Emission Controlled Areas – New Regulations For 2015

From 1 January 2015, all vessels operating in emission controlled areas (ECAs) are prohibited from burning fuel with a sulphur content of more than 0.1%. Prior to 1 January, the limit was 1%, so a considerable decrease.

The implementation of the provisions of Annex VI to IMO MARPOL 73/78 Convention, on 1 January 2015, highlights the need for shipowners and operators to monitor the correct delivery of bunker fuels to avoid the risk of port stay control sanctions and fines, as well as the risk of possibly prejudicing any claims against the oil suppliers.

Presently, there are four IMO adopted ECAs: the Baltic Sea, the North Sea and the English Channel, North America and Canada. Other areas are under consideration, including: Australia, Japan, the Mediterranean and Norway, and these may be proposed as ECAs in the future.

Whilst there are various solutions to meeting the new regulations, such as passing the ship's main engine exhaust gas through a scrubber to remove sulphur before emission from the funnel or using an alternative fuel, such as LNG, the most common method will most likely be to burn low sulphur fuel oil. These distillate fuel oils are more expensive to purchase, and this could result in financial pressure on shipowners and operators, and possibly lead to consideration being given to sourcing fuels from less traditional suppliers offering cheaper fuel bunker sale contracts.

The IMO has implemented regulations to ensure that supply, as well as the actual burning of the fuel, is in compliance with the new rules, as they recognise this is the first level of control. Irrespective of what is said to be purchased, upon delivery to the ship, the bunker delivery must state information including the name, address, and telephone number of the marine fuel oil supplier, product name(s), quantity, density and sulphur content. Also, and importantly, a declaration signed and certified by the fuel oil supplier's representative "that the fuel oil supplied is in conformity with the applicable subparagraph of regulation 14.1 or 14.4 and regulation 18.3 of Annex VI" must be provided.

All vessels are required to retain the bunker delivery note on board for a minimum of three years.

The second level of control is the ship's crew who are there to ensure, in respect of the ECA compliant fuel oils, that bunkers are not loaded into part filled storage, settling all service tanks, and that such fuel oils do not become mixed with other high sulphur content...

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