REPUBLIC OF Marine Notice

THE MARSHALL ISLANDS

No. 2-013-8
OFFICE OF THE
MARITIME ADMINISTRATOR Rev. 12/08

TO: ALL SHIPOWNERS, OPERATORS, MASTERS AND OFFICERS OF

MERCHANT SHIPS, AND RECOGNIZED ORGANIZATIONS

SUBJECT: Implementation of MARPOL Annex VI, Regulations for the Prevention of Air
Pollution from Ships.

References: (a) MARPOL Annex VI

(b) MEPC.1/Circ.614
(c) MEPC.1/Circ.509
(d) MEPC.1/Circ.637
(e) NOx Technical Code
(f) Marine Notice No. 2-011-11
(g) MEPC.59(33) as amended by MEPC.92(45)
(h) MEPC.76(40) as amended by MEPC.93(45)

PURPOSE:

The Marshall Islands is a signatory to MARPOL Annex VI, which came into force 19 May
2005. Annex VI sets limits on ship sulphur oxide (SOx) and nitrogen oxide (NOx) emissions. It also
regulates volatile organic compounds (VOCs), specifies fuel oil quality standards and prohibits
deliberate emissions of ozone depleting substances and incineration of certain products on board
ships. The purpose of this notice is to detail these air emissions requirements, with which Marshall
Islands-flagged ships must comply.

This Notice supersedes Rev. 10/06.

APPLICABILITY:

MARPOL Annex VI applies to all ships -- a vessel of any type operating in the marine
environment, including hydrofoil boats, air-cushion vehicles, submersibles, floating craft, and fixed
or floating platforms except:

(a) Where expressly provided otherwise in Regulations 3, 5, 6, 13, 15, 18 and 19 of

Annex VI;

(b) Any emission necessary for securing the safety of a ship or saving life at sea;

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Inquiries concerning the subject of this Notice should be directed to the Office of the Maritime Administrator, Republic of the Marshall
Islands, c/o Marshall Islands Maritime and Corporate Administrators, Inc., 11495 Commerce Park Drive, Reston, VA 20191-1507 USA.
MI-01, 8/06
 (c) Any emission resulting from damage to a ship or its equipment, provided all
reasonable precautions have been taken to prevent or minimize the emission, except
where an owner/master acted with intent to cause damage or acted recklessly,
knowing damage would probably result; and

(d) Emissions directly arising from the exploration, exploitation and associated offshore
processing of sea-bed mineral resources.

REQUIREMENTS:

1.0 Requirements for Control of Emissions

The following emissions from ships must be addressed:

1.1 Ozone-Depleting Substances (Annex VI, Regulation 12)

1.1.1. Ozone-depleting substances means controlled substances defined in paragraph 4 of article 1

of the Montreal Protocol on Substances that Deplete the Ozone Layer, 1987, listed in
Annexes A, B, C or E to the said Protocol in force at the time of application or interpretation
of this annex. Ozone-depleting substances that may be found on board ship include, but are
not limited to:

• Halon 1211 Bromochlorodifluoromethane

• Halon 1301 Bromotrifluoromethane
• Halon 2402 1,2-Dibromo-1,1,2,2-tetrafluoroethane (a/k/a Halon 114B2)
• CFC-11 Trichlorofluoromethane
• CFC-12 Dichlorodifluoromethane
• CFC-113 1,1,2-Trichloro-1,2,2-trifluoroethane
• CFC-114 1,2-Dichloro-1,1,2,2-tetrafluoroethane
• CFC-115 Chloropentafluoroethane

1.1.2. Deliberate emissions of ozone-depleting substances, including emissions that occur in the
course of maintenance, service, repair or disposal of systems or equipment, are prohibited.
Minimal releases from the recapture or recycling of ozone-depleting substances are not
considered deliberate releases.

1.1.3. New installations 1 containing ozone depleting substances are prohibited, except new
installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until 1 January
2020. See Marshall Islands Marine Notice 2-011-11, Systems Using Halogenated
Hydrocarbons (Halons) and Other Ozone Depleting Substances (reference (f)).

1.1.4. Use of appropriate reception facilities for disposal of equipment containing ozone-depleting
substances is required.

1 New installations means the installation of systems, equipment, including new portable fire-extinguishing units,
insulation, or other material on a ship after 19 May 2005, but excludes repair or recharge of the aforementioned
previously installed.

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1.2 Nitrogen oxides (NOx) (Annex VI, Regulation 13)

1.2.1 The operation of a marine diesel engine is prohibited, unless it complies with the NOx
emission limits and requirements specified in Regulation 13 of Annex VI. This regulation
applies to any ship, irrespective of tonnage, with a diesel engine that has a power output
greater than 130 kW, if the diesel engine:

• Is installed on a ship constructed on or after 1 January 2000; or

• Undergoes a major conversion 2 on or after 1 January 2000.

1.2.2 This regulation does not apply to:

• Emergency diesel engines, engines installed in lifeboats and devices or equipment used
solely for emergency; or
• Engines subject to alternative NOx control measures established by an Administration
for vessels solely engaged in voyages within waters subject to the jurisdiction of the
State the flag of which the ship is entitled to fly.

1.2.3 The operation of a marine diesel engine is permitted when an exhaust gas cleaning system or
other equivalent method approved by a Recognized Organization (RO) on behalf of the
Administration is applied to the engine to reduce onboard NOx emissions to the established
limits.

1.3 Sulphur oxides (SOx) (Annex VI, Regulation 14)

1.3.1 The sulphur content of any fuel oil used on board a ship shall not exceed 4.50% m/m 3 and
must be documented by the bunker supplier as required (Annex VI, Regulation 18).

1.3.2 SOx Emission Control Areas (SECAs) are designated areas where ships must take special
measures to control SOx emissions. To date, two SECAs have been designated. They are:

• Baltic Sea area (defined in Regulation 1 (11.2), MARPOL Annex I); and
• North Sea area (defined in Regulation 5(1)(f), MARPOL Annex V).

.1 Ships within a SECA must comply with either (a) or (b), below:

(a) Use fuel oil with a sulphur content not exceeding 1.50% m/m as documented
by the bunker supplier (Annex VI, Regulation 18). Prior to entering an
SECA, ships using separate fuel oils to comply with option (a) must:

1) Fully flush fuel oil systems of oils exceeding 1.50% m/m sulphur content.

2 A major conversion means a modification of an engine where: a) The engine is replaced by a new or additional
engine built on or after 1 January 2000; or b) Any substantial modification, as defined in the NOx Technical Code, is
made to the engine, or c) The maximum continuous rating of the engine is increased by more than 10%.

3 As amended pursuant to MEPC.1/Circ.614, 15 April 2008.

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 2) Include procedures for change-over from high sulphur fuel oil to low
sulphur fuel oil in ship’s ISM documentation (Chapter 7: Plans for
Shipboard Operation). The procedures should address safety concerns
and apply guidance established by the ROs and as provided in Annex 1 of
this Notice.

3) Record in the engineering log-book and in the MARPOL Annex VI

Record the following information after each change-over:

• Volume in each tank of low sulphur fuels (≤ 1.5% sulphur content);

• Date;
• Time; and
• Position of ship during completion of fuel change-over operation.

A sample changeover recording form, Low Sulphur Fuel Oil Changeover

Completion Form, is provided in Annex 2 of this Notice.

(b) Apply an exhaust gas cleaning system or other verifiable and enforceable
technological method to reduce the total emissions (including from both
auxiliary and main propulsion engines) to 6.0g SOx/W·j or less, calculated as
the total weight of sulphur dioxide emissions. The system must be approved
by an RO on behalf of the Administration.

Discharge of waste streams from such equipment is prohibited in ports,

harbors and estuaries, unless thoroughly documented that there is no adverse
impact on ecosystems based on criteria reported by the Port State to the IMO.

1.4 Volatile Organic Compounds (VOCs) (Annex VI, Regulation 15)

1.4.1 VOC emissions requirements apply to tankers 4 . Gas carriers must comply with the
requirements only if their loading and containment systems allow safe retention of non-
methane VOCs on board, or their safe return ashore.

1.4.2 IMO intends to provide, through MEPC circulars, a listing of ports and terminals where
VOCs are controlled 5 . Tankers subject to vapor emissions control must be fitted with a
vapor collection system approved by an RO on behalf of the Administration taking into
account MSC/Circ.585, within three (3) years after a port/terminal has notified IMO of its
regulation of tanker VOC emissions.

4 Tanker means an oil tanker as defined in regulation 1(4) of Annex I or a chemical tanker as defined in regulation 1(1) of
Annex II of the present Convention.

5 Per MEPC.1/Circ.509, 9 May 2006.

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1.5 Shipboard Incineration (Annex VI, Regulation 16)

1.5.1 Shipboard incineration is allowed only in a shipboard incinerator.

1.5.2 Incineration of the following substances is prohibited:

• Annexes I, II and III cargo residues of the present MARPOL Convention and related
contaminated packing materials;
• Polychlorinated biphenyls (PCBs);
• Garbage, as defined in Annex V of the present MARPOL Convention containing more
than traces of heavy metals; and
• Refined petroleum compounds containing halogen compounds.
• Polyvinyl Chlorides (PVCs), unless incinerated in shipboard incinerators certified under
Resolutions MEPC.59(33), Revised Guidelines for the Implementation of Annex V of
MARPOL 73/78, or MEPC.76(40), Standard Specification for Shipboard Incinerators.

1.5.3 Shipboard incineration of sewage sludge and sludge oil 6 generated during normal operations
is allowed in the main or auxiliary power plant or boilers, but shall not take place inside
ports, harbors and estuaries.

1.5.4 An incinerator installed after 1 January 2000 must meet the requirements of Annex VI,
Appendix IV, Type Approval & Operating Limits for Shipboard Incinerators, and must be
approved by an RO on behalf of the Administration taking into account IMO Resolution
MEPC 76(40), Standard specification for shipboard incinerators, and amendments to these
specifications contained in resolution MEPC.93(45).

Ships must possess a manufacturer’s operating manual that provides guidance in incinerator
operations within the prescribed limits. Personnel with responsibilities for incinerator
operations must be trained and capable of implementing the guidance provided in the
manual.

1.5.5 Monitoring incinerator flue gas temperature is required at all times.

• For a continuous-feed incinerator7 : waste shall not be fed when the temperature is below
850 degrees C.
• For a batch-loaded incinerator: the unit shall be designed so that the temperature in the
combustion chamber reaches 600 degrees C within five (5) minutes of start-up.

1.5.6 Development, installation and operation of alternative thermal waste treatment devices that
meet or exceed the requirements of this regulation are allowable.

6 Sludge oil means sludge from the fuel or lubricating oil separators, waste lubricating oil from main or auxiliary
machinery, or waste oil from bilge water separators, oil filtering equipment or drip trays.

7 Continuous feeding is defined as the process whereby waste is fed into a combustion chamber without human assistance
while the incinerator is in normal operating conditions with the combustion chamber operative temperature between
850°C and 1200°C.

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2.0 Fuel Oil Quality (Annex VI, Regulation 18)

2.1 Fuel oil delivered to and used onboard any ship to which Annex VI applies must meet the
standards of Regulation 18 which address the composition of hydrocarbons to be used for
combustion purposes.

2.2 Fuel oil for combustion purposes derived from methods other than petroleum refining must
meet the standards for of Regulation 18 regarding their composition, must not exceed the
sulphur content requirements set forth in Regulation 14, and must not cause an engine to
exceed the NOx emission limits set forth in Regulation 13.

2.3 The fuel oil quality standards do not apply to coal in its solid form or nuclear fuels or to the
use of hydrocarbons for platforms and drilling rigs which are produced and subsequently
used on site as fuel, when approved by the Administration.

3.0 Bunker Delivery Notes & Fuel Oil Samples

3.1 For every ship of 400 grt and above and every fixed and floating drilling rig and other
platform, details of fuel delivered for combustion purposes shall be recorded by means of a
Bunker Delivery Note. The note must include (per MARPOL Annex VI, Appendix V), at a
minimum, the following information:

• Name and IMO number of receiving ship:

• Port;
• Date of commencement of delivery;
• Name, address, and telephone number of marine bunker supplier;
• Product name(s);
• Quantity (metric tons);
• Density at 15º C (kg/m3) -- tested in accordance with ISO 3675; and
• Sulphur content (% m/m) -- tested in accordance with ISO 8754.

3.2 Bunker Delivery Notes:

• Shall be kept on board in the MARPOL Annex VI Record and be readily available for
inspection;
• Shall be retained for a period of three (3) years after the fuel has been delivered on
board; and
• Are subject to inspection by port State control authorities as well as officers of this
Administration.

3.3 Upon completion of the bunkering operations, a representative sample of the fuel oil
delivered must accompany the Bunker Delivery Note. When obtaining representative
samples under MARPOL Annex VI, Resolution MEPC 96(47) entitled, Guidelines for the
Sampling of Fuel Oil for Determination of Compliance with Annex VI of MARPOL 73/78,
may be considered. The sample must be:

• Sealed and signed by bunker supplier’s representative;

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 • Sealed and signed by master or officer in charge of bunker operations;
• Retained under ship’s control until the fuel oil is substantially consumed, but not less
than 12 months from time of delivery; and
• Analyzed in accordance with the verification procedure set forth in the appendix to
MEPC.1/Circ.614 entitled, Fuel Oil Verification Procedure for MARPOL Annex VI
Fuel Oil Samples, should the Administration require such an analysis.

3.4 If a Bunker Delivery Note or representative sample is not provided by the bunker supplier or
fuel oil is found not to be in compliance with that stated on the Bunker Delivery Note, details
shall be recorded in the ship’s log, and the Administration shall be notified at:

Investigations
Republic of the Marshall Islands
Office of the Maritime Administrator
11495 Commerce Park Drive
Reston, Virginia 20191-1507 USA
Tel: 703-620-4880
Fax: 703-476-8522
Email:investigations@register-iri.com

3.5 Due to reports of difficulties experienced in some areas in obtaining compliant fuel oil for
operation within a SECA, the IMO has adopted the early implementation of certain
principles of Regulation 18.2 of the revised MARPOL Annex VI. Although the revised
Regulation 18 will not enter into force until 1 July 2010, if a ship, despite all best efforts, is
unable to obtain the required fuel oil to meet SECA emission requirements, then the
principles of the revised Regulation 18.2 may be applied early, in accordance with
MEPC.1/Circ.637, effective from 16 October 2008. As application of MEPC.1/Circ.637
may not be recognized or uniformly implemented early by all Parties, prompt notification, as
required to the Marshall Islands Administration and the relevant Port State authorities is
strongly recommended in order to determine the most appropriate course of action.

4.0 Surveys and Certificates

4.1 Every ship of 400 grt and above and every fixed and floating drilling rig and other platform
are subject to initial, annual, intermediate, renewal and additional surveys to establish
compliance with the Annex VI air emissions requirements. Upon successful completion of
the appropriate survey, an International Air Pollution Prevention Certificate (IAPPC) shall
be issued by the RO.

4.2 Each engine installed on a ship, irrespective of tonnage, to which Regulation 13 applies shall
be subject to survey and certified with an Engine International Air Pollution Prevention
Certificate (EIAPPC), in accordance with the NOx Technical Code.

4.3 Prior to entry into force of Annex VI, the ROs were authorized to issue a ‘Statement of
Compliance’, upon satisfactory completion of the pre-certification requirements of the NOx
Technical Code, to each engine that would become subject to the provisions of Regulation
13 upon its entry into force. Such a Statement of Compliance was intended as an interim

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 measure pending issuance of the EIAPPC and/or IAPPC. Therefore, the RO is authorized by
the Administration to replace any Statements of Compliance with corresponding EIAPP
certificates upon completion of the Initial Survey for issuance of a full term IAPP certificate.

4.4 Express approval of the Administration is needed for any changes/alternatives in the
equipment, systems, fittings, arrangements or material covered by a survey. Approval for a
change/alternative will be granted, provided that the ship’s RO confirms to the
Administration that the change/alternative is at least as effective as that required by Annex
VI. The Administration will subsequently notify IMO of any such approvals. Direct
replacement of such equipment and fittings that conform with Annex VI is permitted.

4.5 A new IAPPC is required upon transfer of the ship to the Marshall Islands flag. A new
IAPPC shall be issued only when the RO or a representative acting on behalf of the
Administration is fully satisfied that the ship is in compliance with the requirements of this
Annex.

4.6 Whenever an accident occurs or a defect is discovered that affects the efficiency or
completeness of equipment, the master or ship owner, must:

• Report this information, at the earliest opportunity, to the Administration or RO

responsible for issuing the relevant certificate; and
• Establish a corrective action plan acceptable to the Administration or RO.

5.0 Recordkeeping

5.1 A MARPOL Annex VI Record, to be retained in the custody of the chief engineer, must be
established and maintained for the purpose of filing:

• The Engine Technical Files;

• The Record Book of Engine Parameters, when the Engine Parametric Check Method is
employed;
• The duplicate entries of the SOx fuel changeover record from the engineering log book;
• Bunker Delivery Notes; and
• Tracking/control system for fuel oil samples.

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 Annex 1

GENERAL MARSHALL ISLANDS ADMINISTRATION GUIDANCE

ON
CHANGING FROM HIGH-SULPHUR FUEL OIL TO LOW SULPHUR FUEL OIL

Procedures for changing from a High Sulphur Fuel Oil (HSFO) to a Low Sulphur Fuel Oil (LSFO)
should be included in ships’ ISM documentation (Chapter 7: Plans for Shipboard Operation). Plans
should typically address the issues raised below and include arrangement drawings, together with a
description of change-over procedures and the quantities of fuel available for operation of the
propulsion and generating plant. A number of practical issues relating to the development of plans
have been identified. These include the need to:

• Address safety issues, including whether it is appropriate to change to LSFO with the engine
room unmanned (if applicable).

• Ensure that adequate quantities of ready-to-use fuel oil for engines and boilers used for
propulsion and generating plant remain continuously available during any change-over
procedures from HSFO to LSFO.

• Confirm with engine and equipment manufacturers that main and auxiliary engines and
associated fuel treatment equipment are suitable for use of LSFO and implement any
recommendations made by the manufacturers.

• Implement a procedure onboard the ship to check the compatibility of the different fuels to be
used for the change-over dilution process. This may be by using a compatibility spot test kit
onboard or, preferably, by sending samples of the two fuels to an independent testing service.

• Calculate the time required for the dilution of HSFO by LSFO to achieve the required sulphur
limit of 1.50% m/m. This is a function of:

• HSFO and LSFO sulphur contents;

• fuel consumption rate; and
• quantity of HSFO in the fuel system prior to dilution – this should take into account the
HSFO remaining in the settling tank, service tank, mixing tank and the fuel rail as
applicable.

Lloyd’s Register has developed a LSFO change-over calculator, which provides an estimate of
the time and cost required to dilute HSFO to meet the 1.50% m/m limit. This is based on a
complete linear blend of the two fuels during the dilution stage. It should be noted that this
calculation is an estimate for guidance purposes only and that spot samples to check actual
sulphur content at various stages of the dilution process are recommended to account for any
operations not considered. The LSFO change-over calculator is available online at:
http://www.lr.org. Type in “ls fuel calculator” in the site search box.

• Seek approval from the vessel’s Recognized Organization for any proposed changes to piping
systems or fuel storage arrangements that are planned to accommodate the use of LSFO onboard.

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 Appendix 2
LOW SULPHUR FUEL OIL CHANGEOVER COMPLETION RECORD

Ship’s Position Volume of Low Sulphur Fuel Oils

in Each Tank Fuel Oil Chief Engineer
Date Time Consignment Signature
Latitude Longitude Location Quantity

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