Nitrogen Oxides (NOx) – Regulation 13

The control of diesel engine NOx emissions is achieved through the survey and   Related Links
certification requirements leading to the issue of an Engine International Air GISIS
Pollution Prevention (EIAPP) Certificate and the subsequent demonstration of in
service compliance in accordance with the requirements of the mandatory, (Registration required for publ

regulations 13.8 and 5.3.2 respectively, NOx Technical Code 2008 (resolution users)

MEPC.177(58) as amended by resolution MEPC.251.(66)).

 
The NOx control requirements of Annex VI apply to installed marine diesel
engine of over 130 kW output power other than those used solely for emergency
purposes irrespective of the tonnage of the ship onto which such engines are
installed.  Definitions of ‘installed’ and ‘marine diesel engine’ are given in
regulations 2.12 and 2.14 respectively.  Different levels (Tiers) of control apply
based on the ship construction date, a term defined in regulations 2.19 and
hence 2.2, and within any particular Tier the actual limit value is determined from
the engine’s rated speed:
 
Ship Total weighted cycle emission limit (g/kWh)
construction n = engine’s rated speed (rpm)
Tier
date on or n≥
n < 130 n = 130 - 1999
after 2000
1 January 45·n(-0.2)
I 17.0 9.8
2000 e.g., 720 rpm – 12.1
1 January 44·n(-0.23)
II 14.4 7.7
2011 e.g., 720 rpm – 9.7
1 January 9·n(-0.2)
III 3.4 2.0
2016 e.g., 720 rpm – 2.4
 
The Tier III controls apply only to the specified ships while operating in
Emission Control Areas (ECA) established to limit NOx emissions, outside such
areas the Tier II controls apply. In accordance with regulation 13.5.2, certain
small ships would not be required to install Tier III engines.  A marine diesel
engine that is installed on a ship constructed on or after 1 January 2016 and
operating in the North American ECA and the United States Caribbean Sea
ECA shall comply with the Tier III NOx standards.
 
The emission value for a diesel engine is to be determined in accordance with
the NOx Technical Code 2008 in the case of Tier II and Tier III limits.  Most Tier I
engines have been certified to the earlier, 1997, version of the NOx Technical
Code which, in accordance with MEPC.1/Circ.679, may continue to be used in
certain cases until 1 January 2011.  Certification issued in accordance with the
1997 NOx Technical Code would still remain valid over the service life of such
engines.
 
An engine may be certified on an individual, Engine Family or Engine Group
basis in accordance with one or more of the four duty test cycles as given in
appendix II of the Annex.  In the case of Engine Family or Engine Group
engines it is the Parent Engine which is actually emissions tested, this is the
engine which has the combination of rating (power and speed) and NOx critical
components, settings and operating values which results in the
highest NOx emission value or, where more than one test cycle is to be certified,
values which, to be acceptable, each of which must be no higher than the
applicable Tier limit value. Subsequent series engines, Member Engines, are
thereafter constructed with a rating, components, settings and operating values
within the bounds established for the respective Engine Family or Engine Group.
Generally all new engine certification leading to the issue of an EIAPP
Certificate is undertaken at the engine builder’s works where the necessary pre-
certification survey takes place.
 
Consequently a diesel engine having an EIAPP Certificate is approved, by, or
on behalf of (since almost all engine certification work is delegated to
Recognized Organizations), the flag State of the ship onto which it is to be
installed, to a stated Tier for one or more duty test cycles, for a particular rating
or rating range, and with defined NOx critical components, settings and
operating values including options if applicable. Any amendments to these
aspects are to be duly approved and documented.
 
For each NOx certified diesel engine there must be onboard an approved
Technical File, NOx Technical Code 2008, regulation 2.3.4, which both defines
the engine as approved and provides the applicable survey regime together with
any relevant approved amendment documentation. As of October 2010 virtually
all engines are surveyed using the Parameter Check method, NOx Technical
Code 2008, regulation 2.4.3.1, whereby the actual duty, rating and NOx critical
components, settings and operating values are checked against the given data
in the Technical File. A key document in the Parameter Check procedure is the
Record Book of Engine Parameters, NOx Technical Code 2008, regulation
6.2.2.8, which is maintained to record all replacements and changes
to NOx critical components, settings and operating values. Engine surveys are
undertaken on completion of manufacture and subsequently as part of the
overall ship survey process; flowcharts illustrating the aspects checked at the
various survey stages are given in NOx Technical Code 2008 appendix II.
 
In addition, there is the case where a diesel engine is subject to “major
conversion”, regulation 13.2. Of the three routes given, “substantial modification”
and uprating, both as defined, involve changes to an existing installed engine
and under these circumstances the relevant Tier is that applicable to the
construction date of the ship onto which the engine is installed except, in the
case of ships constructed before 1 January 2000, where Tier I is applied. In the
third route, that of the installation of a replacement, non-identical, or additional
engine then the Tier appropriate to the date of installation applies although,
subject to acceptance by the Administration taking into account guidelines, in
some circumstances it would permitted to install a Tier II replacement engine as
opposed to one certified to Tier III, regulation 13.2.2. In the case of an identical
replacement engine the Tier appropriate to the ship construction date applies.
 
The revised Annex VI has also introduced the prospect of
retrospective NOx certification, regulation 13.7, in the case of diesel engines of
more than 5000 kW power output and a per cylinder displacement of 90 litres
and above installed on ships constructed between 1 January 1990 and 31
December 1999. This will generally therefore affect only the main engines on
such ships, the 90 litre/cylinder criteria represents, for example in current
medium speed engine designs, engines with a bore of 460 mm and above. For
these engines if a Party, not necessarily the ship’s flag State, has certified
an "Approved Method" which results in an emission value no higher than the
relevant Tier I level and has advised of that certification to IMO then that
 Approved Method must be applied no later than the first renewal survey which
occurs more than 12 months after deposition of the advice to IMO.  However, if
the ship owner can demonstrate that the Approved Method is not commercially
available at that time then it is to be installed no later than the next annual
survey after which it has become available. Given within regulation 13.7 are
constraints on the Approved Method that limit its cost and detrimental effects on
engine power and fuel consumption. Notifications of Approved Method from
Parties are available through GISIS.
 
Further requirements are given in chapter 7 of the NOx Technical Code 2008
which includes an outline of the Approved Method File which must be retained
with the engine. To date several notifications of Approved Methods have been
advised to the Organization. It is not clear the extent to which others will become
available however it is expected that, if so developed, these will be limited to
involving aspects such as changing the engine’s fuel injection nozzles.
Consequently, in the case of engines potentially subject to the requirement to
install an Approved Method it will be necessary for ship owners (and also
surveyors and port State inspectors) to remain vigilant over the service life of
those engines as to the availability of such arrangements and to ensure that
they are duly fitted and thereafter retained as required. For those engines where
an Approved Method exists there is the alternative option, regulation 13.7.1.2,
whereby the engine is instead certified in accordance with the
conventional NOx Technical Code requirements.
 

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Equivalents (SOx scrubber, etc.) – Regulation 4

The Administration of a Party may allow any fitting, material, appliance or apparatus, such
as SOx scrubbers, to be fitted in a ship or other procedures, alternative fuel oils, or compliance
methods used as an alternative to that required by MARPOL Annex VI.

 
The Administrations of Party that allow a fitting, material, appliance, apparatus or other procedures,
alternative fuels, or compliance methods used as an alternative to that required by MARPOL Annex
VI shall advise IMO on it. Notifications of use of equivalent provision from Parties are available
through the Global Integrated Shipping Information System (GISIS)  (Registration required for
public users).

Sulphur oxides (SOx) – Regulation 14

SOx and particulate matter emission controls apply to all fuel oil, as defined in regulation 2.9,
combustion equipment and devices onboard and therefore include both main and all auxiliary
engines together with items such boilers and inert gas generators. These controls divide between
those applicable inside Emission Control Areas (ECA) established to limit the emission of SOx and
particulate matter and those applicable outside such areas and are primarily achieved by limiting the
maximum sulphur content of the fuel oils as loaded, bunkered, and subsequently used onboard.
These fuel oil sulphur limits (expressed in terms of % m/m – that is by weight) are subject to a series
of step changes over the years, regulations 14.1 and 14.4:

Outside an ECA established to limit SOx Inside an ECA established to limit SOx and
and particulate matter emissions particulate matter emissions

 
4.50% m/m prior to 1 January 2012 1.50% m/m prior to 1 July 2010
 
 
3.50% m/m on and after 1 January 2012 1.00% m/m on and after 1 July 2010
 
 
0.50% m/m on and after 1 January 2020* 0.10% m/m on and after 1 January 2015
 
 

* depending on the outcome of a review, to be concluded by 2018, as to the availability of the

required fuel oil, this date could be deferred to 1 January 2025.
 
The ECAs established are:

1. Baltic Sea area – as defined in Annex I of MARPOL (SOx only);

2. North Sea area – as defined in Annex V of MARPOL (SOx only);
3. North American area (entered into effect 1 August 2012) – as defined in Appendix VII of
Annex VI of MARPOL (SOx, NOx and PM); and
4. United States Caribbean Sea area (entered into effect 1 January 2014) – as defined in
Appendix VII of Annex VI of MARPOL (SOx, NOx and PM).

Most ships which operate both outside and inside these ECA will therefore operate on different fuel
oils in order to comply with the respective limits. In such cases, prior to entry into the ECA, it is
required to have fully changed-over to using the ECA compliant fuel oil, regulation 14.6, and to have
onboard implemented written procedures as to how this is to be undertaken. Similarly change-over
from using the ECA compliant fuel oil is not to commence until after exiting the ECA. At each
change-over it is required that the quantities of the ECA compliant fuel oils onboard are recorded,
together with the date, time and position of the ship when either completing the change-over prior to
entry or commencing change-over after exit from such areas. These records are to be made in a
logbook as prescribed by the ship’s flag State, in the absence of any specific requirement in this
regard the record could be made, for example, in the ship’s Annex I Oil Record Book.
 
The first level of control in this respect is therefore on the actual sulphur content of the fuel oils as
bunkered. This value is to be stated by the fuel oil supplier on the bunker delivery note and hence
this, together with other related aspects, is directly linked to the fuel oil quality requirements as
covered under regulation 18. Thereafter it is for the ship’s crew to ensure, in respect of the ECA
compliant fuel oils, that through avoiding loading into otherwise part filled storage, settling or service
tanks, or in the course of transfer operations, that such fuel oils do not become mixed with other,
higher sulphur content fuel oils, so that the fuel oil as actually used within an ECA exceeds the
applicable limit.
 
Consequently, regulation 14 provides both the limit values and the means to comply. However, there
are other means by which equivalent levels of SOx and particulate matter emission control, both
outside and inside ECA, could be achieved. These may be divided into methods termed primary (in
which the formation of the pollutant is avoided) or secondary (in which the pollutant is formed but
subsequently removed to some degree prior to discharge of the exhaust gas stream to the
atmosphere). Regulation 4.1 allows for the application of such methods subject to approval by the
Administration. In approving such equivalents an Administration should take into account any
relevant guidelines. As of October 2010 there are no guidelines in respect of any primary methods
(which could encompass, for example, onboard blending of liquid fuel oils or dual fuel (gas / liquid)
use). In terms of secondary control methods, guidelines (MEPC.184(59)) have been adopted for
exhaust gas cleaning systems which operate by water washing the exhaust gas stream prior to
discharge to the atmosphere, in using such arrangements there would be no constraint on the
sulphur content of the fuel oils as bunkered other than that given the system’s certification.

Shipboard incineration – Regulation 16

The requirements of shipboard incineration divide into two sections. Regulations 16.1 – 16.4 cover
onboard incineration in general and hence is potentially applicable to all ships whereas regulations
16.6 – 16.9 are specific only to incinerators installed on ships constructed on or after 1 January 2000
or to units installed on existing ships on or after that date.

Regulation 16.1 requires that incineration is only undertaken in equipment designed for that purpose
while regulation 16.2 prohibits the incineration of certain listed materials and therefore can be seen
as complimentary to the MARPOL Annex V requirements in respect of the processing of ship
generated garbage. Shipboard incineration of polyvinyl chlorides (PVC) is prohibited by regulation
16.3, except in shipboard incinerator for which an IMO Type Approval Certificates has been issued
in accordance with MEPC.59(33), MEPC.76(40) or MPEC.244(66). Regulation 16.4 recognizes that,
while incineration of ship generated sewage sludge and sludge oil could alternatively be undertaken
in main or auxiliary power plant or boilers, it is not to be undertaken within ports, harbours or
estuaries.

Regulation 16.6 generally requires that incinerators installed on ships constructed on or after 1
January 2000 or units which are installed on existing ships on or after that date are to Type
Approved in accordance with resolution MEPC.76(40) – as modified by resolution MEPC.93(45) or
MEPC.244(66)  – Standard specification for shipboard incinerators. For these incinerators operating
manuals are to be maintained onboard, regulation 16.7, and training as to their correct operation is
to be given, regulation 16.8. Regulation 16.9 requires that operation is such that the stated
temperatures are achieved in order to ensure complete incineration.

Volatile organic compounds (VOC) – Regulation 15

This regulation only applies to tankers.  However, this regulation also applies to gas carriers only if
the types of loading and containment system allow safe retention of non-methane VOCs on board or
their safe return ashore.

There are two aspects of VOC control within this regulation. In the first, regulations 15.1 – 15.5 and
15.7, control on VOC emitted to the atmosphere in respect of certain ports or terminals is achieved
by a requirement to utilize a vapour emission control system (VECS). Where so required, both the
shipboard and shore arrangements are to be in accordance with MSC/Circ.585 “Standards for
vapour emission control systems”. A Party may choose to apply such controls only to particular ports
or terminals under its jurisdiction and only to certain sizes of tankers or cargo types. Where such
controls are required at particular ports or terminals, tankers not so fitted may be accepted for a
period of up to 3 years from the implementation date. Where VECS is so mandated the relevant
Party is to notify IMO of that requirement and its date of implementation. A Party regulating tankers
for VOC emissions shall submit a notification to IMO.  Notifications of VOC from Parties are
available through GISIS  ((Public users need to register to use GISIS).

The second aspect of this regulation, regulation 15.6, requires that all tankers carrying crude oil have
an approved and effectively implemented ship specific VOC Management Plan covering at least the
points given in the regulation. Guidelines in respect of the development of these plans is given by
resolution MEPC.185(59) and related technical information on systems and operation of such
arrangements is given by circular MEPC.1/Circ.680.

Ozone-depleting substances (ODS) – Regulation 12

Included within the definition of ODS are the chlorofluorocarbons (CFC) and halons used
respectively in older refrigeration and fire-fighting systems and portable equipment.  ODS were also
used as the blowing agent in some insulation foams.  Hydrochlorofluorocarbons (HCFC) were
introduced as an intermediate replacement for CFCs but are themselves still classed as ODS.  As
part of a world-wide movement, the production and use of all these materials is being phased out
under the provisions of the Montreal Protocol.

The controls in this regulation do not apply to permanently sealed equipment without charging
connections or removable components; this typically covers items such as small, domestic type,
refrigerators, air conditioners and water coolers.

No CFC or halon containing system or equipment is permitted to be installed on ships constructed

on or after 

19 May 2005 and no new installation of the same is permitted on or after that date on existing ships.
Similarly, no HCFC containing system or equipment is permitted to be installed on ships constructed
on or after 1 January 2020 and no new installation of the same is permitted on or after that date on
existing ships.
 

Existing systems and equipment are permitted to continue in service and may be recharged as
necessary.  However, the deliberate discharge of ODS to the atmosphere is prohibited. When
servicing or decommissioning systems or equipment containing ODS the gases are to be duly
collected in a controlled manner and, if not to be reused onboard, are to be landed to appropriate
reception facilities for banking or destruction.  Any redundant equipment or material containing ODS
is to be landed ashore for appropriate decommissioning or disposal. The latter also applies when a
ship is dismantled at the end of its service life.

Additionally, for ships with ODS containing systems or equipment and which are required to have an
IAPP Certificate, an ODS Record Book is to be maintained in which is recorded any related supply,
recharging, repair, discharge or disposal operations.

Prevention of Air Pollution from Ships

Although air pollution from ships does not have the direct cause and effect Link to releva
 
associated with, for example, an oil spill incident, it causes a cumulative effect Resolutions

that contributes to the overall air quality problems encountered by populations in Link to IMO resolutions

many areas, and also affects the natural environment, such as tough acid rain. MEPC 2 1974 to MEPC 66 2013

MARPOL Annex VI, first adopted in 1997, limits the main air pollutants
  Related Information
contained in ships exhaust gas, including sulphur oxides ( SOx) and nitrous
Historic Background
oxides (NOx), and prohibits deliberate emissions of ozone depleting substances
Equivalents (SOx scrubb
(ODS). MARPOL Annex VI also regulates shipboard incineration, and the
etc.) – Regulation 4
emissions of volatile organic compounds (VOC) from tankers.
Ozone-depleting
Following entry into force of MARPOL Annex VI on 19 May 2005, the Marine substances (ODS) – Regulation
Environment Protection Committee (MEPC), at its 53rd session (July 2005), 12
agreed to revise MARPOL Annex VI with the aim of significantly strengthening Nitrogen oxides (NOx) –
the emission limits in light of technological improvements and implementation Regulation 13
experience. As a result of three years examination, MEPC 58 (October 2008) Sulphur oxides (SOx) –
adopted the revised MARPOL Annex VI and the associated N Ox Technical Code Regulation 14
2008, which entered into force on 1 July 2010. Volatile organic

compounds (VOC) – Regulation

 
Revised MARPOL Annex VI 15

The main changes to MARPOL Annex VI are a progressive reduction globally in Shipboard incineration –
emissions of SOx, NOx and particulate matter and the introduction of emission Regulation 16
control areas (ECAs) to reduce emissions of those air pollutants further in Fuel oil availability and
designated sea areas.
quality – Regulation 18

Under the revised MARPOL Annex VI, the global sulphur cap will be reduced
  Relevant studies
from current 3.50% to 0.50%, effective from 1 January 2020, subject to a
feasibility review to be completed no later than 2018. The limits applicable in Feasibility Study on LNG

ECAs for SOx and particulate matter were reduced to 0.10%, from 1 January Fuelled Short Sea and Coastal
2015.  Shipping in the Wider Caribbea
  Region
Progressive reductions in NOx emissions from marine diesel engines installed
Investigation of
on ships are also included, with a “Tier II” emission limit for engines installed on
appropriate control measures t
a ship constructed on or after 1 January 2011; and a more stringent "Tier III"
reduce Black Carbon emissions
emission limit for engines installed on a ship constructed on or after 1 January
2016 operating in ECAs (North American Emission Control Area and the from international shipping

U.S. Caribbean Sea Emission Control Area). Marine diesel engines installed Pilot study on the use of
on a ship constructed on or after 1 January 1990 but prior to 1 January 2000 are LNG as a fuel for a high speed
required to comply with “Tier I” emission limits, if an approved method for that passenger ship from the Port o
engine has been certified by an Administration. Spain ferry terminal in Trinidad
 
and Tobago
The revised NOx Technical Code 2008 includes a new chapter based on the
agreed approach for regulation of existing (pre-2000) engines established in
Relevant informati
MARPOL Annex VI, provisions for a direct measurement and monitoring  
(external sites)
method, a certification procedure for existing engines and test cycles to be
applied to Tier II and Tier III engines. UK Royal Academy of
  Engineering report, July 2013
MEPC 66 (April 2014) adopted amendments to regulation 13 of MARPOL Annex The UK Royal Academy of
VI regarding the effective date of NOx Tier III standards. 
Engineering has just published
 
report on “Future Ship Powerin
The amendments provide for the Tier III NOx standards to be applied to a marine
Options”
diesel engine that is installed on a ship constructed on or after 1 January 2016
and which operates in the North American Emission Control Area or the U.S.
The IMO is not responsible for
Caribbean Sea Emission Control Area that are designated for the control of
NOx emissions. the content of external sites

 
In addition, the Tier III requirements would apply to installed marine diesel TRI-ZEN LNG Markets

engines when operated in other emission control areas which might be Perspective 2014
designated in the future for Tier III N Ox control. Tier III would apply to ships
constructed on or after the date of adoption by the Marine Environment Report on TRI-ZEN's Perspectiv
Protection Committee of such an emission control area, or a later date as may
be specified in the amendment designating the NOx Tier III emission control
area. on LNG as a Marine Fuel
 
Further, the Tier III requirements do not apply to a marine diesel engine installed
on a ship constructed prior to 1 January 2021 of less than 500 gross tonnage, of
24 m or over in length, which has been specifically designed and is used solely,
for recreational purposes.
 
The amendments are expected to enter into force on 1 September 2015.
 
Revisions to the regulations for ozone-depleting substances, volatile organic
compounds, shipboard incineration, reception facilities and fuel oil quality were
also made with regulations on fuel oil availability added.
 
The revised measures are expected to have a significant beneficial impact on
the atmospheric environment and on human health, particularly for those people
living in port cities and coastal communities.
 

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