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IMO DCS (Data Collection System)

Regulation

What is the timeline for IMO DCS implementation?

What is the difference between IMO DCS and EU MRV?

Is DNV GL authorized by all flags to perform IMO DCS?

Answer:
Answer:
DNV GL is authorized by most flags for other statutory services and the process of becoming authorized for DCS too is ongoing. Some flags, however, for example Liberia, will also authorize companies other than traditional class societies (ROs) to perform DCS verification work. 

Will there be any flag-specific requirements, or will the plan prepared in accordance with MEPC.282(70) suffice?

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This is still to be determined, and we will inform our customers if this is the case. Nevertheless, we do not expect significant flag-specific requirements to be adopted. 

If I have class with another class society, can I choose to perform IMO DCS verification and approval with DNV GL?

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It depends on the flag, however, for practical purposes, we do recommend our customers to use the same verifier for EU MRV and IMO DCS. But if you are using another class society for statutory certificates, the flag must accept that another RO is used for DCS (similar as for ISM/ISPS/MLC).

Reporting

Do I need to report both EU MRV and IMO DCS?

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Yes, if the vessel is subject to both EU MRV and IMO DCS, reporting is required as per the respective requirements. 

Can I then do combined reporting?

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Yes. By using DNV GL’s combined reporting template (available around June 2018), you can report on both.

How can I set up the reporting procedure in my company?

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DNV GL will inform its customers in due time about the reporting requirements for DCS. Those shipping companies which have already contracted DNV GL as MRV verifier only need to make minor adjustments for DCS. DNV GL has appointed an interface manager to assist our customers with setting up the reporting to DNV GL. 

I subscribe to DNV GL’s ECO Insight performance solution. Will anything be modified to accommodate the IMO DCS data?

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No. ECO Insight, no matter whether on-board data come from Navigator Insight or from an interfaced in-house or third-party vessel reporting solution, already covers all IMO DCS requirements. Navigator Insight already produces an annual fuel oil consumption report per the regulation.

SEEMP Part II

What is the SEEMP Part II plan and where can I find the template for this?

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  • SEEMP Part II is also referred to as the ship fuel oil data collection plan. It is part of the SEEMP and it describes the procedures for monitoring fuel oil consumption. The guideline for the plan is included in Resolution MEPC.282(70).
  • DNV GL will provide a digital template/app for submitting the plan for approval. Customers should only submit plans through this app, which will be made available around June, well in time for preparation and approval by end of 2018. Customers should submit the plans by the end of August 2018.

If I have class/SEEMP with another class society, can I perform SEEMP Part II with DNV GL?

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Yes, this is possible. The RO must ensure that SEEMP Part II is part of the main SEEMP on board as per MARPOL Annex IV, Reg. 5.4.5 and Reg. 22.2. What is referred to as the main SEEMP does not need to be approved and can thereby independently be handled by another classification society.

I already have an initial main SEEMP on board – can I now make a combined SEEMP which also includes SEEMP Part II?

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SEEMP Part II should be prepared as an attachment to the main SEEMP.

Do ships for which the delivery date is on or after 1 March 2018 need to have SEEMP Part II confirmed by the administration or RO upon delivery?

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SEEMP Part II is to be on board all ships in service on or before 31 December 2018, regardless of the delivery date. 

In case of sale and purchase, is the seller obliged to hand over the plan to buyers?

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The SEEMP remains with the ship and should be handed over to the new owner.

VERIFICATION, OTHER 

What is the fee for approval, and is there any discount if DNV GL has approved the EU MRV plan?

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DNV GL has established a fee level which is competitive compared to other ROs. And, yes, we will provide a discount for companies which use DNV GL both for EU MRV and IMO DCS (synergies and economies of scale). The exact level of pricing and scope of work will be stated in our contract proposal. 

What should I do now?

Answer:
Answer:

DNV GL, as a verifier for the yearly fuel oil consumption reports for DCS, will in due course inform its customers on how to prepare for verification. This includes but is not limited to: 

  • Preparing SEEMP Part II using the SEEMP Part II digital reporting tool at www.dnvgl.com. This will be an online template where customers will be guided to prepare the document. This service will be available by June 2018. We recommend you prepare SEEMP Part II using this app well in advance of the 31 December 2018 deadline to ensure timely assessment for compliance. 
  • In due time, prepare for the DCS reporting of the required data once announced by DNV GL. As for MRV, DNV GL will offer a fully digital reporting approach:
    •  In line with state-of-the-art industry standards for ship-to-shore reporting, minimizing efforts on client’s side 
    •  Providing data quality checks of reported voyage data upon upload so that clients get immediate security about the correctness and completeness of the data they are monitoring and reporting

Whom at DNV GL can we contact in case of further questions?