- Keywords: PSC, Maritime
Relevant for ship owners and managers
The PSC performs regular inspections with a focus on sulphur limits
As fuels with different sulphur content are in use on board ships, compliance with the limit of the ECAs can be a challenge for the crew. Beside the global 0.50% sulphur cap – entering into force in 2020, and already in force in Chinese waters – emissions control in several ECAs with a 0.10% sulphur limit are already in place.
The PSC performs regular inspections on board ships, with a focus on sulphur limits, and a significant increase of sulphurrelated deficiencies has been noticed by PSC within the last years. Some authorities will monitor the exhaust gas plume as a first indication to trigger the PSC inspection of a ship. DNV GL is working closely with owners and operators to stay compliant. Here are a few recommendations:
Typical deficiencies noticed by PSC
Typical deficiencies include missing bunker delivery notes, wrong tank sounding records, incorrect log book entries or a not correctly followed fuel-changeover procedure. In specific cases, such findings can be considered objective evidence of a serious ISM failure, requiring a safety management audit. To avoid such deficiencies, the crew on board should be aware of the problem and trained accordingly.
Bunker delivery notes
- To be kept on board for three years
- To be stored readily available for inspection
Quality of fuel
The fuel quality is also subject for inspection:
- Delivery of fuel to be accompanied by representative fuel samples
- Fuel samples are to be sealed and signed by supplier and crew representative
- To be kept on board for 12 months from delivery
A fuel changeover (FCO) procedure must be in place
- Fuel oil service system to be fully flushed through, enabling the crew to calculate the starting time
- Crew to be trained to handle challenges and manage risks:
- Incompatibility of fuel oils / filter problems
- Low viscosity of distillate fuel / fuel pump failure and injection valve problems
- To be carried out slowly in accordance with manufacturer’s instruction (2°C/minute) / thermal shock of injection equipment
- Volume of low-sulphur fuel onboard, date, time and position when the FCO procedure was completed prior to entering an ECA shall be recorded. The same to be recorded when commencing the FCO after leaving the ECA.
As all operators know, high-sulphur HFO is less expensive than the MGO containing 0.10% sulphur by mass, which is a motivation for the preferred use of HFO. To ensure that the sulphur content meets the ECA limit, the fuel changeover procedure needs to be initiated well in advance considering consumption, volume of the service system, and the different sulphur levels used or mixed up already in tanks. Various fuel changeover tools exist, including the DNV GL FCO calculator which provides ship-specific solutions.
Port state authorities regularly inspect ships for ECA compliance, and we recommend paying attention to the following:
- Raise the awareness for fuel switching when entering ECAs.
- Train the crew in handling and documenting fuel oil matters (e.g. bunker delivery notes, changeover procedure, log book entries and tank sounding records).
- Start the fuel changeover procedure well in advance (depending on consumption, volume of service system and different sulphur levels used or mixed in tanks).
- MARPOL Annex VI, Reg. 14.4 [Sulphur Oxides (SOx) and Particulate Matter];
- MARPOL Annex VI, Reg.18 [Fuel oil availability and quality]
- Directive (EU) 2016/802 relating to a reduction in the Sulphur content of certain liquid fuels
DNV GL resources:
IMO requirements July 2018 to May 2021
This statutory news summarizes the most important IMO requirements entering into force from 1 July 2018 up to and including 31 May 2021.
Outcome of the IMO SSE 6 meeting - from habitable life boat environments to Ro-Ro deck fires
The IMO sub-committee on Ship Systems and Equipment (SSE) met in London on 4–8 March 2019. This statutory news summarizes the main topics discussed, such as, life-saving appliances, fire safety of Ro-Ro passenger ships, and on-board lifting appliances. All agreements made at the meeting are subject to final approval by MSC 101 in June 2019.
Recommissioning of laid-up ships and mobile offshore units - how to avoid surprises
When the market moves back from a downturn, vessels are leaving the lay-up buoys and the focus shifts from preservation to recommissioning. DNV GL has accumulated its best practices into a revised Recommended Practice (RP) containing a new approach for assurance of non-class equipment and systems during recommissioning.
Sulphur limit in ECAs - increased risk of PSC deficiencies and detentions
DNV GL keeps customers and other stakeholders updated on various aspects of the global 2020 sulphur cap and its implications for maritime shipping. While the global cap of 0.5% is just around the corner – entering into force on 1 January 2020 – this PSC news focuses on existing emission control areas (ECAs) with a 0.10% sulphur limit and the role of port state control (PSC) inspections.
2020 sulphur update - outcome of the IMO PPR 6 meeting
The MEPC sub-committee on Pollution Prevention and Response (PPR) met at the IMO in London, 18-22 February 2019. Top of the agenda was the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI, in force from 1 January 2020. This statutory news contains a summary of topics related to sulphur and the implementation of the 2020 sulphur cap. Items agreed at the meeting are subject to final approval/adoption at MEPC 74 in May 2019.
The EU ship recycling regulation - coming into general application on 31 December 2018
The EU Ship Recycling Regulation (EU SRR) is coming into general application on 31 December 2018. Additional requirements are imposed to any new EU-flagged vessel and vessels under EU-flag going for recycling. These measures are subject to PSC and flag state inspections effective from 2019. This statutory news provides you with a summary of the EU SRR (1257/2013) and recommendations of how to manage the Inventory of Hazardous Materials (IHM) process.
Update on emissions to air regulations for ships operating in Chinese coastal waters
This statutory news covers vital information from the Chinese Ministry of Transport: introduction of a 0.5% sulphur limit for ships entering China’s coastal waters, and updated NOx regulations for imported ships engaged in domestic trade. Both regulations will enter into force on 1 January 2019.
Make sure you comply with IMO DCS – Deadline 1 January 2019
With three weeks to go before IMO’s fuel data collection system (DCS) starts on 1 January 2019, many companies still have not submitted their SEEMP Part II fuel oil consumption data collection plan for approval. This statutory news contains some last-minute recommendations.