EMSA’s Sulphur Inspection Guidance contains guidelines for sulphur inspectors regarding the enforcement of Directive 1999/32/EC as amended regarding the sulphur content of liquid fuels (the “Sulphur Directive”). Earlier this year, INTERTANKO welcomed the Guidance noting that it welcomes standardization of such practice and the request for quality evidence from laboratories running tests on fuel samples.
The Sulphur Committee held on the 6th of May 2015 adopted the Guidelines as the reference document for a harmonized enforcement of the Sulphur Directive.
The provisions of the Sulphur Directive apply to all ships of all flags, including domestic shipping and those whose journey began outside the EU. It sets sulphur content limits in the marine fuels that can be used by ships in territorial seas, exclusive economic zones and pollution control zones of the EU Member States, including SOx Emission Control Areas (SECA)
Maximum fuel sulphur content (by mass – % m/m*) established by the Directive
* Concentration for Solutions = grams solute /grams solution × 100%
** Current EU SECAs are the Baltic Sea, North Sea (and English Channel) as defined in MARPOL Annex VI Regulation 14.3.1
*** Referred to as the “General Standard” within the Directive. This can only be exceeded by fuels used on ships with approved emission abatement methods (such as scrubbers operating in closed mode)
**** Emission abatement methods and alternative fuels (e.g. exhaust gas cleaning systems, mixtures of marine fuel and boil-off gas, LNG, fuel cells and biofuels) are permitted for ships of all flags in EU waters as long as they continuously achieve reductions of SOx emissions which are at least equivalent to using compliant marine fuels.
In order to establish whether a ship is in compliance with the requirements of the Directive, the documentation on board the ship shall be examined:
Bunker delivery notes
Details of fuel oil for combustion purposes delivered to and used on board should be recorded by means of a bunker delivery note. In particular, bunker delivery note should be:
- kept on board the ship in such a place as to be readily available for inspection at all reasonable times, and
- retained on board for a period of three years after the fuel oil has been delivered
Ships’ log books
Under the term of ships’ log books, the following documents, as a minimum, are included:
- Oil Record Book Part I,
- Records of navigational activities,
- Records of internal transfer of fuel,
- Engine logbooks,
- Tank sounding records, and,
- Fuel oil change over records.
Written procedure for fuel oil change over
Ships using separate fuel oils to comply with the SOx emission requirements whilst entering or leaving a SECA, should carry a written procedure describing how the fuel oil change-over is to be achieved . To comply with the SOx emission requirements, the procedure should foresee allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the new applicable sulphur content, prior to entry into a SECA, in order to avoid any contamination.
Fuel oil change-over presents some challenges requiring the crew’s attention and experience, for instance, to variables such as risk of thermal shock to injection components, low viscosity of the distillate fuel oil to avoid fuel pump failure or seizure, or risk of incompatibility between the fuel oils that may clog filters5 .
In addition, 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 change-over operation has been completed prior to the entry into the SECA or commenced after exit from such an area, should be recorded in such log-book as prescribed by the flag Administration of the ship.
In addition to the above documents, Sulphur Inspectors may be presented by the crew of the ships with other additional documentation as a proof of compliance with the Directive:
- IAPP Certificate and Supplement
- Nautical charts, Electronic Chart Display and Information System (ECDIS)
- Tank plans and piping diagrams
Sulphur Inspection
Sulphur Inspectors should be duly authorised by the Member States to perform an inspection in relation to the Directive, and be conversant with its requirements, relevant national legislation and the IMO Conventions and Guidelines therein referenced. In addition, organisations authorized by the Member States should be available in case a sample of marine fuel oil needs to be analysed to ascertain its sulphur content. In relation to the pre-boarding preparation, the Member States may need to develop pre-boarding preparation documents, specific instructions regarding the selection of ships for inspection as well as any other relevant form that may be required to conduct sulphur inspection.
A form available in THETIS-S may be used to introduce the report of the on board sulphur inspection.
EMSA Sulphur Inspection Guidance includes more flowcharts to illustrate the process when fuel is being used at port, outside/ inside SECA , the Emission Abatement Method (EAM) and the sampling
Reporting
The Directive requires each Member State to submit a yearly report to the Commission on the compliance with the sulphur standards and on the basis of the results of the sampling, analysis and inspections carried out (Article 7)
The following aggregated information shall be required:
- the total annual number and type of non-compliance of measured sulphur content in examined fuel, including the extent of individual sulphur content non-conformity and the average sulphur content determined following sampling and analysis,
- the total annual number of document verifications, including bunker delivery notes, location of fuel bunkering, oil record books, log books, and fuel change-over procedures and records,
- information about claims of non-availability of marine fuels which comply with the Directive,
- information on notifications and letters of protest with respect to the sulphur content of fuels against marine fuel suppliers in their territory,
- a list containing the name and address of all marine fuel suppliers in the relevant Member State,
- the description of the use of alternative emission abatement methods, including trials and continuous emission monitoring, or alternative fuels and compliance checks of continuous achievement of SOx reduction in accordance with Annexes I and II to Directive of the ships flying the flag of the Member State,
- where applicable, description of national risk-based targeting mechanisms, including specific alerts, and the use and outcome of remote sensing and other available technologies for prioritizing individual ships for compliance verification,
- total number and type of infringement procedures initiated or penalties or both, the amount of fines imposed by the competent authority to both ship operators and marine fuel suppliers.
Please click below to read and download EMSA’s Sulphur Inspection Guidance
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