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Paris Mou Guidelines For Fuel Oil Quality In Emission Control Areas

From January 2015, the requirements for Sulphur Emission (SOx) in the Emission Control Areas(ECA) of The North Sea, English Channel, Baltic Sea and in areas 200 nautical miles from the US and Canada coast will be strengthened. Vessels operating in these areas will have to reduce their Sulphur emissions from today’s 1.00 % level to 0.1%. It is the MARPOL Annex VI (International Air Pollution Prevention) Regulation 14 that sets the limits of Sulphur and Nitrogen oxide emissions (SOx) from ship exhausts. MARPOL Annex VI also prohibits deliberate emissions of ozone depleting substances with currently a global cap of 3.5 % m/m on the Sulphur content of fuel oil.

PSC_Update_no8_2014_Dec

Due to the strengthening of this requirement this will lead to an increased focus by PSC. It is therefore important that operators have updated their procedures for fuel oil change, with the new requirements of 0.10% included before January 1st. Paris MoU has prepared guidelines for what the PSCO will look at during the first PSC inspection after entering an Emission
Control Area:

1. Bunker delivery note showing a Sulphur content of not more than 0.10% m/m for fuel oil used onboard (MARPOL Annex VI Reg. 18 (5))

2. The representative sample of fuel oil with a Sulphur content of not more than 0.10% m/m (MARPOL Annex VI Reg. 18 (8.1))

3.Evidence of a written procedure (note: does not have to be in English) and a record showing that the fuel oil has been changed to an oil containing no more than 0.10 % m/m before entering the ECA. This means that a fuel oil change should have occurred and is already in use when entering the ECA. In addition the date, time and position of the ship when the fuel oil change occurred should be documented and recorded in a log-book as prescribed by the Administration. (MARPOL Annex VI Reg. 14 (6))

For vessels operating in areas with low air and/or water temperature, PSCO may pay special attention to:
1.Check if pipelines for low Sulphur oil are located or equipped with appropriate heating facilities to ensure operation of the pipelines in low temperature conditions
2. Ensure that the written procedure for fuel oil changeover include actions to provide fuel delivery to machinery space in conditions of low air and/or water temperature.
3. Any possibility of unavailability of fuel oil with a Sulphur content of not more than 0.10% m/m due to weather conditions during all times of ship operation in ECA is excluded. Port state may detain the vessel if vessels use fuel oil that is not in compliance with the requirements in the Emission Control Areas.

Vessels should ensure that they have sufficient fuel oil available for compliance with the requirements if they plan to trade in ECA areas. The crew should be trained and familiarized with the fuel oil change-over procedures. For more information and guidance, please read the Technical Update 13-2014/November: DNV GL – Preparing for low sulphur operation.
Source: DNV GL

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