With three weeks to go before IMO’s fuel data collection system (DCS) starts on 1 January 2019, many companies still have not submitted their SEEMP Part II fuel oil consumption data collection plan for approval. This statutory news contains some last-minute recommendations.
Relevant for ship owners and managers.
A selection of clarifications and recommendations can be found below which will make your IMO DCS implementation process more efficient towards 1 January 2019:
- Submit the SEEMP Part II via the digital plan generator (app) as soon as possible to ensure verification in due time
DNV GL urges you to submit the SEEMP Part II for approval as soon as possible to ensure you receive the Confirmation of Compliance (CoC) before the year’s end. For data collection plans generated by the app (available in Fleet Status in Veracity) and without any flag-specific constraints (see below), DNV GL ensures verification and will issue the CoC before 1 January 2019, if the plan is submitted within a few days from today. For manually prepared plans, which should be avoided – please use the app – the verification period is longer, so that DNV GL cannot ensure verification and issuance of the CoC before 1 January 2019. One of the reasons is that manual plans often require additional clarification time. - Stamping of SEEMP Part II plan
Please note that DNV GL does not stamp verified SEEMP Part II plans, since this is not a requirement of the MARPOL Annex VI regulation. Submitted SEEMP II plans are verified and a digital CoC is issued by DNV GL as proof of compliance with the regulation. The CoC issued refers to the latest SEEMP Part II plan verified by DNV GL, and this is sufficient as evidence of compliance. The verified SEEMP Part II and the CoC are required to be available on board, e.g. in connection with port state control. If the methods and processes described in the EU MRV Monitoring Plan are being used as basis for the SEEMP Part II, the MRV MP must be attached to the SEEMP Part II and available on board. - Other practical recommendations to the IMO DCS implementation
- DNV GL recommends you start delivering noon/voyage reports and bunker delivery notes from 1 January 2019, and not wait until the end of the year before submitting all required data. This allows you to correct any reporting mistakes or improve routines as soon as possible. According to DNV GL’s experience, this requires some effort in the beginning but quickly becomes part of daily routines.
- If you are reporting for EU MRV, the same reports can also be used for IMO DCS – there is no need to send duplicate reports.
- In case of owner or flag change, please note that a Fuel Oil Consumption report is required for the period until the changeover. If you are buying a ship, make sure that the previous owner has reported the data and that you receive a Statement of Compliance valid for that period.
- If you are using the EU MRV Monitoring Plan as a basis for creating the IMO DCS Part II – and have not received confirmation from DNV GL (due to ongoing communication, etc.) – we recommend you create the SEEMP II directly with the SEEMP II plan generator app in order to meet the 1 January 2019 deadline.
- Based on frequently asked questions, DNV GL provides a number of guidance videos about MRV and DCS procedures. These videos have been integrated on our IMO DCS webpages and will be posted on My Services in Veracity as well.
The first two videos are about:
- How to prepare voyage data
- How to update report files
More related videos will be released soon.
Recommendations
Make sure the SEEMP Part II is submitted for verification, preferably via the plan generator app, as soon as possible.
References
- DNV GL web pages on IMO DCS
- Technical and Regulatory News No. 14/2018
- Technical and Regulatory News No. 6/2018
Contact
- For customer: DATE – Direct Access to Technical Experts via My Services on Veracity
- Otherwise: Use our office locator to find the nearest DNV GL office.