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What has to be checked upon a revised MARPOL Annex VI survey?

F318AE (or TRON report) covers all relevant aspects of the revised MARPOL Annex VI. By
completing F318AE (or TRON report), you will have checked all necessary items to verify
whether or not the ship complies with the revised MARPOL Annex VI.

The following guidance provides support for filling form F318AE (or TRON report), and you will
find additional information that might be helpful.

Revised MARPOL Annex VI, SURVEY REPORT F318AE


1 Ozone depleting substances



Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.

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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 1/23

1. Applicable regulation: Reg. 12, Ozone-depleting substances:

The regulation applies only to ships with rechargeable systems and equipment containing ozone-
depleting substances.

The regulation does not apply to permanently sealed equipment containing ozone-depleting
substances where there are no refrigerant charging connections or potentially removable components
containing ozone-depleting substances (reg. 12,1).
1.1 Deliberate emissions of ozone-depleting substances are prohibited. In case of maintenance of
such systems, the substances must be taken to reception facilities (Reg. 12, 3.1, 12.4).
1.2 In new installations, ozone-depleting substances are prohibited from 2005-05-19, except for
HCFCs, which are prohibited in new installations on or after 2020-01-01 (Reg. 12.3, 1+2)
1.3 Each ship with an IAPP Certificate shall maintain a list of ozone-depleting substances (Reg.
12.5).
1.4 Each ship that has rechargeable systems which contain ozone-depleting substances shall
maintain an ozone-depleting substances record book. The record book may form part of an
existing record book or electronic recording system as approved by the Administration (reg.
12,6).
1.5 Entries shall be made in terms of mass (kg) upon recharge of equipment, repair and
maintenance of equipment, and discharges of ozone-depleting substances. (Reg. 12.6 + 12.7)
Entries shall be recorded on each occasion:
- recharge, full or partial, of equipment containing ozone depleting substances
- repair or maintenance of equipment containing ozone depleting substances
- discharge of ozone depleting substances to the atmosphere, deliberate, and non-deliberate
- discharge of ozone depleting substances to land-based reception facilities; and
- supply of ozone depleting substances to the ship


2 Instruction:
2.1 Ozone-depleting substances are substances which deplete the ozone-layer. Ozone-depleting
substances contain usually chlorine or bromine. They can usually be found as cooling agents or
agents in fire-fighting equipment in older ships (our category 1+2 below). Newer ships usually
use alternative agents without chlorine or bromine, which are not considered ozone-depleting.
If substances are used which are NOT considered ozone-depleting, they are NOT to be
listed in the survey report or the certificate. (e.g. R290, R134a, R32, R404a, R407a to c,
R410a, R413, R417, R507, R600, R717, CO2, NOVEC1230).
In this case, items 1.2 to 1.5 are not applicable (= in this case, no ozone-depleting sub-
stances record book needs to be kept, no list of equipment required).
Frequently used ozone-depleting substances
Cat. 1 Cat. 2
Halon
R11 to R13
R111 to R115
R211 to R217

R21 to R22
R31
R121 to R124
R131 to R133
R141 to 142
R151
R221 to R226
R231 to R235
R241 to R244
R251 to R253
R261 to R262
R271
R401
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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 2/23

R409a
2.2 Restrictions for categories:
- Cat. 1) Prohibited in new installations on or after 2005-05-19, but old installations may
remain in use
- Cat. 2) Prohibited in new installations on or after 2020-01-01, but old installations may
remain in use
2.3 If there are ozone-depleting substances used in the equipment installed on board, items 1.2 to
1.5. are applicable. If any item is answered with 0, please enter a deficiency.

- Item 1.2: Documentation has to be on board showing that no deliberate emissions of
ozone-depleting substances have occurred. This can be seen e.g. from the entries in the
ozone-depleting record book. If entries of original quantity and quantity of recharge and dis-
charge add up to the quantity currently listed, one would assume that no deliberate emis-
sions have occurred. If these do not match, and no proof is given that these have been
taken to a reception facility, this would be reason for a deficiency.
- Item 1.3: The list of equipment shall match the supplement of the IAPP Certificate, section
2.1.
- Item 1.4: A record book shall be provided on board. The form is not prescribed. If you find
the record book acceptable, i.e., if you do not make any remarks in the survey statement in
this regard, the record book is considered approved by the Administration. The record book
does not have to be submitted to GL Head Office.

Note: Panama requests the use of its own record book (Oil Record Book and Emissions),
a combination of oil record book and air pollution record book. If not found on board, this is
NOT reason for a deficiency, just comment it to the person in charge, please and inform
them that they should use the official book for Panama.


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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 3/23


- Item 1.5: Entries shall be made in the ozone-depleting substances record book about each
recharge, discharge or upon maintenance and repair of system. These quantity added or
taken out shall add up to the quantity currently listed.

The above applies only to ships with rechargeable systems and for equipment containing
ozone-depleting substances (e.g. not for alternative substances like R404A). The above does
not apply to permanently sealed equipment containing ozone-depleting substances where there
are no refrigerant charging connections or potentially removable components containing ozone-
depleting substances [(e.g. not for domestic refrigerators] (reg. 12,1).

The above does not apply if no ozone-depleting substances are used on board. In order to
avoid further inquiries, GL recommends that ship owners keep delivery notes of substances
which are not considered ozone-depleting when using them in above-mentioned equipment and
systems.
2.4. Data entry in certificates:
- Systems of category 1 to be entered under item 2.1.1
- Systems of category 2 to be entered under item 2.1.2
2.5. What happens if the crew cannot provide you with the data which you require for your
survey?
If the crew does not provide you with the data about system and equipment containing
ozone-depleting substances, the survey cannot be completed. The item will have to be put
on part held. The client should be informed in the survey statement that the data about sys-
tem and equipment containing ozone-depleting substances has to be provided for completion
of the survey.

If the crew cannot show you the required ozone-depleting substances record book or list of
equipment, a deficiency is to be imposed. The client should be informed in the survey state-
ment that the ozone-depleting substances record book or list of equipment has to be pre-
sented to a surveyor in order for the deficiency to be deleted.

If the crew cannot provide plausible proof - from the entries in the ozone-substances record
book - that no deliberate emissions of ozone-depleting substances have been occurred, a
deficiency is to be imposed. The client should be informed in the survey statement that the
respective entries have to be presented to a surveyor in order for the deficiency to be de-
leted. If the surveyor is not satisfied with the entries in the record book upon resurvey, the
crew shall be advised to send an explanation about the entries to engine.environmental@gl-
group.com. The deficiency should not be deleted at this time, but only after satisfactory clari-
fication.



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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 4/23

2 Emissions from diesel engines




Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.

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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 5/23


1 Applicable regulation: Reg. 13, Nitrogen oxides (NOx):

1.1 The regulation applies to every marine diesel engine with more than 130 kW.
This reg DOES NOT APPLY to
- engines with a power output (name plate) of 130 kW and less
- engines only used for emergency purposes
- engines installed on a ship which only trades in the waters of the ships flag state ONLY IF
such engines are subject to an alternative NOx control measure established by the Admini-
stration.

1.2 There are 3 emission limits: Tier I, II, and III (Reg. 13, 3, 13.4, 13.5.1)

1.3 The following requirements apply:

NO emission limit:
- applies to engines installed on a ship keellaid before 2000-01-01 UNLESS the engine un-
derwent a major conversion and UNLESS for an engine with more than than 5,000 kW
power output and 90 litres per cylinder displacement on a ship keellaid on or after 1990-01-
01 and 2000-01-01 an Approved Method exists.
NOTE: This applies also to ships keellaid before 2000 and finished after 2000 if the ship is
sailing with her original engines, and provided the NOx-relevant part/adjustments of the engines
were not substantially modified. It applies even if those engines were manufactured after 2000.
Example: Keellaying of ship = 1998, completion = 2007. Engines built and installed 2007, before
completion of the ship. NOx-relevant part/adjustments were not substantially modified. Engines
are not required to have EIAPP Certificates / Approved NOx Technical Files.

TIER I:
- applies to engines installed on ships constructed (keel laid) on or after 2000-01-01 and
before 2011-01-01
- applies to installation of additional engines or non-identical replacement on or after 2000-01-
01 and before 2011-01-01, even if the keel laying date of the ship was earlier.
- applies to substantial modification of engine installed on ships keellaid before 2011-01-01
- applies to engines with a power output of more than 5,000 kW and a per cylinder displace-
ment of more than 90 litres, installed on ships constructed on or after 1990-01-01 and before
2000-01-01, provided that an Approved Method (NOx reduction method) for that engine ex-
ists.
Approved Method means that the engine manufacturer has submitted the NOx reduction
method for approval to an Administration or Classification Society, the method has been certi-
fied, the certification was notified to IMO, and the Approved Method is commercially available.
In this case, carriage of an approved method file is required. Alternatively, the engine can
prove compliance with Tier I through an EIAPP certificate and approved IMO NOx technical file
(Reg. 13.7.1).

TIER II:
- applies to engines installed on ships constructed on or after 2011-01-01
- applies in the case of installation of a non-identical replacement engine or additional engine
on or after 2011-01-01
- applies to substantial modification of engines installed on ships keellaid on or after 2011-01-
01.
- applies when Tier III does not apply because the replacement engine cannot comply with
Tier III (Reg. 13.2.2)
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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 6/23

- applies when Tier III does not apply because the combined propulsion power of the ship is
less than 750 kW and it is demonstrated to the satisfaction of the Administration that the
ship cannot comply with the standards of Tier III because of design or construction limita-
tions of the ship (reg. 13.5.2.2).
- applies when Tier III does not apply because the ship has a length of less than 24 metres
and is used solely for recreational purposes (reg. 13.5.2.1).

Tier III: Applies in ECAs only
- applies to engines installed on ships constructed on or after 2016-01-01 and in ECAs only.
- applies in the case of installation of a non-identical replacement engine or additional engine
on or after 2016-01-01, in ECAs only.
- applies to substantial modification of engine installed on ships keellaid on or after 2016-01-
01 and in ECAs only.

1.4 On the following page, you will find a flow chart for checking if
an engines has to comply with reg. 13, and if so, which emis-
sion tier it has to comply with: Flowchart by MaZe


Item 2.10: All changes made to settings and components have been recorded:
Applicable regulation: NOx Technical Code 2008, 6.2.2.7.1:
The shipowner or person responsible for a ship equipped with a marine diesel engine required
to undergo an engine parameter check method shall maintain on board the following documen-
tation in relation to the on-board NOx verification procedures:
1. a record book of engine parameters for recording all changes, including like-for-like re-
placements, and adjustments within the approved ranges made relative to an engines com-
ponents and settings

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GL-ItS Part I Revision 2012-04
Chapter 3
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 7/23


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GL-ItS Part I Revision 2012-04
Chapter 3 Status: FINAL
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 8/23


2 Instruction:
2.1 In the checklist, please enter all diesel engines installed on board with more than 130 kW
rated power (name plate). ALSO FOR SHIPS KEELLAID BEFORE 2000-01-01
Date of installation: In general, this should be completion of the survey on which the en-
gines were surveyed with satisfactory result for the first time. In case of original engines,
this is usually the newbuilding survey.
2.2 Please enter the use of the engine ACCORDING TO THE ACTUAL USE ON BOARD (not
according to EIAPP Certificate)
- E3= Main propulsion FPP or propeller law operated aux.
- E2= Main propulsion CCP or diesel electric
- D2= Aux. constant speed
- C1=Aux. variable speed, variable load
2.3 Please enter the applicable regulation for the engine (Tier I, II, III for details see 1.3).
2.4 Please enter if the EIAPP Certificate including supplement is available (in cases where
required) and give the EIAPP certificate number. If the certificate including supplement is not
available on board the ship, this is to be noted in the survey report. A deficiency has to be
imposed.
Form of EIAPP Certificate: Generally, if the ship holds an IAPP Certificate; for the engines, EIAPP
Certificates have to be available on board, and if the ship holds an APP DoC; for the engines,
EAPP DoCs have to be on board (or sometimes you might find EAPP SoCs on behalf of the
flag state, some classifications societies issue these instead of DoCs).
Reissuance of EAPP DoCs/SoCs as EIAPP Certificates after ratification of flag state: Flag
states like Antigua and Barbuda, Malta or India did not ratify the MARPOL Annex VI conven-
tion in the beginning, hence you might find APP DoC and EAPP DoCs (or sometimes EAPP
SoCs if they were e.g. issued by another classification society) on board. Antigua and Bar-
buda and also Malta and India have ratified the MARPOL Annex VI convention in the mean-
time. Upon renewal survey, the APP DoC and the EAPP DoCs will have to be issued as IAPP
and EIAPP Certificates. If the EAPP DoCs/SoCs were issued by another classification
society, copies of both the EAPP DoCs/SoCs and Technical Files will have to be sub-
mitted to dept. MC-PE so that the reissuance can be done.
2.5 Please enter if the approved IMO NOx Technical file for the engine is available on board. The
Technical File is needed for the on-board verification of the engine. It the Technical File is not
available on board, a deficiency has to be imposed.
2.6 Please enter if the EIAPP Certificates comply with the applicable emission limit. There are 3
emission limits, Tier I (Reg. 13.3), Tier II (Reg. 13.4) and Tier III (Reg. 13.5.1).
This is stated under item 1.9.5 of the EIAPP Certificate (supplement):

2.7 Please check if power and speed: is the same as on engine name plate + EIAPP Cert. If not,
please enter a deficiency.
2.8 Please check if IMO numbers of emission relevant components (e.g. valve, piston, cylinder,
turbo charger):is the same on engine (spare) parts + NOx Tech File chapter on-board verifica-
tion. If not, please enter a deficiency.
2.9 Please check the items 2.7 + 2.8 at least for one engine per engine model number. This is the
minimum MARPOL Annex VI requirement (See also box below On-board-verification).
The check is required upon each survey, and also before a new engine can be entered
into the IAPP Certificate.

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GL-ItS Part I Revision 2012-04
Chapter 3 Status: FINAL
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 9/23



As a general guideline: No data to be entered in table 2.2.1 if the previous certificate listed no
engines and if no changes have occurred. (Examples: Emergency engines, original engines installed
in ships keellaid before 2000-01-01 if no approved method is required, new engines installed in ships
keellaid before 2000-01-01 if the new engine was built before 2000-01-01 + did not have a major
engine modification on or after 2000-01-01 + was installed before 2011-07-01).

In all other cases, please enter:
Manufacturer, model, serial number: self explanatory
Date of installation: For original engines = completion date of the newbuilding survey. For engines
installed later: completion date of survey which documents that the installation of the engine was
completed.
Use: according to Instructions item 2.2
Power output/rated speed: As per nameplate
Exempted by regulation 13.1.1.2: (Only to be used for identical replacements since 2010-07-01. For
more info, please see below).

Exempted by regulation 13.1.1.2:
1. This concept did not exist before 2010-07-01, and the regulation at the time of replacement
remains valid. Therefore, engine replacements before 2010-07-01, even if identical, are not
to be listed as Exempted by regulation 13.1.1.2 in the supplement to the interim IAPP
Certificate.
Replacements before 2010-07-01 are either a major conversion (if date of build on or after
2011-01-01, or if changes to NOx relevant parts on or after 2011-0-101, or if increase in rated
power of more than 10% on or after 2000-01-01). Then, they should be entered in table 2.2.1,
and the date of the major conversion should be entered either under According to reg.
13.2.2 (in case of new engine, even if the replacement engine is identical) or under Accord-
ing to reg. 13.2.3 (in case of change of NOx relevant parts, or increase of rated power of
more than 10%).
Or, the replacements are no major conversion (if date of build was before 2011-01-01 and if
no changes to NOx relevant parts on or after 2011-0-101 or increase in power of more than
10% on or after 2000-01-01). Then the engine should not be entered at all in the supplement
to the interim IAPP Certificate.
2. Exempted by regulation 13.1.1.2 means that
a) an engine was installed as replacement for another engine on or after 2010-07-01
b) is completely identical to the one it is replacing (maker, model, specification/configuration,
power, speed)
On-board-verification:
The on-board verification procedure (OVP) is an instruction on how to verify whether or not an
engine is compliant with the applicable NOx emission limit: The OVP shall be used to verify that
the engine components/parameters coincide with those stated in the Technical File.

The OVP is to be performed as follows: You will find, in the Technical File, a section OVP. NOx
relevant components and settings and allowable adjustments which influence the emission of
nitrogen oxides are listed. Please use it as reference for the counter check with the actual engine.
In most cases drawings are included showing you where to find the identification numbers on the
engine components. The surveyor has the option of checking one or all of the identified
components, settings or operating values. The survey should be completed for at least one
cylinder and/or one engine in a family or group. The engine log book should be checked for
changes.

If engine components, settings, adjustments or software revision nos. are different from the
specification given in the Technical File, the ships person in charge is to be informed that these
components have to be replaced by such components which are stated in the Technical File. A
deficiency is to be imposed.
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GL-ItS Part I Revision 2012-04
Chapter 3 Status: FINAL
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 10/23

c) the requirement from reg. 13.2.2 (engine has to comply with emission limit in force at the
time of the replacement, currently Tier II) is not valid for this engine. Instead, the replace-
ment engine has to comply with the same regulation which applies to the engine it is re-
placing.
Example: Identical replacement installed in March 2011. Previous engine had to comply with Tier 1,
so the identical replacement has to comply with Tier 1.
Example: Identical replacement installed in April 2011. Previous engine did not have to comply with
any emission limit (no EIAPP Certificate, no approved IMO NOx Technical File). So the identi-
cal replacement does not have to comply with any emission limit (no EIAPP Certificate, no
approved IMO NOx Technical File).

Tier I: Reg. 13.3: If Tier I is applicable and the ship is equipped with the respective EIAPP
certificate (or equivalent) and approved IMO NOx technical file
Tier II: Reg. 13.4: If Tier II is applicable and the ship is equipped with the respective EIAPP
certificate (or equivalent)
Tier II: Reg. 13.2.2: If replacement engines cannot comply with Tier III
Tier II: Reg. 13.5.2: If engines cannot comply with Tier III and ship is less than 24 metres long
and used only for recreational purposes
Tier III: Reg. 13.5.1.1: If Tier III is applicable and the ship is equipped with the respective EIAPP
certificate (or equivalent) and approved IMO NOx technical file

Emergency engines do not have to comply with any emission limit. No EIAPP Certificate and
approved IMO NOx Technical File required.
Emergency engines also used for harbour use (in general: connected to the main switchboard), are
to be treated like an auxiliary engine.

Reporting:
a) identical replacements:
- the engine is to be listed in the survey report
- the engine is to be listed in the supplement to the IAPP Certificate. The box "exempted by
regulation 13.1.1.2" is to be checked.
b) emergency diesel engine:
- the engine is to be listed in the survey report (for our records)
- the engine is not to be listed in the supplement to the IAPP Certificate.

Item 2.10: All changes made to settings and components have been recorded:
As stated in our respective customer information, most Technical Files contain empty pages where
the respective entries can be made. However, shipowners are free to record the changes in any
other way, e.g. in an engine record book, an engine maintenance program, or separately. Even a
folder with receipts and additional remarks might do. However, the surveyor has to check the records
when doing the on-board verification procedure. In order to accelerate the process it is recom-
mended that the records display the engine-specific changes at a glance.

Emission relevant parts are parts regarding the
- combustion chamber geometry, e.g. piston, connecting rod, cylinder liner, cylinder head
- fuel system, e.g. nozzle, fuel pump, camshaft, software, injection timing
- aspiration, e.g. turbo charger, charge air cooler, valve timing

Emission relevant parts and settings are listed in the Technical File of the relevant engine. All
changes made to these parts or settings must be recorded.
All emission relevant parts and settings must be identified (usually by their IMO number) in the
approved IMO NOx Technical File, section on-board-verification.

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2.5. What happens if the crew cannot provide you with the data which you require for your
survey?
If there is no name plate on the engines which shows the necessary engine details, the survey
cannot be completed. The item should be put on part held. If the survey cannot be completed, a
remark is to be made in the survey statement that the survey will be completed upon provision of all
necessary engine details. For engines which do not require an EIAPP Certificate or DoC/SoC, the
name plate is still required. On these name plates, if a detail is missing which can be proven in a
plausible way through documentation on board, this is acceptable.
If the EIAPP Certificates in their required form or if the IMO NOx Technical Files are not available on
board, or not complete or correct, or if there is a discrepancy between engine data found on board
and the documentation, a deficiency should be imposed stating what exactly is not in order. The
deficiency can be deleted after the surveyor has seen all data on board as required and has been
able to perform the necessary engine check against the documentation.




1 Applicable regulation: Reg. 13.7.1

1.1 An approved method is a method for a particular engine, or a range of engines, that, when
applied to the engine, will ensure that the engine complies with the applicable NOx limit. (NOx
Technical Code 2008, 1.3.17).

1.2 An approved method shall be installed no later than the first renewal survey that occurs 12
months or more after an Administration or classification society has notified IMO about the
certification of the Approved method (Reg. 13.7.1). Alternatively, the engine can be equipped
with an EIAPP Certificate if the engine owner decides to prove that the engine complies with
regulation 13 without Approved Method (Reg. 13, 7.2).

2 Instruction:

2.1 Please enter the Approved method file number if available.
Approved Method is available for the following engines:

Engine specification Approved method has to be
available on board for Renewal
Surveys carried out on or after
MAN B&W S70MC with 2,530 2,810 MCR per
cylinder (kW/cyl) and rated speed 81-91 rpm
6 October, 2011

Wrtsil Switzerland Ltd.
RTA52
RTA52U
RTA58T
RTA62
RTA62U
RTA72
RTA72U
5 February, 2012
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Section 2 C 1.14
Technical Details
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RTA84C
RTA84CU
RTA84M
RTA84T-B
RTA96C

MAN B&W S50MC with 1,160-1,430 MCR per
cylinder (kW/cyl) and rated speed 114-127 rpm


12 August, 2012


2.2 A respective instruction to surveyor was entered into the SIS/ Fleet Online. By checking the
instruction for the relevant ship, you will be able to see if an approved method should be
installed for the engine of this ship. Please note 1.2 above.

If you see from the ItS that an approved method should be installed, and if this was not done
in the legal time frame, a deficiency shall be imposed unless the ship owner proves that de-
spite best efforts to obtain it, the Approved Method was not commercially available. If the ship
owner proves this, the box Approved Method not commercially available is to be checked.
The Approved Method shall in this case (=if Approved Method not commercially available
was checked) be installed no later than the next annual survey after it has become commer-
cially available. If, at this date, it is not installed and no proof is submitted that the Approved
Method is still not commercially available, a deficiency is to be imposed.

3 Data entry in certificate:

If an Approved Method is available for this engine type, entry in the certificate should be as
follows:
- Approved Method exists: Please see item item 2.2 above
- Approved Method not commercially available: Please see item item 2.2 above
- Approved Method installed: If Approved Method is installed.
- If an approved method for this engine type is not available, these boxes are not to be
checked
4 What happens if the crew cannot provide you with the data which you require for your
survey?
If there is no name plate on the engines which shows the necessary engine details, the survey
cannot be completed. The item should be put on part held. If the survey cannot be completed, a
remark is to be made in the survey statement that the survey will be completed upon provision of all
necessary engine details. For engines which do not require an Approved Method File, the name
plate is still required. On these name plates, if a detail is missing which can be proven in a plausible
way through documentation on board, this is acceptable.
If the Approved Method File is not available on board, or not complete or correct, or if there is a
discrepancy between engine data found on board and the documentation, a deficiency should be
imposed stating what exactly is not in order. The deficiency can be deleted after the surveyor has
seen all data on board as required and has been able to perform the necessary engine check
against the documentation.


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MARPOL 73/78 - Annex VI Surveys
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1 Applicable regulation: Reg. 13, 2.1, 2.2., 2.3:

A major conversion with regard to reg. 13 of MARPOL Annex VI consists of either one of the
following:
1. replacement with identical engine (engine to comply with standards of the engine it is
replacing)
2. replacement with non-identical engine (engine is to comply with the Tier in force at the
time of installation of replacement engine)
3. installation of additional engine (engine is to comply with the Tier in force at time of
installation of replacement engine)
4. substantial modification /increase in rating over 10% (engine is to comply with Tier I if
ship was keellaid before 2000, else it is to comply with the Tier in force at the time the
ship was keellaid).

2 Instruction:

2.1 In case of major engine conversions, please enter the type of conversion according to the
above box
2.2 Please also enter the date of conversion (=completion date of survey which documents that
the installation of the engine was completed).
For the date of the major conversion, please see the IACS UI MPC98: The date of installation
is either the contractual date (see contract) or the date of delivery (see delivery receipt). If
installation is on or after 2016-01-01, the date is the date of the actual check on board
(classificatory or emission testing, whichever is earlier).

3 Data entry in certificate:
- Date of major conversion accord. to Reg. 13. 2.2 (= in case of replacement or additional
engine)
- Date of major conversion accord. to Reg. 13. 2.3 (= substantial modification of an
installed engine). Substantial modification = change of emission-relevant
parts/adjustments.

4 What happens if the crew cannot provide you with the data which you require for your
survey?
If there is no name plate on the engines which shows the necessary engine details, the survey
cannot be completed. The item should be put on part held. If the survey cannot be completed, a
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MARPOL 73/78 - Annex VI Surveys
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remark is to be made in the survey statement that the survey will be completed upon provision of
all necessary engine details. For engines which do not require an EIAPP Certificate or DoC/SoC,
the name plate is still required. On these name plates, if a detail is missing which can be proven in
a plausible way through documentation on board, this is acceptable.
If the EIAPP Certificates in their required form or if the IMO NOx Technical Files are not available
on board, or not complete or correct, or if there is a discrepancy between engine data found on
board and the documentation, a deficiency should be imposed stating what exactly is not in order.
The deficiency can be deleted after the surveyor has seen all data on board as required and has
been able to perform the necessary engine check against the documentation.



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3 Sulphur oxides (SOx) (regulation 14) / Fuel oil quality (regulation 18)



Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.

1 Applicable regulation: Reg. 14, 18; sulphur oxides (SOx) and particulate matters

1.1 In general, the sulphur content must not exceed the following limits:
- for fuel used before 2012-01-01: 4.5% m/m
- for fuel used on or after 2012-01-01 and before 2020-01-01 = 3.5% m/m
- for fuel used on or after 2020-01-01 0.5% m/m (Reg. 14.1)

1.2 The fuel used in the ECAs must not exceed the following limits:
- on or after 2010-07-01 and before 2015-01-01 = 1.0%
- or or after 2015-01-01 = 0.1% (Reg. 14.4)

1.3 Ships using different fuels shall carry a written procedure showing how the fuel oil change
over is to be done. (Reg. 14.6)

1.4 The fuel change over shall be recorded in a log book, stating volume of low sulphur fuel oil in
each tank, time date and position of ship (Reg. 14.6)

3.1 Emission Control Area
NEW: NORTH AMERICAN ECA as of 2011-08-01. MEPC.1/Circ.723
Ships operating in the North American ECA are exempted from the requirements for SOx and
particulate matter during the first twelve months after entry into force (MEPC.1/Circ.723 item 5).
This means: No fuel with sulphur content below 1.0 % required until 2012-08-01 (3.5% ok), no
bunker delivery notes which confirm sulphur content below 1.0% required until 2012-08-01 (3.5%
ok), no written fuel change over procedure required until 2012-08-01.

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2 Instruction:

2.1 Please check the bunker delivery notes with regard to sulphur content of the fuel. The sulphur
content must be stated on the bunker note. If the sulphur content stated in the bunker delivery
note exceeds the applicable limit (for details, pls see info below), please enter a deficiency.

2.2 Please check if the fuel oil used in ECAs does not exceed the applicable limit, by checking
the bunker delivery notes.
If the ship does not currently trade in ECAs, the question can either be answered as not
applicable: the respective boxes in the certificate will be left blank. If the ship should ever go
to such an area, this item will have to be resurveyed and the certificate will have to be
changed.
Alternatively, if the owners representative can confirm now that only fuel which does not
exceed the applicable sulphur limit will be used when trading in an ECA, the question can be
answered with yes, and the boxes in the certificate can be checked. The owners confirmation
is documented through the signature on the survey statement (or signature of the survey
report in case the paper version is used).

Info regarding item 3.1
- Bunker note issued before 2012-01-01 = 4.5% m/m
- Bunker note issued on or after 2012-01-01 and before 2020-01-01 = 3.5% m/m
- Bunker note issued on or after 2020-01-01 = 0.5% m/m

Info regarding item 3.2
- Date of trading in ECA before 2010-07-01 = 1.5% m/m
- Date of trading in ECA on or after 2010-07-01 and before 2015-01-01 = 1.0%
- Date of trading in ECA on or after 2015-01-01 = 0.1%

2.3 A written procedure is required if:
- The ship enters and leaves an Emission Control Area.
- The ship uses separate fuels in order to comply with sulphur limits inside and outside
an Emission Control Area (reg. 14, 6).
The procedure is considered approved if the GL surveyor does not enter any remarks during
the survey. It is not necessary to submit the procedure to GL HO.

2.3.1 For surveys between 2012 and 2020, the second box is the box that will have to be ticked
in order for the certificate to remain valid. If you tick the first box, this value is not valid
anymore, if you tick the third box, this value is not valid yet.

2.3.2 For surveys between 2012 and 2015, the first box is the box that will have to be ticked in
order for the certificate to remain valid. If you tick the second box, this value is not valid yet.

In these cases, the following shall be recorded in a log book: The volume of low sulphur in
each tank and the date, time and position of the ship when a change over is completed before
entry or started before leaving an Emission Control Area.

3 Data entry in certificate:
If the ship representative presents the fuel oil samples and bunker delivery notes confirming
the currently valid sulphur limit, in the certificate under item 2.3.1 and 2.3.2, please tick
boxes for currently valid sulphur limit only. Please do not tick all boxes.

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4 What happens if the crew cannot provide you with the data which you require for your
survey?
If the required bunker delivery notes and fuel oil samples are not on board, or if they do not
show compliance with the required sulphur limit, a deficiency should be imposed. In the
deficiency, please state that the bunker delivery notes and fuel oil samples have to be
presented to a GL surveyor on board for inspection. Upon satisfactory result, the deficiency
will be deleted.
If the fuel change-over procedure is required and not available on board, or if it is not found
satisfactory, a deficiency is to be imposed. In the deficiency, please state that the fuel change-
over procedure has to be presented to a GL surveyor on board for inspection. Upon satisfac-
tory result, the deficiency will be deleted.


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4 Volatile organic compounds (VOCs) (regulation 15), for tankers only


Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.


1 Applicable regulation: Reg. 15 Volatile organic compounds (VOCs):

1.2 A tanker which is required to carry a vapour collection system because of port requirements
shall have a vapour emission collection system approved on the basis of IMO document
MSC.585 and use this system during the loading of relevant cargoes.
1.3 A tanker carrying crude oil must have on board and implement a VOC management plan
approved by the Administration. NOTE: This is only applicable to ships which really carry
crude oil.
1.4 The VOC management plan must provide written procedures for minimizing VOC emissions,
give consideration to the additional VOC generated by crude oil washing and identify a
person responsible for implementing the plan. For ships on international voyages, the plan
shall be written in English, French or Spanish or include a translation into one of these
languages if the working language is not English, French, or Spanish.

2 Instruction:

2.1 If the ship has a vapour collection system in accordance with IMO document MSC.585, the
respective box shall be checked with 1/yes. This is not mandatory according to MARPOL
Annex VI. Therefore, if not available, this is NO reason for a deficiency.
2.2 If the ship has a VOC management approval plan, please check the box and enter the
reference number. If a tanker which carries crude oil does not have an approved VOC
management plan, a deficiency has to be imposed.

3 Data entry in certificate:
Self-explanatory

4 What happens if the crew cannot provide you with the data which you require for your
survey?
If the crew does not provide you with the data about the vapour collection system, the
question: The tanker has a vapour collection system installed which complies with MSC
Cird. 585 should be answered with No.

If the crew of a tanker which carries crude oil does not show you the approved VOC man-
agement plan, a deficiency should be imposed. . In the deficiency, please state that the VOC
management plan has to be presented to a GL surveyor on board for inspection. Upon
satisfactory result, the deficiency will be deleted.


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5 Incinerator



Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.


1 Applicable regulation: Reg. 16 Incinerators
1.1. Shipboard incineration is only allowed in an incinerator. Exception: Shipboard incineration of
sewage sludge and sludge oil generated during normal operation of a ship may also take place
in the main or auxiliary power plant or boilers, but in those cases shall not take place inside
ports, harbours and estuaries.
1.2 Shipboard incineration of PVCs is prohibited. Except in shipboard incinerators for which IMO
Type Approval Certificates have been issued.
1.3 Incinerators installed on a ship constructed on or after 1 January 2000 or incinerator installed
on board a ship on or after 1 January 2000, shall be approved according to MEPC.76(40).
1.4 Incinerators subject to item 3 above shall be provided with a manufacturers operating manual
1.5 The staff responsible for operation of the incinerator subject to item 3 above shall be trained
and capable of implementing the guidance of the manufacturer's operating manual.
1.6 For incinerators subject to item 3 above, the exhaust gas outlet temperature shall be
monitored at all times.



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2 Instruction:

2.1 Please check if an incinerator is installed.

2.2 If so, please enter the year of installation of incinerator.

2.3 Please check for one of the following and mark the survey report accordingly
2.3.1 Incinerator complies with MEPC.76(40). This is mandatory if the ship is keellaid on or after
2000-01-01 or if the incinerator was installed on or after 2000-01-01. If the incinerator does
not comply, a deficiency has to be entered. In order to check compliance, a copy of the ap-
proval certificate has to be on board.
2.3.2 Incinerator complies with MEPC.59(33)
For an incinerator which was installed on or after 2001-01-01, please check if:
- the exhaust gas outlet temperature is monitored and
- the manual is available on board .
- The personnel responsible for operation of the incinerator is trained and capable of im-
plementing the guidance of the manufacturer's operating manual

If this is not the case, a deficiency is to be entered.

3 Data entry in certificate:

Please check the respective box.

In cases of incinerators installed before 2000-01-01, there is no box to check in the IMO Certificate
for incinerators which are not compliant with reg. 76.(40) or 59.(33). GL HO will submit a letter
together with the new full term IAPP Certifcate, stating that there is an incinerator installed which is
not compliant with reg. 76.(40) or 59.(33), and which must not be used for shipboard incineration of
polyvinyl chlorides (PVCs) according to regulation 16.3 of the revised MARPOL Annex VI (2008).

4 What happens if the crew cannot provide you with the data which you require for your
survey?

If there is no name plate on the incinerator which shows the necessary details, the survey cannot be
completed. The item should be put on part held. If the survey cannot be completed, a remark is to
be made in the survey statement that the survey will be completed upon provision of all necessary
details.
If the required type test certificate or other evidence showing that the incinerator is approved
according to the applicable regulation are not available on board, or not complete or correct, or if
there is a discrepancy between engine data found on board and the documentation, a deficiency
should be imposed stating what exactly is not in order. The deficiency can be deleted after the
surveyor has seen all data on board as required and has been able to perform the necessary check
against the documentation. If the incinerator is not required to comply with a regulation (installation
before 2000-01-01), no deficiency is to be imposed.



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6 Equivalents



Highlighted items: NEW REQUIREMENTS ACCORDING TO REVISED MARPOL ANNEX VI.


1 Applicable regulation: Reg. 4.1 Equivalents

The Administration may allow any fitting, material, appliance, and apparatus to be fitted in a ship
[] if such fittings, materials, appliances, and apparatus are at least as effective.

2 Instruction:

Please state if the ship uses equivalents en lieu of the systems or equipment intended by
MARPOL Annex VI. An equivalent is any equipment which leads to the results required by
MARPOL Annex VI.
Example: The sulphur limit in the fuel can be met by using fuel with a low sulphur content
(intended for use by MARPOL Annex VI). It can also be met by using a scrubber. If the scrubber
is approved, it can be entered under 06.20. The approval number is required in this case.

The Approved Method (items 2.8 and 2.9) is not an equivalent, but (if applicable) a MARPOL
Annex VI requirement.

Alternative cooling agents (cat. 3) are no equivalents, as their use is required in new installations
where HCFCs are no longer allowed. They are not to be entered in the certificate, no approval
no. necessary.

3 Data entry in certificate:
Self-explanatory



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S
e
r
v
i
c
e

GL-ItS Part I Revision 2012-04
Chapter 3 Status: FINAL
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 22/23

7 Remarks:



G
L

-

I
t
S

P
a
r
t

I

C
h
.
3


F
l
e
e
t

i
n

S
e
r
v
i
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e

C
h
.
3
.
2
.
C


S
t
a
t
u
t
o
r
y

S
u
r
v
e
y
s

F
l
e
e
t

S
e
r
v
i
c
e

GL-ItS Part I Revision 2012-04
Chapter 3 Status: FINAL
Section 2 C 1.14
Technical Details
MARPOL 73/78 - Annex VI Surveys
page 23/23

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