1 Introduction
1.1 Objective
1.1.1 The purpose of these Guidelines is to ensure consistent implementation of the 0.50%
sulphur limit under MARPOL Annex
VI. These Guidelines are intended for use by Administrations, port States,
shipowners, shipbuilders and fuel oil suppliers, as appropriate.
1.2 Definitions
1.2.1 For the purpose of these Guidelines, the definitions in MARPOL Annex
VI apply.
1.2.2 The following definitions of fuel oils are used, as applicable:
-
.1 Distillate marine fuels (DM) are as specified in ISO 8217:2017footnote (e.g. DMA, DMB, DMX, DMZ);
-
.2 Residual marine fuels (RM) are as specified in ISO 8217:2017footnote (e.g. RMD 80, RMG 380);
-
.3 Ultra-low sulphur fuel oil (ULSFO) are as specified in ISO 8217:2017footnote (e.g. maximum 0.10% S ULSFO-DM, maximum 0.10% S
ULSFO-RM);
-
.4 Very low sulphur fuel oil (VLSFO) (e.g. maximum 0.50% S VLSFO-DM, maximum
0.50% S VLSFO-RM); and
-
.5 High sulphur heavy fuel oil (HSHFO) exceeding 0.50% S.
2 Ship implementation planning for 2020
2.1 MEPC 70 agreed to "1 January 2020" as the effective date of
implementation for ships to comply with the 0.50% m/m fuel oil sulphur content limit
requirement and adopted resolution MEPC.280(70) on the Effective date of implementation of the
fuel oil standard in regulation 14.1.3 of MARPOL Annex
VIfootnote.
2.2 In this context, MEPC 73 agreed that Administrations should encourage ships flying
their flag to develop implementation plans, outlining how the ship may prepare in order
to comply with the required sulphur content limit of 0.50% by 1 January 2020. The plan
should be complemented with a record of actions taken by the ships in order to be
compliant by the applicable date.
2.3 MEPC 73, recognizing the need for guidance to support the consistent implementation
of the 0.50% sulphur limit under MARPOL Annex
VI, approved MEPC.1/Circ.878 on the Guidance on the development of a ship
implementation plan for the consistent implementation of the 0.50% sulphur limit
under MARPOL Annex VI.
3 Impact on fuel and machinery systems
3.0.1 The experiences and lessons learned from the transition to the 0.10% m/m SOX-ECA
limit indicated that current ship machinery operations should be sufficiently capable of
addressing the concerns regarding combustion of the new 0.50% m/m limit fuel oils.
3.0.2 Currently most of the marine diesel engines and boilers on ships operating outside
Emission Control Areas (ECAs) are optimized to operate on heavy fuel oil. From 2020
ships are required to use fuel oils with a sulphur content of 0.50% m/m or lower, unless
fitted with an approved equivalent means of compliance.
3.1 Distillate fuels
3.1.1 A major challenge with distillate fuels is low viscosity. Low viscosity may cause
internal leakages in diesel engines, boilers and pumps. Internal leakages in fuel
injection system may result in reduced fuel pressure to the engine, which may have
consequences for the engine performance (e.g. starting of the engine). Equipment makers
recommendations should be taken into account, and adequate testing, maintenance and
possible installation of coolers, etc. may be performed.
3.1.2 Cold Filter Plugging Points (CFPP) and Cloud Points (CP) as well as the Pour Point
(PP) for distillate fuels need to be considered in light of the ship's intended
operating area and ambient temperatures.
3.1.3 These issues are critical concerns as they can result in the formation and
accumulation of wax sediment, which can cause costly and avoidable maintenance. In the
worst-case scenario, sediment can cause engine fuel starvation and power loss.
3.1.4 ISO 8217:2017footnote limits the cold flow properties of a fuel through setting
a limit on the PP. However, given that wax crystals form at temperatures above the PP,
fuels that meet the specification in terms of PP can still be challenging to operations
in colder operating regions, as the wax particles can rapidly block filters, potentially
plugging them completely. For cold weather, additional cold flow properties, CFPP and
CP, should be reported by the supplier when the receiving ship has ordered distillate
fuel for cold weather operations, a requirement that is specified in ISO 8217:2017footnote.
3.1.5 Since the residual fuels are usually heated and distillate fuels are not heated,
particular attention needs to be given to the cold flow properties of distillates. Cold
flow property challenges can be managed by heating the fuel. CIMAC has issued "01 2015
CIMAC Guideline Cold flow properties of marine fuel oils"footnote.
3.1.6 Fuel temperature should be kept approximately 10°C above the PP in order to avoid
any risk of solidification, however this may not reduce the risk of filter blocking in
case of high CFPP and CP.
3.1.7 It is good practice to review the possibilities of heating arrangements for
distillate fuels on board. This is usually very limited, as it is not standard practice
to have heating arrangements in distillate storage, settling or service tanks. Transfer
arrangements may be adapted to pass through a residual fuel oil heat exchanger should
the need arise.
3.1.8 Knowing the fuel properties before bunkering will assist in taking the necessary
precautions where and when necessary. If the ship is heading towards colder climates and
the cold flow properties are inferior, the fuel may be:
-
.1 either used before entering cold regions, or
-
.2 used with suitable heating arrangement, as mentioned above.
3.1.9 If the approach of applying heat is being followed it should be ensured that the
fuel is not overheated resulting in the viscosity dropping below the minimum
recommendation of 2 cSt at any point in the fuel system, including the engine inlet. In
order to reduce this risk, heating should be limited to max 40°C.
3.2 Distillate fuel with FAME content
3.2.1 Increased demand for Distillate fuels may result in more land-based products making
their way into the marine supply pool, some of these fuels (e.g. biodiesel) may contain
Fatty Acid Methyl Ester (FAME).
3.2.2 There are various technical challenges associated with use of fuel having FAME
content, e.g. potential oxidation of biodiesel, its biodegradable nature, etc. with
adverse implications, limitations in storage life, etc. It also needs to be tested for
stability.
3.2.3 The ISO 8217:2017footnote standard includes a maximum FAME content of
7.0% by volume for DFA/DFZ/DFB fuel oil grades since some ports may offer automotive
diesel fuel as the only fuel available, which contains FAME and could violate the fuel
flashpoint requirements addressed in SOLAS
chapter II-2. The maximum 7.0% (v/v) has been chosen as this aligns with the
concentrations allowed in some of the countries applying environmental regulations.
3.2.4 Manufacturers of engines and equipment like oily water separators, overboard
discharge monitors, filters, coalescers, etc. need to be consulted to confirm the
ability of engines and equipment to handle biodiesel blends of up to B7 (i.e. 7.0%
v/v).
3.2.5 It is recommended to avoid using such biodiesel blend fuels for lifeboat engines,
emergency generators, fire pumps, etc. where it is stored in isolated individual unit
fuel tanks and subjected to conditions for accelerated degradation.
3.2.6 CIMAC has provided a Guideline for Shipowners and Operators on Managing Distillate
Fuels up to 7.0% v/v Fame (Biodiesel).footnote
3.3 Residual fuels
3.3.1 Stability and compatibility
3.3.1.1 It is essential to distinguish between "Fuel stability" within a single batch of
fuel and "Fuel compatibility" between different fuel batches.
3.3.1.2 Regarding stability: the fuel shall be stable and homogeneous at delivery and it
is the responsibility of the fuel oil blenders and suppliers to ensure this.
3.3.1.3 A wide range of blends of refined products will be used to make the new 0.50%
sulphur fuels, and the stability and compatibility of the blends will be an important
concern for shipowners/operators. Unstable fuels can separate on their own and
incompatible ones can do so when mixed in a single bunker tank, forming sludge that can
block filters and ultimately cause engine failures.
3.3.1.4 It is recommended that ships have a commingling procedure. The procedure should
primarily aim to ensure new bunkers are loaded into empty tanks to the extent possible.
In the event that a ship finds itself possibly having to commingle a new bunker with
bunkers already on board, then it is important that the ship determines the
compatibility between the two said bunkers before comingling.
3.3.1.5 The reference test method shall be the total potential sediment test in
accordance with ISO 10307-2:2009.
3.3.2 Catalytic fines (cat fines)
3.3.2.1 Cat fines are a by-product of refining and consist of small particles of metal
that are deliberately introduced as catalysts to "crack" the fuel oil. Unless reduced by
purification, cat fines will become embedded in engine parts and cause serious and rapid
engine damage. Reference should be made to engine manufacturer's guidance with respect
to managing cat fines.
3.4 Key technical considerations for shipowners and operators
3.4.1 Ship tank configuration and fuel system – the viscosity of most of these blended
residual fuels is such that they cannot be used in distillate fuel-only systems and
machinery, as they require heating for cleaning and combustion. A fully segregated fuel
system for both distillate fuels and these new fuels is recommended.
3.4.2 Tank cleaning is recommended when using a residual fuel tank for storing these new
fuels. This is to prevent sludge that has built up in these tanks from entering the fuel
system. Further information on tank cleaning is set out in appendix 3 of MEPC.1/Circ.878
on Guidance on the development of a ship implementation plan for the consistent
implementation of the 0.50% sulphur limit under MARPOL Annex
VI.
3.4.3 Heating requirements – due to the cold flow properties of most of these new fuels,
permanent heating of the fuel may be necessary to minimize the risk of wax formation,
also in storage. This is especially important in colder regions.
3.4.4 Fuel treatment system – Some of these new fuels may contain cat fines and/or
sediments and therefore need onboard cleaning. Separator temperature and settings should
be adjusted to the fuels' viscosity and density. Please refer to recommendations from
OEM and fuel supplier.
3.4.5 Considering that many of these new fuels have lower viscosities compared to
conventional residual fuels, care should be taken to ensure no overheating occurs.
3.5 ISO Standard for residual fuels
3.5.1 The bunker market uses ISO 8217:2017footnote specifications to ensure that the properties of the fuels
it delivers conform to a standard that mean they comply with MARPOL Annex
VI.
3.5.2 The existing ISO 8217:2017footnote specification for marine fuels takes into consideration
the diverse nature of marine fuels and incorporates a number of categories of distillate
or residual fuels, even though not all categories may be available in every supply
location it covers all marine petroleum fuel oils used today as well as the 0.50%
Sulphur fuels of 2020. The General requirements, in the ISO 8217:2017footnote specification for marine fuels and characteristics,
included in table 1 and 2 of ISO 8217:2017footnote identified safety, performance and environmental concerns
and further takes into consideration the onboard handling requirements, including
storage, cleaning and combustion aspects of all fuel oils used today and the anticipated
fuel blends of 2020, irrespective of the sulphur content of the fuel oils.
3.5.3 It is important that any new standards address and do not preclude the use of
renewable and alternative non-fossil crude derived products, so long as they comply with
the chemical properties specified for these fuel oils.
3.6 Cylinder lubrication
3.6.1 The choice of cylinder lubricating oils will often follow the fuel type in use.
Therefore, when changing to VLSFO operation from RM operation the choice of appropriate
cylinder lubricating oil should be considered in accordance with the recommendations of
the engine manufacturer.
4 Verification issues and control mechanism and actions
4.1 Survey and certification by Administrations
4.1.1 When undertaking a survey in accordance with regulation 5 of MARPOL Annex
VI, the Administration should conduct a survey of a ship to verify that the
ship complies with the provisions to implement the 0.50% sulphur limit. In particular,
the Administration should check whether the ship carries compliant fuel oils for use,
based on the Bunker Delivery Note (BDN) on board, any other document or fuel oil samples
as appropriate consistent with the provisions of regulation 18 of MARPOL Annex
VI. If carriage of HSHFO for use is identified, the Administration should
check whether regulation 3.2, regulation 4 of MARPOL Annex
VI are applied to the ship, or if the ship encountered a fuel availability
problem and is operating pursuant to regulation 18.2 of MARPOL Annex
VI.
4.1.2 When an Administration decides to analyse a fuel oil sample to determine compliance
with the sulphur limits in regulation 14.1 or 14.4, the final analysis should be carried
out in accordance with ISO 8754:2003 by a laboratory that is accredited for the purpose
of conducting the test in accordance with ISO/IEC 17025 or an equivalent standard. The
test results should be in accordance with ISO 8754 reporting protocol, meaning a tested
value at or above 0.10% sulphur should be reported with no more than two decimal places.
4.1.3 According to regulation 11.4 of MARPOL Annex
VI, the Administration shall investigate any report of an alleged violation
and thereafter promptly inform the Party which made the report, as well as the
Organization, of the action taken. When informing the Organization, the MARPOL Annex
VI GISIS module should be used.
4.2 Control measures by port States
4.2.1 Port States should take appropriate measures to ensure compliance with the 0.50% of
sulphur limit under MARPOL Annex
VI, in line with the regulation 10 of MARPOL Annex
VI and the 2019 Guidelines for port State control under MARPOL Annex
VI
(resolution MEPC.[…](74)) (2019 PSC Guidelines). Specifically, the port State should
conduct initial inspections based on documents and other possible materials, including
remote sensing and portable devices. Given "clear grounds" to conduct a more detailed
inspection, the port State may conduct sample analysis and other detailed inspections to
verify compliance to the regulation, as appropriate.
4.2.2 Regulation 18.2.3 of MARPOL Annex
VI requires a Party to take into account all relevant circumstances and the
evidence presented to determine the action to take, including not taking control
measures. Administrations and port State control authorities may take into account the
implementation plan when verifying compliance with the 0.50% sulphur limit requirement.
4.2.3 Inspections based on documents and other possible targeting measurements
4.2.3.1 During the port State control and other enforcement activities, the port State
should investigate whether a ship carries either compliant fuel oils or HSHFOs for use,
based on the documents listed in paragraph 2.1.2 of the 2019 PSC Guidelines additionally
records required to demonstrate compliance should also then be viewed. Results from
remote sensing could be used to trigger inspections and portable devices could be used
during the initial inspections, as appropriate. Remote sensing and portable devices are,
however, of indicative nature and should not be regarded as the evidence of
non-compliance but may be considered clear grounds for expanding the inspection.
4.2.3.2 Port state should determine if regulations 3.2, 4 or 18.2.3 apply together with
retained bunker delivery notes and IAPP Certificate when considering the status of any
HSHFO being carried for use on board.
4.2.4 Fuel oil sample analysis
4.2.4.1 When the port State identifies clear grounds of suspected non-compliance of a
ship based on initial inspections, the port State may require samples of fuel oils to be
analysed. The samples to be analysed may be either the representative samples provided
with BDN in accordance with regulation 18.8.2, MARPOL delivered samples or samples from
designated sampling points in accordance with the 2019 Guidelines for onboard
sampling for the verification of the sulphur content of the fuel oil used on board
ships (MEPC.1/Circ.864/Rev.1) (in-use fuel oil samples) or other samples
obtained by the port State.
4.2.4.2 Where the MARPOL delivered sample is taken from the ship a receipt should be
provided to the ship. The outcome of the analysis undertaken with appendix VI of MARPOL
Annex VI should be advised to the ship for its records.
4.2.4.3 In detecting suspected non-compliance, the sample analysis should be
conducted in a uniform and reliable manner as described in paragraph 4.1.2. The
verification procedure for MARPOL delivered samples should be in accordance with
appendix VIfootnote of MARPOL Annex
VI. For other samples taken on board the ship, the in-use and onboard sample,
the sample should be deemed to meet the requirements provided the test result from the
laboratory does not exceed the specification limit +0.59R (where R is the
reproducibility of the test method) and no further testing is necessary.
4.2.4.4 Notwithstanding the above process, all possible efforts should be made to avoid a
ship being unduly detained or delayed. In particular, sample analysis of fuel oils
should not unduly delay the operation, movement or departure of the ship.
4.2.4.5 If a non-compliance is established, consistent with regulation 18.2.3 the port
State may prevent the ship from sailing until the ship takes any suitable measures to
achieve compliance which may include de-bunkering all non-compliant fuel oil. In
addition, the port State should report the information of the ship using or carrying for
use non-compliant fuel oil to the Administration of the ship and inform the Party or
non-Party under whose jurisdiction a bunker delivery note was issued of cases of
delivery of non-compliant fuel oil, giving all relevant information. Upon receiving the
information, the Party detecting the deficiency should report the information to the
MARPOL Annex VI GISIS module in accordance with paragraph 3.4 of these Guidelines.
4.2.4.6 The Parties (the port and flag States); however, may permit, with the agreement
of the destination port authority, a single voyage for bunkering of compliant fuel oil
for the ship, in accordance with regulation 18.2.4 of MARPOL Annex
VI. The single voyage should be one way and minimum for bunkering, and the
ship proceeds directly to the nearest bunkering facility appropriate to the ship. In the
case that the parties permit a single voyage of a ship, the port State should confirm
that the Administration of the ship has advised the authority at the destination port of
the approval for a single voyage including information on the ship granted with the
approval and the certified record of analysis of the sample as the evidence. Once
confirmation has been provided the port State should permit the ship to sail as agreed.
4.2.4.7 If the port State is made aware that a ship is carrying non-compliant fuel oil,
which is not for use through an equivalent method under regulation 4 or a permit under
regulation 3.2 of MARPOL Annex
VI, the port State should take action to confirm the fuel is not being used.
Action to confirm should include but is not limited to the examination of the oil record
book and the record of tank soundings. Where necessary the port State may require tank
soundings to be undertaken during the inspection. Where it is determined that the fuel
has been used the control action in paragraph 4.2.4.5 should be applied.
4.2.5 Other open-sea compliance monitoring tools:
-
.1 fuel oil changeover calculator;
-
.2 data collection system for fuel oil consumption of ships (resolution MEPC.278(70)); and
-
.3 continuous SOX monitoring.
4.3 Control on fuel oil suppliers
4.3.1 Designated authorities should, if deemed necessary, take a sample and test fuel
oils from bunker barges or shore bunker terminals. Sampling of fuel oils in bunker
barges or shore bunker terminals can be taken and tested in the same manner that the
MARPOL delivered fuel oils are tested by the PSC. All possible efforts
should be made to avoid a ship being unduly detained or delayed. If a sample is
analysed, sample analysis of fuel oils should not unduly delay the operation, movement
or departure of the ship.
4.3.2 If non-compliance, such as issuance of an incorrect BDN or a BDN without
measurement of sulphur content, was found, the designated authorities should take
appropriate corrective measures against the non-compliant supplier. In such case, the
designated authorities should inform the Organization for transmission to the Member
States of the non-compliant supplier, in accordance with the regulation 18.9.6 of MARPOL
Annex VI and paragraph 4.4 of these Guidelines.
4.4 Information sharing related to non-compliances under MARPOL Annex
VI
4.4.1 When a Party finds a non-compliance of a ship or a fuel oil supplier, the
information of the non-compliance should be reported to the MARPOL Annex
VI GISIS module (regulation 11.4).
4.4.2 Publication of information on non-compliant ships/fuel oil suppliers or a reporting
scheme to IMO to be registered on centralized information platforms are proposed as
elements of an effective enforcement strategy. Various PSC regimes have successfully
used the publishing of information related to substandard ships/fuel suppliers as a
deterrent to non-compliance. Port States also need to report detentions of ships to IMO
which may affect the future PSC targeting of the ship. The IMO GISIS database already
makes available certain information related to non-compliances with the MARPOL Annex
VI regulations.
5 Fuel oil non-availability
5.1 Guidance and information sharing on fuel oil non-availability
5.1.1 Regulation 18.2.1 of MARPOL Annex
VI provides that in the event compliant fuel oil cannot be obtained, a Party
to MARPOL Annex VI can request evidence outlining the attempts made to
obtain the compliant fuel oil, including attempts made to local alternative sources.
Regulations 18.2.4 and 18.2.5 then require that the ship notifies its Administration and
the competent authority of the port of destination on the inability to obtain compliant
fuel oil, with the Party to notify IMO of the non-availability. This notification is
commonly referred to as a Fuel Oil Non-Availability Report (FONAR).
5.1.2 Guidance on consistent evidence
5.1.3 Regulation 18.2.1.2 of MARPOL Annex
VI requires that evidence be provided to support a claim that all efforts
were made to obtain compliant fuel oil. In this regard, a Party may develop more
detailed guidance for the consistent use and acceptance of these reports, including what
evidence is needed to accompany a report to ensure that port States are applying the
provisions under regulation 18.2.3, consistently.
5.1.4 Should a ship, despite its best effort to obtain compliant fuel oil, be unable to
do so, the master/company must:
-
.1 present a record of actions taken to attempt to bunker correct fuel oil and
provide evidence of an attempt to purchase compliant fuel oil in accordance with
its voyage plan and, if it was not made available where planned, that attempts
were made to locate alternative sources for such fuel oil and that despite best
efforts to obtain compliant fuel oil, no such fuel oil was made available for
purchase; and
-
.2 best efforts to procure compliant fuel oil include, but are not limited to,
investigating alternate sources of fuel oil prior to commencing the voyage. If,
despite best efforts, it was not possible to procure compliant fuel oil, the
master/Company must immediately notify the port State Administration in the port
of arrival and the flag Administration (regulation 18.2.4 of MARPOL Annex VI).
5.1.5 In order to minimize disruption to commerce and avoid delays, the master/company
should submit a FONAR as soon as it is determined or becomes aware that it will not be
able to procure and use compliant fuel oil.
5.1.6 Investigating non-availability
5.1.7 A Party should investigate the reports of non-availability. This process is
important to ensure a consistent supply of compliant fuel to industry, as well as
prevent incentives for ships to use ports where it is known that compliant fuel is not
available on an ongoing basis. Critical to this process will be the sharing of
information between Member States on reported compliant fuel oil supply issues.
5.1.8 Regulation 18.2.5 of MARPOL Annex
VI provides that a Party to MARPOL Annex
VI notify the Organization when a ship has presented evidence of the
non-availability of compliant fuel oil in a port or at their terminal. For this purpose,
MARPOL Annex VI GISIS module provides the platform for Parties to upload such
notifications.
5.1.9 Regulation 18.1 of MARPOL Annex
VI provides that each Party take all reasonable steps to promote the
availability of above compliant fuel oil and inform the Organization through MARPOL
Annex VI GISIS module of the availability of compliant fuel oils in its
ports and terminals.
5.1.10 Port State control authority may contact the submitter (and/or shipowner or
operator), including in the event of an incomplete submission, and request additional
information, or to pursue an enforcement action such as a Notice of Violation.
5.2 Standard format for reporting fuel oil non-availability
5.2.1 For ships which are unable to purchase fuel oil meeting the requirements of
regulations 14.1 or 14.4 of MARPOL Annex
VI, the standard format for reporting fuel oil non-availability is set out in
appendix 1 to this document, pursuant to regulation 18.2.4 of MARPOL Annex
VI.
6 Possible safety implications relating to fuel oils meeting the 0.50% m/m sulphur
limit
6.1 MEPC 73 (October 2018) approved MEPC.1/Circ.878 on Guidance on the development of
a ship implementation plan for the consistent implementation of the 0.50% sulphur
limit under MARPOL Annex
VI
(hereafter the "Ship Implementation Plan Guidance") addresses some safety issues
identified with regard to 0.50% maximum sulphur fuel oil, in particular through the
section on risk assessment (section 1 of the Ship Implementation Plan Guidance) and
additional guidance provided on impact on machinery systems and tank cleaning (appendix
2 and appendix 3 of the Ship Implementation Plan Guidance, respectively).
6.2 Identified potential safety implications include, but are not limited to, the
following:
-
.1 stability of blended fuel oil;
-
.2 compatibility, including new tests and metrics appropriate for future
fuels;
-
.3 cold flow properties;
-
.4 acid number;
-
.5 flash point;
-
.6 ignition and combustion quality;
-
.7 cat fines;
-
.8 low viscosity; and
-
.9 unusual components.
6.3 Additional technical information and a review, displayed in tabular format, of the
possible potential safety implications is set out in appendix 2.
6.4 Reference should also be made to general industry guidance on potential safety and
operational issues related to the supply and use of 0.50% maximum sulphur fuelsfootnote.
APPENDIX 1
FUEL OIL NON-AVAILABILITY REPORT (FONAR)
Note:
1 This report is to be sent to the flag Administration and to the competent authorities
in the relevant port(s) of destination in accordance with regulation 18.2.4 of MARPOL
Annex VI. The report shall be sent as soon as it is determined that the
ship/operator will be unable to procure compliant fuel oil and preferably before the
ship leaves the port/terminal where compliant fuel cannot be obtained. A copy of the
FONAR should be kept on board for inspection for at least 36 months.
2 This report should be used to provide evidence if a ship is unable to obtain fuel oil
compliant with the provisions stipulated in regulations 14.1 or 14.4 of MARPOL Annex
VI.
3 Before filing a FONAR, the following should be observed by the ship/operator:
3.1 A fuel oil non-availability report is not an exemption. According to regulation 18.2
of MARPOL Annex VI, it is the responsibility of the Party of the
destination port, through its competent authority, to scrutinize the information
provided and take action, as appropriate.
3.2 In the case of insufficiently supported and/or repeated claims of non-availability,
the Party may require additional documentation and substantiation of fuel oil
non-availability claims. The ship/operator may also be subject to more extensive
inspections or examinations while in port.
3.3 Ships/operators are expected to take into account logistical conditions and/or
terminal/port policies when planning bunkering, including but not limited to having to
change berth or anchor within a port or terminal in order to obtain compliant fuel.
3.4 Ships/operators are expected to prepare as far as reasonably practicable to be able
to operate on compliant fuel oils. This could include, but is not limited to, fuel oils
with different viscosity and different sulphur content not exceeding regulatory
requirements (requiring different lube oils) as well as requiring heating and/or other
treatment on board.
1 Particulars of ship
1.1 Name of ship: _______________________________________________________
1.2 IMO number: ________________________________________________________
1.3 Flag: ______________________________________________________________
1.4 (if other relevant registration number is available, enter here): __________________
2 Description of ship's voyage plan
2.1 Provide a description of the ship's voyage plan in place at the time of entry into
"country X" waters (and ECA, if applicable) (Attach copy of plan if available):
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
2.2 Details of voyage:
-
1 – Last port of departure
___________________________________________________________________
2 – First port of arrival in "country X":
___________________________________________________________________
3 – Date of departure from last port (dd-mm-yyyy):
___________________________________________________________________
4 – Date of arrival at first "country X" (dd-mm-yyyy):
___________________________________________________________________
5 – Date ship first received notice that it would be transiting in
"country X" waters (and ECA, if applicable) (dd-mm-yyyy):
___________________________________________________________________
6 – Ship's location at the time of notice:
___________________________________________________________________
7 – Date ship operator expects to enter "country X" waters (and ECA,
if applicable) (dd-mm-yyyy):
__________________________________________________________________
8 – Time ship operator expects to enter "country X" waters (and ECA,
if applicable) (hh:mm UTC):
__________________________________________________________________
9 – Date ship operator expects to exit "country X" waters (and ECA,
if applicable) (dd-mm-yyyy):
__________________________________________________________________
10 – Time ship operator expects to exit "country X" waters (and ECA,
if applicable) (hh:mm UTC):
__________________________________________________________________
11 – Projected days ship's main propulsion engines will be in
operation within "country X" waters (and ECA, if applicable):
___________________________________________________________________
12 – Sulphur content of fuel oil in use when entering and operating
in "country X" waters (and ECA, if applicable):
__________________________________________________________________
3 Evidence of attempts to purchase compliant fuel oil
3.1 Provide a description of actions taken to attempt to achieve compliance prior to
entering "country X" waters (and ECA, if applicable), including a description of all
attempts that were made to locate alternative sources of compliant fuel oil, and a
description of the reason why compliant fuel oil was not available:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
3.2 Name and email address of suppliers contacted, address and phone number and date of
contact (dd-mm-yyyy):
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
Please attach copies of communication with suppliers (e.g. emails to and from suppliers)
4 In case of fuel oil supply disruption only
4.1 Name of port at which ship was scheduled to receive compliant fuel oil:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
4.2 Name, email address, and phone number of the fuel oil supplier that was scheduled to
deliver (and now reporting the non-availability): ___________________________
5 Operation constraints, if applicable
5.1 If non-compliant fuel has been bunkered due to concerns that the quality of the
compliant fuel available would cause operational or safety problems on board the ships,
the concerns should be thoroughly documented.
5.2 Describe any operational constraints that prevented use of compliant fuel oil
available at port:
__________________________________________________________________________
5.3 Specify steps taken, or to be taken, to resolve these operational constraints that
will enable compliant fuel use:
__________________________________________________________________________
6 Plans to obtain compliant fuel oil
6.1 Describe availability of compliant fuel oil at the first port-of-call in "country X",
and plans to obtain it:
__________________________________________________________________________
6.2 If compliant fuel oil is not available at the first port-of-call in "country X", list
the lowest sulphur content of available fuel oil(s) or the lowest sulphur content of
available fuel oil at the next port-of-call:
__________________________________________________________________________
7 Previous Fuel Oil Non-Availability Reports
7.1 If shipowner/operator has submitted a Fuel Oil Non-Availability Report to "country X"
in the previous 12 months, list the number of Fuel Oil Non-Availability Reports
previously submitted and provide details on the dates and ports visited while using
non-compliant fuel oil, as set out below:
Report: ___________________________________________________________________
Date (dd-mm-yyyy): _________________________________________________________
Port: _____________________________________________________________________
Type of fuel: _______________________________________________________________
Comments: ________________________________________________________________
8 Master/Company information
Master name: ______________________________________________________________
Local agent in "country X": ____________________________________________________
Ship operator name: _________________________________________________________
Shipowner name: ___________________________________________________________
Name and position of official: __________________ ________________________________
Email address: _____________________________________________________________
Address (street, city, country, postal/zip code): ____________________________________
Telephone number: _________________________________________________________
Signature of Master: _________________________________________________________
Print name: ________________________________________________________________
Date (DD/MM/YYYY): ________________________________________________________
APPENDIX 2
TECHNICAL REVIEW OF IDENTIFIED POTENTIAL SAFETY IMPLICATIONS ASSOCIATED WITH THE USE
OF 2020 COMPLIANT FUELS
Fuel Property
|
Potential Challenges
|
Remarks
|
Stability
|
The consequences of a ship receiving an
unstable fuel, or one that becomes unstable during storage or
handling, can be serious. Sludge may build up in the storage tanks,
piping systems or centrifuges and filters can become totally blocked
by voluminous amounts of sludge.
|
The challenge for the fuel producer is to
blend a fuel which is not only stable but also has a degree of
reserve stability such that it will remain stable during periods of
storage and treatment at elevated temperatures.
More paraffinic
blend components are expected for Very Low Sulphur Fuel Oil
(VLSFO) compared to existing fuels. Whereas aromatic components
have a stabilizing effect on asphaltenes, paraffins do not. Fuel
suppliers are responsible for ensuring that the supplied fuel is
stable.
|
Compatibility issues
|
Challenges are the same as with stability
(above).
|
An incompatible mix may be harmful to
ship's operation.
VLSFOs are expected to be paraffinic based in
some regions and aromatic based in other regions. There is a
risk of experiencing incompatibility when mixing an aromatic
fuel with a paraffinic fuel. The same risk exists today, but
with the wide range of products which may exist post 2020, it is
important to segregate fuels as far as possible and to be
cautious of how to manage/handle incompatible fuels on
board.
|
Cold flow properties and Pour
Point
|
ISO 8217:2017 limits the cold flow
properties of a fuel through setting a limit on the pour point (PP).
However, given that wax crystals form at temperatures above the PP,
fuels that meet the specification in terms of PP can still be
challenging when operating in colder regions. Wax particles can
rapidly block filters, potentially plugging them completely. The
paraffin's may crystallize and/or deposit in the storage tanks
leading to blockages at the filters and reduced fuel flow to the
machinery plants. If fuels are held at temperatures below the pour
point, wax will begin to precipitate. This wax may cause blocking of
filters and can deposit on heat exchangers. In severe cases the wax
will build up in storage tank bottoms and on heating coils, which
can restrict the coils from heating the fuel (fuel will become
unpumpable from the bunker tanks).
|
VLSFO products are expected to be more
paraffinic compared to existing fuels. As such, it is important to
know the cold flow properties of the bunkered fuel in order to
ensure proper temperature management on board.
It is important to
note that for additives to be effective, they have to be applied
before crystallization has occurred in the fuel.
Reference
1.
|
Acid number
|
The fuel shall be free from strong,
inorganic acids.
Fuels with high acid number test results arising
from acidic compounds cause accelerated damage to marine diesel
engines. Such damage is found primarily within the fuel
injection equipment.
|
There is currently no recognized
correlation between an acid number test result and the corrosive
activity of the fuel.
ISO 8217:2017, appendix E covers the
topic.
|
Flashpoint
|
Flashpoint is considered to be a useful
indicator of the fire hazard associated with the storage of marine
fuels. Even if fuels are stored at temperatures below the determined
flash point, flammable vapours may still develop in the tank
headspace.
|
SOLAS requirement.
|
Ignition and combustion
quality
|
Fuels with poor ignition & combustion
properties can, in extreme cases, result in serious operational
problems, engine damage and even total breakdown. Poor combustion
performance is normally characterized by an extended combustion
period and/or poor rates of pressure increase and low "p max"
resulting in incomplete combustion of the fuel. The resulting
effects are increased levels of unburned fuel and soot that may be
deposited in the combustion chamber, on the exhaust valves and in
the turbocharger system, exhaust after treatment devices, waste heat
recovery units and other exhaust system components. Extended
combustion periods may also result in exposure of the cylinder liner
to high temperatures which may disrupt the lubricating oil film,
leading to increased wear rates and scuffing. Unburnt fuel droplets
may also carry over impinging on the liner surfaces causing further
risk of damage to the liner.
|
High and medium-speed engines are more
prone to experience operational difficulties due to poor ignition
and combustion properties than low speed two stroke types. With four
stroke engines, poor ignition can result in excessive exhaust gas
system deposits, black smoke, engine knocking and difficulties
operating at low load.
If the ignition process is delayed for too
long a period by virtue of some chemical quality of the fuel,
too large a quantity of fuel will be injected into the engine
cylinders and will ignite at once, producing a rapid pressure
and heat rise and causing associated damage to the piston rings
and cylinder liners of the engine.
Reference 2.
|
Cat fines
|
Cat fines will cause abrasive wear of
cylinder liners, piston rings and fuel injection equipment if not
reduced sufficiently by the fuel treatment system. High wear in the
combustion chamber can result.
|
Major engine manufacturers recommend that
the fuel's cat fines content does not exceed 10 mg/kg (ppm) at
engine inlet.
|
Low viscosity
|
Low-viscosity fuels (less than 2 cSt at
engine inlet) challenge the function of the fuel pump in the
following ways:
-
.1 breakdown of the oil film, which could result in
seizures;
-
.2 insufficient injection pressure, which results in
difficulties during start-up and low-load operation; and
-
.3 insufficient fuel index margin, which limits
acceleration.
|
Low fuel viscosity does not only affect the
engine fuel pumps. Most pumps in the external fuel oil system
(supply pumps, circulating pumps, transfer pumps and feed pumps for
the centrifuge) also need viscosities above 2 cSt to function
properly.
Viscosity is highly temperature dependent and the crew
must take proper care of fuel oil temperature management to
avoid viscosity related issues.
Reference 3.
|
Unusual components
|
The below components and group of
components can be linked to the risk of encountering the following
problems:
Polymers (e.g. polystyrene, polyethylene,
polypropylene) Associated with filter blocking
Polymethacrylates Associated with fuel
pump sticking
Phenols Occasionally
Associated with filter blocking/fuel oil pump sticking
Tall oils Associated with filter blocking
Chlorinated hydrocarbons
Associated with fuel pump seizures
Estonian shale oil Associated in the past
with excessive separator sludging
Organic acids
Associated with corrosion as well as fuel pump
sticking
|
- Only for few components, there exists a clear
cause and effect between component and associated
operational problems.
There is no
statistical study performed of which components are
typically found in marine fuels and in which
concentration.
As per ISO 8217:2017,
annex B: The marine industry continues to build on its
understanding of the impact of specific chemical species
and the respective critical concentrations at which
detrimental effects are observed on the operational
characteristics of marine fuels in use.
Only in some of the past cases the origin of
the unusual components found in bunkers were revealed
and were due to various reasons such as:
.1 Russia/Baltic states 1997, cross
contamination in storage/piping (polypropylene);
.2 Singapore 2001, 4 bunker barges received
material from road tankers which, in addition to
transporting fuel, also collected/transported waste oil
from shipyards and motor shops (esters);
.3 Ventspils 2007, Estonian shale oil to
convert HSHFOs to LSFOS; and
.4
Houston 2010/11, bunker barges that were not cleaned
between cargoes (polyacrylates)
Reference 4.
|
References
1 CIMAC WG7 Fuels Guideline 01/2015: "Cold flow properties of marine fuel oils"
2 CIMAC WG7 Fuels 2011: "Fuel Quality Guide: Ignition and Combustion"
3 MAN Service Letter SL2014-593/DOJA
4 Bureau Veritas Verifuel, Investigative analysis of marine fuel oils: Pros & Cons