Sulphur Emission Control Area (SECA) - Entry Guide

Given the requirements for all ships as contained in MARPOL Annex VI, Regulation 14, to be using
1.5% sulphur fuel oil on entering any SECA, the following supplies an outline or guide for fuel
changeover in order to meet the requirements of these Regulations. This document is not intended to be
specific for all vessels or replace the procedures as specified in the ship’s ISM manual for this procedure.
Two simplified shipboard engine room systems are referred to as the basis for the examples of the
changeover procedures that need to be well planned before entry into the SECA.

Before entry it is assumed that the vessel has sufficient low sulphur bunker fuel available for the total
period that the vessel will be in the SECA. Evidence of this bunker fuel will be needed in the event of a
port State inspection and this will consist of the Bunker Deliver Note (BDN) complying with the
requirements and details as shown in Appendix V of MARPOL Annex VI. Together with the BDN there
also has to be the mandatory sample as taken during bunkering in compliance with the procedures as
specified in the Guidelines associated with Annex VI for bunker sampling.

The Regulation requires that upon entry into the SECA the total fuel system in use for delivery of fuel to
both the main and auxiliary engines onboard contains 1.5% sulphur fuel. This will include where
appropriate both the settling and services tanks together with the corresponding pipelines from the main
bunker storage tank to these tanks and the fuel feed pipelines from the service or day tank to the
respective engines. Thus the whole process of changeover has to be pre-planned to meet the requirement.

At the inception of the fuel changeover process it is recommended that the content and tonnage of fuel in
all bunker tanks onboard is recorded in the engine room log book together with the date, time and
position of the vessel at the commencement of the procedure.

If the ship is equipped with two day or service tanks then the time requirement for the procedure will be
very much reduced. It is assumed that one Day or Service tank will contain higher sulphur heavy fuel oil
(HFO) whereas the other is already filled with the required 1.5% sulphur fuel oil. Thus, the whole
procedure will only require the isolation of the feed from the heavy fuel oil service tank and the flushing
of the feed pipeline to the differing engines from the Low Sulphur day or service tank.

If the ship is equipped with only one day or service tank then flushing of the system will take a very
much longer period. The procedure required could consist of:
• Reducing or emptying as far as is possible the settling tank of the previous HFO
• Flushing the pipeline to the settling tank and filling the settling tank with 1.5% sulphur fuel.
• Reducing or emptying as far as is possible the day or service tank.
• Flushing the connecting pipeline from the settling tank to the service or day tank with 1.5% fuel
from the settling tank.
• Filling the service tank with low sulphur fuel and commence use of the low sulphur fuel before
entry to that the feed pipelines to the engines are fully flushed.

It is suggested from the limited experiences so far reported that this whole procedure could take 48
hours if not longer whereas with the two service/day tank scenario it would be approximately 12
hours.

The Regulations require that upon entry into a SECA the distribution and quantity of the diverse
bunkers onboard are recorded in the engine room logbook together with the date, time and position upon
entry into the SECA. It is recommended that the distribution and quantity of bunkers onboard is
thereafter recorded daily in the logbook whilst in the SECA until the vessel leaves the SECA. Upon

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departure from the SECA again the quantity and distribution of bunkers together with the date, time and
position of the departure point should be recorded.

In addition to the foregoing, the quality of both the cylinder and lubricating oil should be reviewed with
regard to its Base number (BN). If the respective engines will be operating for lengthy periods within a
SECA then the lubricating oils may need to be replaced by low BN oils. The engine manufacturers
guidance should be obtained regarding this issue.