MRMC have pulled together this helpful guide to the statutory requirements regarding Engine International Air Pollution Prevention Certificates (EIAPPC) – a subject of much confusion and misunderstanding. This article was written exclusively for The Superyacht Group by Mark Robinson, Master Mariner & Principal Surveyor and published on 12th February 2016.
Read the article here or the full unabridged version below.
EIAPPC? Don’t get caught out.
The acronym EIAPPC stands for an Engine International Air Pollution Prevention Certificate in case you were wondering, and is not to be confused with the IAPPC (International Air Pollution Prevention Certificate).
Mark said: “Having conducted in excess of 200 surveys for various Flag Administrations, pre-purchase and condition surveys, we are still finding that the EIAPPC and associated ‘technical file’ is still generally an unknown statutory obligation.”
Understand the Requirements
MARPOL (in general) applies to all vessels. The magic Gross Tonnage (GT) for yachts that must carry MARPOL certification to prove compliance is 400GT.
There are however some anomalies such as, for example, whether the vessel carries 15 or more persons but less than 400GT (Garbage Record book) or more than 15 persons but less than 400GT (International Sewage Pollution Prevention certificate).
The EIAPPC is similar in a way, being a requirement for vessels that have marine diesel engines fitted and having an output in excess of 130kW; this requirement is for ALL vessels irrespective of being commercially or privately registered.
When Do You Not Need an EAIPPC?
- It does not apply to marine diesel engines intended to be used solely for emergencies (lifeboats etc.)
- It does not apply to marine diesel engines installed on a vessel solely engaged in voyages within waters subject to the sovereignty or jurisdiction of the State of which the vessel is entitled to fly provided that such engines are subject to an alternative NOx control measures established by the Administration.
- It does not apply to a marine diesel engine that was fitted before 01 January 2000.
The legislation is contained within MARPOL Annex VI and the NOx Technical Code (Technical Code on Control of Emission of Nitrous Oxides from Marine Diesel Engines) as amended, which goes into detail if you are in doubt of its applicability to your yacht.
Am I Compliant?
When checking whether your yacht is compliant start with asking the Chief Engineer if he has the engine technical files to hand; in there you will hopefully find the EIAPP certificate for each marine diesel engine, usually issued by the Class society associated with the testing of NOx emissions. This is done at factory level and applies to the family of engines that yours belongs to.
Most Flag Administrations will accept these as proof of compliance. Some Flag Administrations may issue their own or require the Class Society associated with the yacht to issue on their behalf. Keep these originals in the technical files associated with each marine diesel engine. Make copies of the originals and file them in the yacht’s statutory certificate folder so that they are ready at hand for inspection by Port State Control Officials, Flag state surveyors and Class surveyors.
Don’t Get Caught Out
When buying and/or commissioning your yacht the technical files are not always provided (or even mentioned) by the broker, engine manufacturer or yard associated with the build. Make sure that it is a provision of the sale and that the EIAPPCs contained within the technical files are specified. Doing this retrospectively after sale will cost in the region of 2,500EUR upwards for each certificate from the engine manufacturer; remember that EIAPPCs are also required for each generator should the Kilowatt output be >130kW.
Mark concludes: “To put the above into context for a yacht without EIAPPCs (within the technical files) of approximately 50m, you may be looking at a bill in excess of 15,000EUR to meet these requirements. That is surely a point for the negotiation table and none of us like unwanted surprises!”
