barbados maritime

INFORMATION BULLETIN No. 246

Verification of Sulphur Content in Marine Fuels in use on-board

Ships

Application: All shipowners, operators, masters and officers of merchant ships

Ship-owners need to be aware of the differing jurisdictional rules and costs likely to arise in the form of penalties and fines imposed for non-compliance with a jurisdiction’s requirements for low sulphur fuels. Hong Kong and Australia are amongst maritime administrations imposing their own specific requirements.

Low-sulphur fuel of 0.1% or less will be mandatory for all cruise ships berthing in Sydney Harbour after 1 October 2015, and in

all New South Wales (NSW) ports after 1 July 2016. Owners can be fined up to $44,000 and the Master up to $22,000.

For Hong Kong, all ocean-going vessels above 500gt are required to switch to low-sulphur fuels (or LNG or similar approved fuels) during the period the ship is at a berth, excluding the first and last hour the ship is at the berth. The level of sulphur content must not exceed 0.5%). Hong Kong requirements impose criminal sanctions against the owner (including any BB charters and managers) and the Master. There is a maximum fine of HK$ 200,000 and a maximum prison sentence of six months.

There are technical issues with the new fuels; low viscosity, lack of lubricity and low density amongst them. The higher costs of

obtaining the new fuels and the lack of availability in some parts of the world create additional difficulties. It is recommended that ship-owners consult their engine & boiler manufacturers for advice on operating with low-sulphur fuels and on equipment and system modifications that may be required.

The European Union has also mandated rules for the method and frequency of PSC surveys conducted by EU Member States for verification of the sulphur content of marine fuels used on board ships visiting EU ports. In summary, the following will be undertaken:

Ship’s log book and bunker delivery notes to be inspected on at least 10% of ships calling at ports in relevant Member

States per year. As of 1 January 2016, fuel spot samples will be drawn from the ship’s fuel system, or analysis of relevant sealed bunker samples on board or both. The target percentage of ships is given as follows:

(1) 40% in Member States fully bordering SECAs (SOx Emission Control Areas).

(2) 30% in Member States partly bordering SECAs

(3) 20% in Member States not bordering SECAs (rising to 30% from 1 January 2020).

Continued……

The Baltic Sea area and the North Sea specified in reg. 14.3.1 of MARPOL ANNEX VI - Member States are to take on-board sample of the fuel through single or multiple spot sample at the location where a valve is fitted for the purpose of sampling,

as indicated on the ship’s fuel piping systems or arrangement plan and as approved by the flag administration of RO acting on its behalf.

In the absence of such a location, the position of the valve for fuel sampling must meet the following conditions:

(1) be easily and safely accessible

(2) take into account different fuel grades being used for the fuel-oil combustion machinery

(3) be downstream of the fuel in use from the service tank

(4) be as close to the fuel inlet of the fuel-oil combustion machinery as feasible and safely as possible, taking into account

the type of fuels, flow-rate, temperature and pressure behind the selected sampling point

(5) be proposed by the ship’s representative and accepted by the sulphur inspector

In the event that modifications are made for fitting the fuel sampling valve, plan approval should be sought from Class.

16.09.2015