VERIFAVIA SHIPPING - Marine Notice 180625 - Preparation and review of Data Collection Plans (SEEMP Part II)

The amendments to MARPOL Annex VI Chapter 4 Regulation 22A on the collection of fuel oil data of ships - the IMO Data Collection System (IMO DCS) - came into force on 1st March 2018. As a manager of ships subject to the IMO DCS, you now need to prepare a Data Collection Plan (DCP) (SEEMP Part II) for each ship outlining the procedures, systems and responsibilities to monitor fuel data, distance travelled and hours underway.

The DCP has to be submitted to the Flag Administration or any duly authorized organization before 1st September 2018 (recommended deadline) for a review that must be completed before 31st December 2018, just before the start of the first monitoring period (2019). The successful review of the DCP will result in the issuance of a Confirmation of Compliance which must be kept on-board from 1st January 2019 onwards.

The DCP is a new statutory requirement and failure to present this document during PSC inspections may result in the detention of the vessel. Therefore we urge you to start the preparation of the DCP and have it reviewed as soon as possible, to avoid delays due to heavy workload of Flag Administrations and authorized third parties towards the end of the year.

When drafting the DCP within SEEMP Part II, it is critical to bear in mind that it is a statutory document that must be kept on-board. Therefore, all documents referenced in the SEEMP Part II must also be available on-board. If you plan to make references to the procedures within your approved EU MRV Monitoring Plan (MP) in the DCP, the full MP must be included as an Annex to the SEEMP.

Verifavia is duly authorized to perform IMO DCS verification by several Flag States including the Panama Maritime Authority, the Liberia Maritime Authority, The Antigua & Barbuda Department of Merchant Shipping and Marine Services (ADOMS), the Palau International Ship Registry (PISR), and the Vanuatu Maritime Services. Through a cooperation with our partner ROs, we can also perform IMO DCS verification for ships registered in a number of 'small' Flag States including Barbados, Belize, Comoros, Cook Islands, Kiribati, Saint Vincent & the Grenadines, St Kitts & Nevis, etc. See the full list here.

If you operate ships registered in Panama, Liberia, or any of the 'small' Flag States, we can review your DCPs and verify your fuel oil data on behalf of the Flag Administration with a simple amendment to our existing verification agreement. For other Flag States, the review of the DCPs will have to be done by your classification society(ies). However, we are committed to supporting you in the preparation of you DCPs, and guide you through the review process to make it as straightforward as possible for you.

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, with the MP included in the Annex.

For more information:
> read our IMO DCS web page
> read our IMO DCS coming into force article
> read our presentation on IMO DCS, inc. detailed comparative analysis IMO DCS vs. EU MRV
> read our article on our EU MRV and IMO DCS verification approach

Relevant IMO documents to download:
> download IMO Resolution MEPC 278(70)
> download IMO Guidelines for the development of DCP (SEEMP Part II)

Templates to download:
> download DCP template (Word)
> download BDN summaries template and data collection template (Excel)

If you operate ships registered in Panama, Liberia, or in any of the 'small' Flag States, please let us know and we will send you our IMO DCS agreement for your review and consideration. For the sake of simplicity, our agreement will come as a simple extension to our original EU MRV verification agreement.

It is important to note that the IMO DCS does not affect our ability to perform EU MRV verification. As an accredited verifier, we can verify any ship anywhere in the world, regardless of country or Flag State. We will soon send you some information and guidance for the preparation of your 2018 emissions report.

Please feel free to contact us at anytime for any questions you may have on the IMO DCS, on the preparation or review of the DCPs or on the differences between EU MRV and IMO DCS. Back to all Verifavia Shipping News