Increased transparency of local scrubber washwater regulations: BIMCO’...

Increased transparency of local scrubber washwater regulations: BIMCO’s proposal to the IMO

Published: 14 November 2023

BIMCO has submitted a proposal to the 11th session of the IMO Sub-Committee on Pollution Prevention & Response (PPR 11), proposing the establishment of a database of local restrictions on the discharge of scrubber washwater thus enabling greater transparency for the industry.

Currently, there is a vast array of regional, national and local restrictions on the discharge of washwater from scrubbers, all of which differ significantly in their scope and level of stringency. The lack of a common database consolidating all the information on the various local restrictions on the discharge of washwater from scrubbers has resulted in numerous complications, including contractual disputes between shipowners and time charterers. The differences in the wording of the various restrictions and the difficulty in obtaining the necessary information make it problematic for shipowners and operators to stay up-to-date and compliant.

Previously, some suggestions were made to the IMO to tackle this issue. For example, in November 2021, the 77th session of the Marine Environment Protection Committee (MEPC 77) outlined the need to develop a database encompassing the different restrictions on the discharge of water from Exhaust Gas Cleaning Systems (EGCS), also known as scrubbers. However, the question of making the disclosure of local regulation on scrubber washwater more transparent remains open to date.

The proposal submitted by BIMCO is based on creating a publicly available central database, to which the IMO Member States will provide the necessary data. Such a central source of information will significantly increase the transparency thus easing the burden of shipowners and operators to ensure compliance. This database will facilitate the process of navigating the diverse and dispersed field of local scrubber washwater discharge regulations.

The 11th session of the IMO Sub-Committee on Pollution Prevention & Response, which will address this proposal, will be held from 19 to 23 February 2024.

See the currently known local scrubber washwater regulations and restrictions as collected by BIMCO.

The BIMCO proposal to the IMO Sub-Committee on Pollution Prevention & Response is available for downloading below.

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