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By selecting China flag, you have now set your language to Chinese. This has several benefits, including:

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MARPOL Annex VI

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MARPOL ANNEX VI –  USCG: Marine Safety Alert 2/15 Ultra Low Sulphur Fuel Oil & Compliance with MARPOL Requirements – 13 March 2015

The USCG has issue a marine safety alert reminding vessel owners and operators to implement effective fuel change over procedures for vessels intending to operate in Emission Control Areas.

To read the alert in full follow the link

MARPOL Annex VI: USCG Issue a Marine Safety Bulletin on the ECA Sulphur Cap – 12 March 2015

The US Coast Guard has issued a Marine Safety Information Bulletin relating to the new Emission Control Area (ECA) sulphur cap which commenced 1 January 2015.

The bulletin is a reminder that in accordance with MARPOL Annex VI, Regulation 14, fuel oil used by all ships operating in ECAs, including the North American and United States Caribbean Sea ECAs, cannot exceed 0.10% fuel sulphur (1,000 ppm).

Members with ships operating within the North American ECA are reminded to use compliant fuel within 200 nautical miles of the North American coast and within approximately 50 nautical miles of the United States Caribbean Sea coast.

The Bulletin entitled “New Emission Control Area (ECA) Sulfur Cap” can be read here.

European Union – Guidance on Compliance with Sulphur Limits in EU SECA – 4 February 2015

Members are reminded that from 1 January 2015, whilst operating or transiting the EU SOx Emission Control Areas (SECA), vessels are required to comply with sulphur content limits in marine fuels set by Council Directive 1999/32/EC or use an approved emission abatement method.

Members are referred to the attached European Maritime Safety Agency (EMSA) advice, which provides guidance on inspection of ships and ascertaining their compliance with the Directive.

US Penalty Policy for ECA Violations – 22 January 2015

The US Environmental Protection Agency (EPA) has published a penalty policy which it will use when assessing civil penalties for violations of the fuel sulphur standards in the US sections of the MARPOL Annex VI emission control areas (ECAs). The policy’s aim is to remove the benefit of non-compliance and to reflect the gravity of the violations.

Guidelines for compliance with MARPOL Annex VI within ECA’s – 08/01/2015

On 1 January 2015, revised fuel sulphur limits came into force in MARPOL Annex VI Emission Control Areas (ECA) as follows:

This regulation has had a direct impact on Members’ ships operating within the following Emissions Control Areas (ECA):

  • North Sea ECA
  • Baltic Sea ECA
  • North American ECA
  • United States Caribbean Sea ECA

As a consequence, vessels operating within an ECA will be permitted a maximum FO sulphur content of 0.1%.  Members can review the EMSA advice document: here.

The Paris MOU guidelines on Regulation 18 provide details of situations where compliant fuel cannot be bunkered, provided the owner has taken reasonable steps to do so and therefore does not need to deviate from the intended route or unduly delay the voyage to achieve compliance.  A summary of the required actions is as follows:

  • Members are advised to expedite best efforts to source compliant fuels before entering an ECA.
  • In event that compliant fuels are not available Members should accurately document their best efforts and maintain detailed records of all attempts to procure compliant FO.
  • If compliant FO is not available Members should Notify Paris MOU PSCO’s of non-availability of compliant fuel as soon as possible, but prior to entering the ECA.
  • Members should then procure compliant FO at the next available port call within the ECA.
  • Even if compliant fuel has been procured, all ships records pertaining the use and compliance with the ECA regulations must be robustly accurate. This will include but is not limited to: voyage/passage plan (including the time date and entry in the ECA), if transiting an ECA (the date/time of notification of voyage instructions and the date/time entering/exiting the ECA), FO Change Over Procedures (in English), Bunker Deliver Notes (displaying the sulphur content) bunker specification reports, Oil Record Book entries, fuel oil samples, invoices names and addresses of the suppliers and all correspondence with the bunker supplier should be retained with all documentation within a dedicated low sulphur FO file.
  • If the vessel has operated in the ECA in the last 12 months, provide the names of all ports visited.

Full details of the Paris MOU guidelines can be viewed via the following link: here.

The United States Environmental Protection Agency (EPA) and United States Coastguard (USCG) has issued an equivalent set of guidelines on the reporting requirements of non-compliant fuels.

  • Members are advised to expedite best efforts to source compliant fuels before entering an ECA.
  • In event that compliant fuels are not available Members should accurately document their best efforts and maintain detailed records of all attempts to procure compliant FO.
  • If compliant FO is not available Members should File a Fuel Oil Non-Availability Report (FONAR) to the EPA 96 hours before entering the ECA.
  • Members should then procure compliant FO at the next available port of call within the ECA.
  • Even if compliant fuel has been procured, all ships records pertaining the use and compliance with the ECA regulations must be robustly accurate. This will include but is not limited to, Copy of Flag Administration Notification, voyage/passage plan (including whether any attempts were made to locate other sources of compliant FO), FO Change Over Procedures (in English), Bunker Deliver Notes (displaying the sulphur content) bunker specification reports, Oil Record Book entries, fuel oil samples, invoices names and addresses of suppliers and all correspondence with the bunker supplier should be retained with all documentation in a dedicated low sulphur FO file.

Full details of the USCG/EPA guidelines can be viewed via the following link: here.

Note: Detailed and accurate record keeping and documentation is key to avoiding potential problems in any of the ECA’s, so Members are advised to carefully read and understand the full regulations via the above links.

For further detailed information, Members should refer to our forthcoming Signals 98 article here and our previous Industry News article here.

IMO FAQs on Sulphur Limits in Emission Control Areas – 30/12/2014

Revised sulphur limits will be introduced on 1 January 2015 for MARPOL Annex VI Emission Control Areas whereupon the present sulphur limit of 1% for vessels sailing within these areas will be reduced to 0.1%.

The International Maritime Organization (IMO) has published a set of FAQs on the new requirements and can be found here.

Further information can also be found here

North American and Caribbean ECAs – USCG & EPA co-ordinated enforcement campaign – 21/11/2014

Members are reminded that the current legislation under Annex VI of the International Convention for the Prevention of Pollution from Ships (Marpol), which states that  vessels sailing within the North American and U.S. Caribbean Sea Emission Control Areas (ECAs) are required to burn fuel with a sulphur content of no more than 1%, will change on 1 January 2015. After that date the maximum allowable sulphur content will be reduced to 0.1%.

The United States Coast Guard (USCG) and the US Environment Protection Agency (EPA) have advised that they will be taking action to ensure compliance with new regulations from 1 January. The USCG will continue to check Bunker Delivery Notes and other records during Port State visits to vessels. The USCG & EPA are planning joint boardings of vessels to take fuel oil samples and perform in-the-field screenings for sulphur levels.

Members are reminded that advice should be sought from Flag State, Classification Society or Engine manufacturer on how these new changes will affect them. Inclusion of the fuel switchover procedure should be incorporated into their Safety Management System and ship’s crew should become familiar with the fuel switchover procedure and emergency procedures required in case of engine failure during or after the switchover process.

Members are requested to ensure that their crews are making full and accurate entries in the applicable logbooks regarding all operations which involve bunkers and that fuel sampling is carried out as appropriate. Crews should always be open, honest and co-operative when dealing with Coast Guard and EPA staff. Members are also reminded of State of California requirements (Industry News ‘California Air Resources Board OGV Fuel Regulation Sunset Period’ issued on 23 September 2014 – see below) and EPA instructions regarding compliant fuel oil non-availability (Industry News ‘United States Environmental Protection Agency – Non-compliant Fuel Oil Registration System issued on 18 July 2014, accessible here), which should be read in conjunction with this Industry News.

North will also be publishing an article associated with this subject in the next edition of Signals to be published in January 2015 which will be viewable online here.

New 0.1% Sulphur Regulations for EU ECA January 2015 – 10/11/2014

From the 1 January 2015, new European Union environmental legislation will take effect which aims at ensuring a substantial reduction in marine sulphur emissions in Northern Europe to the benefit of the environment. This new legislation cover a large geographic area extending from the English Channel to the Baltic Sea, termed as the Sulphur Emission Control Area (ECA).

The EU legislation means that vessels operating in the ECA from the 1st January 2015 will be allowed a maximum sulphur content in their fuel of 0.1% compared to today’s limit of 1.0%. Alternatively, the use of an exhaust gas cleaning unit can be used to obtain an equivalent reduction. This legislation originates from the International Maritime Organization (IMO), and further information can be obtained by reading the MARPOL Convention from the IMO on their website.

Although auxiliary engines and boilers have been required to utilize 0.1% fuels whilst alongside EU berths since 2010, now with the inclusion of the 1st January 2015 0.1% limit throughout the ECA, ship-owners and operators will have to switch over to compliant fuel whilst operating or transiting the ECA itself.

Members are advised with the date fast approaching they should seek advice from their Flag State, Classification Society or Engine manufacturer on how these new changes will affect them. Inclusion the new changeover regime should be incorporated into their ISM (Safety Management System) and ship’s crew should become familiar with the changeover procedure and any emergency procedures required in cases of engine failure during the switch over process.

You can read the EU ECA advice document here.

California Air Resources Board OGV Fuel Regulation Sunset Period – 23/09/2014

The California Air Resources Board (ARB) have issued an advisory notice which provides guidance for ships visiting ports in the State of California with regard to fuel sulphur limits when the revised MARPOL Annex VI North American Emission Control Area (ECA) sulphur limits come into effect on 1 January 2015.

California ARB Marine Notice 2014-1 advises that the California Ocean-Going Vessel (OGV) Fuel Regulation that is presently in effect within regulated Californian waters is currently subject to a sunset review by the California ARB. The OGV Fuel Regulation has a provision which states that it will cease to apply if the North American ECA requirements meet an equivalent standard.

However, the sunset review is not expected to be completed until after the introduction of the revised North American ECA sulphur limits, and consequently it is likely the OGV Fuel Regulation will remain in effect and continue to be enforced.

The fuel sulphur limits of the OGV Fuel Regulation and the North American ECA will both be 0.1% as of 1 January 2015, but there are two fundamental differences between the two sets of requirements:

  • The ECA Regulation allows alternative emissions control technologies such as exhaust gas cleaning devices (“scrubbers”) to be used, whereas the OGV Fuel Regulation does not have a similar provision. Therefore OGV Fuel Regulation compliance can only be achieved by using low sulphur fuel.
  • The ECA Regulation only requires that a fuel meets the specified percent sulphur requirements, while the OGV Fuel Regulation requires that the fuel also meets the specifications for distillate grades.

It is understood that the California ARB will allow vessels complying with the North American ECA requirements under the above provisions (i.e. using scrubbers or burning non-distillate fuel that otherwise complies with the 0.1% sulphur cap) by submitting a Temporary Experimental or Research Exemption form.

The California ARB Marine Notice 2014-1, which includes templates of the aforementioned exemption forms, as well as details on who should submit this form and where to send it, can be found through the following link:

Marine Notice 2014-1

In addition, Members can access all California ARB’s marine notices, advisories and alerts relating to the California OGV Fuel Regulation at:

http://www.arb.ca.gov/ports/marinevess/ogv.htm

US ECA Enforcement Campaign – 01/08/2014

It has been reported that US Environmental Protection Agency (EPA) officials, accompanied by the US Coast Guard (USCG), are boarding vessels on the west coast of the US to check compliance with MARPOL Annex VI.

Once on board, the EPA obtains fuel samples, to analyse at their own laboratory to ensure the fuel is compliant with the 1% sulphur content requirements of the North American Emission Control Area (NA ECA).

The NA ECA has been in force since 1 August 2012 and the permissible sulphur content is to be further reduced to 0.1% by 1 January 2015.

The EPA and USCG are reportedly increasing efforts to ensure vessels are compliant with MARPOL Annex VI rules and their intention is to extend a fly-over programme to areas that fall under the US ECA.

Members should ensure that fuel oil changeover procedures are in place, that crew are well trained and proficient in expediting it and that proper records, logs and fuel sampling is being carried out as appropriate.

The EPA’s Enforcement of MARPOL Annex VI – Memorandum of Understanding (MOU) can be read here.

USCG enforcement of MARPOL Annex VI designated North American ECA’s – 02/08/2012

The US Coast Guard has recently issued policy letter CG-CVC 12-04 -Guidelines for Compliance and Enforcement of the Emission Control Areas Established within the United States Jurisdiction as Designated in MARPOL Annex VI Regulation 14.

The policy letter details the methods and procedures which will be used by the USCG in verifying a vessel’s compliance with the requirements of MARPOL Annex VI and how any violations will be documented and referred to the Environmental Protection Agency (EPA) for enforcement.

A copy of the CG-CVC 12-04 policy letter can be read here.

In addition to the policy letter, the USCG has issued an ECA Job Aid intended to assist attending inspectors in identifying and documenting any MARPOL related deficiencies when conducting inspections. Inspections relating to MARPOL Annex VI and compliance with the North American ECA’s will be carried out in conjunction with normal PSC and domestic vessel inspections.

A copy of the ECA Job Aid can be read here.

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