Maritime

DCS - Regulation

Which Administrations have authorized DNV GL for DCS?

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We are authorized for all flags except China, South Korea, Indonesia, Brunei Darussalam, Comoros, Cuba, Maldives, Namibia, New Zealand and Tunisia. Gibraltar case-by-case.

Please double-check with FlagIT if in doubt. Please make sure to search for "DCS" also in the upper part of the text, since not all is always included in 12.4.

Are we already aware whether some Administrations will do the approval themselves , as some did for BWM?

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None so far, some Flags like Liberia and probably Germany will issue the confirmations and statements of compliance themselves.

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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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. E.g. Norway has a regulation saying that e.g. SOLAS, MARPOL applies 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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Yes, we see DCS as a service which can be provided by an RO independent from 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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Ref. MARPOL ANNEX VI, Regulation 19 Application, 2.1, 2.2, IMO DCS is not applicable for ships not propelled by mechanical means, and 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?

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In case of flags not party to MARPOL Annex VI, we have no authorization for any of the related certificates.

This means that, as previously mentioned, we can approve SEEMP Part II, issue CoC, verify submitted data, issue SoC – but all of this will be at request of owner and not on behalf of such flag.

The MEPC decision the client is referring to opens up for reporting to IMO also for vessels flying the Flag of non-signatories, as long as DNV GL is authorized by other Flags to submit via GISIS (and we are) – but that this is done separate from the reporting on behalf of ratifying flags. This means that we can undertake IMO DCS, doing it “at the request of owner”, and we can also submit data to IMO on a non-statutory basis.

If the client decides to proceed accordingly, we recommend you contact date@dnvgl.com directly for details on how to proceed.

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

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

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

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Yes, if the vessel starts sailing under a new Flag let's say on 25 April, there has to be prepared and submitted for approval an FOC-report for the period 1 January - 25 April, ref. MARPOL Annex VI, Reg. 22A.4.

DCS - Reporting

How are ships to 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 system to system connection or manually with data files (e.g. csv) in our customer portal. DNV GL will start providing templates and guidance to customers around May / June 2018. System interface specifications and an excel to csv format converter will be provided to ships to ensure that the format of the data is correct when submitted to DNV GL’s system.

What kind of reporting is required from ships to meet the regulatory and verification obligations?

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DNV GL requires the ship to submit disaggregated data by regular 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 upon all port departures and arrivals. In addition, DNV GL recommends that these reports are supplemented by e.g. 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.

Which parameters need to be reported and in which format?

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Consumption data: The report shall include date and time, position, fuel consumed (since last report), distance underway (since last report) and time underway (since last report). 

DNV GL uses the sample form given in Appendix 2 of MEPC.292(71), extended with a timestamp (in addition to date) and port code/position. These two parameters are needed in order to verify the data according to paragraph 4.2 and are required for all ships in order to minimize requests for more information later in the verification process.

Fuel balance:  DNV GL uses the same data fields as in the sample form given in Appendix 1 of MEPC.292(71), extended with a timestamp. This includes remainings on board (ROB) and bunker event reports.

We are already reporting to DNV GL for MRV. Are we covered for DCS?

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DNV GL is offering one combined reporting format covering both MRV and DCS. For DCS 2 parameters have to be added since IMO DCS requires reporting of distance and time spent under own propulsion, which may be different from the total distance and time spent between two ports as required by EU MRV due to e.g. towing and drifting.

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?

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

We do not, however, require to deduct those amounts if included in the total consumption. If the EG-engine is, however, used for operational purposes, the EG-engine must be regarded an auxiliary engine and its consumption be monitored and the emissions be reported.

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

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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?

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

Vessel is changing manager during the calendar year. Which manager is responsible for reporting?

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The previous manager is responsible to submit upon the change of manager the FOC-report for that (first) part of the year during which he was operating the vessel. The new owner shall submit another, 2nd report upon year end (if he doesn't sell the vessel once again prior to year end). This means, Admininstrations (or ROs) have to verify as many FOC-reports for a vessel as the vessel is changing owner 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 ?

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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 will include this option. Daily noon reports are suitable submitted to make such occurrences during a voyage visible.

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

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For DCS, fuels consumed for life boats and emergency generators do not need to be reported, but we don’t require that those consumptions are deducted if included in the total consumption. The fuel consumed for deck lifters, deck chipping machines or hold washing machines is to be reported since these systems are related to operation of the vessel.

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

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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 oil 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?

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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?

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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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No, for DCS consumption needs not 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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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?

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The ship has the following options:

  • departure from berth and arrival at berth
  • daily reports such as noon reports or any other daily reports.
  • Combination of 1+2

How shall we fill in the operational reports / voyage reports / csv-files / event reports?

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Irrespective of the vessel type, the reports shall be filled in accordance with the guidance provided in the sheet "Notes" in the CSV file converter DNV GL is providing in the DNV GL fleet portal > MRV & DCS tab > Manage data > Available templates, file name "Log abstract and bunker report templates".

What is the IMO No. To be put in on the bunker report? The bunker delivery vessel or our bunkered vessel?

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In the bunker reports, the IMO No. Of the vessel receiving the bunker shall be filled in.

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.

Do we have to report log abstracts in the format specified by DNV GL or can we use our own format?

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For the fully digital service we are offering for DCS approvals, the log abstract reports need to be submitted in our format.

In order to support you with formatting the data, we are offering for download a csv-converter which will convert the data into a correctly formatted csv-file when clicking “Export to CSV-file” in the top left corner.

In case you are reporting by noon reports, you can used the sheet “Log abstract – DCS noon”. If you are reporting voyages you can use the sheets “Log abstract – minimum” or “Log abstract – full”. The latest version of the converter can be found on DNV GL Veracity / Fleet status > MRV & DCS > Manage data > Available templates, together with an ever growing set of information about MRV and DCS such as sample files and guidance videos.

Please also note that for reporting log abstracts for MRV, sheets “Log abstract – minimum” or “Log abstract – full” should be used. The same data will be applied also for DCS and there is no need to send duplicate reports.

Please also read carefully the “Notes” sheet which contain important information on how to report correctly.

Isn't the log abstract reporting scope required by DNV GL far more than the scope required by IMO? Aren't the IMO DCS minimum requirements only 1. Period of calendar year, 2. Distance travelled, 3. Fuel per type in total, 4. Hours underway and 5. DWT proxy?

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In order to verify the data, the regulation and guidelines set additional requirements beyond the aggregated annual reporting to IMO. In the IMO guideline MEPC.292(71) the required documentation is stated, including disaggregated data (i.e. noon reports or voyage reports) and BDNs, that is needed for us as RO to do the verification – see in particular appendices 1 and 2.

The minimum scope of log abstract reporting is reflected in sheet “Log abstract – DCS noon” of our csv-converter we are offering for download on DNV GL Veracity / Fleet status > MRV & DCS > Manage data > Available templates.

NOTE: For clients explicitly asking for the minimum reporting requirements for DCS only: The minimum scope of log abstract reporting is reflected in our "CSV file converter - DCS noon" we are offering for download on DNV GL Veracity / Fleet status > MRV & DCS > Manage data > Available templates.

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 by 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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The frequency of the updates is up to the user’s preference. Since DNV GL will provide you 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?

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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 (FOC-report) to be submitted for approval. In order to ensure that the statement of compliance (SOC) on the FOC-report can be issued for the ship also in case of any issues, we recommend submitting the FOC-report well before this deadline.

The digital log abstract and bunker report csv files required for the digital approval approach of DNV GL is a different thing and shall be submitted in addition. The MARPOL deadline does not apply to those reports. While it would theoretically be sufficient if they are submitted together with the FOC-report, we strongly recommend to 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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Cargo monitoring is not required for DCS at all. The cargo capacity (i.e deadweight, GT, NT) of the vessel is declared in the annual FOCR as deadweight as a proxy instead.

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

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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 the declaration of wind force mandatory?

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Wind force declaration is voluntary.

We are exempted from per-voyage reporting for MRV due to doing more than 300 voyages per year. Can we use the same reporting method for DCS?

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Yes, provided that you have made a SEEMP Part II referring to the method in the MRV Monitoring Plan we will accept period reporting for DCS, unless the flag explicitly requires daily/noon reports.

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

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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 in the fleet portal (MRV&DCS > manage data > available templates)

FOC - Report, SoC

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

Guidance videos

WEBINAR: IMO DCS and EU MRV reporting (July 2018)

Video and presentation

From EU MRV to IMO DCS

Download our 8-page guidance paper

EU MRV Regulation guidance paper

Download our 16-page publication

EU MRV Reporting: webinar slide deck

Download PDF (Jan 2019)

Get in touch with the MRV and DCS support team

For customer: DATE – Direct Access to Technical Experts via My Services on Veracity

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CONSOLIDATED VERSION: Regulation (EU) 2015/757 as amended by Commission Delegated Regulation (EU) 2016/2071