What is your experience with Tier 3 (EGR or SCR) systems malfunctions, within NECA?
There is this guidance for scrubber systems ,MEPC.1/Circ.883 , that “allows” for 1 hour malfunctions, full text below:
1. Any malfunction that lasts for more than one hour or in case of repetitive malfunctions, in pursuant to regulation 5.6 of Annex VI of the MARPOL Convention, it is imperative that such a situation is reported to the flag Administration of the vessel, to the vessel’s Class and to the relevant port State control competent authority, along with an explanation of the steps the ship operator is taking to address the failure.
Is it a big leap of logic to apply this “allowance” also to EGR systems?