MARPOL Annex VI requires ocean-going vessels to use fuel with a maximum sulfur level of 1,000 ppm in Emission Control Areas beginning January 1, 2015. U.S. Environmental Protection Agency (EPA) issued a guidance on ECA marine fuel to assist with the compliance with the requirements as suppliers of ECA marine fuel and vessel owners and operators transition to the 2015 standard.
Liability and Violations
Under the 40 CFR Part 80 ECA marine fuel regulations, any person in the fuel distribution system who controls the facility where a violation of the 1,000 ppm ECA marine fuel sulfur standard is found may be liable for the violation. Anyone who produced or distributed this fuel is also presumed liable for the violations unless and until they can establish an affirmative defense. The ECA marine fuel regulations also explicitly prohibit any person from causing another person to violate the 1,000 ppm ECA marine fuel sulfur standards.
Since anyone in the ECA marine fuel distribution system may be held liable for downstream violations of the 1,000 ppm sulfur standard, EPA encourages everyone in the ECA marine fuel distribution system to implement robust quality assurance programs to
assure that the fuel they are producing, transporting, and selling complies with the 1,000 ppm ECA marine sulfur standard and is not contaminated with higher sulfur fuels. While retailers and WPCs are not required to conduct sampling and testing programs under 40 CFR 80.613, EPA highly encourages these parties to implement a quality assurance program to demonstrate that they did not cause the violation (such a program could include voluntary sampling and testing, retention of samples used for bunker delivery notes, etc.).
Sampling and Testing Requirements
For purposes of compliance with the 40 CFR Part 80 ECA marine fuel regulations, per 40 CFR 80.580 and 80.581, refiners and importers are required to sample and test each batch of ECA marine fuel using ASTM D2622 or another authorized test method to determine compliance with the 1,000 ppm sulfur limit prior to the fuel leaving the refinery or import facility.
For purposes of compliance with MARPOL Annex VI, Regulation 18.8.1, APPS and implementing regulations at 40 CFR Part 1043, for delivery of fuel to certain vessels, a sample of the fuel must be taken during bunkering of fuel oil and retained on the vessel for at least 1 year from the date of delivery. The sample must be taken in accordance with MEPC.96(47) “Guidelines for the Sampling of Fuel Oil for Determination of Compliance with Annex VI of MARPOL 73/78” and must comply with the fuel sulfur standards using the ISO 8754 test method. The sample must be sealed and signed by the supplier’s representative and the master or officer in charge of the bunker operation on completion of the bunkering operation. If analysis of the sample is required, per Regulation 18.8.2, the analysis must be done in accordance with the verification procedure in Annex VI Appendix VI.
Registration, Reporting and Recordkeeping Requirements
Refiners and importers of ECA marine fuel are required to register with EPA, and must keep records showing the batch volume, the batch number, the date of production or import, and records designating the batch as ECA marine fuel meeting the 1,000 ppm sulfur standard.
For more information you can read the “EPA Guidance on ECA Marine Fuel“
Source: U.S. EPA
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