CII and EEXI (EPL/ShaPoLi) enforcement by PSC

Hello!
What checks are expected by Port State Controls with respect to the CII and EEXI compliance in 2023?

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Hello @Surcouf_Renard

Energy Efficiency Existing Ship Index (EEXI)

Assuming that the verification that the ship’s Attained EEXI took place at the first annual, intermediate, or renewal survey after 1st January 2023, as part of the scope of the IAPP survey, and the IEE certificate documents the vessel’s compliance, the expected Port State Controls (PSC) checks will include:

  • Check the International Energy Efficiency Certificate (IEEC).
    The IEEC will indicate the Attained EEXI and the Required EEXI. When the Attained EEXI is not calculated, the IEEC will indicate the reason for the exemption; for example, the type of propulsion system is exempted (i.e., a bulk carrier with non-conventional propulsion) or if the type of the ship is exempted from the EEXI (i.e., livestock carrier).
  • Check that the EEXI Technical File (TF) is approved and available on board.
    The EEXI TF should be approved by the Flag Administration or a Recognized Organization duly authorized. Keeping a good record of the EEXI TF and the approval letter in soft and hard copies might be helpful during the PSC.
    The IEEC will indicate when the EEDI Technical File is used as an alternative to EEXI TF; in that case, the EEDI TF should be approved and available on board.
    In case of any major conversion, the vessel’s EEDI should be re-calculated, and the new TF version should be approved and available on board.
  • In case of an Engine Power Limitation (EPL) or Shaft Power Limitation (SHaPoLi), the Onboard Management Manual (OMM) should be approved and available on board.
  • The PSC might check the recording status in OMM (e.g., the reason for the un-limiting, ship speed, maximum unlimited power, Beaufort number and wave height, position and timestamp, etc.)
  • If there is any evidence that the EPL or SHaPoLi was overridden without proper notice, then the PSC might conduct a more detailed inspection.

Ship Energy Efficiency Management Plan and the CII
For the scope of SEEMP, the PSC checks will include the following:

  • Check the International Energy Efficiency Certificate (IEEC).
  • Check that the SEEMP Part I is available onboard.
  • Check that the SEEMP Part II is verified and available onboard and that the vessel has the respective Confirmation of Compliance.
  • Check that the vessel has a Statement of Compliance confirming the fuel oil consumption reporting.
  • Check that SEEMP Part III is verified and available onboard and that the vessel has the respective Confirmation of Compliance.
  • Check that the vessel has a Statement of Compliance confirming the attained CII.
  • If the Master of the ship or the crew is not familiar with the essential operations relevant to the implementation of the SEEMP, a more detailed inspection might follow.
  • For ships rated as D for three consecutive years or E for one year, the PSC might check the corrective action plan included in the SEEMP. The absence of the corrective plan is likely to constitute a detainable deficiency.

Extra info on the CII Correction Plan

  • MEPC79 approved Unified Interpretations of MARPOL Annex VI Regulation 28 relevant to the plan for corrective action to achieve the required CII. Therefore, the corrective action plan should plan for achieving the required CII in the second year (YYYY+2) after the reporting year (YYYY) that resulted in the third consecutive D-rating or one E-rating.
  • When a newly built vessel is delivered on 1 October or later, the following year should be the first year of the three-year implementation plan. In that case, the attained CII for the remaining part of the year of delivery can be excluded when determining whether the ship should develop a corrective action plan.
  • When a ship changes company, a new SEEMP Part III will be required to be submitted for verification by the new company.
    The year of change is the starting year of the three-year implementation plan for the new company, and a rolling three-year period should apply. For example, if the company chance occurs in 2024, the three years to be considered in the implementation plan are 2024, 2025, and 2026.
    However, to determine if the Corrective Action Plan is required, a rolling three-year period should consider the ship’s CII performance before the company’s change.
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