The Maritime Safety Agency in China has recently issued Guidelines for Supervision and Management of Air Pollutant Emissions, aiming to standardize the implementation of the January 1, 2020 sulphur cap.
The Guidelines define inspection procedures in regard to fuel oil in use on ships, and provisions for alternative measures. More specifically:
Ship Exhaust Monitoring
The Maritime Authorities can preliminary screen ships suspected of using fuel oil with sulphur content surpassing the standard through ship exhaust monitoring and AIS system etc. Ships with illegal emission records and ships suspected of exceeding the oil sulphur content in fuel oil through exhaust monitoring will be the key inspection objects.
Inspection of documents
Check the ship’s engine log book, bunker delivery note, fuel consumption information report and other documents. If there is evidence that the ship has serious problems and may be detained, it can also be combined with the ship safety inspection. The specific inspection contents are as follows:
- Engine log book;
- Bunker delivery note;
- Fuel oil conversion procedure;
- FONAR;
- Waste gas cleaning system record book (if any).
Inspection of fuel oil
Check if the arrangement and drawing of the fuel oil service system of the ship comply with the requirements of the specification, and whether the fuel oil service system is consistent with the drawing of the fuel oil service. For ships requiring fuel oil conversion, check whether the valves in the fuel oil service system are in the position of low sulphur oil or high sulphur oil, and verify whether the ship has actually changed the oil.
Inspection to fuel oil on board
By checking the bunker deliver note, oil record book and fuel oil storage in the fuel oil tank, it is verified whether the ships that do not use the sulphur oxide and particulate pollution control devices and other alternative measures such as exhaust gas cleaning system enter the waters under the jurisdiction of China since March 1, 2020 are only loaded with the fuel oil in accordance with the provisions of the “Scheme of Sulfur Cap “.
Sampling and testing of fuel oil in use and on board
For the ships with unqualified documents, violation records or suspected violations, the Maritime Authorities shall conduct selective sampling inspection of ship fuel oil; for the ships with qualified documents, no violation records and suspected violations, the Maritime Authorities may perform selective sampling inspection of ship fuel oil.
Fuel oil sampling
Take the fuel oil sample from the fuel oil service tank or the downstream pipeline of service tank, and on the premise of ensuring safety, try to be close to the combustion system. The sampling work must be carried out along with law enforcement officers and crew members, and may also be entrusted to a third-party organization for sampling.
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The sampling may be conducted in accordance with the IMO guidelines for fuel oil sampling on board. At least 3 oil samples should be taken from the same sampling point. Each oil sample shall contain at least 400 ml of fuel oil. One shall be delivered to the ship, one shall be submitted for testing, and one shall be kept by the Maritime Authorities. Fill in the fuel oil sample label and seal number. After being signed by the ship’s representative and two law enforcement officers, the label shall be pasted on the bottle body.
Site inspection
For the ships with unqualified documents, violation records or suspected violations, the Maritime Authorities shall conduct on-site inspection on the use of shore power, clean energy or new energy and the installation of exhaust gas treatment devices to verify that the ships meet the emission control requirements.
Treatment results
If the alternative measures taken to ensure the ships does meet the requirements of the “Scheme” and “Scheme of Sulfur Cap”, the following one or more methods shall be adopted according to the circumstances of the violation and the provisions of laws and regulations:
- Correction of irregularities;
- If the ship discharges the washing water or washing water residue of the waste gas cleaning system in violation of regulations, it shall be punished in accordance with the relevant provisions of “Water Pollution Prevention and Control Law of the People’s Republic of China” and “Environmental Protection Law of the People’s Republic of China”;
- Detention.
Submission and examination of the information on using and loading of fuel oil by ships
The Maritime Authorities shall, according to the requirements of the “Scheme”, request the international ship which fails to obtain the compliant fuel oil, resulting in using or loading of the non-compliant fuel oil by the ship, and the next port is Chinese port to submit FONAR to the Maritime Authorities of the port through the internet platform of maritime 24 hours prior to the arrival of the vessel in China’s jurisdiction waters.
After receiving the report, the Maritime Authorities will check the integrity of the FONAR and perform authenticity verification. During the authenticity verification, if the ship needs to depart in advance, it shall require the ship to provide security before departure. In case of any of the following circumstances, the Maritime Authorities shall focus on inspection:
- Submit FONAR for many times within one year;
- Call at ports with insufficient supply capacity of compliant fuel oil for a long period;
- The submitted materials are incomplete, and are insufficient to demonstrate that the compliance fuel oil is not available;
- The submitted materials do not conform to the actual situation or there is fraud.
You may see more information on the following report
