Chapter 9, in particular Article 9.01 - Repair to an existing motor or to a replacement or exchange engine
The discussion commenced with the following questioning:
At what point is a repair to a propulsion engine so extensive that the repaired engine is to be deemed a replacement or exchange engine? In this case, is changing the engine block deemed to be a simple repair or replacement of the engine? Does the source of the spare parts affect this in any way?
In accordance with chapter 24 of the RVIR (or chapters 24 and 24a of directive 2006/87/EC), replacement engines could only be installed until 31.12.2011 and in certain circumstances. In accordance with the ES-TRIN 2017, Article 9.01 (4), the installation of a replacement engine is explicitly forbidden.
This then gives rise to the following question: What repairs to an existing propulsion engine installed on a vessel are permitted, in particular concerning the replacement of spare parts?
Permitted repairs are those that are carried out:
- in accordance with the type approval and existing engine parameter protocol; and
- provided that the identity of that repaired engine is traceable to the original engine that was placed on the market and installed on the vessel and no additional engine shall be created by that repair.
This option meets the requirement to define a limit to what is deemed to be a repair and thus enables the competent authority to carry out testing. The vessel’s owner must be able to provide proof of the traceability of the engine and of the repairs to it.
This option is based on the following arguments:
- EU regulations are based on the criterion for placing the engine on the market (directive 97/68/EC Regulation (EU) 2016/1628). A repair must not result in a new engine being placed on the market. If the identity of the engine remains unchanged, the engine can be used and repaired indefinitely.
- After an engine has been placed on the market in accordance with Regulation (EU) 2016/1628 or the prior Directive 97/68/EC, there is no restriction on repair or remanufacture of the engine using spare parts or assemblies of parts as long as the specifications of the engine’s original emission control system are respected.
- The origin of the spare parts (including engine block) has no impact, but these spare parts must comply with the manufacturer’s specifications in order to comply with the type approval.
An engine shall also be deemed to be a replacement engine if, owing to a repair, it ought to be assigned to another engine category in accordance with the NRMM regulations.
CESNI/PT (17) 59 rev. 1, CESNI/PT (17)m 75
CESNI working group technical requirements CESNI/PT, replacement or exchange engine, engine block, repair, engine