How to meet EEXI compliancy when essential components or technicians are unavailable
Verification of a ship’s attained EEXI shall take place at the first annual, intermediate or renewal survey – whichever is first, on or after 1 January 2023. DNV has noted that some shipowners face challenges to install the required equipment on board within the required deadlines due to a global shortage of electronic components or non-availability of service technicians, e.g. limited docking capacities. This statutory news addresses how to deal with this issue.
Relevant for ship owners and managers as well as suppliers and flag states.
The regulations formally do not offer postponements of EEXI compliance, due to unavailability of equipment for instance. However, if such situations should occur, DNV supports an interim EEXI compliance method which is based on continuous power monitoring and data-reported compliance verification. As this method is not formally regulated by the IMO, it needs the formal acceptance of the vessel’s individual flag on a case-by-case basis.
Pending acceptance by flag, DNV supports issuance of a full-term International Energy Efficiency Certificate (IEEC) in combination with an Interim Exemption Certificate. The Interim Exemption Certificate temporarily exempts the vessel from requirements of the guideline on shaft/engine power limitation system (MEPC.335(76)). It also requires the vessel to follow an alternative compliance scheme until the final installation(s) can be verified. The proposed validity of the Interim Exemption Certificate coincides with the next IAPP survey.
To support this formal request to the individual flag states, the following information and documents should be provided to DNV as a minimum for our correspondence with the flag administration:
• An approved EEXI technical file showing that EEXI requirements are met by reducing main engine power
• If applicable, an approved Onboard Management Manual (OMM) for power limitation that is pending implementation
• Description of equipment that is pending implementation
• Letter by maker confirming commercial unavailability of equipment
• Description of procedure on how to ensure verified intermediate power monitoring
• Schedule for expected implementation of final installation
Interim compliance measures need to be implemented and accepted by the first periodical IAPP survey on or after 1 January 2023.
The full process is illustrated in the below figure and consists of the following steps (may be subject to change as per agreement with flag):
1. A letter from the equipment maker or service supplier will be required to confirm the non-availability of components to complete the installation, together with a procedure on how to capture data from the system to enable the proper verification of used power.
2. To enrol in the scheme, flag acceptance is required.
3. Upon acceptance by flag administration, an interim OMM based on the maker’s procedure describing the interim compliance scheme is to be submitted for approval.
4. When completing the first IAPP survey on or after 1 January 2023, a full-term IEEC will be issued by a DNV surveyor, in combination with an interim exemption certificate. This interim certificate will show exemptions from requirements of the EPL/Shapoli guideline by the IMO and refers to the interim compliance scheme instead.
5. The vessel will now enter a new 3-monthly survey scheme following the exemption certificate, whereby records of the actual shaft power used will be submitted for verification by DNV through a remote survey request. Possible means to provide the required data are, for instance, time plots of a torque meter or electronic engine logs.
6. Upon successful verification of the power logs, DNV will issue a survey report confirming the vessel complied with the required power limitation within the verified time. The verification cycle will be repeated every 3 months until the permanent installation can be completed and verified on board, although limited by the validity date of the exemption certificate.
Illustration of the process to achieve interim EEXI compliance
Recommendation
In the case of delayed delivery of equipment to be installed on board ships – and compliance with the required EEXI is at risk – we recommend that our customers urgently get in touch with DNV to avoid non-conformities at the first scheduled periodical survey in 2023.
A formal request to apply the interim scheme should be sent by our customers to DNV via DATE – Direct Access to Technical Experts. Upon agreement from the flag state, an interim OMM should be submitted via DNV’s EEXI tool.
References
MEPC.335(76) 2021 GUIDELINES ON THE SHAFT / ENGINE POWER LIMITATION SYSTEM TO COMPLY WITH THE EEXI REQUIREMENTS AND USE OF A POWER RESERVEContact
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