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.
None so far, some Flags like Liberia and probably Germany will issue the confirmations and statements of compliance themselves.
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.
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.
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.
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 email@example.com directly for details on how to proceed.
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.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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.
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.
Yes, any distances travelled at sea (also including drifting) shall be reported as distance travelled.
No, only fuel consumption for combustion for propulsion or ship operation has to be reported.
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.
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.
The ship has the following options:
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".
In the bunker reports, the IMO No. Of the vessel receiving the bunker shall be filled in.
We have not specified minimum distances, i.e. any distance travelled should be reported.
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.
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.
We recommend that vessels with such service patterns report by daily noon reports.
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.
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.
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.
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.
Wind force declaration is voluntary.
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.
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)
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.
Video and presentation
Download our 8-page guidance paper
Download our 16-page publication
Download PDF (Jan 2019)
For customer: DATE – Direct Access to Technical Experts via My Services on Veracity