WHAT ABOUT SCRUBBERS?
What are scrubbers?
Scrubbers are ‘exhaust gas cleaning systems’ that use seawater or freshwater to remove sulphur and other contaminants from a ship’s air exhaust when heavy oil fuel is used. This process reduces emissions released into the air; however, scrubber wash water is discharged into the ocean and can be toxic to marine life. The use of scrubbers effectively turns air pollution into ocean pollution.
Why do ships use scrubbers?
Regulations by the Internation Maritime Organization (IMO) and the North American Emissions Control Area (ECA) have attempted to reduce air pollution by mandating lower sulphur emissions - to 0.5% and 0.1% respectively. The intent was to have ships switch to using cleaner fuels, such as very low sulphur marine gas oil or distilled low sulphur marine gas fuel.
Unfortunately, IMO guidelines allow the use of scrubbers to meet their reduced emission mandates. Heavy oil fuel is about half the price of low sulphur fuel and many ships have opted to install scrubbers instead of switching to cleaner fuels. Most cruise ships using Victoria as a port of call use heavy fuel oil with scrubbers. The installation of scrubbers reduces costs and increases profits for ship owners with unknown future health and environmental implications and costs for their host communities.
Do scrubbers increase ocean pollution?
It appears so. Contaminants in scrubber discharge wash water include metals, hydrocarbons, sulfurous and nitrous acids, and turbidity that can contribute to long-term contaminant loading to the marine environment.
The IMO’s Task Team on Exhaust Gas Cleaning Systems (EGCS) stated in 2019: “In terms of total amounts of contaminant discharges through EGCS, it appeared that large scale uses of these systems may lead to deterioration of environmental status, especially in the ecologically vulnerable and sensitive areas such as coastal waters, semi-enclosed seas and also in ports and harbours”.
In 2019, the Port of Vancouver commissioned a modelling study to better understand the environmental impact of scrubber wash water discharge in Burrard Inlet. The study showed that scrubber wash water discharge could result in concentrations of metals that exceed thresholds set for the protection of marine aquatic life.
The Port of Vancouver and the Port of Prince Rupert have banned scrubber waste discharges at anchorage and at berth. They require ships to either hold wash water on board, switch to low sulphur fuel or connect to shore power. However, they have not yet banned scrubber discharges from main vessel engines while ships are maneuvering or transitioning in port.
Does Canada monitor and research scrubber discharges?
In 2020, Environment and Climate Change Canada (ECCC) funded an analysis of the use of scrubbers by the International Council on Clean Transportation (ICCT). ICCT recommended an immediate prohibition on using scrubbers and warned of negative effects of scrubber discharges on marine life. Canada submitted the ICCT report to the IMO’s Pollution Prevention and Response Subcommittee.
ECCC conducts ongoing research and investigations on scrubber use in Canada. In 2023-2024, fourteen of the inspections conducted in the Pacific and Yukon Region were directly related to cruise ship discharges, including scrubber wash water. No further information on the outcome of these investigations is currently available, as the matter is ongoing.
How much scrubber wash water and pollutants are discharged on Canada’s Pacific Coast?
Environment Canada and Climate Change calculates that in 2022, ships equipped with scrubbers discharged over 88 million tonnes of wash water on Canada’s Pacific Coast. Cruise ships accounted for nearly 46% of the total wash water discharged in 2022. Scrubber wash water contained 226 kg of PAHphe, and nearly 26,000 kg of metals in 2022.
Read the report from Environment Canada about the impact of scrubbers in our waters.
How much scrubber wash water is discharged in Canada’s endangered Southern Resident Killer Whale habitat?
The Southern Resident Killer Whale (SRKW) is listed as endangered under Canada’s Species at Risk Act. SRKW critical habitat, which is essential to their survival and recovery, is located between the Southern Salish Sea, Juan de Fuca Strait and southwestern Vancouver Island.
ECCC estimates that over 26 million tonnes of scrubber wash water was discharged into SRKW critical habitat in 2022, including 69 kg of PAHphe and over 8,000 kg of metals. Cruise ships accounted for 44% of the wash water discharge and 40% of the PAHphe and 44% of the metals in this habitat.
Read the report from Environment Canada about the impact of scrubbers in our waters.
Do scrubbers eliminate air pollution?
No. Researchers at the International Council for Clean Transportation found that ‘even with scrubbers, ships will continue to emit air and climate pollution emissions such as particulate matter, sulfur oxides, nitrogen oxides, black carbon and carbon dioxide’.
A 2018 study by the University of California for the California Air Resources Board indicated that scrubbers do not provide the same air quality reductions for particulate matter as compared to vessels using low sulphur fuel. Locally, there continues to be concern about ultrafine particulate matter and volatile organic compounds.
How have countries and ports reacted to the use of scrubbers?
Many governments and ports around the world have restricted the use of scrubbers, including California, Norway, China, Saudi Arabia, Portugal, Sweden, Malaysia, Dublin, and Seattle.
Pacific Environment recently published a report which lays out the case for why the International Marine Organization should immediately ban scrubber discharges. For more information, please see Poison-in-the-water.pdf
What about Canada?
Canada does not restrict or ban the use of scrubbers in Canadian waters. Five of seventeen federal port authorities have restricted scrubber use in their ports, including Vancouver and Prince Rupert.
In 2023, Canada issued an Interim Order Respecting the Discharge of Sewage and the Release of Greywater by Cruise Ships in Canadian Waters. The measures state that sewage and greywater cannot be discharged within 3 nautical miles of shore and that any sewage or greywater discharged between 3 and 12 nautical miles from shore should not leave a sheen or residue on the surface. Unfortunately, the Order lacks any prohibition of scrubber wash water discharges by cruise ships in Canadian waters. The Order expires in June 2025.
From November 2024 to January 2025, Transport Canada conducted consultation on vessels using scrubber systems in Canadian waters. The results have not yet been released.
Fair Sailing submitted comments to the consultation and endorsed a submission by the World Wildlife Fund Canada.
What about Victoria?
Victoria is a public port. The cruise ship terminal in Victoria currently has no scrubber wash water discharge restrictions in effect. Most cruise ships visiting Victoria have scrubbers on board. It is unknown whether cruise ships use scrubbers while at berth or while maneuvering and transitioning in the harbour and beyond.