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June, 2015:

Hong Kong and Dubai: Air emission standards

Hong Kong

In recent years there has been more focus on air borne pollution in Hong Kong and in an effort to control the emission of dark smoke from vessels, Hong Kong has recently amended its legislation.

As per section 50 of the Shipping and Port Control Ordinance (Cap 313) and Section 51 of the Merchant Shipping (Local Vessels) Ordinance (Cap. 548), it is now an offence for any vessel in Hong Kong waters to emit dark smoke for 3 minutes or more continuously at any one time. These legislative changes were gazetted on 18 July 2014 and came into effect immediately.

The Shipping and Port Control Ordinance regulates dark smoke emission from ocean-going vessels, whereas the Merchant Shipping (Local Vessels) Ordinance applies to local vessels.

Dark smoke is defined as smoke which is “dark as or darker than shade 2 on the Ringelmann chart”. The Ringelmann chart has 5 shades ranging from 0 (clear) to 5 (black). The darker the smoke, the more polluting it is.

Sample of the Ringelmann Chart - to be used for reference only, and not as a device for dark smoke measurement Source: Hong Kong Marine Department Notice No. 92 of 2014

Sample of the Ringelmann Chart – to be used for reference only, and not as a device for dark smoke measurement
Source: Hong Kong Marine Department Notice No. 92 of 2014

A vessel found to be in contravention is liable to a fine of HK 25,000 on first conviction and a fine of HK 50,000 for any subsequent conviction. In the case of local vessels, the fines are set at HK 10,000 on first conviction and HK 25,000 for any subsequent conviction. The owner of the vessel, his agent and the master are each deemed to have committed the offence and thus all are required to exercise due diligence to maintain the engine and fuel system on-board in a good condition.

While Hong Kong can record up to 400,000 vessel movements a year, the legislation confers power on authorized agents to direct local vessels to be checked if they have reasonable grounds to suspect the vessel is in contravention.


The government of Dubai issued a statement on 2 July 2014 calling all vessels to ensure strict compliance with its rules on air emissions while in port. All vessels calling DP World/ PCFC ports in Dubai are required to comply with the local PCFC-EHS Ports and Maritime Regulations in addition to the IMO Marpol Annex VI Regulations in an effort to curb air pollution in the area.

The statement issued advises vessels to refrain from unsafe practices causing air pollution such as:

· Ships emitting black/grey exhaust smoke
· Incineration during port stay
· Using fuel oil not in line with Marpol Annex VI requirements

Any contravention to these requirements may result in the imposition of appropriate sanctions including fines.

In addition, all vessels are reminded to maintain their engines and other equipment in good conditions so as to prevent the possibility of environmental pollution. All vessels are also reminded to ensure their IAPP (International Air Pollution Prevention) certificate is valid in all aspects.

Find more information on the IMO Marpol Annex VI Regulations here.

For further information, members are asked to contact the Association:

Nikita Lulla
Claims Assistant, Skuld Hong Kong

Christian Ott
Vice President Head of Claims, Skuld Singapore Branch
Loss Prevention and Recurring Claims Team Leader

Potential for shore-side electricity

AcidNews June 2015

Connecting ships at berth to onshore power will provide health and environmental benefits by reducing air pollution, greenhouse gases and noise.

A recent study by Ecofys on behalf of the European Commission’s DG CLIMA has investigated the potential for shore-side electricity (SSE) in Europe, including the barriers to implementation, and provides recommendations on policy action that the Commission could take to accelerate the implementation of SSE in European harbours.

When at berth, ships typically burn fuel oil in their auxiliary engines to generate electrical power for communications, lighting, ventilation and other onboard equipment. Ships may also burn fuel oil in boilers, for instance to  supply hot water and heating and to prevent the heavy fuel oil from solidifying.

This combustion of fuel oil results in emissions of air pollutants, including the main greenhouse gas, carbon dioxide, in the port areas, which are often located in or near cities. SSE is an option for reducing unwanted environmental impacts of ships at berth.

According to the study’s mapping of the health benefits of SSE, ports in the UK, France, Belgium, the Netherlands, Germany, Denmark, Sweden, Italy, Greece and the Mediterranean islands would gain large benefits from NOx reductions.

Concerning SO2, the biggest benefits of SSE are to be found in the Mediterranean area, Ireland and the western part of the UK.

Current SSE projects show that there can be a business case for all parties, says the study. The initial investment for ship owners and in ports is substantial, but can be recouped from lower operating costs.

Furthermore, huge benefits have been documented in terms of reductions in noise and air pollutant emissions.

The study estimates that if all seagoing and inland ships in European harbours in 2020 were to use SSE to cover their energy demand at berth, they would consume 3,543 GWh annually, equivalent to 0.1 per cent of the electricity consumption of Europe as a whole in 2012. In general, the increase in demand is not seen as problematic for the electricity grid, especially considering that expanding the use of SSE is a medium to long-term process.

The study: Potential for Shore Side Electricity in Europe (January 2015). By Ecofys, the Netherlands.

Downloadable from:

Efficiency standards for ships too easy to meet

AcidNews June 2015

CE Delft has released a study, commissioned by Brussels-based NGOs Seas at Risk and Transport & Environment, which calculated the Estimated Index Values (EIVs) of new ships built between 2009 and 2014, and concluded that the majority of container and general cargo ships built in recent years already meet the IMO’s Energy Efficiency Design Index (EEDI) standards set for 2020.

Of the ships in the study that were built in 2014, some 34 per cent of container ships and 43 per cent of general cargo ships also met the EEDI target for 2030.

The study confirms that the EEDI targets need substantial revision since the current standards fall short on reflecting best practice or the pace with which improvements in efficiency can be brought about.

The study identified a large variation in the EIV of ships of similar type and size, indicating that large additional fuel savings and associated reductions in CO2 emissions would be possible if all ships were built to the best available designs and technologies.

The EIV improvements have coincided with increases in average design speed and decreases in main engine power for a number of ship categories, which suggests an improvement in hull or propulsion efficiency. The findings also suggest that, if design speeds were kept constant, larger improvements in design efficiency would have been possible.

More information at:

New ships less fuel efficient than those built in 1990

AcidNews June 2015

Ships are significantly less energy-efficient today than in 1990, calling for greater steps in regulation and binding energy efficiency standards for the shipping sector.

New ships built in 2013 were on average 10 per cent less fuel-efficient than those built in 1990, according to a new study, “Historical trends in ship design efficiency”, by CE Delft. On average, those earlier ships already beat the so-called “Energy Efficiency Design Index” standard that the International Maritime Organization (IMO) has set for new ships built in 2020.

This first-ever study of the historical trend in the design efficiency of new ships, commissioned by Seas At Risk and Transport & Environment, finds that bulk carriers, tankers, and container ships built in 2013 were on average 12, 8 and 8 per cent less fuel efficient respectively than those built in 1990.

The findings are particularly valuable as they starkly contradict claims that shipping has been constantly improving its environmental performance. They also demonstrate that market forces cannot by themselves lead to more fuel-efficient ships being built and that more regulation is necessary as well as a much stricter Energy Efficiency Design Index standard. It is interesting that at a time when ships were most energy efficient the price of oil was proportionally much cheaper than today (around $25 vs $100 per barrel, in today’s prices).

John Maggs, policy advisor at Seas At Risk and president of the Clean Shipping Coalition, said: “Now we know that we cannot rely on rising fuel prices, other market forces or the good intentions of industry to solve shipping’s climate problem. Instead we need a clear and ambitious target for reducing ship greenhouse gas emissions and legally binding measures to get us there.”

The IMO will review the stringency levels of its Energy Efficiency Design Index (EEDI) – the efficiency standards for new ships – during a meeting of its Marine Environmental Protection Committee (MEPC) in London in May 2015.

Information sources:

CE Delft study:

Press release from Transport and Environment: