EU MRV Implementation
Once submitted, the MP must be assessed by an independent verifier by 31st December, 2017. With the first legal deadline only three months away, it’s imperative that ship owners and operators begin on the road to compliance now, not only to avoid severe bottlenecks, but to also ensure quality and operational excellence during demanding times. It is also worth noting the distinction between monitoring plan assessment and emissions report verification, which only takes place yearly effective from January 2019.
A monitoring plan outlines the procedures in place, to monitor, collect, control, and report the data and demonstrates how the ship is compliant with the EU MRV regulation. It combines all the information about ship systems and should be complete, accurate, relevant and compliant. And, where relevant, references should be made to compatible monitoring elements from existing management systems, for example SMS, SEEMP, ISM etc.
There are six distinct sections in the monitoring plan:
- Part A – Versions: This should only take a matter of seconds to complete, as it requires the ship owners or operators’ name and version number
- Part B – Basic Data: Again, this is fairly straightforward and should only take a few minutes. It requires information such as the name of the vessel, the IMO number, what sort of emission sources and the office address.
- Part C – Activity data: This requires additional information such as further details on the emission sources, the fuels used, the distance travelled, the time at sea etc.
- Part D- Data gaps: For this section, the owner or operator must clearly describe how they manage to cover any data gaps of part C, if they appear.
- Part E – Management: This requires details on company management including quality assurance, reviews, as well as any updates when something in operation changes.
- Part F – Further information: This section gives you the option to add any further comments not previously covered. Like Part A, it takes minimal time to complete.
Step 1: Identify your fleet subject to EU MRV
As a first step, the owner or operator must list all vessels for which they are the ‘Company’. In doing so, they must also remove any vessels which are below 5000 GT, do not operate for commercial purposes, or do not plan to operate in the EU in 2018. Then, they must identify ship families, lead ships, and groups of sister-ships.
Step 2: Get Familiar with the Regulatory Requirements
This step requires a thorough review of the requirements outlined within the regulation to ensure quick and efficient compliance.
Step 3: Categorise procedures
Categorise the procedures into company-specific procedures that can be replicated for all company vessels. These are the company’s specific information, the data gap management, and the quality management of the EU MRV regulation. Then, start focusing in on the ship family specific procedures. Once these are complete, focus on the lead vessel procedures. The categorisation procedure helps to ensure a lean and efficient process.
Step 4: Collect Relevant Documents
There are a number of important documents that will be useful and should therefore be kept within easy reach/access. These include the SEEMP, general arrangement plan, bunkering procedure, piping diagrams, fuel management procedure, fuel measurement equipment description, and other relevant manuals and procedures. Based on our experience, we can attest to the fact that between 70-90% of the monitoring plan can be found within these documents. Therefore, the monitoring plan is already available through various sources of information that the ship owner or operator must collect and reference.
Step 5: Prepare a Monitoring Plan for a First Lead Ship
The ship owner or operator is able to use any format they wish for the monitoring plan as there are no restrictions on this. It can either be word, excel, or a solution available from their ICT provider or verifier, for example Verifavia Shipping’s “extranet” (extranet.verifavia-shipping.com), which guides owners and operators through the six-step process towards completion.
Step 6: Engage an Independent Accredited Verifier and Have your MP Assessed
By completing the above steps, ship owners and operators will have a robust, draft monitoring plan to enable them to liaise with Verifavia Shipping and begin our assessment cycle.
The aim of MP assessment is to check consistency between the EU MRV rules, the monitoring plan, and the existing company procedures. To this end, Verifavia Shipping’s EU MRV extranet helps to facilitate the efficient and uniform exchange of any required documents during the assessment of Monitoring Plans.
The EU MRV Regulation is now officially a reality for an estimated 15,000 vessels, and with only three months remaining, shipping operators should focus on completing their selection process as quickly and efficiently as possible, so that they may concentrate on the technical, operational, and commercial procedures.
Verifavia Shipping, and Verifavia Shipping (Hellas) which serves the Greece and Cyprus-based shipping market commit to providing top-of-class service and expertise and ensure the utmost expert, robust, flexible, cost-efficient, swift, and smooth regulatory compliance experience. [...]
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