MARPOL Annex VI came into force on 19th May 2005. From this date, ships of 400 gt and above engaged on international voyages are required to bunker with fuel oil which has a maximum sulphur content of 4.5% m/m and which complies with the requirements of Regulations 14 and 18. From 19th May 2006 the Baltic Sea will become a sulphur oxide emission control area (SECA). Ships trading in SECAs must either use fuel oil with a maximum sulphur content of 1.5% m/m or fit an approved exhaust gas cleaning system or other technological method to reduce the emission of sulphur oxides to 6.0g SOx/kWh or less. It is expected that the North Sea and English Channel will become a SECA in November 2007.
To ensure compliance owners should have a strategy to demonstrate that any fuel onboard complies with the following requirements:
- Clear instructions should be given to ship’s personnel
- Bunker clauses should indicate fuel quality and sulphur content, and state how statutory samples are to be taken
- Statutory fuel oil samples should be retained until the fuel is consumed, but for not less than 12 months from the date of delivery. Bunker delivery notes (BDNs) should be retained for three years
- Samples should be kept in a designated safe storage area and be traceable through an administrative system that ensures accurate documentation of the samples and their accompanying BDNs
- Samples are to be drawn through drip samplers, compliant with ISO 3170, ASTM D 4057 or BS 3195, and fitted at the bunker manifolds for both diesel and heavy fuel oil. These may be manual valve-setting continuous-drip samplers, or time- or flow–proportional automatic samplers as required by Resolution MEPC.96(47)
- It is the responsibility of the bunker supplier to provide an Annex VI compliant sample; some suppliers will provide the drip sampler, but others may expect the ship to do so
- The ship’s ISM bunker procedures should be updated to reflect these new requirements
Owners are advised to consult engine manufacturers for guidance on operating with low-sulphur fuel. Further information about the Annex VI requirements can be found in Lloyd’s Register’s Practical Guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18.
In addition, Lloyd’s Register’s fuel oil and bunker analysis service has produced a Marine Fuel Sulphur Record Book, which provides a system for the production and maintenance of the documentary evidence required by Regulations 14 and 18.