MARPOL Annex VI
New regulations
Annex VI of MARPOL 73/78 "Regulations for the prevention of Air Pollution from ships" will enter
into force on 19 May 2005, and apply to all ships, fixed and floating drilling rigs and other platforms
of 400 gross tons and above. Such vessels are required to hold an International Air Pollution
Prevention Certificate (IAPP Certificate).
This certificate must be on board upon
delivery of newbuildings with keels laid after 19 May 2005. For other vessels, the
IAPP certificate must be on board at the
first scheduled drydocking after 19 May
2005,
but not later than 19 May 2008.
Annex VI requires that every vessel for
which the regulation applies is subject to an initial survey as well as annual,
intermediate and renewal surveys.
Regulation 12 – Emissions from Ozone
Depleting Substances (ODS) from
refrigeration plants and fire fighting
equipment
Annex VI prohibits any deliberate emissions
of ODS (CFC’s, Halons, HCFC’s) as defined
in the 1987 Montreal Protocol. Minimal
releases in connection with recapture or
recycling are, however, permitted.
New installations containing ODS are
prohibited on all ships after 19 May 2005,
with the exception of those containing
Hydrochlorflouro-carbons (HCFCs),
such as R22. These are permitted until
1 January 2020.
The EIAPP certificate is issued for marine
diesel engines after demonstrating
compliance with NOx emission limits, as
per the NOx Technical Code issued by IMO.
All certified engines are to be provided with
an individual Technical File that contains
the engine’s specifications for compliance
with the NOx regulation and onboard
verification procedures. Further, each
engine is to be provided with a Record
Book of engine parameters, where any
changes to the engine are to be recorded.
The phrase "major conversion", means a
modification of an engine where:
• The engine is replaced by a new engine
built on or after 1 January 2000, or
• Any substantial modification is made to
the engine, or
• The maximum continuous rating of the
engine is increased by more than 10%
Note that for engines installed on keels laid
on or after 1 January 2000, a substantial
modification would be classed as any
modification outside the ranges specified
in the Technical File (see later description).
For engines installed on vessel keels laid
before 1 January 2000, a substantial
modification means any modification made
to an engine that increases its existing NOx
emission. These changes include, but are
not limited to, changes in its operation or
its technical parameters (e.g. to reduce
fuel consumption).
Regulation 14 – Sulphur Oxide (SOx)
emissions from ships
Upon entry into force of Annex VI to
MARPOL on the 19 May 2005, the
maximum sulphur content of marine fuel
oils used on board ships, regardless of
application, is 4.5%. Further, a limit of 1.5%
on the sulphur content of marine fuel oil,
applies in the following designated SOx
Emission Control Areas (SECAs):
• The Baltic Sea Area which enters into
force on 19 May 2006
• The North Sea Area and the English
Channel which will not enter into force
until 19 November 2007
An alternative to using marine fuel oil with
a 1.5% sulphur content in SECAs, is an
exhaust gas cleaning system or other
equivalent abatement technology. The
emission criteria for such systems are
6 g SOx/kWh.
Operational impact of low sulphur fuel
Fuel quality issues
There have been indications that low
sulphur fuel oil production may lead to
increased quality problems, such as
instability, incompatibility, ignition and
combustion difficulties, increase in levels
Designated SOx Emission Control Areas
Excessive sludging in fuel oil separator
of catalytic fines and the potential
introduction of chemical waste.
Fuel tank/system configuration
When approaching a SECA a change to
1.5% sulphur content fuel must be made
and recorded before entry into the area.
Given fuel compatibility problems, and in
consideration of the differences in cost,
some owners are considering installing an
additional set of service and settling tanks
for low sulphur fuel oils. Such measures
would also simplify change-over
procedures and bunker management.
Inadequate availability of low sulphur heavy
fuel oils may force owners to increase
consumption of low sulphur diesel oils
within SECAs. Accordingly, allocation of
additional marine diesel oil tank capacity
may have to be considered.
Lube oil considerations
Experience has indicated that for 2-stroke
engines, long term operation on blended
low sulphur fuel oils and the use of high
base number (BN 70) cylinder lube oils
may lead to deposit build-up on piston
crowns, piston ring grooves and,
subsequently, liner scuffing.
The maximum operation time on fuel oils
with low sulphur content and high BN lube
oils appears to vary substantially depending
on fuel quality, engine make, type, age, load
profile, liner temperature, efficiency of water
mist catchers, installation of scraper rings,
as well as cylinder lube oil quality, feed rate
and lubrication system. Accordingly, the
relevant engine manufacturer and lube oil
supplier should be consulted prior to
operation on low sulphur fuel oil.
Regulation 15 – Volatile Organic
Compounds (VOC) emissions from
cargo oil tanks in oil tankers
The requirements apply to tankers
operating in terminals that have been
designated by the Port state as an area
where VOC is regulated. The relevant
Port state is required to give advance
notification to IMO of such designations.
Any tanker that has a USCG compliant
vapour emission control system will
automatically comply with the IMO
requirements.
Regulation 16 – Emissions from
shipboard incinerators
Each incinerator installed on board on or
after 1 January 2000 is to be type approved
under the IMO Resolution MEPC 76(40).
The operation manual and the type
approval certificate for such incinerators
must be provided on board and the crew
trained and capable of operating the
incinerator in accordance with the manual.
Further, shipboard incineration of certain
specified substances (e.g. PCB’s) is
prohibited. Incineration of sewage sludge
and sludge oil is not permitted in boilers or
diesel engines inside ports, harbours and
estuaries.
Regulation 18 – Fuel oil quality
General points
Regulation 18 specifically requires that fuel
oil supplied to ships must be free from
inorganic acids or chemical wastes that
could jeopardise the safety of the ship, be
harmful to ships' personnel, or pollute the air.
Guidelines relating to Regulation 18 are
found in Resolution MEPC. 96(47)
"Guidelines for the sampling of fuel for
determination of compliance with Annex VI
of MARPOL 73/78".
Bunker delivery notes
Regulation 18 requires that any fuel oil
delivered on board must be recorded on
a Bunker Delivery Note (BDN).
There is a requirement that BDNs must
contain specific information, including
quantity, sulphur content and a declaration
by the fuel oil supplier's representative that
the fuel oil supplied conforms with
regulations 14 and 18.
The BDNs must be kept on board for a
three-year minimum and be ready for
inspection at all times.
MARPOL Annex VI fuel oil samples
Regulation 18 requires that every BDN is
to be accompanied by a representative
sample of the fuel oil delivered, taking into
account the guidelines in Resolution
MEPC.96(47).
New regulations
Annex VI of MARPOL 73/78 "Regulations for the prevention of Air Pollution from ships" will enter
into force on 19 May 2005, and apply to all ships, fixed and floating drilling rigs and other platforms
of 400 gross tons and above. Such vessels are required to hold an International Air Pollution
Prevention Certificate (IAPP Certificate).
This certificate must be on board upon
delivery of newbuildings with keels laid after 19 May 2005. For other vessels, the
IAPP certificate must be on board at the
first scheduled drydocking after 19 May
2005,
but not later than 19 May 2008.
Annex VI requires that every vessel for
which the regulation applies is subject to an initial survey as well as annual,
intermediate and renewal surveys.
Regulation 12 – Emissions from Ozone
Depleting Substances (ODS) from
refrigeration plants and fire fighting
equipment
Annex VI prohibits any deliberate emissions
of ODS (CFC’s, Halons, HCFC’s) as defined
in the 1987 Montreal Protocol. Minimal
releases in connection with recapture or
recycling are, however, permitted.
New installations containing ODS are
prohibited on all ships after 19 May 2005,
with the exception of those containing
Hydrochlorflouro-carbons (HCFCs),
such as R22. These are permitted until
1 January 2020.
The EIAPP certificate is issued for marine
diesel engines after demonstrating
compliance with NOx emission limits, as
per the NOx Technical Code issued by IMO.
All certified engines are to be provided with
an individual Technical File that contains
the engine’s specifications for compliance
with the NOx regulation and onboard
verification procedures. Further, each
engine is to be provided with a Record
Book of engine parameters, where any
changes to the engine are to be recorded.
The phrase "major conversion", means a
modification of an engine where:
• The engine is replaced by a new engine
built on or after 1 January 2000, or
• Any substantial modification is made to
the engine, or
• The maximum continuous rating of the
engine is increased by more than 10%
Note that for engines installed on keels laid
on or after 1 January 2000, a substantial
modification would be classed as any
modification outside the ranges specified
in the Technical File (see later description).
For engines installed on vessel keels laid
before 1 January 2000, a substantial
modification means any modification made
to an engine that increases its existing NOx
emission. These changes include, but are
not limited to, changes in its operation or
its technical parameters (e.g. to reduce
fuel consumption).
Regulation 14 – Sulphur Oxide (SOx)
emissions from ships
Upon entry into force of Annex VI to
MARPOL on the 19 May 2005, the
maximum sulphur content of marine fuel
oils used on board ships, regardless of
application, is 4.5%. Further, a limit of 1.5%
on the sulphur content of marine fuel oil,
applies in the following designated SOx
Emission Control Areas (SECAs):
• The Baltic Sea Area which enters into
force on 19 May 2006
• The North Sea Area and the English
Channel which will not enter into force
until 19 November 2007
An alternative to using marine fuel oil with
a 1.5% sulphur content in SECAs, is an
exhaust gas cleaning system or other
equivalent abatement technology. The
emission criteria for such systems are
6 g SOx/kWh.
Operational impact of low sulphur fuel
Fuel quality issues
There have been indications that low
sulphur fuel oil production may lead to
increased quality problems, such as
instability, incompatibility, ignition and
combustion difficulties, increase in levels
Designated SOx Emission Control Areas
Excessive sludging in fuel oil separator
of catalytic fines and the potential
introduction of chemical waste.
Fuel tank/system configuration
When approaching a SECA a change to
1.5% sulphur content fuel must be made
and recorded before entry into the area.
Given fuel compatibility problems, and in
consideration of the differences in cost,
some owners are considering installing an
additional set of service and settling tanks
for low sulphur fuel oils. Such measures
would also simplify change-over
procedures and bunker management.
Inadequate availability of low sulphur heavy
fuel oils may force owners to increase
consumption of low sulphur diesel oils
within SECAs. Accordingly, allocation of
additional marine diesel oil tank capacity
may have to be considered.
Lube oil considerations
Experience has indicated that for 2-stroke
engines, long term operation on blended
low sulphur fuel oils and the use of high
base number (BN 70) cylinder lube oils
may lead to deposit build-up on piston
crowns, piston ring grooves and,
subsequently, liner scuffing.
The maximum operation time on fuel oils
with low sulphur content and high BN lube
oils appears to vary substantially depending
on fuel quality, engine make, type, age, load
profile, liner temperature, efficiency of water
mist catchers, installation of scraper rings,
as well as cylinder lube oil quality, feed rate
and lubrication system. Accordingly, the
relevant engine manufacturer and lube oil
supplier should be consulted prior to
operation on low sulphur fuel oil.
Regulation 15 – Volatile Organic
Compounds (VOC) emissions from
cargo oil tanks in oil tankers
The requirements apply to tankers
operating in terminals that have been
designated by the Port state as an area
where VOC is regulated. The relevant
Port state is required to give advance
notification to IMO of such designations.
Any tanker that has a USCG compliant
vapour emission control system will
automatically comply with the IMO
requirements.
Regulation 16 – Emissions from
shipboard incinerators
Each incinerator installed on board on or
after 1 January 2000 is to be type approved
under the IMO Resolution MEPC 76(40).
The operation manual and the type
approval certificate for such incinerators
must be provided on board and the crew
trained and capable of operating the
incinerator in accordance with the manual.
Further, shipboard incineration of certain
specified substances (e.g. PCB’s) is
prohibited. Incineration of sewage sludge
and sludge oil is not permitted in boilers or
diesel engines inside ports, harbours and
estuaries.
Regulation 18 – Fuel oil quality
General points
Regulation 18 specifically requires that fuel
oil supplied to ships must be free from
inorganic acids or chemical wastes that
could jeopardise the safety of the ship, be
harmful to ships' personnel, or pollute the air.
Guidelines relating to Regulation 18 are
found in Resolution MEPC. 96(47)
"Guidelines for the sampling of fuel for
determination of compliance with Annex VI
of MARPOL 73/78".
Bunker delivery notes
Regulation 18 requires that any fuel oil
delivered on board must be recorded on
a Bunker Delivery Note (BDN).
There is a requirement that BDNs must
contain specific information, including
quantity, sulphur content and a declaration
by the fuel oil supplier's representative that
the fuel oil supplied conforms with
regulations 14 and 18.
The BDNs must be kept on board for a
three-year minimum and be ready for
inspection at all times.
MARPOL Annex VI fuel oil samples
Regulation 18 requires that every BDN is
to be accompanied by a representative
sample of the fuel oil delivered, taking into
account the guidelines in Resolution
MEPC.96(47).
