Marpol annex VI and NOxTECHNICAL code

When the prevention of the air pollution becomes a double edge weapon....
The adoption of the  Marpol Annex VI and Nox technical code has opened new and unknown sceneries on  the after market world.
Below the main issues of the above regulation:
“All diesel engines 130KW and above installed on or after 1st  Jan 2000 or in case of major conversion of the engine on or after the same date and each diesel engine  more than 5000 kW  installed on a ship constructed on or after 1 January 1990 but prior to 1 January 2000, must be provided by  the EIAPP (Engine International Air Pollution Prevention) certificate demonstrating compliance with NOx emission limits. The certification process is to be carried out in accordance with the NOx Technical Code issued by IMO. The certification process includes an emission test for compliance with the Nox requirements on the manufacturer’s test bed, and approval of the Technical File. All certified engines are delivered with an individual Technical File that contains the engine’s specifications for compliance with the NOx regulation, and the applicable on board verification procedure.”

The NOx Technical Code opens for 3 different onboard verification procedures:
- Engine parameter check method
- Simplified measurement method
- Direct measurement and monitoring method

The most used procedure is the “Engine parameter check method”, because it is does not require measuring the NOx level to prove that the engine is likely to comply with the NOx emission limits. It is sufficient to know that the present state of the engine corresponds to the specified components, calibration or parameter adjustment state at the time of initial certification.
The engine’s Technical File identifies its components, settings and operating values that influence the exhaust emissions and these must be checked to ensure compliance during surveys and inspections.
The NOx-influencing components and settings are listed in the engine’s Technical File.

The below list shows typical NOx-influencing parameters:
- Injection timing
- Injection system components (nozzle, injector, fuel pump)
- Injection pressure
- Camshaft components (fuel cam, inlet- and exhaust cam)
- Valve timing
- Combustion chamber (piston, cylinder head, cylinder liner)
- Compression ratio (connecting rod, piston rod, shim, gaskets)
- Turbocharger type and build (internal components)
- Charge air cooler/charge air pre-heater
- Auxiliary blower
- NOx abatement equipment “water injection”
- NOx abatement equipment “emulsified fuel” (fuel/water emulsion)
- NOx abatement equipment “exhaust gas recirculation”
- NOx abatement equipment “selective catalytic reduction

How can all this affect the after market?
One of the main consequences of MARPOL Annex VI is that the on board verification procedure “Engine parameter check method” requires identification markings on the NOx influencing components. These components are typically those specified in above list.
All the components listed are to be fitted with identification markings according to the Technical File, normally referred to as IMO-marking. Please note that these markings may not be the same as the article No’s usually found on the engine components, but they must be exactly those stated in the Technical File.
What can we assume? Well, that the air pollution prevention is preserved just by comparing numbers!
Who holds these IMO-markings? The engine makers who have another way to exercise their monopoly on the spare parts  market now.
What can this IMO-marking method carry out? A mess!
The surveyor in the “Engine parameter  check method” must verify the IMO-markings on the NOx-influencing components, but the same manufacturer, who is producing engines on licensee, could have their own IMO-marking on the engine components which however may differ from the designer’s Id Numbers. Moreover, there may be situations where the engine maker comes up with a new design for one of the NOx-influencing components, with a different Id No/IMO marking from the one stated in the Technical File…Therefore the Id No’s will not match in the Technical File as well as.

Nevertheless, everybody knows very well that the variables during the engine running are many and can differ any moment from the on bed test’s results, therefore if the air pollution prevention is the goal that  every human being should aim, then the rules should be focused on the emissions only. 
Emisa wants to fight the effect of the Marpol Annex VI on the independent makers, who have the merit to  keep the after market business still alive and free. In fact, although the independent makers build up their fame on the quality of their parts and services, they seem to be ignored by the institutions.
It is time to act: Emisa is aiming to get the Consultative Status at IMO just to give voice to all those people,  who working hard, have achieved a standard quality that is recognized as equivalent and alternative to the OEM’s equipment.
This is one of the main reasons to join EMISA, united in quality: we will stake our claims!

*sources: “Technical & operational implication of Marpol 73/78 Annex VI” by DNV


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