maRPol annex Vi

MARPOL Annex VI
Regulations for the Prevention
of Air Pollution from Ships
Verband Deutscher Reeder
I. Introduction
The idea for this brochure was developed by ship owners and
Administrations to help seafarers onboard in their work to understand and make use of the regulations of MARPOL Annex VI
which is in force since 19 May 2005 with corresponding European
legislation.
So this brochure can serve as a proactive approach to prevent
illegal air emissions or possible violations from ships.
Although ships are the most effective mode of transport, the
political debate about emissions from ships is still very intensive.
According to various statistics ships are responsible for 2% of Carbon dioxide emissions while carrying 90% of international goods.
Sulphur Oxide emissions account to around 4% world wide. Nitrogen Oxide emissions from ships are responsible for 7% of world
wide emissions.
Heavy Fuel Oil is often used on board of ships as fuel. Most common in bunker ports today are IFO 380 and IFO 180.
Bunker quality is of great concern since many years and especially
sampling procedures are needed to be established to guarantee a representative sample that could be used in case of legal
disputes.
The ISO 8217 standard sets minimum requirements for contents
and compositions in marine fuels.
Since 2005 MARPOL Annex VI Regulations 14 and 18 set additional requirements for the composition of marine fuels.
From 19 May 2006 the sulphur content of fuel oil used in the
Baltic Sea SOx Emission Control Area (SECA) is limited to 1.5%.
As from the 22 November 2007 this obligation also applies to the
North Sea area according to Resolution MEPC. 132 (53).
This requirement already applies to European flagged ships from
11 August 2007 according to EU Directive 2005/33.
II. Guide for practice on board
Annex VI contains provisions which allow prosecution in case of
non-compliance. In Germany for example the fees amount up to
50.000 €.
The most important regulations of Annex VI with regard to sulphur are listed below:
1.) Prohibition of exceeding the required limiting values
as to the sulphur content of any fuel oil used on
board ships:
Regulation 14 (1) stipulates a general sulphur content of
4,5 % m/m which shall not be exceeded.
Regulation 14 (4) (a) stipulates a maximum sulphur content
of 1,5 % m/m within a SECA.
Change over procedures:
Upon entry into the SECAs the ships´ crew has to ensure that for
any fuel used on board the maximum sulphur content is 1,5%.
This change over procedure incorporates the main and auxiliary
diesel engines and also auxiliary equipment as marine steam
boilers and Inert Gas-plants. Emergency generators and lifeboat
engines are exempted.
The ship normally is equipped with a heavy fuel oil system with
one day tank system or two day tanks. If the ship has two day
tanks than one day tank is filled with high sulphur heavy fuel oil
and the other is filled with low sulphur heavy fuel oil. The level of
filling in the low sulphur tank has to be sufficiently high before
changing from one to the other tank to avoid a shortage of fuel in
case of separator or fuel problems. Before entering the SECA the
fuel supply has to be changed from the high sulphur to the low
sulphur tank and has to be completed in advance before entering
the SECA. The necessary records of the fuel change over shall be
made in the log book or into a separate “fuel change over bunker
record book”.
In case of a one fuel system with one day tank, the preparation
of low sulphur heavy fuel oil has to start well in advance before
entering the SECA. The preparation time for the mixing of low
and high sulphur fuel has to be pre-calculated to ensure that the
sulphur limit of 1,5% is reached before entering the SECA. For this
calculation, computer files (e.g. EXCEL-files from fuel oil suppliers)
or approved change over manuals (e.g. from classification societies) can be used. Depending on the sulphur content of the fuels
and the tank capacities the mixing time can be up to 40 hours or
even longer.
Changing back to High Sulphur Fuel Oil (HSFO) is allowed only
after leaving the SECA. Again the relevant records shall be made
into the appropriate ships log book when leaving the SECA.
Please note that the Total Base Number (TBN) of the lubrication
oil may have to be adjusted when using Low Sulphur Fuel Oil
(LSFO).
Incineration of Sludge Oil in SECAs:
According to Annex VI the incineration of sludge in shipboard
incinerators or auxiliary boilers is not prohibited. It has to be considered that only sludge oil produced during normal operation is
allowed to be incinerated. This means that only sludge from the
low sulphur heavy fuel oil separation can be incinerated within
the SECA.
Considering the HELCOM requirements in the Baltic Sea Area the
incineration of sludge is prohibited within the 12 mile nautical
area. There are only a few areas left in the Baltic sea area outside
this zone. Therefore it is recommended not to use the incinerator
in the Baltic Sea Area.
2.) Details of the Bunker Delivery Note (BDN)
Regulation 18 (3) stipulates that details of the fuel oil have
to be recorded by means of a bunker delivery note.
The BDN has to contain at least the following information (as
laid down in Appendix V of MARPOL Annex VI):
–Name and IMO Number of receiving ship
– Bunkering Port
– Date of commencement of delivery
–Name, address and telephone number of
marine fuel oil supplier
– Product name
–Quantity in metric tons
– Density at 15 °C kg/m³
–Sulphur content (% m/m)
–A declaration signed and certified by the fuel oil suppliers
representative that the fuel oil supplied is in conformity with
regulation 14 and 18 of Annex VI
Furthermore it must be noted, that the BDN shall state the detailed sulphur content of the fuel oil. General statements, as for example “sulphur content less than 1,50%” shall not be accepted. This
statement is not in line with current interpretations of MARPOL
Annex VI and does also not allow the crew to calculate a correct
fuel change over time.
Ideally the detailed sulphur content is stated with two decimals,
which is common practice in fuel oil industry. Only one decimal
might lead to confusion whether a fuel meets the “1,50% - limit”
or not.
In addition it is recommended, that the BDN contains also the
seal numbers of all associated fuel samples, as to allow easy
cross-reference. In case the seal numbers of the fuel samples were
not stated by the supplier, the officer in charge should record the
numbers on the BDN before signing.
Before signing or before taking bunker, the officer in charge shall
check the presented BDNs thoroughly. In case of incorrect BDNs a
Letter of Protest should be issued against the fuel supplier otherwise the responsible officer can be held liable as well.
The BDNs shall be kept on board readily available for inspection
until the fuel is completely consumed but in any case for a time
period of not less than three years.
III. Regulations
for bunker oil suppliers
There is also a number of regulations addressing the suppliers of marine bunker oil, e.g.:
1.) Obligation to deliver fuel oil of a specified quality:
Regulation 18 (1) regulates the fuel oil quality delivered to
and used on board ships for combustion purposes.
In case of delivering fuel oil that does not meet the requirements specified in Reg. 18 (1) the supplier becomes liable.
Inorganic acids, chemicals and other substances are identified as well which should not be compounds of marine
bunker fuels.
2.) Sampling in accordance with the »Guidelines for
the sampling of fuel oil for determination of compliance with Annex VI of MARPOL 73/78 « adopted by
ResolutionMEPC. 96 (47)
Regulation 18 (6) states that the bunker delivery note shall
be accompanied by a representative sample of the fuel oil
delivered (which is the so called MARPOL sample.)
Fuel Oil Sampling:
The sampling shall follow a.m. Guidelines and consequently
the sampling has to be done at the receiving ships’ bunker
manifold.
The MARPOL sample shall be drawn throughout the whole bunker delivery time continuously. For taking samples approved drip
sampling methods are to be applied. There are three samplers to
choose from:
1.) manual valve-setting continuous-drip sampler
2.) time-proportional automatic sampler
3.) flow-proportional automatic sampler
Other samples than the MARPOL sample can be taken for commercial purposes but they are not relevant with regard to the
MARPOL requirements.
On completion of the bunkering process, the “MARPOL sample” is
to be sealed and signed by the fuel suppliers representative and
the officer in charge of the bunker operation.
The sample bottle label shall contain at least
the following information:
–Location and method of the sampling
– Bunkering date
–Name of bunker tanker resp. bunker installation
–Name and IMO number of receiving ship
–Signatures and names of the supplier’s representative
and the ship’s representative
–Seal identification
– Bunker grade
The MARPOL sample shall not be used in any commercial dispute.
It shall be kept under the vessel’s control until the fuel oil is
completely consumed but in any case for a time period of not less
than 12 months from the time of delivery.
It is recommended, that the MARPOL sample is stored in a safe
and sheltered storage location outside the ship’s accommodation. Also an inventory system should be developed to allow easy
tracking of the samples.
In case the authorities require the handover of the MARPOL
sample it is recommended that the officer in charge records this
in the log book in order to proof the remaining of the sample. The
log book entries shall contain the following:
The log book entries shall contain the following:
–Date, time and port where the MARPOL sample was given to
authorities
–Seal number of respective sample
–Name, address and contact details of receiver
– Reason for hand over of the MARPOL sample
Ideally the receiver signs for the receipt of the MARPOL sample.
In case authorities draw their own fuel oil samples from the vessel’s
fuel tanks it is recommended that the officer in charge records this
also in their log books.
Generally these records should contain the same information as
mentioned above.
IV. EU Sulphur Directive
2005/33 and 1999/32
The European Commission has set legislation in place with the EU
Regulation 2005/33 and 1999/32 which have to be read in conjunction. European legislation applies to ships trading between
European ports and ships flying the flag of a European member
state. Both regulations set standards for bunker suppliers, owners
and ships` crew.
European legislation is imposed on ships as well. Although shipping is global, regional legislation can effect shipping in a quite
considerable way.
The EU Directive 2005/33 and 1999/32 apply to all ships calling
European ports irrespective of their flag.
Two different scenarios have to be distinguished:
1.) Ships alongside berth
2.) Ships trading between European ports (underway)
Similar to IMO MARPOL Annex VI also the European Commission with its Directive 2005/33, amending Directive 1999/32, has
established new requirements for the quality of fuel oils used
onboard ships. Besides limitations on the fuel´s sulphur contents,
the Directives define identical SECAs as already found in MARPOL
Annex VI, but at different application dates.
Following application dates applied to the SECA »Baltic Sea«:
MARPOL Annex VI:
19 May 2006
EU Directive 2005/33:
11 August 2006
Regarding SECA »North Sea / English Channel« application
dates will be:
EU Directive 2005/33:
11 August 2007
MARPOL Annex VI:
21 November 2007
Furthermore the EU Directives define new limits for the fuel´s sulphur content which mean, that all marine fuels used within both
SECAs are to have a maximum sulphur content 1,5%. This limit is
similar to the limit found in MARPOL Annex VI.
Additionally the EU Directive gives new limitations to marine
distillate fuels, which are as follows:
From 11 August 2006 until 31 December 2007:
ISO 8217 grades DMX and DMA: Max. sulphur content = 0,2 %
ISO 8217 grades DMB and DMC: Max. sulphur content = 1,5 %
From 01 January 2008 until 31 December 2009:
ISO 8217 grades DMX and DMA: Max. sulphur content = 0,1 %
ISO 8217 grades DMB and DMC: Max. sulphur content = 1,5 %
From 01 January 2010:
A 0,1 % sulphur limit start to apply to all types of marine fuels
used by ships at berth in EU ports. This applies to any use of the
fuel with the following exceptions:
– Ships which spend less than 2 hours at berth according to
published time tables.
– Ships which switch off all engines and use shore-side
electricity.
The Sulphur Directive also puts up special requirements for
passenger ships and ferries following a regular schedule between
European Union ports. (further information can be found under
http://ec.europa.eu/environment/air/transport.htm).
V. Inspections
1.) MARPOL Inspections
Within MARPOL Inspections in German ports water police officers
verify compliance of the regulations of Annex VI along with the
control of the other Annexes of MARPOL 73/78.
At this the Bunker Delivery Note, samples and the engine log
book or other record books are the relevant documents.
The Federal Maritime and Hydrographic Agency (BSH) in Hamburg is the competent authority in Germany for taking action
against violations of MARPOL 73/78.
2.) PSC Inspections
During port State Control Inspections the ship’s crew has to be
prepared to show on demand to the PSC inspectors the Bunker
Delivery Note, the Fuel Oil Samples and the documentation of the
fuel change over procedures in the engine log book or the „fuel
change over bunker record book“.
Furthermore it has to be ensured that enough low sulphur fuel
oil is on board to enter the SECA boarder before leaving the port
of PSC control. Otherwise the ship may be detained or may be
forced to bunker low sulphur fuel in that port.
All European waters
Passenger Ships on regular
voyages with a schedule
(EU-flag)
All ships flying EU-flags ***
All
Marine gas oil ships (or MDO)
All
11.08.06
11.08.07
22.11.07
01.07.00
01.01.10
%
MARPOL Annex VI
1,5
MEPC.132(53) in
force (22.11.2006)**
1,5 ---
1,5 ---
1,5 ---
1,5 Regulation 14,
European Union
---
EU-Directive
2005/33
EU-Directive
2005/33
--EU-Directive
2005/33
* In Germany the suppliers are held liable in this case
( 3. BImSchV, § 8 Ordnungswidrigkeiten, Paragraph 1)
** 12 months after in force date, the North Sea SECA is implemented
*** or trading between European waters
All European ports
All European ports
0,1 ---
0,2 ---
EU-Directive
2005/33
EU-Directive
1999/32
European legislation in ports and inland waterways
North Sea and English
Channel
North Sea and English
Channel
Baltic Sea
Area
All
Baltic Sea
11.08.06
Ship Type
All
19.05.06
Date
OverviewofSECA-Stadiumsandrelevantlegislation:
Germany
other legislation in place with
BImSchV*
8. Schiffssicher-heitsanpassungs VO
10. VO Umweltschutz-See
---
8. Schiffsicherheitsanpassungs VO
--8. Schiffsicherheitsanpassungs VO
Contact Points
For further information concerning MARPOL Annex VI
please contact:
Bundesamt fuer Seeschifffahrt und Hydrographie (BSH)
Ms. Mareike Wendland
Bernhard-Nocht-Str. 78 | 20359 Hamburg
Tel: +49 (0) 40 3190-2123 | Fax: +49 (0) 40 3190-5000
www.bsh.de | email: [email protected]
Seeberufsgenossenschaft (SEE BG)
Schiffssicherheitsabteilung | Ship Safety Division
Mr. Holger Steinbock
Reimerstwiete 2 | 20457 Hamburg
Tel: +49 (40) 36137-217 | Fax: +49 (40) 36137 204
www.see-bg.de | email: [email protected]
Verband Deutscher Reeder
German Shipowners’ Association
Mr. Heinrich Braun
Esplanade 6 | 20354 Hamburg
Tel: +49 (40) 35097-226 | Fax: +49 (40) 35097-211
Verband Deutscher Reeder
www.reederverband.de | email: [email protected]
Furthermore we especially thank Mr. Dirk Hundt of the
shipping company NSB for his support and practical
guidance for this brochure.
Imprint: Herstellung: VDR Presse & Öffentlichkeitsarbeit , Esplanade 6, 20354 Hamburg
Grafik: Geßner, Druck: Storck Verlag, Stand: Dezember 2007