As a CE, what is your strategy and action wrt Annex VI when you join?

Answer

As Chief Engineer, on joining I would first verify that the ship is continuously compliant with MARPOL Annex VI and that all machinery, fuel, records, and certificates support that compliance.

1. Check statutory certificates

   • IAPP Certificate
   • EIAPP certificates for applicable diesel engines
   • IEEC
   • SEEMP Part I/II/III as applicable
   • Record of Construction and equipment attached to certificates.

2. Check fuel compliance

   • Verify present fuel sulphur content:
     • 0.50% m/m globally
     • 0.10% m/m in SOx ECAs
   • Check BDNs, bunker samples and retention period.
   • Verify fuel changeover procedure and records.
   • Check any scrubber/EGCS if fitted.

3. Check NOx compliance

   • Verify engines are operating as per NOx Technical File.
   • Check critical components, settings and records.
   • For Tier III ships, confirm SCR/EGR system readiness in NOx ECAs.

4. Check ODS and refrigerants

   • Verify ODS Record Book.
   • Check refrigerant inventory, leaks and maintenance.
   • Ensure prohibited deliberate release is avoided.

5. Check incinerator

   • Confirm IMO-approved incinerator where applicable.
   • Check operating limits and records.
   • Ensure prohibited materials are not incinerated.

6. Energy-efficiency compliance

   • Check EEXI/EPL or SHaPoLi arrangements if applicable.
   • Verify EPL seals/settings and override records.
   • Review CII status and SEEMP Part III corrective actions, if applicable.
   • Monitor fuel consumption and energy-efficiency performance.

7. Fuel consumption data

   • Verify IMO DCS data collection arrangements.
   • Check fuel flowmeters/tank soundings and reporting accuracy.
   • Ensure annual fuel-consumption data is properly recorded.

8. Physical inspection

   • Inspect fuel system, changeover arrangements, sampling points, EGCS/SCR/EGR, incinerator and refrigeration plant.
   • Confirm no unauthorized modifications have been made.