Following an in-depth review, Sustainable Maritime Solutions has provided a briefing document to EGCSA, which roundly rejects Swedish/German proposals for substance Emission Factors in scrubber water overboard discharges at IMO. The briefing document, reproduced below, supports a submission to the 82nd session of the IMO Marine Environment Protection Committee by IBIA – The International Bunker Industry Association, which calls for Emission Factors to be developed from a large sample analysis programme using IMO agreed standards