Onboard Management Manual (OMM) for EPL/SHaPoLi

According to IMO Resolution MEPC.335(76), all new and existing overridable shaft or engine power limitation systems need to be approved and verified by the Administration or the Recognized Organization (RO). This requires the Administration or the RO to approve the applied EPL/SHaPoLi and the Onboard Management Manual (OMM).

The OMM is to include the technical details and identification of key components of the applied EPL/SHaPoLi, service, maintenance and calibration requirements for SHaPoLi, methods of locking and monitoring the EPL, procedures for limiting and releasing the power reserve, time required for un-limiting the power reserve, procedures for notification of the use of power reserve, procedures for survey, etc.

Additional information to be provided, as applicable:

In accordance with IMO Resolution MEPC.390(81), the pilot card, wheelhouse poster and maneuvering booklet (as applicable) shall be updated to include the maneuvering characteristics of the ship when the ship has all shaft and engine power available and when shaft or engine power has been limited.

If the power reserve has been used, the ship should without delay notify its Administration or RO responsible for issuing the relevant certificate, as well as the competent authority of the relevant port of destination refer to 3.4 of MEPC.375(80).

The information shown in the 3.2 of MEPC.375(80) (see attached appendix) is to be submitted to the Administration or RO. The above information must also be recorded on the record page of the OMM for SHaPoLi/EPL, signed by the master and kept on board.

By 30 June, the Administration should annually report to the IMO Secretariat uses of a power reserve over a 12-month period from 1 January to 31 December for the preceding calendar year using the format as set out in the annex of MEPC.1/Circ.908.

Override is activated Power reserve not used

Where an EPL or SHaPoLi override is activated but the power reserve is not subsequently used, this event should be recorded in the bridge and engine-room logbooks. The engine-room logbook should record power used during the period when the override was activated. The EPL/SHaPoLi should be reset as soon as possible, and details of the reset should also be recorded in the bridge and engine-room logbooks.

The U.S. Coast Guard issued USCG Policy Letter 01-24 regarding the use of devices that alter the maneuvering characteristics of ships to ensure safe navigation in U.S. waters. Ships that employ an EPL/SHaPoLi must inform pilots of the engine response characteristics prior to entry into U.S. territorial waters are required to comply with 33 CFR § 164.11(k). While transiting in U.S. restricted waters, it is required to follow the guidance and procedures to pre-emptively override the EPL/SHaPoLi when necessary for safe operations.

Short-term Exceedances

During normal operation of a limited engine, there might be transitory periods and isolated spikes in the recorded output (e.g. fluctuation of load due to weather and sea conditions). IMO Resolution MEPC.390(81) details that the override of limitation is indicated by giving an alarm on the bridge, the ship's master or OICNW to manually reduce the power within the limit, data recording to commence automatically, in case of short-term unintentional exceedance of the power limit the system may inhibit the initiation of the exceedance alarm for up to a maximum of five minutes.

Reactivating or resetting of EPL/SHaPoLi

The Administration or RO should confirm reactivation of the EPL or SHaPoLi, regardless of whether the power reserve has been used or not.

The reactivation or replacement of the SHaPoLi/EPL system should be confirmed (e.g. validation of mechanical sealing) with supporting evidence (e.g. engine power log, photo taken at the occasion of resetting the mechanical sealing) by the flag Administration or RO at the earliest opportunity (see section 3.5 of MEPC.335(76)).

In case power reserve has been used or reactivated, an occasional survey/audit shall be carried out. This occasional survey/audit may be carried out by remote methods. Please contact your local ABS office or submit a request to OperationsSupport@eagle.org or through the ABS MyFreedom™ portal.

The owner/operators are encouraged to use the form of the apendex to report the use of power reserve. Administration’s need this information as it is required to  report this to the IMO Secretariat.

What is overridable EPL/SHaPoLi?

Fixed in place and can only be overridden by permission of the ship’s master. It can be mechanically or electronically installed.

Examples of mechanical EPL:

  • Locking of the fuel index by a mechanical stop screw sealed with wire

  • Setting of the governor limit via sealed mechanical screw

  • Turbocharger cutout via butterfly valve

Examples of electronic EPL:

•    Password protected electronic locking of the fuel index or governor SHaPoLi Arrangement:

•    Torque and rotational speed sensors

•    Data recorder and processing device

•    Control unit for calculation and Limitation of the power transmitted

What is non-overridable EPL (a.k.a. PPL – permanent power limitation)?

Permanent and non-reversible de-rating of the engine via:

•    Turbocharger(s) (can be multiple T/C’s) cutout by removable blinding plate, or

•    Permanent blinding plate and turbocharger dismantling

•    Permanent adjustment of fuel index, i.e. welded in place

•    Permanent engine de-rating, i.e. cylinders cutoff or reduction of combustion volume

•    Propeller retrofit with shaft power limitation to prevent damage on propeller or shaft

Do I need to do a minimum propulsion power (MPP) assessment for overridable EPL/SHaPoLi?

No, unless the vessel has undergone a modification so extensive that the Administration regards it as a newly constructed ship.

Do we need to do a minimum propulsion power assessment for non-overridable EPL?

• Yes, for tankers, bulk carriers or combination carriers over 20,000 DWT, MPP assessment to be verified according to MEPC.1/Circ. 850 latest revisions.

• No requirement for a new sea trial.

Do I need to update the maneuvering information and pilot cards for overridable EPL/SHaPoLi?

Yes, the existing maneuvering booklet, if available, and the pilot card as per IMO Resolution A.601 (15). Maneuvering information displayed on the navigating bridge to include that the ship’s power has been limited for the attention of the master to account for the ship’s performance. Below is the best practice. Additional figures show the RPM(EPL), speed (EPL) and MCR Lim. No other update is required (unless class notation MAN/MAN-A was assigned, shall contact to engineering for review case by case).

Do we need to update the maneuvering information and pilot cards for non-overridable EPL/SHaPoLi?

Yes, the stopping times and distances, and the data of the turning circles as per SOLAS Reg. II-1/28.3 and Res.MSC.137(76), to be recorded on new trials where applicable. Also, the existing maneuvering booklet, if available, and the maneuvering information should be displayed on the navigating bridge (pilot card and wheelhouse poster) to be updated.

Do I need to update the NOx Technical File (TF) for overridable EPL/SHaPoLi?

No, unless engine critical settings or components affecting the NOx TF are changed. Statements from the engine maker may be considered as acceptable supporting documentation and filed together with NOx TF.

Do we need to update the NOx TF for non-overridable EPL/SHaPoLi?

•    Yes, for turbocharger dismantling/cutout and permanent engine de-rating. Engine de-rating also requires a change in the name plate.

•    No, for propeller retrofit or fuel index permanent adjustment.

Our vessel did a preemptive override of the EPL/SHaPoLi when necessary for safe operations. However, EPL/SHaPoLi override is activated but the power reserve is not subsequently used. Do we need to report to flag/class?

There is no need to inform flag/class about the preemptive override. However, the Administration or recognized organization should confirm reactivation of the EPL or SHaPoLi, regardless of whether the power reserve has been used or not. See section 3.5 of MEPC.335(76). The confirmation may be carried out by remote survey.

Below is the United States Coast Guard (USCG)-ENG Policy Letter 01-24 Frequently Asked Questions

Installation of an EPL/SHaPoLi only limited my top speed by a very small amount. Do I still need to update my pilot card?

Yes, any change to the maximum achievable top speed is considered to be a change in the ship’s maneuvering characteristics and maneuvering information must be updated (33 CFR 164.35(g)).

If the EPL/SHaPoLi is overridden prior to entry into U.S. territorial waters each time the vessel calls on a U.S. port, is this considered compliance?

No, the maneuvering information must accurately reflect the true and current power configuration of any vessel at all times, both in U.S. territorial waters and elsewhere (Res.A.601(15), 33 CFR 164.35(g)). So, if a vessel has multiple power configurations, each must be reflected in a clear way on the documents, or additional documents for each condition produced.

This is not a U.S.-specific regulation; paragraph 2.3 of IMO Res.A.601(15) requires the maneuvering information to be amended following any modification to a ship that could change the maneuvering characteristics.

The EPL/SHaPoLi installed on my vessel is the type that gives an alarm when the set point is exceeded but there is no delay in accessing the reserve power (also called a “stand alone solution”). What actions am I required to take?

No action is required. Systems of this type do not alter the maneuvering characteristics of ships and thus the guidance in USCG Policy Letter 01-24 does not apply.

What is the USCG expectation for updating pilot cards and maneuvering posters? Are sea trials required or will CFD methods suffice?

The USCG won't detail exactly how the new or updated pilot cards and maneuvering posters are created, they're simply held to the same standard as they always have been according to IMO Res.A.601(15) and 33 CFR 164.35(g).