Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

Further information
Contact: Lloyds Register FOBAS Telephone: +44 (0)20 7423 1862 Email: [email protected]

www.lr.org
2005 Lloyds Register Registered office: 71 Fenchurch Street London EC3M 4BS, United Kingdom Services are provided by members of the Lloyds Register Group. Lloyds Register, Lloyds Register EMEA and Lloyds Register Asia are exempt charities under the UK Charities Act 1993.

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

Contents
1. Introduction 2. Regulation 14: controlling sulphur oxide (SOx) emissions from ships 3. Regulation 18: fuel quality, sampling and delivery requirements a. Fuel quality b. The statutory sample c. The statutory bunker delivery note (BDN) 4. The Annex VI enhanced FOBAS sampling kit and analysis report a. b. c. d. e. f. The FOBAS sample bottle kit Taking the fourth statutory sample using a FOBAS bottle The analysis report The bunker clause Sampling equipment to be used Readiness for May 19, 2005 2 2 3 3 3 3 4 4 4 4 4 5 5 5

5. Further information and contact

APPENDIX 1: Records of fuel oil changeovers when entering/leaving a SECA a. Information to be recorded b. Flushing through the system on changeover c. Logbooks APPENDIX 2: Fuel oil sampling arrangements a. b. c. d. e. Sampling methods Sampling location Retained sample handling Sealing of the retained sample Retained sample storage

6 6 6 6 8 8 8 8 8 9 10 11 18

APPENDIX 3: Information to be included in the bunker delivery note (BDN) APPENDIX 4: Frequently asked questions APPENDIX 5: Flowcharts
1

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

1. Introduction
This document outlines Lloyds Registers strategy for supporting its clients in their responsibility to ensure that their ships comply with Annex VI Regulations 14 and 18. It also provides some practical instruction as to what actions need to be taken, highlighting issues related to fuel delivered and used onboard ships. The MARPOL 73/78 Annex VI Regulations for the Prevention of Air Pollution from Ships enter into force on May 19, 2005. The global limit for the sulphur content of marine bunkers is set by the Regulations at 4.5% m/m. This is not expected to have much operational impact as the incidence of marine fuels exceeding this level is not high. The main impact will be felt when the Baltic and North Sea/English Channel SOx Emission Control Areas (SECAs) become operational on May 19, 2006 and in November 2007, respectively, further limiting sulphur content of fuels to 1.5% m/m. Note: The breakdown of Annex VI Regulations 14 and 18 below highlights only the key requirements and we therefore recommend that the full original text is reviewed. Copies of Annex VI, as well as the Resolution MEPC.96(47) guidelines for drawing statutory fuel samples for the determination of Annex VI compliance, are available from Rulefinder a PC-based software system that provides searchable access to the latest marine statutory and Lloyds Register classification requirements. They may also be purchased directly from IMO (www.imo.org).

2. Regulation 14: controlling sulphur oxide (SOx) emissions from ships

Regulation 14 addresses the mechanisms for controlling sulphur oxide (SOx) emissions on a global basis, as well as in defined environmental protected areas called Sulphur Oxide Emission Control Areas (SECAs). The aim is to reduce the SOx emissions which contribute to acidification and acid rain by setting a limit on the sulphur content in the marine fuels. The limitation applies to all vessels and will be enforced from May 19, 2005. Regulation 14 provides the following: The sulphur of any fuel used onboard ships must not exceed 4.5% m/m. The sulphur content of any fuel used onboard ships operating in a SECA must not exceed 1.5% m/m. The only established SECA so far is the Baltic Sea, as specified in Annex I paragraph 10.1 (b), in force 19 May 2006. It is expected that North Sea and English Channel will become a SECA in November 2007. Alternatively, exhaust gas cleaning systems or other approved technological methods may be installed to reduce the total SOx emissions from both main and auxiliary engines and boilers to a maximum of 6.0 g SOx/kWh when operating in a SECA. If an exhaust gas cleaning system is used, waste streams from the system must not be discharged to enclosed ports, harbours or estuaries based on criteria set by port state controls and communicated through IMO. Details of fuel changeover procedures from high- to low-sulphur, and vice versa, need to be recorded. See Appendix 1 in this document for full instructions and logbook requirements.
2

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

3. Regulation 18: fuel quality, sampling and delivery requirements

Regulation 18 covers issues related to fuel quality, sampling and delivery requirements. While in theory the responsibility lies with the supplier to comply with this regulation, the practical reality is that the enforcement agencies will be looking to ships to verify their compliance. Implementation and further actions required from the fuel supplier and the ships are also addressed in this regulation.

a. Fuel quality
Fuel oil for combustion on board ships must: be a blend of hydrocarbons derived from petroleum refining techniques (this does not preclude the incorporation of small amounts of additives intended to improve performance) be free from inorganic acids not include any added substance or chemical waste which either jeopardises the safety of ships or adversely affects the performance of the machinery, is harmful to personnel, or contributes overall to additional air pollution. This gives legal endorsement to similar requirements set down in the ISO 8217 international marine fuel standard defining the quality of Marine Fuels.

b. The statutory sample

Regulation 18 requires the bunker supplier to provide a statutory sample of at least 400ml in volume. This sample must be retained onboard for 12 months or until the complete bunker is consumed, whichever is the greater period. This statutory sample is in addition to any commercial control sample offered to the ship by the supplier. The statutory sample must not be used for commercial quality/quantity verification purposes and should only be handed over, upon request, to a port state control enforcement officer from a country that has signed up to the Annex VI protocol. Annex II of Resolution MEPC.96(47) provides guidelines for the sampling of fuel oil for determination of compliance with Annex VI, and clearly defines the point of sample collection to be at the receiving vessels inlet bunker manifold. For further instructions to ensure compliance, please see Appendix 2 of this document.

c. The statutory bunker delivery note (BDN)

Regulation 18 also requires that the supplier issues a bunker delivery note (BDN to accompany the statutory sample. The BDN must accord with certain requirements, and the information which must be included is outlined in Appendix 3 of this document.

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

4. The Annex VI enhanced FOBAS sampling kit and analysis report

Lloyds Register will provide FOBAS clients with a complete solution giving the required confidence to the shipowners that their fleets will be compliant. Given recent poor quality trends, it will be prudent for a shipowner to continue testing each bunker as supplied. This will verify that the supplier has complied with the Annex VI on sulphur content and fuel quality. Annex VI onboard procedures prepare the way to meet the more stringent regional environmental controls expected to be imposed on ships, such as the pending amendment to the EU Sulphur Directive 1999/32/EC COM(2002) 595.

a. The FOBAS sample bottle kit

FOBAS sample bottles are already Annex VI compliant. New kits being issued in May will contain the following additions: statutory sample bottle labels supplementary instructions with a checklist to accompany the sampling procedures manual, ensuring suppliers are Annex VI compliant and that appropriate records are being maintained on board ten 15ml sample tubes these may be used where only a sulphur check, or a compatibility test between the new bunker and another fuel supplied or already in storage, is required a Lloyds Register FOBAS Annex VI Logbook will be available upon request.

b. Taking the fourth statutory sample using a FOBAS bottle

It is anticipated that there will be occasions where the physical supplier is unaware or unprepared to meet his obligation to provide a statutory sample for whatever reason. Alternatively, he may not have a spare compliant sample bottle to fill. In either case, the ship should use a fourth FOBAS sample, ensuring that the statutory sample seal number details are placed on the BDN.

c. The analysis report

FOBAS analysis reports will include a reference to the statutory sample seal number and an additional statement referring to the extent of the fuels compliance with Regulations 14 and 18, based on the tests carried out on the sample.

d. The bunker clause

The bunker clause should continue to reference the required fuel quality against ISO 8217 fuel grades and state any vessel-specific limitations. The ISO 8217 sulphur maximums are not fully in line with Annex VI. The bunker clause must therefore: state the sulphur limit required (i.e. 1.5%, 4.5% or other) outline your expectation of the supplier to provide the Annex VI statutory sample following the recommended IMO sampling guidelines in MEPC.96(47) outline your expectation of an Annex VI compliant BDN (see Appendix 3).

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

The revised version of ISO 8217, due in summer 2005, will conform to the new sulphur limits.

e. Sampling equipment to be used

Approved drip samplers, valve locking plates and cubitainer primary collection samplers should be placed onboard all ships as standard equipment to ensure that representative samples are drawn according to the MEPC.96(47) guidelines. All the required equipment may be sourced through Lloyds Register FOBAS.

f. Readiness for May 19, 2005

It is possible that some ships will not have the enhanced Annex VI sample kits on board by May 19, 2005. To assist these ships, an electronic version of all the documentation will be available. Should it be necessary to take a fourth sample using the FOBAS sample kit under these circumstances, an old label may be used. The label should be marked Annex VI Statutory sample and the appropriate data should be included as outlined in Appendix 2 of this document.

5. Further information and contact

FOBAS is the Lloyds Register Groups fuel oil and bunker analysis and advisory service. A recognised leader in the evaluation of all grades of fuel oil used in the marine industry, we are only a telephone call away when you require urgent analysis of a fuel sample or technical advice. Answers to a number of frequently asked questions about Annex VI can be found in Appendix 4 of this document. Should you have any further questions, please do not hesitate to contact your local Lloyds Register office account manager or speak to FOBAS directly at: Lloyds Register FOBAS 71 Fenchurch Street London EC3M 4BS Tel: +44 (0)20 7423 1862 Email: [email protected]

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

APPENDIX 1: Records of fuel oil changeovers when entering/leaving a SECA a. Information to be recorded
The regulation requires the following details to be officially recorded when any fuel changeover operation is carried out between low- and high-sulphur content fuels: the volume of low-sulphur fuel oils (less than or equal to 1.5% m/m sulphur) in each tank date time position of the ship. These details are to be taken and recorded once it has been established that only fuel oil with a sulphur content of less than 1.5% m/m is being burned.

b. Flushing through the system on changeover

It is the responsibility of the shipowner to ensure that it can be established, to the satisfaction of the administration or appointed representative, that the fuel oil being burned whilst traveling within a SECA has a net sulphur content below 1.5% m/m (i.e. that enough time has been allowed for the fuel oil service system to be fully flushed of all fuels with a sulphur content of over 1.5% m/m on changeover, prior to entry into a SECA). Segregated systems: if separate fuel oil/storage tank systems are installed for fuels with a sulphur content below and above 1.5% m/m, respectively, changeover from one fuel to the other, including flushing time, may be relatively simple and quick. Non-segregated systems: care must be taken in such cases to ensure that the entire system is purged of any fuel oil with a sulphur content above 1.5 % m/m prior to entering a SECA. For this purpose, it may be necessary to calculate the volume of 1.5% m/m sulphur fuel required to flush the system completely, including any tanks, to avoid mixing and subsequently raising the net sulphur content above 1.5% m/m. The actual volume used during flushing may be found if the details mentioned above are recorded immediately prior to flushing the system. This figure may then be compared with that calculated so as to determine compliance. To aid this process, changeover procedures and flushing calculations may be contained in the ISM manual on-board the vessel. This would also ensure that all officers responsible for the changeover operation are fully conversant in the procedure to be followed and the details to be recorded.

c. Logbooks
The required details are to be recorded in a logbook prescribed and approved by the administration. The format of this logbook is dependent upon the requirements of the administration, however it is expected that this may be one of the following: a separate logbook, for this purpose only the engine room logbook
6

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

the deck logbook the official logbook the fuel oil record book, already in use on board Lloyds Register FOBAS Annex VI logbook

The Lloyds Register FOBAS Annex VI logbook will enable clients to record details of the statutory samples and changeover procedures in one easy-to-access location. It will provide procedural consistency from one ship to another within a particular fleet. Note, however, that use of the logbook will not supersede any flag administration requirements that a ship may be required to comply with.

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

APPENDIX 2: Fuel oil sampling arrangements

The following has been drawn from the MEPC.96(47) sampling guidelines, which should be referred to in the event of a dispute or if further clarification is necessary.

a. Sampling methods
The sample should be obtained using one of the following methods: manual valve setting continuous-drip sampler time proportional automatic sampler flow proportional automatic sampler. The sampling device should be of a type approved in accordance with one of the following standards: ISO 3170 ASTM D 4057 BS 3195. FOBAS sample bottle kits will complete requirements for sampling equipment on board.

b. Sampling location
The fuel delivered to the ship should be sampled at the receiving ships inlet bunker manifold and should be drawn continuously throughout the bunker period.

c. Retained sample handling

Immediately prior to filling the retained sample container, the sample quantity should be thoroughly agitated to ensure it is homogenous. The retained sample should be of sufficient quantity to perform the tests required, but should not be less than 400ml in volume. The container should be filled to 90% (+/- 5%) capacity and sealed.

d. Sealing of the retained sample

Immediately following collection of the retained sample, a tamperproof security seal with a unique means of identification should be installed by the suppliers representative in the presence of the ships representative. A label containing the following information should be secured to the retained sample container: location at which and method by which sample was drawn date of commencement of delivery name of bunker tanker/bunker installation name and IMO number of the receiving ship names and signatures of the suppliers representative and the ships representative details of seal identification bunker grade.

To facilitate cross reference, details of the seal identification may also be recorded on the bunker delivery note.
8

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

e. Retained sample storage

The retained sample should be kept in a safe and sheltered location outside the ships accommodation. It should not be subject to elevated temperatures, but preferably kept at a cool/ambient temperature where it will not be exposed to direct sunlight and where personnel would not be exposed to vapours which may be released from the sample. Typically, a suitable storage location may be the steering flat in a steel cupboard. Care should be exercised when entering a sample storage location. In the event that a sample is to be delivered to a port state control inspector, it is also important to secure a record of the sample custody transfer. The transfer should be recorded in the logbook with the BDN, with specific reference to: the sample label details and seal number the port, date and time of handover of the sample the identity of the person to whom the sample was handed, together with the name, signature and authority stamp as appropriate contact details of those who will hold the sample.

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

APPENDIX 3: Information to be included in the bunker delivery note (BDN)

Name and IMO number of receiving ship. Port of bunkering. Date of commencement of delivery. Name, address and telephone number of marine fuel oil supplier. Product name(s). Quantity (metric tons) of bunkers delivered. Density at 15C (kg/m) * Sulphur content (% m/m) (actual figure) . A declaration signed and certified by the fuel oil suppliers representative that the fuel oil supplied is in conformity with Regulation 14(1) or (4)(a) and Regulation 18(1) of Annex VI.

* Fuel oil should be tested in accordance with ISO 3675. Fuel oil should be tested in accordance with ISO 8754.

10

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

APPENDIX 4: Frequently asked questions 1. What equipment do I need to install on board my ship to ensure compliance with Annex VI Regulations 14 and 18, and what specific action do I need to start taking now?
To ensure compliance on May 19, 2005 you will need to: fit an approved drip sampler (see Appendix 2) at the inlet of the bunker manifold for both diesel and heavy fuel bunker lines ensure that you have a sampler valve lock and a sufficient supply of primary samples collection devices (cubitainers) in stock station a storage facility for the statutory samples and BDNs in a safe location. This can be a steel box, which must be capable of holding at least 18 months worth of all fuel type bunker samples; the steering flat is typically a suitable location in most vessels consult machinery manufacturers for their guidance and any additional requirements for operating on low-sulphur fuel oils update the ISM bunker procedure. This should include: ships strategy for compliance with Annex VI Regulation 14 (see question 17 for options) details of where and how the changeover procedures will be recorded (if applicable) where applicable, the changeover procedure itself, which should include the flush-through time that needs to be allowed to clear the high-sulphur fuel from the fuel lines prior to crossing into a SECA low-sulphur fuel and cylinder oil tank storage allocation and capacity (if applicable) this may require two separate cylinder oil storage tanks review of the bunker clause instruction to the crews on the additional processes required for compliance with Annex VI.

2. What is the date for Annex VI Regulation 14 and 18 enforcement?

Annex VI will come into force on May 19, 2005. However, a grace period of 12 months will apply to the section of Regulation 14 referring to fuels with 1.5 % m/m sulphur content that will be used in the Baltic Sea SECA zone (May 19, 2006) . It is expected that North Sea and English Channel will become a SECA zone in November 2007, although the exact date has yet to be confirmed.

3. Is the bunker supplier obliged to provide a fuel analysis report from a reputable laboratory on the delivered bunkers?
Annex VI only requires certain details to be recorded on the BDN, including a declaration of compliance by the supplier with Annex VI (see Appendix 3). The supplier does not in fact have any obligation to provide the ships chief engineer or Master with comprehensive analysis results of the fuel to be supplied unless this has been specifically requested of them. For practical reasons, this is almost impossible. Some suppliers do provide such analyses to ships, but the report provided does not necessarily correspond to the product actually delivered to the ship and therefore such reports should not be accepted as quality verification certificates or as bunker receipts.
11

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

4. Is a separate logbook required for recording fuel changeover details prior to entering or exiting SECA zones?
IMO has long recognised the importance of new regulations and the impact that they may have on the shipping industry and, in particular, the crew onboard ships. Crews are faced with an ever-increasing responsibility to maintain and keep documentation up to date. It has been left to the discretion of each flag administration to ensure that ships comply with Annex VI and to decide where records of compliance are to be documented. It is suggested that ships may not need an additional logbook to comply with the new requirements; instead, they may be able to use the oil record book, E/R logbook and/or the ships logbook in order to record changeover from high to low-sulphur fuels, or vice versa, when entering or leaving a SECA. However, since the overall responsibility of enforcing compliance with Annex VI falls on the flag administration, we would recommend that the relevant administration is contacted in order to obtain confirmation of its logbook requirements in writing. By request, Lloyds Register is formulating a FOBAS Annex VI logbook for recording sample storage, bunker delivery notes, custody transfer of statutory samples and fuel changeovers. This is expected to simplify cross-fleet procedures for record-keeping. Flag administration approval should be sought as to whether keeping this record book will be sufficient.

5. Do I have to amend my bunker clause?

Bunker clauses should already include reference to ISO 8217, thus clearly defining the quality requirements of the fuels to be delivered to ships. However, the current version of ISO 8217 (1996:E) quotes a maximum sulphur content of 5.0% m/m for the majority of the heavy fuel oil grades, which conflicts with the global limit of 4.5% m/m set by Annex VI Regulation 14. Bunker clauses must therefore specify specific sulphur limit requirements, indicating whether the fuel should contain a maximum of 4.5% or 1.5% m/m, and be drafted so as to reflect the quality and environmental requirements outlined in both Regulations 14 and 18, as well as ISO 8217. To avoid any misunderstanding, bunker clauses should include a reminder that the supplier is to provide a statutory sample over and above the quality control sample normally supplied, which is to be accompanied by a BDN and drawn in accordance with the MEPC.96(47) sampling recommendations. We therefore recommend that all bunker clauses are reviewed and, where necessary, redrafted prior to Annex VI enforcement on May 19, 2005 in order to meet the new regulatory needs and to avoid any ambiguity and confusion about what should be actually supplied. A new version of ISO 8217 is expected to be published around July 2005. This version will be in line with Annex VI, incorporating a number of changes, including a maximum sulphur content cap of 4.5% m/m.

6. Are there any changes to the bunkering and sampling procedures?

There are no specific changes, except that a fourth statutory sample should be taken, and the supplier should ensure that this is provided. Greater emphasis is placed on the sampling position, which must be at the ships bunker manifold connection, as stated in MEPC.96(47).
12

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

Bunker delivery plans should include the people, and their position, responsible for overseeing the whole bunkering operation. Those people should make sure that both the vessel and the suppliers comply with Regulations 14 and 18 and that all the compliant documentation is produced. FOBAS sampling procedures (including FOBAS Annex VI Regulations 14 and 18 Instruction Supplement) remain applicable and should be closely followed. Resolution MEPC.96(47) endorses a sampling position at the ships inlet bunker manifold. Wherever possible, ensure that a pre-agreement has been made with suppliers that joint sampling should be carried out at the receiving vessels inlet manifold suppliers who have registered under the requirements of Annex VI should already be complying with this statutory sampling position. For practical reasons and the fact that, generally, the ships manifold connection is the point of custody transfer, all four samples should be taken from the same primary sample, and this would naturally be at the ships manifold connection

7. Whose responsibility is it to provide the Annex VI statutory sample to the vessel?

The responsibility of providing the representative Annex VI statutory sample to the vessel lies with the supplier. The supplier has the responsibility of drawing the statutory sample from the manifold of the receiving vessel using the drip method and handing it over to the chief engineer or ships representative. In the event that the supplier is not able to supply the required fourth bottle, a FOBAS bottle may be offered to the supplier for statutory purposes. These are designed with selfsealed caps and space for two additional seals and specific Annex VI labels to clearly differentiate the commercial samples from the statutory. Both the supplier and the ship can use their own seals on the FOBAS sample bottle. The labels should be available in new bottle kits from May 01, 2005.

8. How long should the vessel keep the BDN onboard?

BDNs should be kept onboard ships for a minimum period of three years and they should be available for inspection by port state control and/or other authorities. Suppliers have an equal responsibility to retain their BDN for the period of three years, and these should be equally available for inspection at any given point in time.

9. How long should the vessel keep the statutory samples onboard?
Ships are to keep the Annex VI statutory sample for a period of no less than 12 months or until the fuel is consumed, whichever is longer. Those samples should be kept away from the ships accommodation in a safe and risk-free environment.

10. Can the statutory sample be used to validate the quality of the fuel or to resolve commercial quality/quantity disputes?
The Annex VI Statutory sample(s) must not be used for the purpose of resolving quality disputes other than that prescribed by Annex VI and for verifying suppliers compliance to Annex VI. Only port state control authorities (or other environmental authorities belonging to a country which has ratified the Annex VI protocol) have the right to take
13

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

the sample for verification of compliance to Annex VI. In the event that the sample is to be removed form the ships custody, the ships Master or chief engineer should request a signed custody transfer note from the authority who takes the sample away from the ship. This can be used in case another authority in the next port of call requests the same sample.

11. Which administration is responsible for the implementation/enforcement of Annex VI Regulations 14 and 18?
The overall responsibility for the implementation of Annex VI belongs to IMO. However, enforcement of Annex VI will be the responsibility of the flag administrations as well as other local authorities for example, port state control, MCA and the coastguard. It is therefore imperative to familiarise yourselves with any specific requirements the flag administration may have.

12. Do I need more sample bottles or additional sample bottle kits?

Those ships using the FOBAS service already have Annex VI compliant bottles. Ships may use the FOBAS bottle kits for drawing the fourth sample after determining that the supplier will not be providing their own bottle for filling at the ships bunker inlet manifold.

13. Do I have to alter the changeover procedures?

The ships changeover procedures may need to be amended to reflect the new requirements of Annex VI Regulations 14 and 18. It is imperative, for example, to assess the needs of each specific vessel, record all bunker tanks and their capacity. In cases where the vessel is not designed with two separate settling/service tanks, changeover should take place in advance in order to make sure that, when the ship is entering a SECA zone, the high-sulphur content fuel is flushed through the fuel oil system and the only fuel in the system is low-sulphur, as required by Regulation 14.

14. What abatement technology is available at the moment?

Abatement technology is one of the alternatives for reducing SOx emissions. One possible solution is to adopt an exhaust gas cleaning system for example, sea water scrubbers in order to reduce emissions. The technology is still under testing and evaluation, since there are many more parameters to consider. Some suppliers believe that, with the future expansion of the SECAs, exhaust gas cleaning systems are the only viable solution.

15. Will the new regulations affect demand and low-sulphur fuel availability in the SECAs?
We have been informed by the major suppliers that the increased demand for lowsulphur fuels for the EU SECAs is expected to be met, although costs may increase by as much as US$60 per metric tonne. Your bunker brokers and suppliers should be approached for their latest understanding of the availability of low-sulphur fuel. Forward planning for the fuel bunker requirements of the ship will be necessary, and there may be an impact on trading routes.

14

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

16. What fuel system arrangement options does my fleet have to comply with in a SECA?
In the first instance, Annex VI focuses on SOx emission levels. Therefore, providing no other regulation is breached, any number of arrangements will be allowed as long as the final solution results in the correct fuel being used by the machinery plant. The following are five of the most typical options. Option 1 The decision is made for the ship to consume only fuels with a sulphur content of less than 1.5% m/m. This is perhaps the simplest option, although global availability may be an obstacle in keeping to this strategy. Low-sulphur fuel prices are expected to be anything up to US$60 per metric tonne greater than a high-sulphur fuel. Option 2 The ship will carry both low- and high-sulphur fuel oil grades, but there is only one service tank and one settling tank. The changeover procedure will require sufficient flushing times to cover the fuel change in the service tank and feed lines to the machinery plant. High-sulphur fuels in the settling tanks may be dumped back into the storage tanks and refilled with low-sulphur fuels. Option 3 The ship will carry both high- and low-sulphur fuels, and has two service tanks and one or two settling tanks. In this case, one service tank and one settling tank may be nominated as low-sulphur tanks. This is the most preferable arrangement, minimising the flushing time required prior to entry into the SECA. For extended operations on lowsulphur fuels, a second cylinder oil tank should be allocated to hold lower BN fuels for low-sulphur operations. Option 4 An approved exhaust cleaning system is fitted. However, it is unlikely that any system will be approved until 2008 at the earliest and, even then, they may only be suited to newbuilds. Option 5 An option that may have to be adopted by some ships is to avoid SECAs altogether. Compliance would then only involve the recording of the statutory sample and maintaining of fuels.

17. What if a ship is simply unable to get hold of a sufficient quantity of low-sulphur fuel before arriving at a SECA?
No precedent has been set, and so a full answer to this question is not yet possible, but it is clearly important that ship records identify all attempts to bunker the required fuel. It is expected that ports which are intending to enforce the low-sulphur regulations will make compliant bunkers available to ensure that ships can quickly restock their lowsulphur fuel requirements.

15

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

18. What will happen if a ship enters a port and is not able to demonstrate that low-sulphur fuel has been used (in other words, that it is not fully compliant with Annex VI)?
It is not yet clear what course of action each administration will take if they identify noncompliance. We understand, for example, that the UK Marine Coastguard Agency is still debating the various courses of action that are open to it, as well as the most appropriate deterrents.

19. What will happen if a ship takes bunkers from a country that is not a party to the Protocol of 1997 and is found, for example, in a SECA zone with a non-compliant fuel from a non-signatory body?
It is the responsibility of the ship to ensure that the fuel in use complies with the SECA requirements. To avoid any risk of non-compliance it is important that the initial bunker clause specifically states the sulphur level required and that independent analysis is carried out to ensure the supplier has complied.

20. Do Regulations 14 and 18 and the EU Directive also apply to fuel for boilers?
Yes, they apply to all fuels on board. Remember that these regulations are focused on reducing the combined SOx emissions from the ships funnel, and this affects all fuels.

21. Does the drip sampler need to be type approved?

Yes, it does.

22. Will there be any incompatibility issues in service/settling tanks during the changeover procedure?
Incompatibility is always a risk when mixing two different fuels of which at least one is a residual fuel. We recommend that the different fuels intended for mixing are checked for compatibility, and that the results recorded (see FOBAS documentation pack for instructions for spot tests that can be carried out on board). You can minimise the risk of incompatibility by keeping the ratio of the mix as large as possible at least 10:90 or, even better, 5:95. When the changeover is in progress, monitor filters for any increase in the rate of filter blockages or the frequency of back flushes to avoid fuel starvation of the machinery plants.

23. Will there be any issues as a result of pumps/piping having to cope with variant sulphur fuel?
There are no concerns here accept for incompatibility issues (see question 22).

16

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

24. Will Lloyds Register issue a manual on the changeover procedures, or will the Marine Coastguard Agency do so?
It the responsibility of the fleet operations technical division to produce such a manual in conjunction with the machinery manufacturers guidelines, since the procedure will be specific to the machinery installation and arrangements on the ship. However, if you have any particular concerns, Lloyds Register will be happy to offer assistance.

25. Do shipowners/operators need to have strategies in place for the changeover procedure prior to enforcement in May 2005 and May 2006?
An IAPP Certificate can only be issued for Regulations 14 and 18 if the ship has some strategy in place to handle all aspects of Annex VI, whether or not it will be trading in a SECA. There will be many ships that do not currently intend to trade in a SECA, and a statement to that effect should be sufficient no changeover procedures would need to be documented in such cases. A shipowner uncertain on May 19, 2005 as to how he will bring his ship into compliance with the requirements for SECA zones will need to adopt a strategy for non-SECA operations until such time as he is certain. This would be reflected in the IAPP Certificate, which could then be updated upon implementation of a SECA-compliant strategy. It may be possible in the future for ships to implement a SECA trading strategy by installing approved exhaust gas cleaning equipment or complying with an approved emissions trading programme. In either case, it is unlikely that changeover procedures would need to be documented for Annex VI compliance.

26. What will be the implications of the revised EU Directive for ships trading in EU waters? Will there be further sulphur restrictions?
The EU has yet to fix the final details and dates for the revision of this Directive. Details will be communicated in a separate bulletin once they are available.

__________________________________________ This list of frequently asked questions is by no means exhaustive. A full list of questions and answers will be made available on the Lloyds Register website (www.lr.org) this list will be added to as more questions are received. Should you have any further questions regarding Annex VI Regulations 14 and 18, please contact us using one of the methods listed above (see Further information and contact above).
17

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

APPENDIX 5: Flowcharts 1. Compliance guide MARPOL 73/78, Annex VI Regulation 14

18

Lloyds Register FOBAS

Practical guidelines for handling MARPOL 73/78, Annex VI Regulations 14 and 18

2.

Compliance guide MARPOL 73/78, Annex VI Regulation 18

19