Maritime

DCS - Regulation

What is the different flags' scope of authorization for SEEMP II and FOC-R verification?

Answer:
Answer:

Most flags have authorized DNV GL for all five tasks:

  1. Verification of SEEMP II
  2. Issuance of the confirmation of compliance (CoC) on the SEEMP II
  3. Verification of fuel oil consumption report (FOC-R) data
  4. Issuance of the statement of compliance (SoC) on the FOC-R
  5. Reporting the FOC-R data to IMO-database GISIS

Several flags have, however, limited the scope of authorization to only some of the five tasks or they have imposed additional requirements, e.g.:

  1. DNV GL shall report the FOC-R data to flag (e.g. VUT, PAN)
  2. DNV GL shall recommend to flag to issue SoC (e.g. PAN, LBR)
  3. DNV GL shall report the disaggregated data to flag (e.g. LBR+)
  4. DNV GL shall recommend owner to request issuance of SoC from flag (e.g. MYS)
  5. DNV GL shall invoice the ship and pay certain DCS surcharge to flag (e.g. LBR)

Can a vessel (OSV) flying Singapore flag operating merely in Norway be regarded on “local trade” and as such as not as being subject to DCS?

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Answer:

Usually, a ship operating solely within the economic zone (200 nm) flies the flag of that country and is subject to national rules which may or may not differ from the international rules. For instace, Norway has a regulation stating that SOLAS and MARPOL, for example, apply with some adjustments – the DCS regulation applies without modification for ships in domestic trade. A ship operating on the Norwegian shelf with a non-Norwegian flag is required to have international trading certificates, which includes the DCS statement of compliance.

Does DNV GL offer the DCS service for vessels not classed by DNV GL?

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Answer:

Yes, DCS is as a service which can be provided by an RO independent of the class of the vessel, if not instructed otherwise by the responsible flag state authority.

Are there any exemptions of application for ships with gross tonnage 5000 tonnes and above for IMO Data Collection System?

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Referring to MARPOL Annex VI, Regulation 19, Applications 2.1 and 2.2, the IMO DCS is not applicable to ships not propelled by mechanical means as well as to platforms, including FPSOs and FSUs and drilling rigs, regardless of their propulsion.

Can DNV GL support clients operating vessels flying flags of non-MARPOL parties?

Answer:
Answer:

Yes, DNV GL can perform such verification work upon request by the owner/manager, but not on behalf of such a flag (ref. MEPC.1/Circ.871 from 4 September 2017).

DNV GL can also submit data to the IMO on a non-statutory basis. If the customer decides to proceed accordingly, we recommend you contact date@dnvgl.com directly for details on how to proceed.

If a ship changes company during a year, who is responsible to prepare the fuel oil consumption reports in that year?

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Answer:

Each manager is responsible for reporting his part of the year, i.e. upon change of company, the previous manager shall submit the report for his part of the year (ref. MARPOL Annex VI, Reg. 22A.5).

In such a case, the manager must request the creation of the related reporting period and submit the FOC-R via the Fleet Status portal on Veracity.

If the vessel changes flag during the year, does that trigger an FOC-report?

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Answer:

Yes, a flag change triggers an FOCR verification for the respective flag period of the vessel (ref. MARPOL Annex VI, Reg. 22A.4).

What are the legal requirements for DCS compliance?

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Answer:
  1. Develop a Data Collection Plan (SEEMP Part II) and have it reviewed by the flag administration or any duly authorized organization.
  2. Monitor and report fuel oil consumption data, hours underway and distance travelled, and have the data verified by the flag administration or any duly authorized organization.
  3. Carry a confirmation of compliance on board for the updated SEEMP (from 1 January 2019) and carry the statements of compliance on board for the required fuel oil consumption reports.

Are there any exemptions possible from DCS requirements?

Answer:
Answer:

Exemptions may be granted by the flag administration from any of the requirements in chapter 4 of MARPOL Annex VI as per IMO MEPC.1/Circ.863 (vessels not normally engaged in international voyages).

What are the compliance deadlines for DCS?

Are there any exemptions possible from DCS requirements?
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Answer:
  • 1 September 2019: Submission of the SEEMP Part II to the verifier
  • 1 January 2019: Confirmation of compliance (CoC) for the updated SEEMP must be on board
  • 30 March each year: Deadline for the submission of the annual fuel oil consumption report to the verifier (MARPOL Reg. 22a)
  • 31 May each year: Statement of compliance (SoC) for the fuel oil consumption report must be on board

DCS - SEEMP Part II

What is the SEEMP part II plan?

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Answer:

The SEEMP Part II is also referred to as the ship fuel oil data collection plan. It is part of the SEEMP and describes the procedures for monitoring fuel oil consumption. The SEEMP II document requires confirmation from a verifier. The guideline for the plan is included in Resolution MEPC.282(70) under Paragraphes 6 through 8, and a sample form is provided in Appendix 2.

Is DNV GL providing a template for preparation of the SEEMP II plan?

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DNV GL provides a web application (app) for creating and submitting the plan for approval on the DNV GL customer portal. Clients should submit plans through this app instead of manually preparing their SEEMP II plans.

DNV GL also offers the possibility to have MRV monitoring plans verified by us and approved as SEEMP II if the client confirms in the app that the monitoring methods for the IMO DCS are the same as for the EU MRV.

Are the SEEMP II plans subject to approval?

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The regulations require that the SEEMP contains the above-mentioned data collection plan (SEEMP II). The SEEMP II is subject to confirmation by the flag or an RO. After confirmation, a confirmation of compliance will be issued.

Will DNV GL confirm compliance of SEEMP II plans for non-DNV GL classed vessels?

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Answer:

Yes, subject to authorization and approval by the respective flag. Vessels not under DNV GL class are also welcome to order the DNV GL DCS verification service (SEEMP II and annual FOC report verification). In certain cases, the flag may decide that the RO performing the DCS certification should be the same RO covering the statutory.

Do the emergency generator engine or lifeboat engines have to be listed under the consumers in SEEMP II?

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Answer:

No, the fuel consumed by the EG engine or the LBEs is not considered fuel in terms of MARPOL since it is not used for propulsion or operation. If the EG engine is, however, used for operational purposes, it must be regarded an auxiliary engine and, as such, that engine has to be listed as an emission source, its consumption be monitored and the emissions be reported.

Can SEEMP II be submitted separately of SEEMP part I ?

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Answer:

Yes, SEEMP II should be submitted separately. SEEMP I is not subject to approval. Only part II of SEEMP is subject to approval according to MARPOL Annex VI, Reg. 5.4.5.

Regulations 5.4.1 to 5.4.4 only require the SEEMP to be on board but don't require a check or approval of SEEMP Part I.

Will DNV GL accept the Confirmation of Compliance (CoC) for the SEEMP II from the previous RO?

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No, upon change of flag and/or company, a new SEEMP II has to be submitted and a new CoC issued.

Can DNV GL approve SEEMP II plans if not authorized for that by the flag of the vessel?

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Yes, in such cases DNV GL can approve the plan and issue a confirmation of compliance on their behalf.

Do all flags accept the digital signature on the CoC for the SEEMP II plans?

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The CoC is not a certificate, it is a compliance letter. In cases of statements of compliance or other certificates, the IMO guideline FAL.5/Circ.39/Rev.2 applies.

Specific flag conditions may apply and must be taken into account.

If a vessel has ice class, is this to be declared in the SEEMP II plan or in the fuel oil consumption report?

Answer:
Answer:

The DCS regulation requires that ice class be reported as part of the fuel oil consumption report, and it should also be included in SEEMP Part II.

What is the deadline to submit SEEMP II plans to DNV GL for approval?

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Answer:

All existing vessels engaged in international trade from 5,000 GT upwards shall have an SEEMP II on board.

Newbuilt vessels shall have the plan on board before starting international trade. In order for DNV GL to verify the SEEMP II and to issue the confirmation of compliance in time before delivery, clients are advised to submit the plans well in advance.

Plans generated with DNV GL's app will be approved normally within 1 week or a maximum of 2 weeks after submission.

Depending on the authorization by flag, additional time should be considered for the flag's handling.

Why is DNV GL not stamping the SEEMP II after approval? How is the link between the CoC and the plan ensured?

Answer:
Answer:

DNV GL does not stamp verified SEEMP II plans, since this is not required by the regulation.

After approval of the SEEMP II, a digital confirmation of compliance (CoC) of the plan with the regulation is issued.

The CoC contains a reference to the approved SEEMP II as evidence that the particular SEEMP II is approved and compliant.

Verified plans shall be kept on board together with the CoC issued by DNV GL.

For some flags, we receive a verification letter and not a confirmation of compliance after verification of the SEEMP II. Why is that so?

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Answer:

DNV GL is not authorized to issue the confirmation of compliance for some flags, e.g. Liberia or Germany. The confirmation of compliance will be issued by the flag.

Since the International Energy Efficiency Certificate (IEEC) requires that a SEEMP II is on board, can DNV GL issue the IEEC if the CoC for the SEEMP II was issued by an RO other than DNV GL?

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Generally yes. If DNV GL is handling the statutory issues for a vessel, DNV GL will issue the IEEC for that vessel, also if the SEEMP II was approved by an RO other than DNV GL, provided flag doesn't require that the RO performing DCS shall be the same RO covering the statutory.

In the SEEMP II generator app, the form is filled with one or more incorrect ship's particulars. How can I get this corrected?

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In the SEEMP II generator app, you can now change vessel particulars. After editing, press the Submit button to submit the updated plan .

If a vessel holds an International Energy Effeciency Certificate (IEEC) issued by DNV GL prior to the SEEMP Part II approval/issuance of CoC, does the IEEC need to be re-issued?

Answer:
Answer:

No, the IEEC does not need to be re-issued due to SEEMP Part II approval/issuance of CoC.

Can we submit SEEMP II before vessel comes into our management? By when shall we do that?

Answer:
Answer:

The SEEMP Part II should be updated and approved and the CoC issued before bringing the vessel into service after the takeover.

In order for DNV GL to verify the SEEMP II and to issue the confirmation of compliance in time before delivery, clients are advised to submit the plans well in advance.

Plans generated with DNV GL's app will be approved normally within 1 week or a maximum of 2 weeks after submission.

Depending on the authorization by flag, additional time should be considered for the flag's handling.

DCS - Digital reporting to DNV GL

Which disaggregated data shall ships report to DNV GL?

Answer:
Answer:

DNV GL requires ships to submit disaggregated data by regularly reporting on specific events throughout the year (para 4.1). Event reports are required to calculate:

  • Consumption data: based on log abstract reports (arrival/noon/departure) containing position, fuel consumption, distance and time. At minimum, ships should report on all port departures and arrivals. In addition, DNV GL recommends that these reports be supplemented bym, for instance, noon reports to ensure that there is at least one daily report.
  • Fuel balance: based on bunker delivery note reports and log abstracts reports containing remaining on board (ROB). DNV GL requires reporting at bunkering (BDN) and a remaining on board (ROB) report at the start, mid and end of the year.

How shall ships report to DNV GL?

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Ships need to report voyage data / log abstracts to DNV GL in a digital manner. The data can be submitted by a system-to-system connection or manually with data files (e.g. .csv) in our customer portal. System interface specifications and an Excel to .csv format converter are provided to ensure that the format of the data is correct when submitted to DNV GL’s system.

Can I do combined reporting for MRV & DCS?

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Yes. By using DNV GL’s combined reporting template, you can report both.

Customers are advised to contact their customer support to ensure the contractual basis is set for the needed verification service scope, i.e. that DCS is also covered.

Do we need to report the consumptions of emergency generator engines or lifeboat engines? How about the fuel consumed for e.g. deck lifters on e.g. PCTCs, deck chipping machines or bulk carrier hold washing machines?

Answer:
Answer:

That is not required since the fuel consumed by the EG engine or the LBEs is not considered fuel in terms of MARPOL, as it is not used for propulsion or operation.

We do not, however, require the deduction of those amounts if included in the total consumption.

If the EG engine is, however, used for operational purposes, it must be regarded an auxiliary engine and its consumption be monitored and the emissions be reported. The fuel consumed for deck lifters, deck chipping machines or hold washing machines is to be reported since these systems are related to the operation of the vessel.

Vessel is changing company during the calendar year. Which company is responsible for reporting voyage data and submitting the FOC-R?

Answer:
Answer:

Each company is responsible for reporting voyage data and submitting FOC reports for their part of the year. This means administrations (or ROs) have to verify as many FOC reports for a vessel as the vessel changes companies during the year.

If a vessel is doing negative speed in any 24 hr period due to bad weather / current, how it will be accounted for in the subsequent verification / plausibility check of data ?

Answer:
Answer:

There is no negative speed. If the vessel is moving in the opposite direction for some time during a voyage due to bad weather / currents, the distance shall be reported as distance under own propulsion if propulsion is on. If propulsion is off, the distance is to be reported as distance not under own propulsion. Our reporting template for DCS includes this option. Daily noon reports are suitable to make such occurrences during a voyage visible.

How do we calculate the consumption for a voyage extending across the data reporting period acc. MEPC.282(70), ch. 7.1.1.3?

Answer:
Answer:

Regarding MEPC.282(70)/Chapter 7.1/1.3, our understanding is as follows:

If a voyage extends beyond the end of the data reporting period, the fuel oil consumption of the part of the voyage belonging to the previous reporting period is assessed as follows:

Remainings on board (ROB) are measured at the start and at the end of the voyage in order to determine the fuel oil consumption for the entire voyage. The consumption to be reported for the first part of the voyage (C) is then calculated by multiplying the total voyage fuel oil consumption (X) with the ratio between the duration of the first part of the voyage (Y) and the duration of the total voyage (Z), hence C = X*Y/Z.

Should the distance travelled during DP operations also be recorded as distance travelled for IMO DCS?

Answer:
Answer:

Yes, any distances travelled at sea (also including drifting) shall be reported as distance travelled.

Does fuel consumed for other means than combustion for propulsion or ship operation, e.g. for well intervention (diesel injection) have to be reported as consumption for DCS?

Answer:
Answer:

No, only fuel consumption for combustion for propulsion or ship operation has to be reported.

Does fuel consumed for other means than combustion for propulsion or ship operation, e.g. for well intervention (diesel injection) have to be reported as consumption for DCS?

Answer:
Answer:

No, only fuel consumption for combustion for propulsion or ship operation has to be reported.

Do vessels need to split consumption monitoring between port and voyage times?

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Answer:

No, for the DCS, consumption does not need to be split between port and voyage times. Please note, however, that time at sea is the time between departure from berth and arrival at berth.

How is time at sea defined?

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Answer:

As per the regulation, the time spent at sea is defined as the time spent under own propulsion. We interpret this as the time between departure from berth and arrival at berth, including drifting, DP and tug assistance / towage but excluding anchorage.

Which events have to be reported?

Answer:
Answer:

The ship has the following options:

  1. Departure from berth and arrival at berth
  2. Daily reports such as noon reports or any other daily reports
  3. Combination of 1 and 2

What is the IMO-no. to be put in on the bunker report? The bunker delivery vessel or our bunkered vessel?

Answer:
Answer:

In the bunker reports, the IMO number of the vessel receiving the bunker shall be entered.

Shall small distances travelled under DP, e.g. 0.1nm be reported?

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We have not specified minimum distances, i.e. any distance travelled should be reported.

How should we report log abstracts for seismic vessels or offshore service vessels at sea for months without port call?

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We recommend that vessels with such service patterns report via daily noon reports.

How often do we need to upload the log abstract and bunker report csv files – daily, weekly, monthly, once a year?

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This is up to the user’s preference. But, since DNV GL provides managers with a quality check of the data as they come in, we recommend taking advantage of this by submitting the data on a frequent basis in order to fix any issues timely.

If we chose to submit the digital log abstract report csv files only once a year, i.e. after the end of the year, by when do we have to submit it? Can we chose to submit the files within three months after the end of the calendar year, i.e. By 31 March?

Answer:
Answer:

The deadline specified in MARPOL (Annex VI, Reg. 22A. 3), namely "within three months after the end of the year", refers to the annual aggregated fuel oil consumption report (FOCR) to be submitted for approval. The digital log abstract and bunker reports (disaggregated data) need to be submitted prior to the FOCR so that DNV GL's system can use them to prepare the FOCR and present it to the manager for his review and submission for verification. Since the disaggregated data need to be free from issues before the DNV GL system can aggregate them to the FOCR, managers should submit these data on a frequent basis throughout the reporting year to take advantage of DNV GL's data quality check service in order for the manager to be able to fix any issues in the monitoring of the data in a timely manner.

Do we need to log every cargo change for DCS?

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Answer:

Cargo monitoring is not required for DCS at all. The cargo capacity (i.e dead weight, GT, NT) of the vessel is declared in the annual FOCR as dead weight as a proxy instead.

Is the declaration of the duration and the distance of navigation in ice mandatory?

Answer:
Answer:

No, it is voluntary, even for ice-classed vessels. We recommend not reporting those figures separately. Those figures shall, however, not be left out but shall be reported together with the non-ice navigation figures.

Is there a similar exemption from voyage monitoring for DCS as there is for MRV?

Answer:
Answer:

For DCS, there is no requirement for voyage monitoring. Vessels using the DNV GL approach for period monitoring for MRV, however, are fulfilling the DNV GL approach for DCS reporting automatically. In general, if the vessel has to fulfil DCS only, it should report departures and arrivals or one (noon) event per day (ref. the notes sheet in the .csv converter available on the Fleet Status portal [MRV & DCS > Manage Data > Available Templates]).

We have uploaded csv-files for DCS reporting. How can we tell the upload was successful? Can we see any feedback in the data quality dashboard?

Answer:
Answer:

It is appreciated that you familiarize yourselves with the upload of .csv files to our system.

Immediately after a successful upload, our system will inform you about the number of reports (lines) it has received. By clicking the blue Overview link on the far left in the Manage Data tab, you can get an overview of uploaded log abstracts and bunker reports and the last date of upload for each vessel. You can also download the uploaded data for a certain time frame and make sure that what was received is what you intended to upload.

After a maximum of 24 hours after the upload, you can find that data quality feedback in the data quality tab on the Fleet Status portal.

Do we need to keep the disaggregated data onboard the ship?

Answer:
Answer:

No, according to MEPC.1 Circ.795 Rev. 3, item 13, interpretation on Reg. 22A.8, the disaggregated data is not required to be kept on board the ship, provided that the disaggregated data can be made available by the company.

What is the reporting period for DCS?

Answer:
Answer:

The reporting period starts either on 1 January or on the day after the end of a previous period and ends either on 31 December or on the day of a change of flag or of a change of company.

This means that if the vessel does not change flag or company during a calendar year, the reporting period is that calendar year. Otherwise, there will be reporting periods ending and starting at change of flag or change of company (ref. MARPOL IV, Reg. 22A.4 and 22A.5).

Which emission factor shall we use for 0.5% VLSFOs which may range from residual (HFOs or LFOs) to distillate (MDO / MGO) type?

Answer:
Answer:

The reporting of the fuel type should be according to the ISO 8217 grade, merely viscosity being decisive:

  • Grades RME through RMK, Emission factor 3.114: HFO
  • Grades RMA through RMD, Emission factor 3.151: LFO
  • Grades DMX through DMB, Emission factor 3.206: MGO

The emissions from the combustion of 0.5% VLSFOs, which, depending on the stock of the bunker supplier, may be of residual (HFOs or LFOs) or distillate (MDO / MGO) type, may be monitored as follows:

  1. Either use the correct emission factor according to the viscosity and type
  2. Or use the highest Cf of the fuels involved, e.g.:
    a. If mixing HFO, LFO and MDO in one tank: use Cf of MDO
    b. If mixing HFO and LFO in one tank: use Cf of LFO

Do we need to report the consumption of the GCU (gas combustion unit) on our LNG carrier as consumption for DCS?

Answer:
Answer:

Yes, the consumption of the GCU must be reported. As per MARPOL, “fuel oil means any fuel delivered to and intended for combustion purposes for propulsion or operation on board a ship, including gas, distillate and residual fuels”. GCUs are related to the operation, thus the gas burnt there, even if only for flaring, is for operational purpose, thus qualifies as fuel oil the consumption of which must be reported.

8. DCS - FOC-report, SoC

If a vessel has ice class, is this to be declared in the SEEMP II plan or in the fuel oil consumption report?

Answer:
Answer:

The DCS regulation requires that the ice class is reported as part of the fuel oil consumption report, and it should also be included in the SEEMP Part II.y/p>

By when does the FOC-report have to be submitted to the ADM / RO?

Answer:
Answer:

Within three months after the end of each calendar year (ref. MARPOL Annex VI, Reg. 22A.3).

DNV GL as RO recommends, however, that FOC reports are submitted as soon as possible after the end of the reporting period to facilitate timely approval.

By when does the statement of compliance for the FOC-report have to be issued?

Answer:
Answer:

Five months after the beginning of the calendar year (ref. MARPOL Annex VI, Reg. 6.6).

Will the annual fuel oil consumption report be approved by a surveyor on board?

Answer:
Answer:

No, DNV GL aims to minimize site visits. All data are required to be reported online and will be verified in DNV GL offices, thus also the FOC report will be verified and the statement of compliance will be issued in the involved DNV GL offices.

Upon verificiation, a digitally signed statement of compliance will be issued and sent to the client.

Will DNV GL verify annual fuel oil consumption reports for non-DNV GL classed vessels?

Answer:
Answer:

Yes, subject to authorization and approval by the respective flag. Vessels not under DNV GL class are also welcome to order the DNV GL DCS verification service (SEEMP II and annual FOC report verification).

Will DNV GL provide the yearly aggregations for the IMO DCS FOC-reports?

Answer:
Answer:

Yes, just as for MRV, we will also provide clients with the aggregation of the figures for the DCS FOC reports based on their submitted voyage data for their confirmation.

What happens if the previous owner does not provide the new owner with an SoC for the previous part of the period? Will the new owner suffer any consequences?

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Answer:

The regulation requires all SoCs to be on board, but does not specify the consequences for the new owner if they have not received it from the previous owner. This is still to be determined by the IMO and PSC.

Can FOC-Rs be verified if the vessel has not CoC of the SEEMP II?

Answer:
Answer:

No, all vessels of 5,000 GT and above shall carry the SEEMP II on board. Laid-up or docked vessels are no exception. According to MARPOL Annex VI, Reg. 22.2 and 22A.1, FOC-Rs cannot be verified without the SEEMP II.

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