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IMO Data Collection System (DCS) - FAQ

31/07/2018
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IMO DATA COLLECTION SYSTEM (IMO DCS) - FREQUENT ASKED QUESTIONS (FAQ)



1. What is the legal framework?

The Amendments to MARPOL Annex VI, Regulation 22A on a data collection system for fuel oil consumption of ships were adopted at MEPC70 on 28 October 2016 and came into force on 1st March 2018 (IMO Resolution MEPC.278(70).

Three relevant guidelines and one circular have also been published:
   
2. What are the key compliance deadlines?

1st September 2018: recommended deadline for the submission of the Data Collection Plans (SEEMP Part II) to the Flag administration or any duly authorized organization

1St January 2019: Confirmation of Compliance for the updated SEEMP must be on-board. Start of the first monitoring period.

31St December 2019: end of the first monitoring period.

30th April 2020: deadline for the submission of the data to the Flag Administration or any fully authorized organization for verification.

31st May 2020: Statement of Compliance for the fuel oil consumption data must be on-board.


3. Which ships are subject to the IMO DCS?

All ships of 5000 GT or above performing international voyages regardless of Flag or country of ownership. Ships engaged on domestic voyages, ships not propelled by mechanical means and platforms, including FPSOs, FSUs and drilling rigs, are excluded.


4. What are the key legal requirements?

Every ship must:
 
  • Develop a Data Collection Plan (SEEMP Part II) and have it reviewed by the Flag Administration or any duly authorized organization
  • Monitor and report fuel oil consumption data, hours underway and distance travelled, and have the data verified by the Flag Administration or any duly authorized organization
  • Carry on-board a Confirmation of Compliance for the updated SEEMP (from 1st January 2019)
  • Carry on-board a Statement of Compliance for the fuel oil consumption data (from 31st May 2020)
 
5. Which parameters shall be monitored?

Only three parameters shall be monitored:
 
  • Fuel oil consumption data for each type of fuel
  • Hours underway while the ship is underway under its own propulsion
  • Distance travelled over ground while the ship is underway under its own propulsion
 
6. Which fuel consumption monitoring methodologies can be used?

There are three acceptable fuel consumption monitoring methodologies:
 
  • Method 1: bunker delivery notes (BDN)
  • Method 2: Flow meters
  • Method 3: Bunker fuel tank monitoring on-board
Direct CO2 emission measurements may also be used.


7. Which emissions sources must be considered?

There are five emissions sources for which fuel consumption shall be monitored for each type of fuel oil consumed, regardless of whether a ship is underway or not:
 
  • Main engines
  • Auxiliary engines
  • Boilers, if any
  • Gas turbines, if any
  • Inert gas generators, if any
 
8. Which information shall be included in the SEEMP Part II (Data Collection Plan)?

The SEEMP Part II has 9 sections:
 
  • Ship particulars
  • Record of revision of fuel oil consumption data collection plan
  • Ship engines and other fuel oil consumers and fuel oil types used
  • Emission factor
  • Method to measure fuel oil consumption
  • Method to measure distance travelled
  • Method to measure hours underway
  • Processes that will be used to report the data to the Administration
  • Data quality
The template of the SEEMP Part II is presented in the Appendix 1 of IMO Resolution MEPC.282(70).


9. What are the differences between EU MRV and IMO DCS requirements?




10. What happens if the Flag Administration of the vessel is changed during the year ?

In the event of the transfer of a ship from one Administration to another, the ship shall on the day of completion of the transfer or as close as practical thereto report to the losing Administration or any duly authorized organization, the aggregated data for the period of the calendar year corresponding to that Administration, and, upon prior request of that Administration, the disaggregated data.


11. What happens if the Company changes during the year?

In the event of a change from one Company to another, the ship shall on the day of completion of the change or as close as practical thereto report to its Administration or any duly authorized organization, the aggregated data for the portion of the calendar year corresponding to the Company, and, upon request of its Administration, the disaggregated data.


12. How shall the data be reported to the Flag Administration or any duly authorized organization?

The data shall be reported as per the standardized data reporting format laid out in Appendix 3 of IMO Resolution MEPC.282(70).


13. How shall deadweight be calculated?

Deadweight means the difference in tonnes between the displacement of a ship in water of relative density of 1025 kg/m3 at the summer load draught and the lightweight of the ship. The summer load draught should be taken as the maximum summer draught as certified in the stability booklet approved by the Administration or any duly authorized organization.


14. What is the format of the Confirmation of Compliance and Statement of Compliance?

The format of the Confirmation of Compliance (COC) is laid out in the Annex of the IMO Circular MEPC.1/Circ.876.

The format of the Statement of Compliance (SOC) is laid out in the Appendix X of the IMO Resolution MEPC.278(70).


15. How shall the daily fuel oil consumption and BDN data be reported?

The daily fuel oil consumption data shall be reported as per the Appendix 1 of IMO Resolution MEPC.292(71).

The BDN summaries shall be reported as per the Appendix 2 of IMO Resolution MEPC.292(71).


16. Is it mandatory to keep a paper version of the Confirmation of Compliance (COC) and Statement of Compliance (SOC) on-board, or is an electronic version sufficient?

This depends on the requirements of the Flag Administration.


17. If a vessel performing a single international voyage exempted of IMO DCS reporting obligations?

A ship which is not normally engaged on international voyages but which, in exceptional circumstances, is required to undertake a single international voyage, may be exempted by the Administration from any of the requirements in chapter 4 of MARPOL Annex VI as per the IMO MEPC.1/Circ.863.


18. Who will provide the Confirmation of Compliance after review of DCP?

The Confirmation of Compliance (COC) will be issued by the Flag Administration or any duly authorized organization on its behalf.


19. Who will provide the Statement of Compliance (SOC) after verification of DCS fuel oil data?

The Statement of Compliance (SOC) will be issued by the Flag Administration or any duly authorized organization on its behalf.


20. Which documents must be provided for the verification of IMO DCS fuel oil data?

According to Resolution MEPC.92(71), documentation to facilitate data verification may include the following :
 
  • a copy of the ship’s Data Collection Plan
  • summaries of BDNs
  • summaries of disaggregated data for fuel oil consumption, distance travelled and hours underway
  • information to demonstrate that the ship followed the DCP set out in its SEEMP, including information on data gaps and how they were filled (if any)
In addition, a ship may also be requested to submit document needed to perform a more comprehensive review of the data in order to confirm the consistency of reported data and calculated values (including previous periods if applicable), the completeness of the data and its reliability and accuracy.


21. Who is authorized to perform review of DCP and verification of fuel oil consumption data?

The vessel’s Flag Administration or any duly authorized organization by it.


22. Can I use the assessed EU MRV Monitoring Plan (MP) for a vessel for elaborating a SEEMP Part II (Data Collection Plan)?

The DCP template provided by IMO is very similar to the MP template but only includes 9 procedures, most of which are the same as the procedures you can find in your MP. You may either prepare a separate DCP that is independent of the MP (and still re-use the procedures in the MP), or prepare a DCP that makes references to the relevant procedures of your MP.

If you plan to make references to the procedures within your approved MP in the DCP, the full MP must be included as an Annex to the SEEMP. More generally, make sure all documents referenced in the SEEMP Part II are available on-board during PSC inspections.


23. Is an on-board visit required during the review of SEEMP Part II / Data Collection Plan? During fuel oil data verification?

No, an on-board visit is not required.


24. Is an office visit required during the review of SEEMP Part II / Data Collection Plan? During fuel oil data verification?

An office visit may be required only if information and documents cannot be communicated by electronic means.


25. What are the penalties for non-compliance?

The DCP is a new statutory requirement and failure to present this document during PSC inspections may result in the detention of the vessel.


26. Which information will be submitted to the IMO Ship Fuel Oil Consumption database?

As per appendix IX of the IMO Resolution MEPC.278(70), the following information shall be submitted:
 
  • Identity of the ship / IMO number
  • Period of calendar year for which the data is submitted:
    • Start date (dd/mm/yyyy)
    • End date (dd/mm/yyyy)
  • Technical characteristics of the ship
    • Ship type, as defined in regulation 2 of this Annex or other (to be stated)
    • Gross tonnage (GT)
    • Net tonnage (NT)
    • Deadweight tonnage (DWT)
    • Power output (rated power) of main and auxiliary reciprocating internal combustion engines over 130 kW (to be stated in kW)
    • EEDI (if applicable)
    • Ice class
  • Fuel oil consumption, by fuel oil type in metric tonnes and methods used for collecting fuel oil consumption data
  • Distance travelled
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