TECHNICAL AND REGULATORY NEWS No.

02/2019 – PSC

SULPHUR LIMIT IN ECAS –

INCREASED RISK OF PSC DEFICIENCIES
AND DETENTIONS
Relevant for ship owners and managers.

March 2019

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.

Area Sulphur limit Scrubbers

Global 0.50% (2020) Local restrictions may apply
for open-loop scrubbers
SECA 0.10% Yes

EU 0.10% in all ports Open-loop scrubbers

restricted in some countries
China 0.50% in national Certain restrictions apply
0.50% limit, global (MARPOL, 2020) waters (12 nm) for open-loop scrubbers
0.10% limit, SECAs (MARPOL) California 0.10% within No, only with
0.50% limit, China national waters (12 nm), 2019 24 nm research exemption

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 sulphur-
related 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.

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Bunker delivery notes
ƒƒ To be kept on board for three years
ƒƒ To be stored readily available for inspection
Quality of fuel
The fuel quality is also subject for inspection:
ƒƒ Delivery of fuel to be accompanied by representative fuel
samples
ƒƒ Fuel samples are to be sealed and signed by supplier and
crew representative
ƒƒ To be kept on board for 12 months from delivery
A fuel changeover (FCO) procedure must be in place
ƒƒ Fuel oil service system to be fully flushed through, enabling
the crew to calculate the starting time
ƒƒ Crew to be trained to handle challenges and manage risks:
ƒƒ Incompatibility of fuel oils / filter problems
ƒƒ Low viscosity of distillate fuel / fuel pump failure and
injection valve problems
ƒƒ To be carried out slowly in accordance with manufacturer’s
instruction (2°C/minute) / thermal shock of injection
equipment
ƒƒ 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
DNV GL – Maritime, Brooktorkai 18, 20457 Hamburg, Germany, Tel: +49 40 36149 0, www.dnvgl.com/maritime
already in tanks. Various fuel changeover tools exist, including the
DNV GL FCO calculator which provides ship-specific solutions.
Recommendations
Port state authorities regularly inspect ships for ECA compli-
ance, and we recommend paying attention to the following:
ƒƒ Raise the awareness for fuel switching when entering ECAs.
ƒƒ Train the crew in handling and documenting fuel oil matters
(e.g. bunker delivery notes, changeover procedure, log book
entries and tank sounding records).
ƒƒ Start the fuel changeover procedure well in advance
(depending on consumption, volume of service system and
different sulphur levels used or mixed in tanks).
References
ƒƒ MARPOL Annex VI, Reg. 14.4 [Sulphur Oxides (SOx) and
Particulate Matter];
ƒƒ MARPOL Annex VI, Reg.18 [Fuel oil availability and quality]
ƒƒ Directive (EU) 2016/802 relating to a reduction in the Sulphur
content of certain liquid fuels
DNV GL resources:
ƒƒ Fuel-change-over calculator web page
ƒƒ Global sulphur cap 2020 web page
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