Verband Deutscher Reeder

Regulations foR the PReVention of aiR Pollution fRom shiPs

maRPol annex Vi

i. intRoDuctionthe idea for this brochure was developed by ship owners and administrations to help seafarers onboard in their work to un-derstand and make use of the regulations of maRPol annex Vi which is in force since 19 may 2005 with corresponding european legislation.

so this brochure can serve as a proactive approach to prevent illegal air emissions or possible violations from ships.

although ships are the most effective mode of transport, the political debate about emissions from ships is still very intensive.

according to various statistics ships are responsible for 2% of car-bon dioxide emissions while carrying 90% of international goods.

sulphur oxide emissions account to around 4% world wide. nitro-gen oxide emissions from ships are responsible for 7% of world wide emissions.

heavy fuel oil is often used on board of ships as fuel. most com-mon in bunker ports today are ifo 380 and ifo 180.

Bunker quality is of great concern since many years and especially sampling procedures are needed to be established to guaran-tee a representative sample that could be used in case of legal disputes.

the iso 8217 standard sets minimum requirements for contents and compositions in marine fuels.

since 2005 maRPol annex Vi Regulations 14 and 18 set additio-nal requirements for the composition of marine fuels.

from 19 may 2006 the sulphur content of fuel oil used in the Baltic sea sox emission control area (seca) is limited to 1.5%.

as from the 22 november 2007 this obligation also applies to the north sea area according to Resolution mePc. 132 (53).

this requirement already applies to european flagged ships from 11 august 2007 according to eu Directive 2005/33.

ii. guiDe foR PRactice on BoaRDannex Vi contains provisions which allow prosecution in case of non-compliance. in germany for example the fees amount up to 50.000 €.

the most important regulations of annex Vi with regard to sul-phur are listed below:

1.) PRohiBition of exceeDing the RequiReD limiting Values as to the sulPhuR content of any fuel oil useD on BoaRD shiPs:

Regulation 14 (1) stipulates a general sulphur content of 4,5 % m/m which shall not be exceeded.

Regulation 14 (4) (a) stipulates a maximum sulphur content of 1,5 % m/m within a seca.

change oVeR PRoceDuRes:upon entry into the secas the ships´ crew has to ensure that for any fuel used on board the maximum sulphur content is 1,5%. this change over procedure incorporates the main and auxiliary diesel engines and also auxiliary equipment as marine steam boilers and inert gas-plants. emergency generators and lifeboat engines are exempted.

the ship normally is equipped with a heavy fuel oil system with one day tank system or two day tanks. if the ship has two day tanks than one day tank is filled with high sulphur heavy fuel oil and the other is filled with low sulphur heavy fuel oil. the level of filling in the low sulphur tank has to be sufficiently high before changing from one to the other tank to avoid a shortage of fuel in case of separator or fuel problems. Before entering the seca the fuel supply has to be changed from the high sulphur to the low sulphur tank and has to be completed in advance before entering the seca. the necessary records of the fuel change over shall be made in the log book or into a separate “fuel change over bunker

record book”.

in case of a one fuel system with one day tank, the preparation of low sulphur heavy fuel oil has to start well in advance before entering the seca. the preparation time for the mixing of low and high sulphur fuel has to be pre-calculated to ensure that the sulphur limit of 1,5% is reached before entering the seca. for this calculation, computer files (e.g. excel-files from fuel oil suppliers) or approved change over manuals (e.g. from classification socie-ties) can be used. Depending on the sulphur content of the fuels and the tank capacities the mixing time can be up to 40 hours or even longer.

changing back to high sulphur fuel oil (hsfo) is allowed only after leaving the seca. again the relevant records shall be made into the appropriate ships log book when leaving the seca.

Please note that the total Base number (tBn) of the lubrication oil may have to be adjusted when using low sulphur fuel oil (lsfo).

incineRation of sluDge oil in secas: according to annex Vi the incineration of sludge in shipboard incinerators or auxiliary boilers is not prohibited. it has to be con-sidered that only sludge oil produced during normal operation is allowed to be incinerated. this means that only sludge from the low sulphur heavy fuel oil separation can be incinerated within the seca.

considering the helcom requirements in the Baltic sea area the incineration of sludge is prohibited within the 12 mile nautical area. there are only a few areas left in the Baltic sea area outside this zone. therefore it is recommended not to use the incinerator in the Baltic sea area.

2.) Details of the BunkeR DeliVeRy note (BDn)

Regulation 18 (3) stipulates that details of the fuel oil have to be recorded by means of a bunker delivery note.

the BDn has to contain at least the following information (as laid down in appendix V of maRPol annex Vi):

– name and imo number of receiving ship– Bunkering Port– Date of commencement of delivery– name, address and telephone number of

marine fuel oil supplier– Product name– quantity in metric tons– Density at 15 °c kg/m³– sulphur content (% m/m)– a declaration signed and certified by the fuel oil suppliers

representative that the fuel oil supplied is in conformity with regulation 14 and 18 of annex Vi

furthermore it must be noted, that the BDn shall state the detai-led sulphur content of the fuel oil. general statements, as for exa-mple “sulphur content less than 1,50%” shall not be accepted. this statement is not in line with current interpretations of maRPol annex Vi and does also not allow the crew to calculate a correct fuel change over time.

ideally the detailed sulphur content is stated with two decimals, which is common practice in fuel oil industry. only one decimal might lead to confusion whether a fuel meets the “1,50% - limit” or not.

in addition it is recommended, that the BDn contains also the seal numbers of all associated fuel samples, as to allow easy cross-reference. in case the seal numbers of the fuel samples were not stated by the supplier, the officer in charge should record the numbers on the BDn before signing.

Before signing or before taking bunker, the officer in charge shall check the presented BDns thoroughly. in case of incorrect BDns a letter of Protest should be issued against the fuel supplier other-wise the responsible officer can be held liable as well.

the BDns shall be kept on board readily available for inspection until the fuel is completely consumed but in any case for a time period of not less than three years.

iii. Regulations

foR BunkeR oil suPPlieRsthere is also a number of regulations addressing the sup-pliers of marine bunker oil, e.g.:

1.) oBligation to DeliVeR fuel oil of a sPecifieD quality:Regulation 18 (1) regulates the fuel oil quality delivered to and used on board ships for combustion purposes.

in case of delivering fuel oil that does not meet the require-ments specified in Reg. 18 (1) the supplier becomes liable. inorganic acids, chemicals and other substances are iden-tified as well which should not be compounds of marine bunker fuels.

2.) samPling in accoRDance with the »guiDelines foR the samPling of fuel oil foR DeteRmination of com-Pliance with annex Vi of maRPol 73/78 « aDoPteD By ResolutionmePc. 96 (47)Regulation 18 (6) states that the bunker delivery note shall be accompanied by a representative sample of the fuel oil delivered (which is the so called maRPol sample.)

fuel oil sampling:the sampling shall follow a.m. guidelines and consequently the sampling has to be done at the receiving ships’ bunker manifold.

the maRPol sample shall be drawn throughout the whole bun-ker delivery time continuously. for taking samples approved drip sampling methods are to be applied. there are three samplers to choose from:

1.) manual valve-setting continuous-drip sampler2.) time-proportional automatic sampler3.) flow-proportional automatic sampler

other samples than the maRPol sample can be taken for com-mercial purposes but they are not relevant with regard to the maRPol requirements.

on completion of the bunkering process, the “maRPol sample” is to be sealed and signed by the fuel suppliers representative and the officer in charge of the bunker operation.

the sample bottle label shall contain at least the following information:– location and method of the sampling– Bunkering date– name of bunker tanker resp. bunker installation– name and imo number of receiving ship– signatures and names of the supplier’s representative and the ship’s representative– seal identification– Bunker grade

the maRPol sample shall not be used in any commercial dispute. it shall be kept under the vessel’s control until the fuel oil is completely consumed but in any case for a time period of not less than 12 months from the time of delivery.

it is recommended, that the maRPol sample is stored in a safe and sheltered storage location outside the ship’s accommodati-on. also an inventory system should be developed to allow easy tracking of the samples.

in case the authorities require the handover of the maRPol sample it is recommended that the officer in charge records this in the log book in order to proof the remaining of the sample. the log book entries shall contain the following:

the log book entries shall contain the following:– Date, time and port where the maRPol sample was given to

authorities– seal number of respective sample– name, address and contact details of receiver– Reason for hand over of the maRPol sample

ideally the receiver signs for the receipt of the maRPol sample.

in case authorities draw their own fuel oil samples from the vessel’s fuel tanks it is recommended that the officer in charge records this also in their log books.

generally these records should contain the same information as mentioned above.

iV. eu sulPhuR DiRectiVe

2005/33 anD 1999/32the european commission has set legislation in place with the eu Regulation 2005/33 and 1999/32 which have to be read in con-junction. european legislation applies to ships trading between european ports and ships flying the flag of a european member state. Both regulations set standards for bunker suppliers, owners and ships` crew.

european legislation is imposed on ships as well. although ship-ping is global, regional legislation can effect shipping in a quite considerable way.

the eu Directive 2005/33 and 1999/32 apply to all ships calling european ports irrespective of their flag.

two different scenarios have to be distinguished:1.) ships alongside berth2.) ships trading between european ports (underway)

similar to imo maRPol annex Vi also the european commissi-on with its Directive 2005/33, amending Directive 1999/32, has established new requirements for the quality of fuel oils used onboard ships. Besides limitations on the fuel´s sulphur contents, the Directives define identical secas as already found in maRPol annex Vi, but at different application dates.

following application dates applied to the seca »Baltic sea«:maRPol annex Vi: 19 may 2006eu Directive 2005/33: 11 august 2006

Regarding seca »north sea / english channel« application dates will be:eu Directive 2005/33: 11 august 2007maRPol annex Vi: 21 november 2007

furthermore the eu Directives define new limits for the fuel´s sul-phur content which mean, that all marine fuels used within both secas are to have a maximum sulphur content 1,5%. this limit is similar to the limit found in maRPol annex Vi.

additionally the eu Directive gives new limitations to marine distillate fuels, which are as follows:

from 11 august 2006 until 31 December 2007:iso 8217 grades Dmx and Dma: max. sulphur content = 0,2 %iso 8217 grades DmB and Dmc: max. sulphur content = 1,5 %

from 01 January 2008 until 31 December 2009:iso 8217 grades Dmx and Dma: max. sulphur content = 0,1 %iso 8217 grades DmB and Dmc: max. sulphur content = 1,5 %

from 01 January 2010:a 0,1 % sulphur limit start to apply to all types of marine fuels used by ships at berth in eu ports. this applies to any use of the fuel with the following exceptions:– ships which spend less than 2 hours at berth according to

published time tables.– ships which switch off all engines and use shore-side

electricity.

the sulphur Directive also puts up special requirements for passenger ships and ferries following a regular schedule between european union ports. (further information can be found under

http://ec.europa.eu/environment/air/transport.htm).

V. insPections 1.) maRPol insPectionswithin maRPol inspections in german ports water police officers verify compliance of the regulations of annex Vi along with the control of the other annexes of maRPol 73/78.

at this the Bunker Delivery note, samples and the engine log book or other record books are the relevant documents.

the federal maritime and hydrographic agency (Bsh) in ham-burg is the competent authority in germany for taking action against violations of maRPol 73/78.

2.) Psc insPectionsDuring port state control inspections the ship’s crew has to be prepared to show on demand to the Psc inspectors the Bunker Delivery note, the fuel oil samples and the documentation of the fuel change over procedures in the engine log book or the „fuel change over bunker record book“.

furthermore it has to be ensured that enough low sulphur fuel oil is on board to enter the seca boarder before leaving the port of Psc control. otherwise the ship may be detained or may be forced to bunker low sulphur fuel in that port.

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contact Pointsfor further information concerning maRPol annex Vi please contact:

Bundesamt fuer seeschifffahrt und hydrographie (Bsh)ms. mareike wendlandBernhard-nocht-str. 78 | 20359 hamburgtel: +49 (0) 40 3190-2123 | fax: +49 (0) 40 3190-5000www.bsh.de | email: mareike.wendland@bsh.de

seeberufsgenossenschaft (see Bg)schiffssicherheitsabteilung | ship safety Divisionmr. holger steinbockReimerstwiete 2 | 20457 hamburgtel: +49 (40) 36137-217 | fax: +49 (40) 36137 204www.see-bg.de | email: holger.steinbock@see-bg.de

Verband Deutscher Reedergerman shipowners’ associationmr. heinrich Braunesplanade 6 | 20354 hamburgtel: +49 (40) 35097-226 | fax: +49 (40) 35097-211www.reederverband.de | email: braun@reederverband.de

furthermore we especially thank mr. Dirk hundt of the shipping company nsB for his support and practical guidance for this brochure.

Verband Deutscher Reeder

imprint: herstellung: VDR Presse & Öffentlichkeitsarbeit , esplanade 6, 20354 hamburg grafik: geßner, Druck: storck Verlag, stand: Dezember 2007