From 1 January 2020, the limit for sulphur in
fuel oil on board ships operating outside designated Emission Control Areas
(ECAs) will fall to 0.50% mass by mass (m/m).
For this reason, the Shipowners'
Club published a checklist, which may be used as a guide to compliment any
operational changes that operators are planning, so as to ensure compliance
with the upcoming MARPOL convention changes.
The checklist is divided into three categories. These are:
General
Ø
Have you developed a ship specific implementation plan, in
accordance with guidance from the IMO?
Ø
In case that any structural modifications are necessary, have
these been added to the ship specific implementation plan and approved by the
flag state and/or classification society as applicable?
Ø
Has a risk assessment for compliance been conducted and is it
available on board?
Ø
Has crew and shore side personnel training been carried out with
appropriate records available?
Ø
If the ship is more than 400GT, is the International Air
Pollution Prevention (IAPP) Certificate or related exemption documentation
available on board?
Ø
Are the Oil Record Book and any other required records available
and up to date?
Ø
Do records note the condition of tanks, pipelines and other
associated bunkering equipment?
Ø
Do the Bunker Delivery Notes clearly verify whether the fuel oil
sulphur content is above 0.50% m/m?
Ø
Have you taken precautions to avoid comingling of supplied
bunkers with fuel already on board the vessel?
Ø
If comingling of fuel is unavoidable, have you made sure that
clear fuel test documentation is available for each batch of fuel?
Ø
Have you made preparations for entry into Emission Control Areas
(ECAs) in sufficient time to allow for complete flushing of the fuel system or
effective operation of the scrubber system?
Ø
If so, are written changeover procedures available to crew and
the necessary associated records available and maintained on board the vessel?
On ships where scrubbers are installed
Ø
Is the scrubber system type approved, in good working order with
planned maintenance tasks up to date and monitoring devices fully operational?
Ø
Are operational and maintenance records for the scrubber system
and its related equipment being maintained on board and are these available for
inspection?
Ø
Do any ports restrict or have additional requirements for the
discharge of open loop scrubber system wash water on the upcoming voyage(s)?
Ø
If so, have you made arrangements for specialist disposal
arrangements if necessary?
Switching to a new fuel type
Ø
Have you completed a suitability assessment, including reference
to manufacturer’s instructions, to establish what impacts a change in fuel type
may have on existing machinery and equipment?
Ø
Have the tanks and pipelines been thoroughly flushed and cleaned
to avoid cross contamination?
Ø
Do records note that segregation of fuel system tanks and pipe
work has been maintained where necessary?
Ø
Have you carried out additional tests for bunkers before
utilising them?
Ø
If additional tests are not practicable, are you monitoring the
vessel’s filters and fuel consumption when commencing use of fresh bunkers in
order to identify any problem at the earliest opportunity?
The port state control authorities will inspect the vessel posing
several risk factors, such as vessel’s historic PSC performance, its age, flag,
classification society and ISM manager performance.
Also, PSC may also target a vessel if they are alerted by a
third party, such as a pilot, or by ‘sniffing’ devices that detect stack
emissions.
#2 Inspection process
Except IMO's PSC guidance, the inspection depends on the factor
whether the vessel has an exhaust gas cleaning system (EGCS) installed, and
this may be different from state to state.
PSC
inspectors will ask to see several documents, as:
Ø Ship’s certificates relating to
MARPOL Annex VI (e.g. IAPPC + supplement, EIAPPC)
Ø Bunker delivery notes (BDN)
retained as required
Ø Bunker operation checklists
Ø Bunker certificates of quality
Ø Ship implementation plan
North alerts that if the port State
believes that the vessel and its equipment are not in line with the
documentation or if the crew seems unfamiliar with the operations, then a more
thorough inspection will follow. In the meantime, when a ship is not
equipped with an exhaust gas clean system (EGCS) or the use of it is banned
form the port, then the PSC are likely to check that its fuel is compliant.
This
may require testing of:
Ø the MARPOL delivered sample (drawn
at time of bunkering and retained by the vessel)
Ø the not-in-use
onboard sample (drawn from the vessel’s bunker storage tanks during inspection)
Ø The in-use sample
(drawn as close as possible to the engine inlet during inspection)
Learn more on "Preparing for PSC guidance" at,
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