Global Sulphur Cap
From 1st of January 2020 on the sulphur content of any fuel oil used on board ships must not exceed 0.50 % m/m as per regulation 14.1.3 of MARPOL Annex VI. This means that the effective period for transition ends at midnight on 31 December 2019! This is a due date means no time frame for change is allowed.
This new regulation will be in addition to the 0.1 % sulphur limit in ECASs, which are already established under MARPOL Annex VI.
Baltic Sea (Gulf of Bothnia, Gulf of Finland, entrance to the Baltic Sea bounded by the parallel of the Skaw at 57°44’.8 N) North Sea (From southwards 62° N, eastwards 4° W, English Channel from eastwards 5° W and northwards 48°30’ N) North America 200 nm from coast, Hawaii, US Caribbean (For exact co-ordinates please check your MARPOL book Appendix VII)
Present Global Situation:
In addition to the mentioned established ECAs some coun-tries have local rules in force. As described in Briese’s “SOx - FUEL CHANGE OVER” Manual, which is on board of all ves-sels, local rules for example apply in Iceland, Turkey, Califor-nia, Italy, Panama Canal etc.
In China and Taiwan there have been some changes an-nounced just recently: In the Yangtze River Delta ECA already from 1st of October 2018 only fuel oil not exceeding 0.5% m/m is allowed.
From 01.01.2019 on the sulphur content requirement for the Pearl River Delta and Bohai Gulf areas are 0.5 % m/m.
All ocean-going ships entering Taiwanese international commercial ports will be required to use a fuel oil whose sulphur content does not exceed 0,5% by weight from 1st of January 2019 on; applicable ports will be: Keelung, Tai-chung, Kaohsiung, Hualien, Taipei, Suao and Anping.
Local rules may change from time to time therefore please verify with the local agent once a port call is scheduled.
The sulphur limits are decreasing globally step by step. Below graphic displays the general decrease.
The allowed sulphur limit will be reduced by 86 % in 2020.
Global Sulphur limit 0,50 % Smax – January 2020
Below map gives an overview of the global sulphur limit from 2020 on. Up to 70.000 ships may be affected by the new IMO regulations.
Effect on Briese Shipping
The new MARPOL Regulation will affect also the complete Briese fleet. The due date of 01st January 2020 leaves no room for any alternatives. The new limit applies to fuel used in main and auxiliary engines and boilers.
The amendment obliges to burn low sulphur, alternative fuel or to use ‘equivalent’ compliance mechanism which in-clude LNG or exhaust gas cleaning systems (ECGS) (scrub-bers) as from 1st of January 2020! In order to be compli-ant Briese Shipping will need to use residual, distillate and blended fuel oil pending on availability. Installation or retro-fit of alternative mechanism in order to be compliant is no option at the moment.
Everybody (Master, Chief Engineer, Charterers and Ship Owners) has to take care and think about the changeover to compliant fuel oil early in advance, as the availability and quantity of these different types of fuel around the imple-mentation date are currently unknown.
This means especially vessels operating in tramp trades have to start ordering and bunkering compliant fuels sev-eral months in advance depending on the upcoming voyage orders.
It has to be kept in mind that in the event the only available compliant fuel in a port is 0.10 % distillate, the ship will be required to use the 0.10 % distillate in order to fulfill the new regulation, regardless of any additional cost and incon-venience. Considerations have to be made when and where any new 0.50 % Smax fuels will be bunkered and into which tanks it will be pumped.
As the diversity of types of fuel oil will increase even more attention has to be paid to Technical Circular T-002: “Bunkering / Mixing of Heavy Fuel Oil” • Do not mix different supplies of HFO in one tank.
In addition decisions need to be done on following points:
- Cleaning of tanks for the bunkering of compliant fuel or • Bunkering compliant fuel into designated tanks on top of the remnants of 3.5 % Smax fuel as part of dilution / flush-ing process
Bunkering compliant 0.5% Smax fuel on top of remnants of 3.5 % Smax fuel has to be carried out carefully keeping in mind the possible associated risks resulting from incompat-ibility between the two fuel grades. Before mixing the differ-ent Smax grades fuel it has to be tried to get the designated tanks as empty as possible. • Try to empty the tank whilst in different trim situations • Flush all respective pipes carefully already a few days in advance. • Keep as little as possible un-pumpable remnants in the designated tank Mixing of different Smax grades may also result in testing variances associated with the testing of fuel oil samples e.g. during PSC. The IMO is considering amendments to Appen-dix VI of MARPOL Annex VI to ensure that a 95 % confidence limit is applied. This would mean that a sulphur content of up to 0.53 % could be accepted as complaint. But this amendment is not in force and will only be decided in mid of 2019!
There are templates available for a recommended Ship Im-plementation Plan for achieving compliance with the 0,5 % sulphur limit. In order to keep the administrative work on board as low as possible it is not planned to develop such a ‘Ship Implementation Plan’ for each vessel at the moment.
Such a plan would include for example following aspects. • Date and Time of the commencement of the changeover procedure based on trading area, voyage order • Identification of bunker tanks designated to receive an store 0.50 % Smax compliant fuel that will be used for the changeover • Preparation and / or cleaning of designated tanks and fuel oil system before bunkering 0.50 % Smax fuel • Time that is required to changeover the fuel oil system to compliant fuel based on the maximum volume of fuel in the system to be flushed; changeover calculator to be used. • Procedures and schedule for checking remote indication, transmitters, alarm and shutdown systems for fuel oil storage, settling, service and overflow tanks, and for checking the availability of standby machinery to promptly start in case of any issues. These checks should be carried
out before initiating the changeover procedure. • Associated changes in auxiliary systems. For example, purifier gravity discs for different viscosities, cylinder oil with different base numbers In order to check compliance it is anticipated that PSC offic-ers obtain and test samples taken directly from the fuel oil system of a ship; so called ‘in use’ or ‘on board’ samples. An accurate documentation of change of fuel has to be done including following points: • Oil Record Book Part 1, providing details of all bunkering operations including the location, date, time, details of tank contents and fuel types (including sulphur content) and grades bunkered; • Bunker delivery notes must be kept on board, which states the sulphur content of the fuel oil supplied; Samples may be taken for verification. • Fuel change over log book that records the volume of low sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel oil changeover operation is completed; Beginning of 2019 all Briese vessels should send an over-view of remaining fuel on board including sulphur content to their Inspection Groups. From middle of 2019 on all re-maining fuel with a sulphur content above 0,50% m/m should be consumed.
Special attention has to be taken in following cases: • Redelivery of a vessel from charter with HFO HS on board • Delivery of a vessel into a new charter • Change of trading areas For example if a vessel will be delivered into a Charter in an ECA Zone before 2020 with HFO HS on board and same will not be used there is no chance to use it after 31.12.2019. In 2020 the HFO HS will be worthless and costs for disposal may apply.
Therefore HFO HS which is not to be used until end of 2019, should be sold on the market in close cooperation with the Inspection Group. For a better implementation of the new regulation IMO has approved prohibition on the carriage of non-compliant fuel. That means from March 2020 the car-riage of non-compliant fuel (above 0.50 % sulphur) on board is prohibited!