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News: Requirements for the use of scrubbers in Australian waters & reporting to AMSA

30 December 2019

​Further to club’s previous article on scrubber guidance, members with ships trading in Australian waters are advised that AMSA has issued a marine notice 05/2019 on the requirements for the use of scrubbers in Australian waters and associated reporting. Following is the summary of requirements relating to the use of EGCS in Australian waters. 

Approval and operation of scrubbers (EGCS)

  • The EGCS must be approved by the vessel’s flag state, or a recognised organisation appointed by the flag state.
  • The EGCS must also be operated in accordance with IMO requirements, including the IMO 2015 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68)).
  • Crew members must be properly trained in the use of the EGCS and the system must be kept in good working order, with maintenance up to date and monitoring devices fully operational.
  • The EGCS approval documents, as well as operational and maintenance records for the EGCS must be maintained on board the vessel and made available for inspection upon PSC Officer request.

Notification to AMSA before arrival at the first Australian port

The master, owner or operator of a vessel using an EGCS is requested to notify AMSA before first arrival at an Australian port after 1 January 2020, and provide the following information to

  1. Vessel name (in email subject title)
  2. IMO number
  3. Arrival port
  4. Arrival date
  5. EGCS Scheme A or Scheme B approval
  6. Make and Model of EGCS
  7. Open-loop, closed-loop or hybrid-type system
  8. Results of all wash water testing that has been undertaken in accordance with 2015 Guidelines for Exhaust Gas Cleaning Systems

Wash water testing should be conducted upon commissioning of the EGCS and repeated every twelve months, as a minimum, for a period of two years. Ships may be directed not to discharge wash-water from an EGCS in Australian waters if this data, or evidence that samples have been taken for analysis, cannot be provided to AMSA before arrival at the first Australian port.

EGCS malfunctions

If there is an EGCS malfunction, action must be taken as soon as possible to identify and remedy the malfunction. Any EGCS malfunction that lasts more than one hour, or repetitive malfunctions, should be reported to the flag State Administration and Competent Authority of the port state of the vessel's destination. The report should include an explanation of the steps that are being taken to address the failure.

If the vessel’s EGCS cannot be returned to a compliant condition within one hour, the vessel must then change over to compliant fuel oil. If the vessel does not have sufficient compliant fuel oil to reach the next port of destination, the vessel will need to make a report to the relevant authorities, including the vessel’s flag State Administration and the Competent Authority for the next port of destination.

The report must outline the vessel's proposed course of action which might include bunkering compliant fuel oil at the next port or carrying out repair works. Where this occurs on an Australian vessel or a foreign vessel within Australian waters, this report should be sent to

Any EGCS found to be not in compliance with IMO guidelines in any respect (including but not limited to the wash water discharge criteria) may be prohibited from use in Australian waters.

Monitoring of wash water discharges

AMSA may take samples of EGCS wash water discharges for the purposes of further studies on potential environmental impacts.

AMSA is undertaking further assessment of potential cumulative impacts of EGCS wash water discharges, which may result in further restrictions on their use in Australian waters in the future.

Members are also recommended to refer to AMSA marine notice 04/2019 which provides details on the implementation of the IMO 2020 low sulphur fuel requirement, in line with MARPOL Annex VI and Australia’s domestic law.