Liberia issues advisory on SEEMP audits and deadline extension

The Marine Advisory 36/2024 issued by Liberia Maritime Authority provides a comprehensive guideline for the implementation and auditing of the Ship Energy Efficiency Management Plan (SEEMP), as required by the 2021 Revised MARPOL Annex VI. The advisory focuses on ensuring that ships comply with the regulations regarding carbon intensity and fuel consumption through periodic company and shipboard audits. Below is a detailed breakdown of the key information:

Purpose and Scope

The advisory informs Shipowners, Operators, Masters, and Recognized Organizations about the procedures for conducting audits of the SEEMP in line with the 2021 Revised MARPOL Annex VI and MEPC Resolution 347(78). The SEEMP is a critical part of managing a ship’s energy efficiency and achieving the required carbon intensity reductions as part of the global maritime industry's efforts to reduce greenhouse gas emissions.

Background

MARPOL Annex VI, adopted by the International Maritime Organization (IMO), regulates the prevention of air pollution from ships. Regulation 26 of the 2021 revision introduced the requirement for ships to maintain a SEEMP (Part III) onboard, which outlines how the ship will achieve its carbon intensity goals.
Ships must calculate their Annual Operational Carbon Intensity Indicator (CII) and outline how this will be managed in the SEEMP.
The SEEMP must also describe:
- The methodology used to calculate the ship’s attained annual operational CII.
- The required operational CII for the next three years.
- An implementation plan to achieve the operational CII targets.
- A procedure for self-evaluation and improvement.
Regulation 28.3 requires ships rated as E or D for three consecutive years to develop corrective actions to improve the CII performance and update the SEEMP accordingly.

Audit Requirements

As per Regulation 26.3.3 of the revised MARPOL Annex VI, the SEEMP is subject to periodic company audits and shipboard audits. These audits are essential for verifying compliance with carbon intensity targets and ensuring that corrective actions are taken when necessary.

1. Company Audits

Deadline for Audits: Companies with ships that have received an E rating (poor performance in carbon intensity) in any given year must have their company audit completed no later than November 30 of the following year.
Companies with ships receiving consecutive D ratings for two years should undergo a company audit no later than November 30 of the second year (XXXX+2).
For ships that do not receive poor ratings, the audits should occur at intervals not exceeding three years.

2. Shipboard Audits

For Ships with Consecutive E Ratings: Shipboard audits must be conducted for ships that receive two consecutive E ratings (i.e., in year XXXX+2). This audit will help verify that corrective actions are being implemented and that the ship is improving its carbon intensity performance.

3. Audit Flexibility

Company audits in 2024 can be combined with the annual Document of Compliance (DOC) audit if it falls within the same audit window. Alternatively, it may be conducted separately, depending on the company’s preference or the Administration's decision.

Implementation and Deadlines

Extension of Deadlines: The due date for company audits has been extended to May 31, 2025. This gives companies more time to comply with the auditing requirements.
Companies should contact an authorized Recognized Organization (RO), which is listed on the Liberia Maritime Authority’s website, to schedule their audits.

Validity and Future Updates

This advisory is valid until May 31, 2025. The Liberia Maritime Authority will review the procedures and may issue revised guidelines after this date based on any changes to international regulations or operational requirements.