(www.MaritimeCyprus.com) With only four months to go (1 January 2019) before data collection starts for the IMO DCS (Data Collection System), companies should, as soon as possible, submit their SEEMP Part II for approval. Some recommendations from DNVGL to make your IMO DCS implementation process more efficient:
EU MRV Monitoring Plan accepted as a basis for SEEMP Part II
For ships with an EU MRV Monitoring Plan, the monitoring method described in the plan will be accepted as the data collection method required in the SEEMP Part II. The MRV data requirements are more comprehensive than for DCS. As such, the MRV Monitoring Plan content also fulfils the requirements for DCS if the same method is applied also outside the EU. To accept this “combined solution”, the EU MRV Monitoring Plan shall be approved by DNV GL (they cannot accept EU MRV Monitoring Plans approved by other verifiers)
Some other useful practicalities:
- A SEEMP Part II Fuel Oil Consumption Plan should be issued referring to the EU MRV Monitoring Plan. This SEEMP Part II shall be kept on board the vessel together with the EU MRV Monitoring Plan, as part of the Ship Energy Efficiency Management Plan (SEEMP).
- A Confirmation of Compliance document will be issued.
- Any references in the EU MRV Monitoring Plan that only apply to voyages within the scope of the EU MRV shall be understood to include all voyages in the context of this (SEEMP Part II) data collection plan.
- For 2019 and beyond, for the combined EU MRV / IMO DCS reporting solution: if you are reporting for MRV, you will also fulfill the IMO DCS reporting requirements if reporting throughout the year (i.e. also for voyages outside the EU).
This option will be available for DNVGL customers under Fleet Status on the Veracity platform (separate tab for MRV and DCS).
- Start early! Deadline for submission of the SEEMP Part II is 31 December 2018, but we recommend you submit your Part II for approval before the end of September 2018 – this to ensure verification before the year’s end.
- For those who do not use DNVGL for EU MRV verification, we recommend you develop the SEEMP Part II Fuel Oil Consumption Plan in our app for easy compliance. The app is available in My Services on Veracity (this is for DNV GL customers only)
- We also recommend you start reporting fuel oil consumption data already on 1 January 2019, and not wait until end of the year to submit all data. This allows you to correct any reporting mistakes or improve routines as soon as possible.
- If reporting for MRV, the same reporting format can be used for DCS as well, but reports must then also cover voyages outside the EU.
- If reporting for IMO DCS only, customers can select to report by daily (noon) reports or at all port departures and arrivals. DNV GL recommends that departure and arrival reports are supplemented by, for instance, noon reports to ensure that there is at least one daily report.
- Remember that bunker delivery notes must be reported for both MRV and DCS.
We do recommend that those of our customers who have used our app for generating the EU MRV Monitoring Plan, use this as basis for generating the SEEMP Part II for IMO DCS compliance. This saves time and money, and ensures compliance. For those of our customers who not already use DNVGL for EU MRV verification, or do not sail in the EU, we recommend to use our SEEMP Part II app for IMO DCS compliance.
- DNV GL web pages on IMO DCS
- Technical and Regulatory News from May 2018: "Practical advice for IMO DCS data collection starting 1 january 2019"