06 March 2015

A previously reported in the club’s web alerts dated 20 January2015 and 16 January 2015, the North American Emission Control Area (ECA), underthe International Convention for the Prevention of Pollution from Ships(MARPOL), came into effect on 1 August 2012, establishing strict controls onemissions of sulphur oxide (SOx), nitrogen oxide (NOx) and particulate matterfor ships trading primarily off the coasts of Canada and the United States.Since 1 January 2015, the sulphur content of fuel oil burned within the ECAsmust be no more than 0.10% m/m.

The US Coast Guard (USCG) issued a Safety Alert on 3 March 2015,regarding ultra-low sulphur (ULS) fuel oil changeover procedures and compliancewith MARPOL requirements. In this Safety Alert, the USCG notes that severalincidents have been reported involving substantial machinery space fuelleakages which occur while vessels switch fuel oil. USCG said fuel tankmodifications, proper management of fuel mixing and temperatures, and ensuringsufficient supplies of ECA compliant fuel may all form part of adequateswitchover procedures. Furthermore, the USCG advised all ship owners to notethe important technical issues that have been highlighted by classificationsocieties, insurers, and industry associations. The Safety Alert provided linksto a few of the documents.

Importantly, the USCG recommended the following to all shipowners and operators:

Ensure fuel oil switching is accomplished outside of busytraffic lanes and the ECA. Generally the ECA is 200 nm from the North AmericanCoast and 50 miles from the U.S. Caribbean coast (e.g., the Commonwealth ofPuerto Rico and the U.S. Virgin Islands);

Utilize their technical resources to develop safe operations andmaintain full compliance with emission requirements;

Consult with engine and boiler manufacturers for fuel oilchangeover guidance and to determine if system modifications or additionalsafeguards are necessary;

Consult fuel suppliers for proper fuel selection;

Ensure all sensors, controls and alarms – pressure, temperature,viscosity, differential pressure, flow indicators, etc., are operational andfunction as designed;

Ensure system piping, seals, gaskets, flanges, fittings,brackets, etc., are maintained;

Ensure detailed system schematics are available;

Review and update fuel oil changeover procedures as needed;

Establish a fuel oil system inspection and maintenance schedule;

Review and update fuel changeover procedures based on lessonslearned;

Provide initial and periodic crew training for accomplishing safe,effective and leak-free fuel switching;

Remember that the energy content of a given volume of ULS fueloil may differ from residual fuel, such that existing throttle settings may notgive the desired propeller shaft RPM or generator loads and performance/speedtrials on ULS fuel oil may need to be conducted;

Anticipate that there may be many technical challenges foroperators when beginning to use ULS fuel oil as a matter of routine andcompliance. These range from excessive leakages of fuel system components,increased wear and tear on these components, lack of lubricity of the fuels andthe need for possible changes in maintenance schedules, operational methods,etc. The link below provides additional information on this topic.

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