The purpose of these guidelines is to provide advice on the implementation of Reg 18 of Chapter III of Annex VI of MARPOL – Fuel Oil Availability. Reg 18 provides for situations where compliant fuel cannot be bunkered, provided the owner has taken reasonable steps to do so and therefore does not need to deviate from the intended route or unduly delay the voyage to achieve compliance.

It is possible that, from 01/01/2015 when the requirement to burn fuel oil with a sulphur content of not more than 0.10% m/m SOx content fuel in an ECA comes into force, shipowners may invoke Reg 18 and claim it was not possible to bunker the correct fuel before entering the ECA.

Guidance

During the Initial Inspection within an ECA or first port after transiting an ECA the PSCO will look at:

1. Bunker delivery note showing a sulphur content of not more than 0.10% m/m for fuel oil used onboard (MARPOL Annex VI Reg 18 (5))
2. The representative sample of fuel oil with a sulphur content of not more than 0.10% m/m (MARPOL Annex VI Reg 18 (8.1))
3. Evidence of a written procedure (Note: there is no requirement for this to be in English) and record of changeover to fuel oil with a sulphur content of not more than 0.10% m/m before entering the ECA such that this fuel is being burnt when entering the ECA and the volume of low sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oilchange-over operation is completed prior to the entry into an ECA or commenced after exit from such an area, shall be recorded in such log-book as prescribed by the Administration. (MARPOL Annex VI Reg 14 (6))

For the vessels operating in climate conditions with low temperature of air and/or water or expecting low temperature of air and/or water the PSCO may pay special attention to the following:

1. Existing pipelines for required fuel oil with a sulphur content of not more than 0.10% m/m delivery to machinery space are located or equipped with appropriate heating facilities to provide operation of the pipelines in low temperature conditions of air and/or water.
2. Written procedures of changeover to fuel oil with a sulphur content of not more than 0.10% m/m before entering the ECA include actions to provide that fuel delivery to machinery space in conditions of low temperature of air and/or water.
3. Any possibility of unavailability of fuel oil with a sulphur content of not more than 0.10% m/m due to possible considerable changing of weather conditions during all times of ship operation in ECA is excluded.

For the complete guideline, download the document below.