MARPOL 73/78 Annex VI

Regulations for the Prevention of Air Pollution from

Ships
MARPOL 73/78 Annex VI Regulations for the prevention of Air Pollution from ships came into force from !
Ma" #$$%
&he a'option of MARPOL Annex VI has follo(e' some "ears of 'e)ate (ithin organisations* At
the same time IMO &echnical co'e on the +ontrol of ,missions of -itrogen Oxi'es from Marine .iesel
,ngines (as a'opte'* MARPOL Annex VI an' the &echnical +o'e have retroactive re/uirements for 'iesel
engines 3$ 01 an' a)ove installe' on ships 2eel3lai' on or after 4anuar" #$$$5 an' Incinerators
installe' on)oar' on or after 4anuar" #$$$*
MARPOL Annex VI (ill appl" to all ships5 fixe' an' floating 'rilling rigs an' other platforms
from ! Ma" #$$%5 )ut the certification re/uirements are 'epen'ing on si6e of the vessel an' time of
perio'ical surve"*
7hips of 8$$ gross tons an' a)ove engage' in international vo"ages involving countries that
have ratifie' the conventions5 or ships fl"ing the flag of those countries5 are re/uire' to have an
International Air Pollution Prevention ertifi!ate "IAPP ertifi!ate#*
&his certificate must )e on )oar' at 'eliver" for a ship constructe' 92eel lai': after ! Ma"
#$$%*
;or ships constructe' )efore this 'ate5 the IAPP certificate must )e on )oar' at the first
sche'ule' 'r"3'oc2ing after ! Ma" #$$%5 )ut not later than ! Ma" #$$8*
&he IAPP certificate (ill )e issue' follo(ing an initial surve" carrie' out )" the ;lag
A'ministration or )" a recognise' organi6ation 9e*g* .et -ors2e Veritas: on )ehalf of the ;lag
A'ministration5 confirming compliance (ith MARPOL Annex VI* ;or ships (ith the flag of an A'ministration
that have not "et ratifie' Annex VI5 a ertifi!ate of omplian!e $ith Annex VI ma" )e issue' )" .-V*
Annex VI also re/uires 'iesel engines 9as 'escri)e' a)ove: to carr" in'ivi'ual certificates (ith
regar' to -Ox emissions5 name' %ngine International Air Pollution Prevention "%IAPP#
ertifi!ates*
Annex VI requires that every ship of 400 gross tonnage or above and every fixed and floating drilling
rig and other platforms shall be subject to the following surveys:
An initial survey before the ship is put into service or before the IA !ertificate is issued for
the first time"
eriodical surveys at intervals specified by the Administration# but not exceeding five years"
A minimum of one intermediate survey during the period of validity of the certificate"
In the case of ships of less than 8$$ gross tons5 the A'ministration ma" esta)lish appropriate
measures in or'er to ensure that Annex VI is complie' (ith*
&he A'ministration shall arrange for unsche'ule' inspections 'uring the perio' of vali'it" of the
certificate* If the A'ministration esta)lishes man'ator" annual surve"s5 these unsche'ule' inspections
shall not )e o)ligator"5 an' for this purpose .-V has so far consi'ere' that all A'ministrations (ill appl" a
s"stem (ith man'ator" annual surve"s*
Annex VI has requirements to the following main issues# which will be highlighted more in detail in
this paper"
$egulation %& ' (missions from )*one depleting substances from refrigerating plants and fire
fighting equipment"
$egulation %+ ' ,itrogen )xide -,)x. emissions from diesel engines
$egulation %4 ' /ulphur )xide -/)x. emissions from ships
$egulation %0 ' Volatile )rganic compounds emissions from cargo oil tan1s of oil tan1ers
$egulation %2 ' (missions from shipboard incinerators"
$egulation %3 ' 4uel )il quality"
Appli!ation for ships &eel'lai( )efore * +anuar, -...
7hips constructe' 92eel3lai': )efore 4anuar" #$$$ nee' to compl" (ith operational re/uirements in
MARPOL Annex VI from ! Ma" #$$%* <nless existing engines are su)=ect to ma=or mo'ification5 or ne(
engines or incinerators are fitte'5 the re/uirements in Regulation 3 an' constructive re/uirements in
Regulation > 'o not appl"*
;ormal certification of the ships applies at the first sche'ule' 'r"3'oc2ing after ! Ma" #$$%*
Regulation *- O/one (epleting su)stan!es
Annex VI prohi)its an" 'eli)erate emissions of o6one3'epleting su)stances* O6one3'epleting su)stances5
an' e/uipment containing such su)stances5 shall )e 'elivere' to appropriate reception facilities (hen
remove' from a ship*
-e( installations (hich contain o6one3'epleting su)stances are prohi)ite' on all ships after the entr" into
force 'ate5 except that ne( installations containing h"'rochlorflourocar)ons 9?+;+s: are permitte' until
4anuar" #$#$*
&he use of ?alon in fire extinguishing s"stems an' e/uipment is alrea'" prohi)ite' for
ne()uil'ings* ;or ne()uil'ings5 this re/uirement in Annex VI (ill therefore al(a"s )e complie' (ith*
More restrictive re/uirements for o6one 'epleting su)stances are in place regionall"5 e*g* in the ,uropean
<nion 9,<:*
Regulation *3 0itrogen Oxi(es "0Ox#
$egulation %+ of Annex VI concerns ,)x'emission from diesel engines and shall apply to:
each diesel engine with a power output of more than %+0 15 which is installed on a ship
constructed on or after % 6anuary &0007 and
each diesel engine with a power output of more than %+0 15 which undergoes a major
conversion on or after % 6anuary &000"
&his regulation 'oes not appl" to ,mergenc" 'iesel engines5 engines installe' in life )oats or
for an" e/uipment inten'e' to )e use' solel" in case of emergenc"*
&he phrase ma=or conversion5 means a mo'ification of an engine (here the engine is replace'
)" a ne( engine )uilt on or after 4anuar" #$$$5 or an" su)stantial mo'ification is ma'e to the engine5
as 'escri)e' in the -Ox
8ajor 8odifications
a" changing camshaft# fuel injection system
b" other ,)x'related settings or components
c" the maximum continuous rating of the engine is increased by more than %09
/ubstantial 8odification is defined as follows
a" 4or engines installed on vessels constructed on or after % 6anuary &000# a /ubstantial
8odification means any modification to an engine that could potentially cause the engine to
exceed the emission standards set out in $egulation %+ of Annex VI" $outine replacement of
engine components by parts specified in the :echnical 4ile that do not alter emission
characteristics shall not be considered a /ubstantial 8odification# regardless of whether one
part or many parts are replaced"
b" 4or engines installed on vessels constructed before % 6anuary &000# a /ubstantial 8odification
means any modification made to an engine which increases its existing emission
characteristics established by the simplified measurement method in excess of the allowances
set
:hese changes include# but are not limited to# changes in its operations or in its technical parameters
-e"g" changing camshaft# fuel injection systems# air systems# combustion chamber configuration# or
timing calibration of the engine.
According to Annex VI the operation of applicable diesel engines are prohibited except when the
emission of nitrogen oxides from the engine is within the following limits:
i. 17,0 g/kWh when n is less than 130 rpm
ii. 45,0 n(-0,2) g/kWh when n is 130 or more !t less than 2000 rpm
iii. ",# g/kWh when n is 2000 rpm or more
where n ; rated engine speed -cran1shaft revolution per minute. and the emission of nitrogen oxides
are calculated as total weighted emission of ,)&
&he ta)le )elo( illustrates the allo(a)le -Ox emissions from 'iesel engines@
ertifi!ation an( on)oar( verifi!ation
&he %IAPP "%ngine International Air Pollution Prevention# !ertifi!ate is re/uire' for all 'iesel
engines as 'escri)e' a)ove5 an' (ill )e issue' for marine 'iesel engines after 'emonstrating compliance
(ith -Ox emission limits* &he certification process is to )e carrie' out in accor'ance (ith the 0Ox
1e!hni!al o(e issue' )" IMO*
:he following engines require (IA !ertificates:
(ngine power output above %+0 15
Is the vessel constructed -1eel laid. before or after % 6anuary &000<
8ajor conversion of the engine on or after % 6anuary &000<
;or vessels (hch re/uire to carr" ,IAPP +ertificates )ut 'o not currentl"5 approach shoul'
)ema'e to the engine manufacturer for assistance* &he certificate (ill )e hel' (ith a 1e!hni!al 2ilethat
contains the engineAs specifications
:he ,)x :echnical !ode opens for + different onboard verification procedures:
(ngine parameter chec1 method
/implified measurement method
=irect measurement and monitoring method
&he applica)le on)oar' verification proce'ure is initiall" 'eci'e' )" the engine manufacturer5
an' is usuall" a specific chapter in the engineAs &echnical ;ile*
Metho(s of he!&ing omplian!e
%ngine parameter !he!& metho(
Rather than having to measure the actual level of -Ox it is accepta)le that a recor' )e 2ept to
ensure the current status of the engine is e/uivalent to that (hen -Ox rea'ings (ere ta2en initiall"* &he
engineAs &echnical ;ile i'entifies the components5 settings an' operating values that influences the
exhaust emissions an' these must )e chec2e' to ensure compliance 'uring surve"s an' inspections*
:o satisfy the requirements of this method the following must be available:
:echnical 4ile including the onboard verification procedure"
$ecord boo1 of engine parameters for recording all of the changes made relative to an
engine>s components and settings" Also to include technical documentation in case of
modification of any of the engine>s designated components"
(IA certificate -/tatement of !ompliance. for each applicable engine"
:he ,)x'influencing components and settings depend on the design of the particular engine# and
shall be listed in the engine>s :echnical 4ile" :he below list shows typical ,)x'influencing parameters:
Injection timing
Injection system components -no**le# injector# fuel pump.
Injection pressure
!amshaft components -fuel cam# inlet' and exhaust cam.
Valve timing
!ombustion chamber -piston# cylinder head# cylinder liner.
!ompression ratio -connecting rod# piston rod# shim# gas1ets.
:urbocharger type and build -internal components.
!harge air cooler?charge air pre'heater
Auxiliary blower
,)x reducing equipment @water injection@
,)x reducing equipment @emulsified fuel@ -fuel?water emulsion.
,)x reducing equipment @exhaust gas recirculation@
,)x reducing equipment @selective catalytic reduction@
:he actual :echnical 4ile of an engine may include less components and?or parameters other than the
list above# depending on the particular engine and the specific engine design"
One of the main conse/uences of MARPOL Annex VI is that the on)oar' verification proce'ure
B,ngine parameter chec2 metho'B re/uires i'entification mar2ings on the -Ox influencing components*
&hese components are t"picall" those specifie' in a)ove list* All the components liste' are to )e fitte'
(ith i'entification mar2ings accor'ing to the &echnical ;ile* Please note that these mar2ings ma" not )e
the same as the article noAs usuall" foun' on the engine components 9spare parts num)ers5 serial
num)ers:* It ma" )e the case that parts are availa)le )uilt un'er liscence* &hese must )e stampe' (ith
the same num)er other(ise the" are not accepta)le* &hese parts must )e accepte' )" the A'ministration
overseeing the issue of certification*
&here ma" )e situations (here the engine ma2er comes up (ith a ne( 'esign for one of the
-Ox3influencing components5 (ith a 'ifferent I' -o from (hatAs state' in the &echnical ;ile* &he ne(
'esign shoul' then )e approve' )" the A'ministration 9or .-V on )ehalf of a ;lag A'ministration (hen
authorise': an' the change is to )e 'ocumente' in the 3Re!or( )oo& of engine parameters3* &he same
is applica)le for all other changes the engine ma" )e approve' for 'uring its lifetime*
Simplifie( measurement metho(
&his involves full loa' running of the engine for a)out #$ minutes5 an' (ill in most cases
re/uire a test trial*
.ue to the possi)le 'eviations (hen appl"ing the simplifie' measurement metho'5 an
allo(ance of $C of the applica)le limit value is accepte' for confirmation tests an' 'uring perio'ical an'
interme'iate surve"s*
4ire!t measurement an( monitoring metho(
&he ship3o(ner (ill have the option of 'irect measurement of the -Ox emissions 'uring the
engine operation* 7uch 'ata can either ta2e the form of spot chec2s logge' (ith other engine operating
'ata on a regular )asis an' over the full range of engine operation5 or the" can result from continuous
monitoring an' 'ate storage* .ata must )e ta2en (ithin the last 3$ 'a"s5 an' must have )een ac/uire'
using the test proce'ures given in the -Ox &echnical +o'e* &hese monitoring recor's are to )e 2ept
on)oar' for at least three months for verification purposes*
&o 'emonstrate the compliance )" the 'irect measurement metho'5 sufficient 'ata shall )e
collecte' to calculate the (eighe' average -Ox emissions in accor'ance (ith the -Ox &echnical +o'e*
It shoul' )e note' that the t(o metho's that involve measuring of the exhaust emissions 'o
not inclu'e an" 2in' of i'entification mar2ings of the -Ox3influencing components*
Surve,s an( inspe!tions
4ollowing the regime of the IA certificate# the diesel engines will also be subject for the following
surveys:
An initial survey before the ship is put into service or before the IA !ertificate is issued for
the first time"
eriodical surveys at intervals specified by the Administration# but not exceeding five years#
A minimum of one intermediate survey during the period of validity of the certificate"
Annual /urveys -or a 4lag Administration may instead implement unscheduled inspections as
an alternative to Annual surveys.
If the @(ngine arameter !hec1 8ethod@ is the selected onboard verification procedure# the
surveyor will typically want to see:
i. $%&'' (erti)i*ates )or all appli*ale +iesel engines onoar+
ii. &ppro,e+ -e*hni*al .iles in*l!+ing /0noar+ ,eri)i*ation pro*e+!re1 )or all the appli*ale
+iesel engines onoar+
iii. 2e*or+ 3ook o) $ngine parameters )or all the appli*ale +iesel engines onoar+
i,. 0ne or all o) the i+enti)ie+ *omponents, settings or operating ,al!es spe*i)ie+ in the
engines4 -e*hni*al .ile
If the @/implified 8easurement 8ethod@ is the selected onboard verification
procedure# the surveyor will witness the testing in addition to review the following
documentation:
,. $%&'' (erti)i*ates )or all appli*ale +iesel engines onoar+
,i. &ppro,e+ -e*hni*al .iles in*l!+ing /0noar+ ,eri)i*ation pro*e+!re1 )or all the appli*ale
+iesel engines onoar+
,ii. &ll re*ommen+ations )rom engine man!)a*t!rer an+ appro,als )rom the &+ministration
*on*erning the 56impli)ie+ 7eas!rement 7etho+5
,iii. -est res!lts
If the @=irect 8onitoring and 8easurement 8ethod@ is the selected onboard
verification procedure# the surveyor will typically want to see:
i8. $%&'' (erti)i*ates )or all appli*ale +iesel engines onoar+
8. &ppro,e+ -e*hni*al .iles in*l!+ing 50noar+ ,eri)i*ation pro*e+!re5 )or all the appli*ale
+iesel engines onoar+
8i. 9o*!mentation/&ppro,al o) the installe+ meas!ring e:!ipment
8ii. ;ogge+ meas!rement res!lts in or+er to ,eri)< that the engines *ompl< with the =08
-e*hni*al (o+e.
$egardless of what onboard verification procedure the /hip')wner chooses# the IA !ertificate for
the vessel will be issued if all other requirements are found to comply with the applicable
requirements"
%ngines $ith %IAPP !ertifi!ates issue( ), another !ompan,
Although there are several companies a)le to certif" engines onl" those approve' )" flag 7tate (ill )e
accepta)le to the a'ministration 9generall" +lass: (ho have )een authorise' to issue certification*
Regulation *5 ' Sulphur Oxi(es "SOx#
6eneral
<pon entr" into force of Annex VI to MARPOL on the ! Ma" #$$%5 the sulphur oxi'e 97Ox: emissions
from ships (ill )e controlle' )" setting a limit of 8*%C on the sulphur content of marine fuel oils*
;urther5 a limit of *%C on the sulphur content of marine fuel oil (ill appl" in 'esignate' SOx
%mission ontrol Areas "S%As#* IMO has currentl" agree' on the 'esignation of t(o 7,+AAs as per
)elo(* &he first 'esignate' 7,+A is the Daltic 7ea Area (hich has )een agree' that (ill enter into force on
the ! Ma" #$$>* &he secon' area5 the -orth 7ea Area an' the ,nglish +hannel has also )een agree'5
)ut 'ue to the amen'ment process in IMO5 it has )een in'icate' that it (ill not enter into force as a 7,+A
until ! -ovem)er #$$7* It is expecte' that further 7,+AAs (ill )e 'esignate' in the future an' IMO has
set forth certain criteria for 'esignating such 7,+AAs*
&he limitations in sulphur content applies to all fuel oils 9heav" fuel oils5 marine 'iesel oils an'
gas oils: an' regar'less of use on )oar' 9i*e* in com)ustion engines5 )oilers5 gas tur)ines etc*:*
+urrentl"5 the average sulphur content in fuel oils is in the region of #*7C (ith onl" $*#C
having 7ulphur content a)ove 8*%C* ?o(ever onl" 8C of fuels have less than *%C*
%xhaust 6as leaning s,stems
As an alternative to using marine fuel oil (ith a *%C sulphur content in 7,+AAs5 an exhaust gas cleaning
s"stem or other e/uivalent s"stem ma" )e use' 9a)atement technologies:* &he emission criteria for such
s"stems are > g 7Ox/21h*
.evelopment of a t"pe approval stan'ar' for such s"stems is ongoing in IMO* &he current
availa)le a)atement technolog" is )ase' on sea(ater scru))ing principles*
:here is however a few concerns related to these types of scrubber type systems:
Annex VI states that port states may prohibit discharge of scrubber effluent overboard in ports
within /(!A>s unless it can be documented that the effluent complies with criteria set by that
port state" A mitigating measure is installation of filtration?treatment systems"
It has been indicated that conventional scrubber technology may be struggling to meet the
emission criteria at high exhaust gas discharge flows"
It has been indicated that there is a ris1 of blue'sheen originating from the scrubber overboard
discharge" Although# not necessarily constituting an environmental ha*ard# the mere ris1 of
such occurrences is to some operators unacceptable"
:here are space considerations in the engine room and more specifically the funnel" Although
it has been indicated that the more advanced scrubber types can replace standard silencers#
the associated piping systems may represent a challenge" ressure drop in scrubbers has
also been indicated as a limitation# particular in way of main engines upta1es"
:an1er owners have had mixed experiences with corrosion of inert gas scrubbers and
associated piping systems"
:he (A has been reluctant to accept scrubbers" Based on trials they have indicated that they
may accept abatement technology as an equivalent to low sulphur fuel" ,ote that (A has
indicated that it will develop criteria for resulting waste streams in their ports"
The author understands that the trial of this scrubbers have been pretty disastrous and have often
ended up being expensive follies
%7 4ire!tive *888/3-/% $ith propose( amen(ments
In connection (ith MARPOL Annex VI one cannot 'isregar' ongoing lo(3sulphur 'evelopments in the ,<*
(A directive %CCC?+&?(! has been amended a number of times# and in force today is the following:
8ember states to ensure that 8arine =istillates used within their territory from 6uly &000 do
not exceed 0#&9 /ulphur -0#% 9 from 6anuary &003." In other words# ships must ensure that if
they are using 8arine =istillates in (A territory -territorial waters including seas %& nautical
miles from shore and inland waterways.# their sulphur content is below 0#&9" 8arine =istillates
in this context include both marine gas oils and marine diesel oils -=8D# =8A# =8B and =8!."
As far as =,V/ has been informed this requirement is currently only enforced by =utch
Authorities Amendment to (A directive %CCC?+&?(! reached a common position in 6uly &004#
and although the amendment process is in its final stages# implementation date is highly
uncertain and further amendments cannot be ruled out" As of 6uly &004 the following is in the
pipeline:
A %"09 sulphur limit for fuels used by all ships in the Baltic /ea# ,orth /ea E !hannel in
accordance with the implementation dates of Annex VI to 8A$)F -i"e" starting in %C 8ay &002
for the Baltic /ea Area." As of %C 8ay &002# (A member states shall ensure that the sulphur
content in marine diesel oils -I/) 3&%G grades =8B and =8!. supplied within their territory
does not exceed %"09"
A %"09 sulphur limit for fuels used by passenger vessels on regular services between (A ports
as of %C 8ay &002"
A 0"%9 sulphur limit on fuel used by inland vessels and by seagoing ships at berth in (A ports"
:he !ouncil agreed this limit delayed until % 6anuary &0%0# to allow single'fuel ships time to
adapt their fuel tan1s"
A further two year delay has been proposed given to %2 unifuel -vessels using heavy fuel oil
for both main and auxiliary engines. ferries serving the Hree1 islands"
As of % 6anuary &0%0# (A member states shall ensure that the sulphur content in marine gas
oils -I/) 3&%G grades =8D and =8A. supplied within their territory does not exceed 0"%9"
4or ships arriving from outside the (A# the requirement need only be complied with upon
leaving the (A port of call"
Lo$ sulphur heav, fuel
It has )een in'icate' that experience in terms of lo( sulphur resi'ual 9or heav": fuel oil )len'ing is
var"ing an' that /ualit" pro)lems are to )e expecte'* Although there is limite' usage of 9)len'e': lo(
sulphur fuel oils5 .-V Petroleum 7ervices has alrea'" seen in'ications that the lo( sulphur processing of
fuel oils ma" lea' to a''itional /ualit" pro)lems such as insta)ilit"5 incompati)ilit"5 ignition an'
com)ustion 'ifficulties an' an increase of catal"tic fines levels* Regretta)l" one has also seen cases (here
chemical (aste has )een intro'uce' in such fuel*
Anyone who has bunkered in Singapore will not be unfamiliar with this
2uel tan&/s,stem !onfiguration
It shoul' )e note' that (hen approaching a 7,+A the fuel must )e change' over to the *%C sulphur
content fuel an' complete' )efore entering the 7,+A* &hat is all the fuel lines to the engine must have
this fuel onl"*
:here are two approaches to this
1. .;!shing - low s!lph!re )!el is !se+ to )l!sh o!t the higher s!lph!r )!les )rom the
settling/ser,i*e tank
2. 9!pli*ation o) tanks- seperate 6ettling/ser,i*e tanks are installe+ )or the two t<pes o) )!els.
-his has the potential to simpli)< the *hange o,er pro*ee+!re an+ re+!*e risk o) )!el
im*ompatiilities.
Ina'e/uate availa)ilit" of lo( sulphur heav" fuel oils ma" force o(ners to increase the
consumption of lo( sulphur 'iesel oils (ithin 7,+AAs* O(ners (ill therefore have to assess (hether the
'iesel oil tan2 capacit" nee's to )e upgra'e'* &a2ing into account the current ,< re/uirements to use of
ultra lo( sulphur 'istillates (ithin its territories5 an' not to mention the proposal for ultra lo( sulphur fuel
at )erth in ,< ports5 there is also an issue of (hether to allocate or convert existing fuel tan2s to tan2s for
marine gas oil*
&he 'ifferences in cost )et(een lo( an' high sulphur heav" fuel oils as (ell as )et(een heav"
fuel oils an' lo( sulphur 'iesel oils5 has le' some o(ners to consi'er separating fuel treatment an'
service piping s"stems* &his is increasingl" important (ith respect to potential re/uirements to use of
ultra lo( sulphur fuels in ,< ports
In or'er to facilitate safe an' simple change3over5 the installation of separate marine gas
oil/'iesel oil suppl" piping (ith heating capa)ilities shoul' )e consi'ere'* 91hile separate 'irect 'iesel oil
suppl" lines are often arrange' for auxiliar" 'iesel engines5 the same is less fre/uentl" encountere' for
)oilers an' main engines*:
&he )elo( serves as examples of propose' mo'ifications regar'ing 'uplicate' heav" fuel oil
service an' settling tan2s an' piping s"stems*
hange'over pro!e(ures
&he time5 shipAs positions at the start an' completion of change3over to an' from *%C fuel oil must )e
recor'e' in a log)oo2 9e*g* ,R log* )oo2:5 together (ith 'etails of the tan2s involve' an' fuel use'* It can
)e anticipate' that the same (ill )e applica)le (ith respect to the ,< proposal upon entr" into force*
Regulation *9 : Volatile Organi! ompoun(s
,missions of volatile organic compoun's 9VO+s: from tan2ers ma" )" each part" to Annex VI )e regulate'
in its ports an' terminals* 7uch re/uirements shall )e given in a list pu)lishe' )" IMO* &he list shall also
specif" si6e of tan2ers5 an' (hich cargoes5 that re/uires vapour emission control s"stem*
All tan2ers (hich are su)=ect to vapour emission control in accor'ance (ith a)ove list shall )e
provi'e' (ith an approve' vapour collection s"stem5 an' shall use such s"stem 'uring the loa'ing of such
cargoes*
,xisting tan2ers (hich are not fitte' (ith vapour collection s"stems ma" )e accepte' for a
perio' of three "ears after the terminal (as inclu'e' in the a)ove list* .-V has for man" "ears ha' class
notations V+7 an' # for vapour control s"stems compl"ing (ith IMO Eui'elines 9M7+/+irc*%8%:5 an'
<7+E regulations* It ma" )e note' that a vessel compl"ing (ith V+73 or # (ill compl" (ith regulation
%* &his regulation shall onl" appl" to gas carriers (hen the t"pe of loa'ing an' containment s"stems
allo( safe retention of non3methane VO+s on )oar'5 or their safe return ashore*
Regulation *; : Ship)oar( In!ineration
On)oar' incineration outsi'e an incinerator is prohi)ite' except that se(age slu'ge an' slu'ge oil from oil
separators ma" )e incinerate' in auxiliar" po(er plants an' )oilers (hen the ship is not in ports5 har)ours
an' estuaries*
Incineration of Annex I5 II an' III cargo resi'ues5 of P+DBs 9Pol"chlorinate' )iphen"ls:5 of
gar)age containing more than traces of heav" metals an' of refine' petroleum pro'ucts containing
halogen compoun's is al(a"s prohi)ite'*
Incineration of PV+As 9pol"vin"l chlori'es: is prohi)ite' except in ship)oar' incinerators t"pe
approve' accor'ing to resolutions M,P+ %!933: or M,P+ 7>98$:*
Monitoring of com)ustion flue gas outlet temperature shall )e re/uire' at all times an' (aste
shall not )e fe' into a continuous3fee' ship)oar' incinerator (hen the temperature is )elo( the minimum
allo(e' temperature of 8%$F+* ;or )atch3loa'e' ship)oar' incinerators5 the unit shall )e 'esigne' so that
the temperature in the com)ustion cham)er shall reach >$$F+ (ithin % minutes after start3up* It must )e
ensure' that the incineratorsB flue gas outlet temperature monitoring s"stem is operational*
All incinerators installe' on or after 4anuar" #$$$ shall )e t"pe approve' in accor'ance (ith
Resolution M,P+ 7>98$: giving the IMO stan'ar' specification for ship)oar' incinerators* ;or such
incinerators a manufacturerBs operating manual is re/uire'*
Regulation *8 : 2uel Oil <ualit,
Eeneral 1hile fuel oil /ualit" is currentl" primaril" a matter )et(een o(ners/managers 9an' charterers:
an' suppliers5 it (ill un'er Annex VI of MARPOL 73/78 also )ecome a statutor" matter*
In a''ition to re/uirements limiting the sulphur content of oil fuel5 Annex VI contains
re/uirements preventing the incorporation of potentiall" harmful su)stances5 an' in particular (aste
streams 9e*g* chemical (aste:5 into fuel oils*
Regulation 8 specificall" re/uires that fuel oil supplie' to ships is to )e free from inorganic
aci's or chemical (astes that coul' =eopar'ise the safet" of the ship5 )e harmful to shipsB personnel5 or
(hich (oul' contri)ute overall to a''itional air pollution* &he a''ition of small amounts of a''itives
inten'e' to improve performance is ho(ever permitte'*
Inci'entall"5 the re/uirements to fuel oil /ualit" in Regulation 8 are more or less i'entical to
the general re/uirements of I7O 8#75 although no references are ma'e to the same* Accor'ingl" one
/uestion raise' has )een (hether a fuel foun' off3spec compare' to I7O 8#7 test parameters is in
violation of Regulation 8* +onsultations (ith certain port states in'icate that this (ill li2el" not )e the
case* Instea' it has )een in'icate' that Regulation 8 ma" )e enforce' in case a ship is involve' in
acci'ents or near3acci'ents (here fuel /ualit" is a suspecte' contri)utor*
Isn't that disgraceful
Operational issues
It is important to note that ela)oration an' clarifications relating to Regulation 8 are foun' in Resolution
M,P+* !>987: BEui'elines for the sampling of fuel for 'etermination of compliance (ith Annex VI of
MARPOL 73/78B* Although this is a gui'eline5 it is expecte' that the gui'eline (ill )e use' as re/uirements
)" port state inspectors* It shoul' )e note' that Intertan2o has issue' a thorough an' useful gui'eline
relate' to Annex VI (hich ela)orates on the issues at han'*
=un&er (eliver, notes
It is a re/uirement of Regulation 8 that an" fuel oil for com)ustion purposes 'elivere' to an' use'
on)oar' shall )e recor'e' )" means of a =un&er 4eliver, 0ote "=40#* &his implies that a )un2er
'eliver" note shall )e presente' for ever" )arge 'eliver" an' ever" gra'e*
Bun1er =elivery ,otes are required to contain all specific information as follows:
,ame and I8) number of receiving ship
Bun1ering ort
=ate of commencement of bun1ering
,ame# address# and telephone number of marine fuel oil supplier
roduct name
Iuantity -metric tons.
=ensity at %0 o! -1g?m+.
/ulphur content -9 m?m.
A declaration signed and certified by the fuel oil supplier@s representative that the fuel oil
supplied is in conformity with regulation %4 and %3 -I"e" that the fuel supplied has a sulphur
level below 4"09 and that the fuel is free from inorganic acid# does not include any added
substance or chemical waste which either jeopardises the safety of ships# adversely affects
the performance of the machinery# is harmful to personnel# or contributes overall to additional
air pollution."
$esolution 8(!"C2-4G. recommends that the seal number of the associated 8A$)F Annex
VI fuel sample is included in the B=,@s for crossreference purposes"
&he D.-Bs are to )e 2ept on )oar' an' rea'il" availa)le for inspection at all times* It shall )e
retaine' for a perio' of three "ears after the fuel oil has )een 'elivere' on )oar'*
MARPOL 73/78 Annex VI fuel oil samples
Regulation 8 re/uires that ever" D.- is to )e accompanie' )" a representative sample of the fuel oil
'elivere'5 ta2ing into account the gui'elines in Resolution M,P+*!>987:*
&he sample is to )e seale' an' signe' )" the supplierBs representative an' the master or
officer in charge of the )un2er operation on completion of )un2ering operations5 an' retaine' un'er the
shipBs control until the fuel oil is su)stantiall" consume'5 )ut in an" case for a perio' of not less than #
months from the time of 'eliver"* Although M,P+*!>987: specifies that the volume of the sample )ottle
shoul' )e no less than 8$$ ml5 'ue to potential nee' for repetitive testing5 Intertan2o has recommen'e'
that the sample volume is not to )e less than 7%$ ml*
;or the sa2e of goo' or'er it shoul' )e note' that the practical purpose of this sample is to
ena)le port states to verif" the sulphur content of the fuel5 as (ell as to verif" that the fuel oil /ualit" is in
accor'ance (ith Regulation 8*
As Annex VI specifies that the Annex VI sample is not to )e use' for commercial purposes5
.-V Petroleum 7ervices recommen's that for shipAs alrea'" participating in a fuel oil /ualit" testing
scheme5 the Annex VI sample shoul' )e the fourth sample 9in a''ition to the sample sent to la)orator"
for testing5 suppliers sample an' the retaine' on)oar' sample:* &he reason is that it is consi'ere' an
a'vantage to al(a"s have an Annex VI sample on)oar' in case of port state controls*
Sampling pro!e(ures
-ote that the referre' to Resolution M,P+*!>987: specifies in 'etail that the fuel sample is to )e o)taine'
at the receiving shipAs inlet )un2er manifol' an' is to )e 'ra(n continuousl" throughout the )un2er
'eliver" perio'* &he term continuousl" 'ra(n is specifie' to mean a continuous collection of 'rip sample
throughout the 'eliver" of )un2er fuel* 7ampling metho's are further clarifie' as eitherG manual valve3
setting continuous3'rip sampler 9e/uivalent to .-V Petroleum 7ervicesA Line sampler:5 time3proportional
automatic sampler5 or flo(3proportional automatic sampler*
4urther the guidelines specify that sample bottle labels are to contain the following information:
Focation at which# and the method by which# the sample was drawn
Bun1ering date
,ame of bun1er tan1er?bun1er installation
,ame and I8) number of the receiving ship
/ignatures and names of the supplier>s representative and the ship@s representative
=etails of seal identification
Bun1er grade"
Sample inventor,
Resolution M,P+*!>987: also contains recommen'ations on sample storage location*
Supplier>s responsi)ilit,
1hile most IMO conventions place full responsi)ilit" on the ships an' ship o(ners5 Regulation 8 places a
certain responsi)ilit" on the suppliers 9fuel oil /ualit" 'eclaration5 D.- an' the Annex VI fuel oil sample )"
continuous 'rip an' at the receiving ships manifol':*
Annex VI of 8A$)F also contains instruments to encourage port states to ensure that suppliers fulfil
their obligations" ort states are therefore required to:
8aintain a register of local suppliers of fuel oil7
$equire local suppliers to provide the B=, and sample# certified by the fuel oil supplier that
the fuel oil meets the requirements of regulations %4 and %3"
$equire local suppliers to retain a copy of the bun1er delivery note for at least three years for
inspection and verification by the ort /tate as necessary7
:a1e action as appropriate against fuel oil suppliers that have been found to deliver fuel oil
that does not comply with that stated on the Bun1er =elivery ,ote7
Inform the 4lag Administration of any ship receiving fuel oil found to be noncompliant with the
requirements of regulations %4 or %3 of this Annex"
Inform I8) for transmission to arties to the rotocol of %CCG of all cases where fuel oil
suppliers have failed to meet the requirements specified in regulations %4 or %3"
?o(ever5 'espite the suppliersA responsi)ilities an' the instruments availa)le5 previous
experience from Port 7tate +ontrols in'icates that it is a'visa)le for o(ners/managers themselves to
ensure compliance* In or'er to assist ships in ensuring that the operational re/uirements are met5 it
shoul' )e consi'ere' to inclu'e clauses relate' to MARPOL Annex VI compliance in )un2er contracts an'
agreements (ith suppliers5 as (ell as charter parties*
1hir( part, inspe!tions
It can )e expecte' that upon implementation5 class surve"ors5 port state inspectors an' possi)l" also
vetting inspectors (ill scrutinise on)oar' 'ocumentation an' recor's 9e*g* sampling proce'ures5 change3
over proce'ures5 ,R log )oo2s5 D.-Bs5 sample inventor" log )oo2s etc*:5 as (ell as the fuel oil sample
inventor"*
The updated list showing state of ratification can be found on IMO's web pages
www!imo!org"home!asp# under 'conventions' and 'status of conventions by country! $or further
information% please contact& Annex 'I in general& ()'% *argo +andling% ,iping Systems% Marpol and
-as *arriers MT,)O../0dnv!com# )Ox and engine related in1uiries&
()'% Section for machinery% Ships in Operation
MT,)O.230dnv!com#
()'% Section for machinery% )ewbuilding
MT,)O4340dnv!com#
SOx and fuel related in1uiries&
()'% *argo +andling% ,iping Systems% Marpol and -as *arriers MT,)O../0dnv!com#
()',S% ()' ,etroleum Services ()',S!OS5O0dnvps!com#