The Chinese Maritime Safety Administration (MSA) has developed guidelines that document what their officers must examine when completing vessel compliance checks under the Chinese ECA requirements.
The West of England P&I club recently detailed the contents of the guidelines for their members: http://www.westpandi.com/Publications/News/china—emission-control-areas–msa-inspection-criteria/
In the guidelines the checks are split between vessels which switch to low-sulphur bunker fuels and vessels that use alternative compliance measures, for example scrubbers.
When subjected to an inspection by MSA officers, vessels which have switched to low-sulphur bunker fuel will initially undergo a documents check in which the engine logbooks, the supporting paperwork for supply and receipt of bunkers and the records pertaining to fuel switching operations will be examined.
If it is suspected or determined that the vessel’s documentation is non-compliant then sampling and testing of the bunker fuel on board the vessel, in accordance to MARPOL Annex VI, will be undertaken by the Chinese Authorities.
Failure of a vessel in this category to comply with the fuel oil usage requirements within the ECA will result in penalties based on the severity of the infringement.
The punishments imposed could be a warning, a rectification of the violation, the arrest of the vessel or the imposition of financial penalties. Fine imposed under Article 106 of the Law of the Peoples Republic of China (PRC) on the Prevention and Control of Atmospheric Pollution can range from RMB 10,000 to RMB 100,000 and/or under Article 63 of the Regulation on Administration of the Prevention and Control of Marine Environment Pollution Caused by Vessels, a fine of up to RMB 20,000 can be levied.
Vessels using alternative compliance measures (shore base power, clean energies or exhaust gas cleaning equipment) will be subjected to a document check in which the engine logbooks, fuel switching records and vessel certification that governs on board air pollution prevention will be examined by the MSA officers.
If, during the documentation check, there is a suspicion or actual determination that the vessel is in breach of the requirements, then an onsite inspection of the ancillary facilities utilised by the vessel and their operation will be conducted by the MSA.
Penalties for vessels in this category which are not in compliance with regulatory requirements could involve a warning, a requirement for a rectification of the violation or the arrest of the vessel.
Should there be any departure of a vessel from the ECA prior to the completion of the examination by the MSA officer, the MSA will utilise their national inspectorate offices in the PRC to pursue a vessel calling at Chinese ports of call in the future.
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