2016 Discharge is not allowed in port
note on discharge of scrubber waters, according to port rules and
washwater conditions of use approved by the
Ministry of Transport.
Malaysia Prohibited the use of open-loop
EGCS. Ships are banned from
releasing washwater from open-loop
EGCS while operating in Malaysian
waters.
Norway 1 March 2019 amendments of Open loop EGCS is prohibited in the
Regulation No.488 on the Norwegian fjords. Also, for ships
environmental safety of ships using closed or hybrid type
and mobile offshore units. scrubbers, a device for reducing
visible emissions to air is required.
Panama Canal waters Notice to Shipping No. 01 of Discharging EGCS washwater into
2019 bodies of water under the
responsibility of Panama Canal is not
permitted. Use of closed loop
systems is permitted.
Singapore Maritime and Port Authority Discharge is prohibited in Singapore
of Singapore (MPA) port waters from 1 January 2020.
Ships fitted with open loop scrubbers
to must switch to either closed-loop
mode or to compliant fuel well in
advance of the vessel’s arrival at the
port waters. Residues from scrubbers
have been classified as toxic
industrial waste under Singapore’s
Environmental Public Health (Toxic
Industrial Waste) Regulations. It can
only be collected by licensed Toxic
Industrial Waste Collectors.
South Africa Marine Notice no. 08 of 2019, All EGCS Types are allowed, wash
water discharge shall be according to
IMO guidelines. However this
position should be verified.
UAE
Abu Dhabi 2013 Abu Dhabi authorities EGCS washwater can be discharged
issued ‘Vessel Discharge and in port waters if free form pollutants
Maintenance Guidelines For whilst scrubber sludge should be
Owners, Masters And discharged from the vessel to an Abu
Agents’. Dhabi Ports Company (ADPC)
licensed waste disposal contractor.
Fujairah Fujairah has decided to ban the use
of open-loop scrubbers in its waters.
USA
Hawaii Conditional section 401 WQC Allows for discharge of washwater
(Water Quality Certification) subject to certain requirements being
section 6.7 of 2013 VGP fulfilled. (Requirements included in
the same section)
Connecticut section 6.5.9[UK1] of the Specific conditions have been
2013 VGP established. Vessel General Permit
CGS section 22a-427, and (VGP) requirements. Discharge of
Connecticut Water Quality EGCS washwater into Connecticut
Standards (CT WQS). waters from any vessel covered
under the VGP is prohibited.
California The CARB OGV (California Do not permit the use of abatement
Air Resource Board for technologies such as EGCS thus; any
Ocean Going Vessels) discharge of washwater is prohibited.
Vessel discharge regulations Long Beach state prohibited the
for Port of Long Beach discharge washwater from EGCS in
Marine Notice 2017-1 port waters. Discharge is only
(temporary Research permit) permitted if the vessel has a
temporary research or experimental
permit.
3. Recommendations
Considering the different regulations imposed by coastal states and ports, and future
discussions on EGCS, it is recommended to contact your local agency to obtain updated
information well in advance of the ships’ entering the areas with prohibition or restrictions
in places including washwater discharge. Ship’s operators should observe options to ensure
compliance with the sulphur limits, for example:
use compliant fuel instead of open loop scrubbers; or
Switch over to closed loop mode of operation, in which case it will be necessary to convert
currently installed open loop systems to closed loop or hybrid systems, if not already done.
November, 2019
Inquiries concerning the subject of this Circular or any other request should be directed to:
Segumar Panama.
Directorate General of Merchant Marine
Panama Maritime Authority
Phone: (507) 501-5348/5350
E-mail:
[email protected]PanCanal Building
Albrook, Panama City
Republic of Panama
Tel: (507) 501-5355 [email protected]
