Guidance notes

Revised MARPOL Annex VI

Regulation 12 – Ozone Depleting Substances

1. Introduction

1.1. These Guidance Notes have been prepared and updated for the use of Lloyd’s Register (LR)
Group Surveyors, Ship Owners and Ship Managers. They provide guidance on the
requirements of MARPOL 73/78, Annex VI, Regulation 12 (hereafter referred to as Revised
MARPOL Annex VI).

1.1.1. These guidance notes are divided into sections covering; the application, survey, reporting
and certification of equipment under Revised MARPOL Annex VI.

1.2. Revised MARPOL Annex VI will enter into force on 01 July 2010. The original MARPOL
Annex VI entered into force on 19 May 2005. Ship Owners have already undertaken
verification surveys and International Air Pollution Prevention (IAPP) Certificates should be
in place.

1.3. Revised MARPOL Annex VI covers air pollution from ships caused by emission of ozone
depleting substances. Whilst new fire-extinguishing installations containing ozone
depleting halons had been prohibited as from 1 October 1994, existing system may still
contain halons. Therefore, fire-fighting aspects continue to be included in these guidance
notes.

1.4. Revised MARPOL Annex VI, Regulation 12 applies to all ships and to fixed and floating
drilling rigs and other platforms. Ships of 400 gross tons and above must be surveyed and
issued with an IAPP Certificate before the ship is put into service. For existing ships of 400
gross tons and above, engaged in international voyages, the next renewal survey shall be
such as to ensure that equipment, systems, fittings, arrangements and material comply fully
with applicable requirements of the Revised MARPOL Annex VI.

2. Surveys

2.1. A survey is conducted to confirm that the arrangements and equipment will, with proper
maintenance, be expected to remain in good condition and good working order until the
next survey.

2.1.1 Only on those occasions where the required reception facilities or necessary replacement
equipment is not available locally, would items be considered for deferment.

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2.1.2 Revised MARPOL Annex VI surveys will normally be dealt with in their entirety and not as
part surveys.

2.2 An Annual Survey will consist of:

2.2.1 Verification that the certificate on board is in order.

2.2.2 An examination of the various items of equipment to an extent which, in the surveyor’s
judgement, indicates that no changes, additions or disposal has occurred since the last survey,
that the equipment remains in a satisfactory condition and that the standard of maintenance is
considered acceptable until the next due Survey.

2.3 An Intermediate Survey will consist of:

2.3.1 An Annual Survey plus:

2.3.2 A thorough examination to ensure that the equipment complies with the requirements of the
current Regulations and is in good working order, sufficient until the next Survey.

2.4 To assist in preparing for an Annual Survey or Intermediate Survey, a provisional survey
checklist has been developed. (Refer to Appendix I)

3. Applicable sections of Revised MARPOL Annex VI

3.1 Regulation 3 (Part)

Exceptions and Exemptions

General

1. Regulations of this Annex shall not apply to:

.1 any emission necessary for the purpose of securing the safety of a ship or saving life at sea; or

.2 any emission resulting from damage to a ship or its equipment:

.2.1 provided that all reasonable precautions have been taken after the occurrence of the
damage or discovery of the emission for the purpose of preventing or minimizing the
emission; and

.2.2 except if the owner or the master acted either with intent to cause damage, or recklessly
and with knowledge that damage would probably result.

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3.2 Regulation 6 (Part)

Issue or endorsement of a Certificate

1 An International Air Pollution Prevention Certificate shall be issued, after an initial or renewal survey
in accordance with the provisions of regulation 5 of this Annex, to:

.1 any ship of 400 gross tonnage and above engaged in voyages to ports or offshore terminals under
the jurisdiction of other Parties; and

.2 platforms and drilling rigs engaged in voyages to waters under the sovereignty or jurisdiction of
other Parties.

3.3 Regulation 12 (Full)

Ozone Depleting Substances

1 This regulation does not apply to permanently sealed equipment where there are no refrigerant charging
connections or potentially removable components containing ozone depleting substances.

2 Subject to the provisions of regulation 3.1, any deliberate emissions of ozone depleting substances shall
be prohibited. Deliberate emissions include emissions occurring in the course of maintaining, servicing,
repairing or disposing of systems or equipment, except that deliberate emissions do not include minimal
releases associated with the recapture or recycling of an ozone depleting substance. Emissions arising
from leaks of an ozone-depleting substance, whether or not the leaks are deliberate, may be regulated by
Parties.

3.1 Installations which contain ozone depleting substances, other than hydro-chlorofluorocarbons, shall be
prohibited:

.1 on ships constructed on or after 19 May 2005; or

.2 in the case of ships constructed before 19 May 2005, which have a contractual delivery date of the
equipment to the ship on or after 19 May 2005 or, in the absence of a contractual delivery date,
the actual delivery of the equipment to the ship on or after 19 May 2005.

3.2 Installations which contain hydro-chlorofluorocarbons shall be prohibited:

.1 on ships constructed on or after 1 January 2020; or

.2 in the case of ships constructed before 1 January 2020, which have a contractual delivery date of
the equipment to the ship on or after 1 January 2020 or, in the absence of a contractual delivery
date, the actual delivery of the equipment to the ship on or after 1 January 2020.

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4 The substances referred to in this regulation, and equipment containing such substances, shall be
delivered to appropriate reception facilities when removed from ships.

5 Each ship subject to regulation 6.1 shall maintain a list of equipment containing ozone depleting
substances.2

6 Each ship subject to regulation 6.1 which has rechargeable systems that contain ozone depleting
substances shall maintain an Ozone Depleting Substances Record Book. This Record Book may form
part of an existing log-book or electronic recording system as approved by the Administration.

7 Entries in the Ozone Depleting Substances Record Book shall be recorded in terms of mass (kg) of
substance and shall be completed without delay on each occasion, in respect of the following:

.1 recharge, full or partial, of equipment containing ozone depleting substances;

.2 repair or maintenance of equipment containing ozone depleting substances;

.3 discharge of ozone depleting substances to the atmosphere:

.3.1 deliberate; and

.3.2 non-deliberate;

.4 discharge of ozone depleting substances to land-based reception facilities; and

.5 supply of ozone depleting substances to the ship.

2 See Appendix I, Supplement to International Air Pollution Prevention Certificate (IAPP Certificate),
section 2.1.

3.4 Regulation 17 (Full)

Reception Facilities

1 Each Party undertakes to ensure the provision of facilities adequate to meet the:

.1 needs of ships using its repair ports for the reception of ozone depleting substances and
equipment containing such substances when removed from ships;

.2 needs of ships using its ports, terminals or repair ports for the reception of exhaust gas cleaning
residues from an exhaust gas cleaning system, without causing undue delay to ships; and

.3 needs in ship-breaking facilities for the reception of ozone depleting substances and equipment
containing such substances when removed from ships.

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2 If a particular port or terminal of a Party is – taking into account the guidelines to be developed by the
Organization – remotely located from, or lacking in, the industrial infrastructure necessary to manage
and process those substances referred to in paragraph 1 of this regulation and therefore cannot accept
such substances, then the Party shall inform the Organization of any such port or terminal so that this
information may be circulated to all Parties and Member States of the Organization for their information
and any appropriate action. Each Party that has provided the Organization with such information shall
also notify the Organization of its ports and terminals where reception facilities are available to manage
and process such substances.

3 Each Party shall notify the Organization for transmission to the Members of the Organization of all
cases where the facilities provided under this regulation are unavailable or alleged to be inadequate.

4. Guidance for surveyors for compliance with Regulation 12

4.1 General

4.1.1 The following notes are provided to give guidance on compliance with Regulation 12 of
Revised MARPOL Annex VI and are expected to produce a more consistent approach to
compliance. There is at present no section in the Marine Survey Procedures Manual (MSPM)
which covers compliance with Regulation 12 and as such the following notes should be used
when appropriate. There will always be exceptions to allow compliance. Novel
arrangements should not be discounted but should be given special consideration.

4.1.2 It is considered that no specific plans or information are required to be submitted to allow
appraisal of the fire fighting and refrigeration systems which may utilize ozone depleting
substances. If deemed necessary by the attending surveyor, details of the refrigerant leak
monitoring system and a plan showing the location of all detector sensor heads may be
submitted, to allow verification of its acceptability.

4.2 Changes to the legislation

4.2.1 Regulation 12 covers the recording of refrigerant use, the deliberate emission of ozone depleting
substances and the removal of these substances from the ship. It does not cover the operation
of systems which utilize these refrigerants or halons onboard existing ships. Whilst still not
specifically stipulating that a leak detection regime needs to be undertaken, the statement that
emissions arising from leaks of an ozone-depleting substance, whether or not the leaks are deliberate, may
be regulated by Parties is perceived to indicate that a form of leak prevention and leak detection
need to be provided as regulated by the Parties.

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4.2.2 The statement now made in Regulation 12, paragraph 3.2 is for installations which contain
hydrochlorofluorocarbon (HCFC) refrigerants to be prohibited as from the 01 January 2020.
The previous statement was for new installations containing HCFCs to be banned after 01
January 2020; however, the meaning is the same.

4.2.3 Since the original MARPOL Annex VI entered into force the requirements of the Montreal
Protocol has been tightened. The Nineteenth Meeting of the Parties decided in December
2007 to accelerate the phase-out of HCFCs. Now, by 2020 the global consumption of HCFCs
in developed counties is to be limited to 0.5% of the 1989 level and non-developed (Article 5)
countries 65% of the 2009 level. No mention has been made of prohibiting the use of HCFCs
in existing systems.

4.2.4 It is likely that compliance with the Revised Marpol Annex VI Regulation 12 requirements
will be overtaken by national and global legislation, especially if the requirements of the
Montreal Protocol are again accelerated.

4.3 Applicability – circulating fluids

4.3.1 The applicability is defined in paragraph 1 of Regulation 12. The regulation does not apply to
permanently sealed equipment where there are no refrigerant charging connections or
potentially removable components containing ozone depleting substances. Domestic
refrigerators, domestic freezers, ice makers, water coolers and self contained air-conditioners
are usually sealed systems and thus outside the scope of complying with Regulation 12.

4.3.2 There are no fixed definitions of which refrigeration systems and fire fighting arrangements
are considered to fall within Regulation 12. For air conditioning systems and refrigeration
installations guidance on what equipment is considered to be subject to Regulation 12 stems
from the construction practices used. The following statements may clarify this situation.

4.3.3. If all the items of refrigeration equipment which contain the primary refrigerant, such as; the
compressor, receiver, condenser and evaporator form part of a ‘stand alone’ unit which is
supplied in a fully charged condition, (with the refrigerant already in the system), then it is
considered to be a sealed or ‘retail’ unit and not considered under Regulation 12. Examples of
this are; domestic refrigerators and freezers, small self contained (free standing) air
conditioning units, drinking water fountains and self contained service air dryers.

4.3.4 Refrigerant machinery supplied loose and fabricated onboard is considered subject to the
Regulation 12. Systems manufactured or fabricated ashore where all the refrigeration
equipment is installed, pressure tested and filled with a holding charge of refrigerant and
supplied as part of a package unit are considered subject to Regulation 12. Any system,
independent of size, which is manufacture from separate items of equipment and fitted to
bedplates or skid, is also considered subject to Regulation 12.

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4.3.5 All centrally located accommodation air conditioning system packaged units are considered
subject to Regulation 12. If the air conditioning unit is of integral construction, where only
cooling water and electrical supplies are connected, such as a ‘through the bulkhead’ unit,
then this may be exempt.

4. 3.6 Independent of the type of system, if the equipment is supplied loose and is installed,
pressure tested and charged with refrigerant on board then this type of unit is considered to
fall within the requirements of Regulation 12. It is normally obvious from looking at the
refrigeration pipework and components that the system has been constructed from separate
items of equipment. The tell-tail signs being; equipment mounted on bulkheads, multiple
bedplates, de-mountable (flare) couplings and flange connections on the major items of
equipment. Examples of this type of unit are; domestic provision rooms with the
compressors remotely located, split air conditioning units with the condenser mounted
externally away from the evaporator/compressor set (often referred to as “splits”) and air
conditioning air handling units utilising primary refrigerant.

4.4 Applicability – blowing agents use in insulation

4.4.1 The most popular insulation materials used on existing ships are; polyurethane foam,
expanded polystyrene and extruded polystyrene. Polyurethane foam, either in the standard
50/50 mix or 80/20 polyisocyanurate mix, is the most widely used insulation especially for
pre-fabricated domestic provision rooms and cold chambers constructed from panels.

4.4.2 To make the rigid polyurethane foam, two components - MDI (diphenyl methane diisocyanate)
and polyol (polyether or polyether resin), are mixed together. During the initial mixing stage
other components are added. The main one, termed the ‘blowing agent’, is a chemical with a
suitably low boiling point which is added in smaller quantities. As the heat of reaction
volatilises the blowing agent, numerous small bubbles of blowing agent vapour, known as
cells, are formed in the mixture.

4.4.3 When rigid foams were first developed the blowing agent selected was chlorofluorocarbon
(CFC) R-11. When CFC R-11 started to be phased out under the Montreal Protocol in the
early 1990’s, HCFC R-141b, with a boiling point of 32°C, was near universally introduced for
blowing polyurethane foam. As both of these gases are ozone depleting, thus affected by
Regulation 12, there is a requirement for them to be delivered to a suitable reception facility.
Thus if foam is being replaced, or the ship scrapped, the removed insulation must be sent to
a suitable reception facility.

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 4.5 Ozone depleting substances

4.5.1 CFC (chlorofluorocarbon) refrigerants, such as R-11, R-12 and R-502 are ozone depleting
substances and as such have been banned under the Montreal Protocol. A major landmark
was passed on 01 January 2010, when the production and consumption of CFCs, even in the
developing (Article 5) countries, was banned. Thus, the use of these refrigerants to maintain
existing installations, which is construed as being consumption, is also prohibited.

4.5.2 There may be possible essential-use exemptions for CFCs; however, these are likely to be
only for medical inhalers. In conclusion, CFC refrigerants are now prohibited from use in
any refrigeration systems on all ships, independent of the Flag Administration, as from 01
January 2010.

4.5.3 HCFC (hydrochlorofluorocarbon) refrigerants, such as R-22, R-123 and various blends are
currently going through a transitional period of legislation. Regulation 12 makes an
exception for HCFCs and only requires them to be prohibited by 01 January 2020. However,
other legislation, such as Regulation (EC) 2037/2000 (now recast as Regulation (EC)
1005/2009) of the European Parliament, banned the use of HCFCs from use in new
refrigeration and air-conditioning installations effective from 01 January 2001. In accordance
with the European Commission, if the ship’s Flag Administration is a member of the
European Community, this legislation applies. America, Australia and Japan all have HCFC
specific legislation, however, the applicability of this legislation has not be confirmed.

4.5.4 Halons, such as 1211 or 1301, have been used as fire fighting media and as they are ozone
depleting substances they are affected by Regulation 12. SOLAS II-2 Regulation 10-4.1.3 has
prohibited the installation of new systems using halon since October 1994. On existing ships,
systems containing halon can remain in service until replaced or required to be removed by
international, national or other legislation or requirements. The release of halon can still be
undertaken in accordance with the requirements of Regulation 3. Where there is any concern
regarding the acceptability of the fire fighting media being used, advice should be obtained
from a local Plan Appraisal Centre or London.

4.6 Ozone benign substances

4.6.1 HFC (hydrofluorocarbon) refrigerants and fire fighting media, such as HFC R-134a and HFC
R-227ea (FM-200) were originally developed as alternatives to CFC refrigerants and halons.
Subsequently, there has been a plethora of binary and ternary HFC mixtures being
promoted as HFC refrigerants, such as R-410A and R-404A. Regulation 12 does not affect
HFC refrigerants as these are not ozone depleting substances.

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4.6.2 Natural substances, such as ammonia (R-717), carbon dioxide (R-744) and propane (R-290),
are all used as refrigerants and are not ozone depleting substances. Thus, Regulation 12 is
also not applicable to these refrigerants.

4.6.3 The various HFC gases and fluorinated ketone which are being marketed as direct or near
direct drop in replacements for halon 1301 are all considered ozone benign substances. A list
of these substances is shown in Appendix 2. Other alternatives to halon 1301 such as
nitrogen, argon and carbon dioxide are all ozone benign substances and need not be
considered.

4.7 Maintenance equipment

4.7.1 Compliance with the statement in paragraph 32 of Regulation 12, that deliberate emissions
occurring in the course of maintaining, servicing, repairing of the equipment shall be
prohibited will require specialist servicing equipment. If maintenance of the refrigeration
and air-conditioning equipment is to be undertaken by ship’s staff, then this specialist
equipment will need to be available onboard. If maintenance is contracted out to a third
party, such as a shore-side refrigeration contractor, this company and not the ship is to
provide all necessary equipment.

4.7.2 Before maintenance of the refrigeration equipment can be undertaken, the refrigerant needs
to be removed or reclaimed from the section or item of equipment to be worked on. This
requires the section or item of equipment to be ‘pumped down’ (put under a partial vacuum
using the refrigeration system’s own compressor if possible) and then isolated. After
isolation the section is to be connected to a refrigerant recovery unit.

4.7.3 If the refrigeration system utilises HCFC refrigerant, then some form of refrigerant recovery
system is essential.

4.7.4 Refrigeration recovery units contain a vacuum pump, which can work to very low vacuums
(less than 1 torr), and a condensing unit, which allows the gas to be removed, condensed to
a liquid and stored. The unit has either its own (internal) recovery refrigerant container
(usually 13 kg) or is connected to an external cylinder (13, 26 or 55 kg). These cylinders are
supplied in various colours, the colour may indicate which refrigerant it contains, but it
should, in every case, have a yellow band or section around the cylinder neck to indicate
that it contains recovered refrigerant.

4.7.5 It should also be noted that it can take considerable time for the entire refrigerant charge to
be reclaimed from a system, especially to liberate all refrigerant from the oil retained in the
compressor sump.

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4.7.6 Minimal releases of refrigerant, such as will occur when the recovery unit pipework is
disconnected from the system, can not be readily prevented and as such is acceptable in
accordance with paragraph 2 of Regulation 12.

4.7.7 If the ship’s staff are to undertake the maintenance of the refrigeration system(s) and a
recovery unit, complete with a specialist container or external cylinder, or cylinders if more
than one type of refrigerant is used, is not provided, then paragraph 2 of Regulation 12 is
considered to be contravened.

4.8 Plan appraisal aspects - refrigeration

4.8.1 Very few refrigeration system installed on ships are classed. Only when the owner, or
operator, requests the Refrigerating Machinery Certificate (RMC) notation to be assign to
the ship, is the refrigeration system approved. If the Environmental Protection (EP) notation
is to be assigned, the applicable refrigerant systems are also considered but do not require
plan approval. When the RMC or EP notation is assigned, compliance with Revised
MARPOL Annex VI will form part of the appraisal process. However, for the vast majority
of air-conditioning and provision room systems, no plan appraisal has been undertaken.

4.8.2 Thus, on new ships it will be for the attending surveyor to investigate which refrigerants are
being used. It is a requirement of most refrigeration and air conditioning design codes that
the refrigeration plant is clearly labelled with the refrigerant used. The quantity of
refrigerant in a system can be difficult to determine, especially if long pipe runs are used.
The amount of refrigerant in each system should be requested from the yard or when
possible the specialist sub-contractor. If no information is available, a refrigerant charge
calculator can be provided, if required contact; refrigeration@lr.org.

4.8.3 Refrigerants and refrigerant blends have been formulated to operate at their most efficient
under certain evaporating and condensing temperatures. Thus it is normal to have one
refrigerant in an air-conditioning system which has a high evaporating temperature and
another in a provision room system which has a lower evaporating temperature. Thus it is
common to have two different refrigerants on the same ship and in use next to each other.

4.8.4 Once the type (R number) and quantity of refrigerant charge (kg) for each refrigeration
system is known, this information and the locations of the main items of equipment should
be recorded under paragraph 2.1.2 of the Supplement to the International Air Pollution
Prevention Certificate. The same information should be recorded in the refrigerant log book,
retained on board. If replacement refrigerant is stored onboard, then the number, size and
the content of each cylinder and its location should be recorded.

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 4.9 Plant appraisal aspects – fire fighting media

4.9.1 As fire fighting system are always appraised for SOLAS and Class requirements it is
proposed that the fire fighting medium is also considered for compliance with the
requirements of Revised MARPOL Annex VI.

5. Guidance for surveyors – Initial Survey

5.1 Fire fighting equipment and extinguishing media

5.1.1 The surveyor attending the initial SOLAS survey is to confirm that the equipment and
extinguishing media on board are in keeping with the approved fire control plans and
suitable for use.

5.1.2 It should be confirmed that no fire fighting system on board, including secondary systems
such as compressor rooms on gas carriers and galley cooker hoods on passenger ships,
contain halon or any other banned substance.

5.2 Refrigeration equipment and systems

5.2.1 The location of each applicable refrigeration system is to be established.

5.2.2 The type and quantity of refrigerant in each system is to be determined by inspection and
the documentation for each system. For smaller systems, such as engine room control room
air conditioning, an estimate of the charge may be necessary if no documentation is
available.

5.2.3 Existing equipment containing CFC refrigerants may continue in operation. However,
Revised MARPOL Annex VI bans the use of all CFCs in existing refrigeration systems if the
ship was constructed on or after 19 May 2005. Some countries, foe example Denmark, tried
to legislate against CFCs continuing to be ‘used’ in existing refrigeration installations but
were defeated. The term ‘use’ is defined as:

The charging, topping up and removal of refrigerant from the system or equipment.

5.2.4 Paragraph 2 of Regulation 12 includes the statement:

Emissions arising from leaks of an ozone depleting substance, whether or not the leaks are deliberate,
may be regulated by Parties.

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 It is therefore considered that a refrigerant leak monitoring system is required but only if an
ozone depleting substance is being used, such as HCFC R-22, and the Flag Administration
of the ship requires compliance with other Statutory Instruments or legislation such as
Regulation (EC) No. 842/2006 or Regulation (EC) 1005/2009 for EC countries.

5.2.5 If maintenance of the refrigeration equipment is carried out by ship’s staff, then a refrigerant
recovery unit and associated cylinders need to be provided. The special cylinders used for
recovery should be specially marked and labelled, e.g. “HCFC R-22 – Recovered”. The
markings should be clear and near the top of the cylinder.

5.2.6 Care must be taken not to overcharge the recovery unit's internal container or the recovery
cylinder(s). A method of ensuring that overcharging does not occur should be provided,
normally a set of dedicated scales. Charging and recovery lines should be kept as short as
possible and equipped with valves or self-closing connections to minimise any unavoidable
loss of refrigerant to the atmosphere upon disconnection.

5.3 Periodic leak detection

5.3.1 To reduce the possibility of leaks occurring, periodic leak detection should be undertaken.
This is separate from the leak monitoring system required by paragraph 5.2.4. A simple leak
detection method uses a solution of soap in water. This is painted onto all joints and
connections which are then inspected for the formation of bubbles. A more effective method
is to use an electronic leak detector which is specifically calibrated for the refrigerant in use.
For refrigerants which contain a fluorine atom, such as HCFC R-22, a further method is to
use a hand-held halide torch.

5.3.2 The halide torch burns propane or butane to heat a copper element; sample air is drawn
over the element using the venturi effect. If fluorine atoms are present they decompose and
the colour of the flame changes to blue. The shade of blue gives an indication of the severity
of the leak. If a halide torch is used, toxic fumes are produced (phosgene gas) when HCFCs
are burnt. This method is no longer considered acceptable, especially in confined spaces
such as refrigeration machinery spaces, and as such should not be promoted.

5.3.3 Electronic detector operates by measuring the variation in current flow caused by ionisation
of decomposed refrigerants between two oppositely charged platinum electrodes. This type
of detector is suitable for HCFC and HFC refrigerants. They are extremely effective at
finding leaks as small as 5 grams per year. Electronic detectors need to be periodically
recalibrated. The periodicity of recalibration must be in accordance with the manufacturer’s
instructions.

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5.3.4 A further system of leak detecting involves adding a small amount of fluorescent dye to the
refrigerant circulating around the system. Any leaks from flanges, glands, connections, etc,
will include a small amount of the dye. As this has smaller molecules than the refrigerant it
is more susceptible to leaking. The location of any leaks can then be easily identified by
illuminating the area with an infrared lamp.

5.3.5 The periodicity of leak detection is at the discretion of the owner/operator. The quantity of
refrigerant in each system is one way to establish the time interval between leak detection.
For guidance purposes, the following NVKL recommendations are considered acceptable
and are more stringent than those presently required by the European legislation:

Charge Example of System Type Periodicity

< 3 kg Bottle cooler, walk-in chambers, split A/C units Yearly

3 ≤ 30 kg Control room A/C, small provision chambers Quarterly
30 ≤ 300 kg Cargo ship accommodation A/C, provision rooms Monthly
300 kg & over Cargo refrigeration plants, passenger ship A/C Weekly *

* interval may be extended depending on the number of leaks being found.

5.3.6 It is recommended that the leak test regime as listed above is followed, however, if a system
is completely sealed, with no breakable connections, then leak testing may be waived at the
discretion of the owner/operator.

5.3.7 Any detected leakage should be repaired as soon as possible. If the leaking system is
maintained by a third party, such as a shore-side refrigeration contractor, then the repair
should be completed in the next port. The equipment or system shall be checked for leakage
after the repair and then again within one month to ensure that the repair has been effective.

5.4 Ozone Depleting Substance Record Book

5.4.1 To comply with the need to maintain a record, it is proposed that a form of refrigerant ‘log
book’ should be kept. The information it contains should comply with paragraph 7 of
Regulation 12 and that proposed by other refrigeration legislation such as Regulation (EC)
No. 842/2006 and Regulation (EC) 1005/2009 for EC countries.

5.4.2 In accordance with paragraph 5 of Regulation 12, a record of the equipment containing ozone
depleting substances must be maintained. It is therefore envisaged that the refrigerant log
book would also be used to record this information. In addition to the log book, it is
considered that a dedicated entry should also be made in the engine room log sheet to
record any refrigerant usage.

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5.4.3 In accordance with paragraph 6 of Regulation 12, this record or log book is to be approved by
the Administration. An example of a suitable log sheet is shown as Appendix 3.

5.4.4 By using a log book, an annual refrigerant usage figure can be established and maintained
for each system. This would allow a refrigerant usage trend to be determined and so
indicate whether a system has started to leak significantly. An allowable annual leakage
figure is hard to estimate but the following may be used as an indication;

30% of initial charge for small systems

10% of initial charge for medium systems
3% of initial charge for large systems

It should be noted that if a catastrophic failure occurred, such as a pipe fracture, a large
proportion of the charge may escape. In this case, the above figures would be meaningless.

5.4.5 The logs recording the refrigeration systems installed on board and their refrigerant usage
should be inspected at each survey. These logs are to include details and location of each
system which is considered applicable under Revised MARPOL Annex VI Regulation 12.

The following information should be recorded:

• Refrigerant number and charge amount (kg) in each system

• If any recharging, full or partial, has occurred to each system and the amount of
refrigerant added or removed
• Any repair or maintenance done to a refrigeration system
• The discharge of refrigerant, both deliberate and non-deliberate
• The number and location of any full, or part full, cylinders of virgin refrigerant used for
maintenance and servicing.
• The amount and location of any full or part full cylinders of recovered refrigerant.
• The amount and date when any recovered refrigerant has been sent ashore for recycling
or disposal.
• The amount and date of any refrigerants supplied to the ship

5.5 Leak monitoring system

5.5.1 For fixed refrigerant leak monitoring systems, the number and location of the proposed leak
detector sensors is at the discretion of the owner/operator/yard. For guidance, where fixed
refrigerant detection system sensors are to be located Part 6, Chapter 3, Paragraph 5.1.1 of
the Rules and Regulations for the Classification of Ships stated that a detector may be
considered to cover an area of 36 m².

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Page 14 of 25
5.5.2 It is not normally considered necessary for an individual provision room to be fitted with a
leak detector sensor, as the number of de-mountable joints and possible leak locations, for
example valve stem seals, is limited and is often zero. If however, the provision room
system has all the thermostatic expansion valves, bypass valves, filter driers and other
ancillary valves and fittings located in a central lobby area, this space should be fitted with a
detector.

5.5.3 If all refrigeration control and isolating valves, etc. are fitted in the individual rooms, then a
detector should be fitted in each room. Spaces that houses only welded or braised
refrigerant pipework need not be fitted with a detector, as the chance of a leak occurring is
considered remote.

5.5.4 Whilst the Rules state that a detector sensor head normally covers an area of 36 m2; if the
manufacturer’s recommendation is less than this figure then their requirements should be
adhered to. The location of the sensor head is dependant on the type of refrigerant used and
whether the leak is most likely in the liquid or vapour phase. Where leakage is likely to be in
the liquid phase (e.g. liquid pumps) the sensor heads are to be placed beneath the
equipment or at deck level. Where leakage would be in the vapour phase (e.g. compressors)
and the refrigerant is lighter than air, sensor heads should be placed at deckhead level. Due
regard is also to be taken of the expected direction of the ventilation air stream. If the
refrigeration space has a dedicated ventilation system then it is good practice to place a
detector sensor head in the ventilation outlet duct.

5.5.5 A single detector sensor head may be fitted in a space. Standby sensor heads are not
considered necessary provided they are so designed as to be readily tested and calibrated
and failure of the sensor head initiates an alarm.

5.5.6 It is recommended that a detector sensor head is fitted in the common discharge line from
the safety relief valves fitted to the compressors and pressure vessels in each refrigeration
system.

5.5.7 Refrigerant detector systems normally consist of a central electronic control unit to which a
number of detector sensor heads are connected. The number of sensor heads fitted is
normally between 4 and 12 but large systems may be of modular construction and allow
additional input cards to be fitted. Some detector sensor heads need to be changed as
regularly as every two years. The system manufacturer’s requirements need to be
established and the date stamped on each sensor head checked. Air sampling or ‘Sniffer’
type detector systems were common but are now almost unknown for refrigeration
installations.

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5.5.8 The refrigerant alarm detector panel may be located on the bridge or in the engine control
room (ECR). It is proposed that refrigerant detector alarm activation will initiate; the ship's
engine room alarm or dedicated audible and visual alarms on the bridge or in the event of
the engine room being unmanned, the engineers’ call.

5.5.9 Current construction practice, for air conditioning and produce chamber refrigeration
installations, is for all the refrigeration equipment, containing the primary refrigerant, to be
located in a designated space. In this case only this dedicated refrigerant machinery space
needs to be provided with a fixed leak detection system.

5.5.10 Where air conditioning refrigeration systems are split between the machinery compartment,
housing the compressors and condensers, and air handling units, housing the evaporators,
located at upper deck level in separate compartments, then each space containing primary
refrigerant valve stations and demountable joints should be fitted with a fixed refrigerant
detector sensor head.

5.5.11 The refrigerant concentration at which a leak monitoring system alarm is instigated is to be
an acceptable value in keeping with the system manufacturer’s recommendations. Two
types of refrigerant detectors are normally used with halogenated fluorocarbon refrigerants.
Infrared is the most accurate but carries a significant price premium. The semi-conductor
type is cheaper and less accurate. The latter type is the most commonly specified and will be
most widely found in ship applications.

5.5.12 For the semi-conductor type of detector, the minimum concentration of halogenated
fluorocarbon which can normally be detected is around 50 ppm. This value is quoted for
ideal or laboratory conditions with no air flow and the sensor heads in perfect condition.
Higher operating temperatures, contamination from paint fumes or oil mist and partial
blockage of sensor heads may result in concentrations between 150 and 175 ppm being
necessary before a leak can be detected. To allow for background contaminants and high
ambient temperature and humidity, a detection level of 300 ppm is considered the practical
minimum to prevent nuisance alarms.

5.5.13 This figure should be compared with the 150 to 200 ppm initial alarm and 750 to 800 ppm
leakage alarm set points claimed by a number of leak detector manufacturers as the ‘normal’
alarm levels. As qualified personnel will be available to investigate any detector system
alarm the second level is considered redundant.

Revised MARPOL Annex VI – Regulation 12 Guidance Notes

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5.5.14 If the owner or operator wishes, the alarm set point may be reduced depending upon the
type of equipment provided. If however, it is found that nuisance alarms continue, when the
detector system is set to activate below 300 ppm, then after checking for any leaks, the alarm
level may be raised in small increments until nuisance alarms cease. Any variation in the
alarm set point should be recorded in the system’s operating manual and refrigerant log
book.

5.5.15 Dates of leak detection, number and severity of any leaks detected, steps taken to repair
leakage and amount of refrigerant added should be included in the refrigerant log book or
engine log. This should be done for each refrigeration system tested.

5.6 Operation manuals

5.6.1 Suitable manuals or procedure sheets, covering the operation and maintenance of each
refrigeration system are to be available on board. The operating manual should be suitable
for the system installed. For small systems, the amount of maintenance will be limited and
no preventative maintenance will normally be required, thus the manual or procedure
sheets will be limited in their complexity.

5.6.2 For larger systems the operation and maintenance manual should suitably cover charging,
pumping down and evacuating the system. Other simple maintenance procedures such as
defrosting, leak detection and filter-drier replacement should also be covered.

Revised MARPOL Annex VI – Regulation 12 Guidance Notes

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6. Refrigerants

6.1 Listed below are all the currently available refrigerants that have zero ODP and a GWP100
value below 1950 thus being suitable for the ‘R’ character associated with the Environmental
Protection Notation. The refrigerants that are considered ‘mainline’ and suitable for use in
marine applications for refrigerated cargo, air conditioning and provision room refrigeration
systems are shown with an asterisk thus *.

A number of refrigerants from the hydrocarbon group have been included. Special
consideration would need to be given to the use of these refrigerants.

Refrigerant No. Name Formula ODP GWP100

R-134a * 1,1,1,2-Tetrafluoroethane CF3CH2F 0 1300

R-718 Water H2O 0 0
R-744 * Carbon dioxide CO2 0 1
R-407A * Blend of R-32/125/134a CH2F2 0 1770
CF3CHF2
CF3CHF2F
R-407C * Blend of R-32/125/134a CH2F2 0 1526
CF3CHF2
CF3CHF2F
R-410A * Blend of R-32/125 CH2F2 0 1725
CF3CHF2
R-32 Difluoromethane CH2F2 0 580
R-50 Methane CH4 0 24.5
R-152a 1,1-Difluoroethane CHF2CH3 0 140
R-30 Methylene chloride CH2Cl2 0 15

R-717 * Ammonia NH3 0 0

R-170 Ethane CH3CH3 0 3

R-290 * Propane CH3CH2CH3 0 3
R-600 * Butane C4H10 0 3
R-600a * Isobutane CH(CH3)3 0 3

Revised MARPOL Annex VI – Regulation 12 Guidance Notes

© Lloyd’s Register June 2010
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 The GWP100 figure for each of the following refrigerants has yet to be confirmed. However,
it is unlikely that any of these refrigerants will be considered for commercial applications.

Refrigerant No. Name Formula ODP GWP100

R-160 Ethyl chloride CH3CH2Cl 0 TBC

R-764 Sulphur dioxide SO2 0 TBC
R-40 Methychloride CH3Cl 0 TBC
R-611 Methylformate C2H4O2 0 TBC
R-1130 1,2-Dichloroethylene CHCl=CHCl 0 TBC
R-1150 Ethylene CH2=CH2 0 TBC
R-1270 Propylene C3H6 0 TBC

The above tables are not a complete list of substances which might be used. If other blends
are produced that meet the appropriate ODP and GWP limits, they should also be included.

Lloyd's Register, its affiliates and subsidiaries and their respective officers, employees or agents are, individually and collectively, referred to in this
clause as the ‘Lloyd's Register Group’. The Lloyd's Register Group assumes no responsibility and shall not be liable to any person for any loss,
damage or expense caused by reliance on the information or advice in this document or howsoever provided, unless that person has signed a
contract with the relevant Lloyd's Register Group entity for the provision of this information or advice and in that case any responsibility or liability
is exclusively on the terms and conditions set out in that contract.

Revised MARPOL Annex VI – Regulation 12 Guidance Notes

© Lloyd’s Register June 2010
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Appendix 1 – List of compounds used as refrigerants or refrigerant blends

Family Refrigerant No. Name Formula ODP GWP100

CFC R-11 Trichlorofluoromethane CCl3F 1 4,000

CFC R-12 Dichlorodifluoromethane CCl2F2 1 8,500
CFC R-13 Chlorotrifluoromethane CClF3 1 11,700
CFC R-113 1,1,2-trichloro 1,2,2-trifluoroethane CCl2FCClF2 0.8 5,000
CFC R-114 1,2-dichloro 1,1,2,2-tetrafluoroethane CClF2CClF2 1 9,300
CFC R-115 Chloropentafluoroethane CF3CClF2 0.6 9,300

CFC R-500 Azeotropic blend of R-12 and R-152a CCl2F2 0.74 6,300
CHF2CH3
CFC R-502 Azeotropic blend of R-22 and R-115 CHClF2 0.33 5,600
CF3CClF2
CFC R-503 Azeotropic blend of R-23 and R-13 CHF3 0.6 11,900
CClF3

Family Refrigerant No. Name Formula ODP GWP100

HCFC R-22 Chlorodifluoromethane CHClF2 0.055 1,700

HCFC R-123 2,2-dichloro 1,1,1-trifluoroethane CF3CHCl2 0.012 120
HCFC R-124 2-Chloro-1,1,1,2-tetrafluoroethane CF3CHClF 0.026 620

HCFC R-401A Zeotropic blend R-22/R-152a/R-124 CHClF2 0.027 1,130

CHF2CH3
CF3CHClF
HCFC R-401B Zeotropic blend R-22/R-152a/R-124 CHClF2 0.028 1,220
CHF2CH3
CF3CHClF
HCFC R-402A Zeotropic blend R-125/R-290/R-22 CF3CHF2 0.013 2,690
CH3CH2CH3
CHClF2
HCFC R-402B Zeotropic blend R-125/R-290/R-22 CF3CHF2 0.02 2,310
CH3CH2CH3
CHClF2
HCFC R-403A Zeotropic blend R-22/R-218/R-290 CHClF2 0.026 3,000
C3 F8
CH3CH2CH3
HCFC R-403B Zeotropic blend R-22/R-218/R-290 CHClF2 0.019 4,310
C3 F8
CH3CH2CH3
HCFC R-408A Zeotropic blend R-125/R-143a/R-22 CF3CHF2 0.026 3,100
CF3CH3
CHClF2
Family Refrigerant No. Name Formula ODP GWP100

HCFC R-409A Zeotropic blend R-22/R-124/R-142b CHClF2 0.048 1,400

CF3CHClF
CH3CClF2
HCFC R-411B Zeotropic blend R22/R-152a/R-1270 CHClF2 0.032 1,600
CHF2CH3
C3H6

Family Refrigerant No. Name Formula ODP GWP100

HFC R-23 Trifluoroethane CHF3 0 12,000

HFC R-32 Difluoromethane CH2F2 0 550
HFC R-125 Pentafluoroethane CF3CHF2 0 3,400
HFC R-134a 1,1,1,2-Tetrafluoroethane CF3CH2F 0 1,300
HFC R-143a 1,1,1-Trifluoroethane CF3CH3 0 4,300
HFC R-152a 1,1-difluoroethane CHF2CH3 0 120

HFC R-404A Zeotropic blend R-125/R-143a/R-134a CF3CHF2 0 3,780

CHF2CH3
CF3CH2F
HFC R-407A Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,990
CF3CHF2
CF3CHF2F
HFC R-407B Zeotropic blend R-32/R-125/R-134a CH2F2 0 2,700
CF3CHF2
CF3CHF2F
HFC R-407C Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,650
CF3CHF2
CF3CH2F
HFC R-407D Zeotropic blend R-32/R-125/R-134a CH2F2 0 1,500
CF3CHF2
CF3CH2F
HFC R-410A Zeotropic blend R-32/R-125 CH2F2 0 1,980
CF3CHF2
HFC R-417A Zeotropic blend R-600a/R-125/R-134a CH(CH3)3 0 1,920
CF3CHF2
CF3CH2F
HFC R-507 Azeotropic blend R-125/R-143a CF3CHF2 0 3,850
CF3CH3
HFC R-508B Azeotropic blend R-23/R-116 CHF3 0 11,950
CF3CF3

Family Refrigerant No. Name Formula ODP GWP100

HC R-50 Methane CH4 0 24.5

HC R-170 Ethane CH3CH3 0 20
HC R-290 Propane CH3CH2CH3 0 20
HC R-600 Butane C4H10 0 20
HC R-600a Isobutane CH(CH3)3 0 20
HC R-1150 Ethylene CH2=CH2 0 *
HC R-1270 Propylene C3H6 0 *
Family Refrigerant No. Name Formula ODP GWP100

Nat Sub R-718 Water H2O 0 <1

Nat Sub R-744 Carbon dioxide CO2 0 1
Nat Sub R-717 Ammonia NH3 0 <1

Other refrigerants from different families

The GWP100 figures for the following refrigerants have yet to be confirmed. However, it is unlikely that any of these
refrigerants will be considered for commercial applications.

Family Refrigerant No. Name Formula ODP GWP100

Methane R-30 Methylene chloride CH2Cl2 0 15

Methane R-40 Methyl chloride CH3Cl 0 TBC
Ethane R-116 Hexaflouroethane CF3CF3 0 *
Propane R-218 Octofluoropropane CF3CF2 CF3 0 7,000
Oxygen R-611 Methyl formate C2H4O2 0 TBC
Inorganic R-764 Sulphur dioxide SO2 0 TBC
Unsat organic R-1130 1,2-Dichloroethylene CHCl=CHCl 0 TBC

The above tables are not a complete list of substances which may be used, if other blends are produced meeting the
appropriate ODP and GWP limits, they should also be considered.

Notes

1. Refrigerant numbers in bold are, or were, the most commonly used.

2. Not all HCFC blends have been included – many were developed but not marketed.
3. * - signifies not known
4. Nat Sub – natural substances (not legislated against with regard to ODP or GWP)
5. TBC – signifies to be confirmed
6. GWP values are taken from Intergovernmental Panel on Climate Change (IPCC), 2001
‘Climate Change 2001: The Scientific Basis’.
7. Current as of October 2004
8. The use of CFC refrigerants is banned or severely restricted under the Montreal Protocol
Appendix 2 – Halons and Halon replacements

Halons

Trade name Formula ODP Atmospheric

lifetime
Halon 1211 CF2BrCl 3.0 25
Halon 1301 CF3Br 10.0 110
Halon 2402 C2F4Br2 6.0 28

Halon replacements

Trade name Formula Designation GWP100 Atmos’ lifetime

FE-13 CHF3 HFC 23 11,700 264

FE-125 CF3CHF2 HFC 125 2,800 33
FM-200 CF3CHFCF3 HFC 227ea 2,900 37
FE-36 CF3CH2CF3 HFC 236fa 6,300 209

CEA-308 (perfluoropropane) C3F8 PFC-2-1-8 7,000 2,600

CEA-410 (perfluorobutane) C4F10 PFC-3-1-10 7,000 2,600
Perfluorohexane C6F14 PFC-5-1-14 7,400 3,200

NN100 N2 IG-100 0 Natural substance

Argotec Ar IG-01 0 Natural substance
Argonite N2/Ar mix IG-55 0 Natural substance
Inergen N2/Ar/CO2 mix IG-541 0 Natural substance

Water mist 0
Fine particulate aerosol 0

Notes

1. The PFC family of replacements is banned by IMO, SOLAS Chapter II-2, Reg 10, 4.1.3 refers.
2. Not all replacement blends have been included – many have been developed but no information is available, for example
Novec 1230, a fluorinated ketone.
3. Natural substances cannot be legislated against with regard to ODP or GWP; however, toxicity may be an issue.
Appendix 3 – sample log sheet
Log Sheet for Record Keeping Obligation, RAC Equipment
This record sheet allows compliance with Revised MARPOL Annex VI, Reg 12, 1005/2009 & 842/2006. A
separate sheet must be kept for each refrigeration system that contains 3 kg or more of refrigerant.

RECORD SHEET FOR MARPOL ANNEX VI & EUROPEAN REGULATION COMPLIANCE

General Information
Ships Name IMO No.
Plant Name Reference No.
Location of plant
Company and operator’s name
Cooling loads served
Refrigerant Type Refrigerant Quantity (kg)
Plant manufacturer Year of installation
Refrigerant Additions
Date Engineer/Company Amount Added, kg Reason for addition

Refrigerant Removals
Reason for removal. What was done
Date Engineer/Company Amount Removed, kg
with recovered refrigerant

Leak Tests
Test Result (including location and
Date Engineer/Company Follow up actions required
cause of any leaks identified)

Follow-up Actions
Date Engineer/Company Related to test on Actions Taken

Testing of Automatic Leak Detection System (if fitted)

Date Engineer/Company Test Result Comments

Refrigerant delivered or removed from ship

Date Company Quantity Comments
Appendix 4 – flow chart

Do any systems Does any fire suppression or Was the ship Installation
onboard contain Yes inerting system contain halon? Yes constructed on or Yes prohibited
ODSs? after 19 May 2005?

Permitted until replaced or

No required to be removed by
Complies, no further international, national or
No action required No other requirements.
Complies, no further Systems containing halons
action required to be listed

Does any air-conditioning or Does refrigeration equipment

refrigeration system contain a Yes have charging connection or Yes
man-made refrigerant? removable components?

Complies, no further Complies, no further

No No
action required action required

No
Does any system No
Does any system
contain HCFCs? contain CFCs?

Revised MARPOL Annex VI Yes Yes

CFCs are prohibited from use in
existing refrigeration systems if the
ship was constructed on or after 19 Complies, no further Permitted until required to Permitted until required to
May 2005 action required be removed by be removed by
international, national or international, national or
HCFCs will be prohibited in new other requirement. other requirement.
installations after 01 January 2020 Systems containing Systems containing CFCs
HCFCs to be listed to be listed