Stricter Sulfur Requirements for ECA's entering into foroce 1 January 2015


On 1 January 2015 will the sulfur requirements in Emission Control Areas (ECA) be stricter again. At that time will vessels operating in ECA's be required to comply to a sulfur content of just 0,10 per cent. The SOx requirements apply to all fuel oils as defined in MARPOL Annex VI Reg.2.9.

Currently there are four (4) designated ECA’s which includes; the Baltic Sea, the North Sea, the North American ECA, which extends up to 200 nm from the coasts of the continental United States & Canada & the US Carribean Sea. Compliance with the new ECA requirements can be obtained by either using ECA compliant fuel at all times, or to switch to low sulfur fuel when entering an ECA. When switching to ECA compliant fuel oil, it is required to have a “written procedure showing how the fuel oil change over is to be done” according to MARPOL Annex VI Reg.14.6. The detailed change over procedure should be readable available and the ship’s crew shall be familiar with it. Further it is required that the change-over process is fully completed before entering the ECA. A logbook for registeringthe fuel oil change-over has to be kept on board as prescribed by the Administration. As already mentioned in different newsletters issued by DNVGL earlier, imposes the fuel oil change over potential challenges as specified in ISO 8217, such as low viscosity, lubricity, flashpoint, ignition and combustion quality. A major challenge is the low viscosity of the fuel oils which might cause leakages on the diesel engines, boilers and pumps. Internal leakages in fuel supply and fuel injection pumps, might result in reduced fuel supply to the engine, which will have consequences for the engine performance (e.g. starting of engine). Ship owners may consider installing fuel pumps and injection nozzles which adapt to fuel with low viscosity. Too low viscosity oil will lead to increased wear or seizure of fuel oil pumps. Because of the explosion risks connected to the use of highly volatile fuels on board ships, IMO has banned the use of fuels with a flashpoint lower than 60 degrees Celsius. An internal study has shown that most of the low sulfur fuel oils have a flashpoint lower than 60 degrees. These fuel oils should not be used on board and shall be handled in accordance with instructions from the Flag Administration and Class Society. Please note that the flashpoint is part of the Bunker Delivery Note. It might be advisable to install cooler or chiller units in the fuel or return line to prevent that the fuel oil is heated above 40 degrees Celsius which will lead to lower viscosity and hence may concur problems with the diesel engines, boilers, pumps etc. as described. Ship owners should be aware that MARPOL Annex VI Reg.4.1 allows the use of alternative compliance measures provided that the vessels flag administration certifies that these installations are “at least as effective in terms of emissions reductions as that required”.

Class Socisties constantly monitors international development on the environment for you and may assist in updating your organization on legislation developments and corresponding technical developments, both on the ship design and systems / equipment needed for you to be prepared for the future.

Author: International Cooperation Dept, VR