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SULPHUR AMENDMENTS





Low-Sulphur Fuel Requirements 

EU Commission Recommendation on the safe use of low sulphur fuel by ships at berth in EU ports
On 21 December 2009, the EU Commission recommended to EU Member States, when enforcing the requirement that ships at berth in EU ports use marine fuels with a sulphur content not exceeding 0.1% by mass from 1 January 2010, to consider the existence of detailed evidence of the steps taken by ships to achieve safe compliance with the Directive. EU Member States may consider the existence of an "approved retrofit plan" when assessing penalties for non-complying ships. The Commission also intends to take action to allow LNG carriers to use mixtures of fuels resulting in emissions of sulphur dioxide equal to or lower than required by the Directive.
The EU Commission has issued a “Recommendation” to EU Member States on 21 December 2009 with respect to implementation/enforcement of the 0.1% sulphur requirement. However, it is up to each EU/EEA Member State to decide whether and how they choose to respond to the EU Recommendation. Click here for the EU Recommendation.
As more stringent sulphur requirements are put in place, owners are urged to determine whether they intend to operate within areas affected by the below regulations:
(1)     Article 4b of "EU COUNCIL DIRECTIVE 1999/32/EC of 26 April 1999 relating to a reduction in the sulphur content of certain liquid fuels and amending Directive 93/12/EEC", as amended, introduces 0.1% sulphur limit (m/m) for marine fuel.
a. Effective Date: January 1, 2010.
b.  Applies to: All types of marine fuel used by ships at berth for more than two hours in EU ports, unless an approved emission abatement technology is employed or shore power is available.
(2)     California Air Resources Board (CARB)
a. Effective Dates:
Phase I (in force) since July 1, 2009 [MGO (ISO 8217, DMA Grade) at or below 1.5%S or MDO (ISO 8217, DMB Grade) at or below 0.5%S]
Phase II - January 1, 2012 [MGO (ISO 8217, DMA Grade) or MDO (ISO 8217, DMB Grade) at or below 0.1%S]
b. Applies to: All types of marine fuel used by ships within California Waters (within 24NM of the California Baseline).
[Note: MGO = Marine Gas Oil; MDO = Marine Diesel Oil]
Please be advised that all engines and boilers(**) are affected by the above Regulations and it will be mandatory to operate the engines and boilers on the low-sulphur marine fuel with the sulphur content and effective dates as indicated in the respective Regulations noted above.
[Note: (**) = As for boilers, the EU Directive applies to main and auxiliary boilers, while the CARB Regulations apply to only the auxiliary boilers i.e., non-propulsion]
ABS Guidance
If operation within affected areas is intended and the vessel is not designed to operate on low sulphur fuels, owners should evaluate the potential risks associated with such operation.  To assist operators in their evaluations, ABS has prepared two “Notes” which identify a list of potential risks (this list is not exhaustive) associated with such operation.
  • ABS Notes - Use of Low-Sulphur Marine Fuel for Main and Auxiliary Diesel Engines, and
  • ABS Notes - Use of Low-Sulphur Marine Fuel for Boilers
The above "ABS Notes" are developed with a view to assist the owners, operators, shipyards and designers as appropriate. ABS emphasizes that the above “ABS Notes” are to be used for guidance purposes only. The ABS requirements that are required to be satisfied for any modified system are specifically delineated in the above “ABS Notes”.
ABS Requirements
We require each owner/operator conduct a design evaluation of each ship for low sulphur fuel operation by systematically assessing the related systems  taking into consideration (but not to be limited to) these identified potential risks in the ABS Notes as applicable to the specific systems and take necessary actions, as appropriate, to establish safeguards.
Owners and operators are reminded that all modifications to engines, boilers and associated fuel oil piping and control systems, together with the results of the above mentioned design evaluation, are required to be submitted to ABS for approval so that that class and statutory certification can be maintained. Where the owner is satisfied that modifications to the vessels’ installed equipment and systems are not required, it is recommended that the results of the design evaluation that has been conducted be maintained on board. 
In all cases it is expected that operating procedures, including guidance for switching between fuel types, will be provided onboard by owners/operators.  As this is a safety issue, availability of the proper operating guidance may be verified during ISM audits.
Regarding Survey, ABS is prepared to issue a Statement of Fact (SOF) Certificate(s) as follows:
(1)      ABS Surveyor will verify fitting of and report on the following:
a.       The vessel is fitted with dedicated low sulphur fuel oil storage tank(s) with a capacity of xx m3 fitted between fr. and fr. port/starboard side.
b.       The fuel oil piping system is arranged to allow main engine(s), auxiliary engines, and boiler(s) to operate on low-sulphur fuel.
c.       The structure, piping and control systems are in accordance with ABS approved drawings. (dwg. no., rev. 0, ddmmyyyy)
d.       Operational procedures for fuel-change-over are provided on board the vessel.  (doc. no., rev. 0, ddmmyyyy)
e.       Operating procedures for using low sulphur fuel in engines and boilers are provided on board the vessel.  (doc. no., rev. 0, ddmmyyyy)
f.       Main engine(s), auxiliary engines, auxiliary boiler(s), were observed in operation on MGO for a period of (hh:mm) in accordance with operational procedures.
(2)      For vessels equipped to operate in a cold iron condition in port through the shore-power connection installation, the Surveyor will verify and report that “The vessel is arranged with a shore-power system as per drawing no., rev., dated."
(3)   Issuance of a Statement of Fact for the installation of exhaust gas scrubber / emission abatement technologies will be considered on a case by case basis, with details to be submitted to an ABS engineering review office for review prior to surveyor issuance of the statement of fact report.  The Statement of Fact will report on what the Surveyor has surveyed.
Questions regarding engineering submittal requirements should be submitted to the ABS Divisional Engineering Office.  Divisional Survey Offices may be contacted for questions pertaining to Survey.  Click here to locate the closest appropriate office from the ABS Directory


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