A nod to our friends at Gard for this very useful guide.
The local regulations on open loop scrubbers are proving to be a minefield for ship owners and operators. The list of countries with special rules seems to grow by the month. This also brings into question the business model for scrubbers versus MARPOL compliant low sulphur fuels.
We have seen lots of legal issues related to this area where advance permission is required to use open loop at certain ports which has not been done, causing delays that feed through into off hire and demurrage related issues. In some cases fines have also been imposed which has led to claims by ship owners against their charterers.
