As Marpol Annex VI's worldwide sulphur cap came into effect on January 1st 2012 Global is fully prepared with Marpol compliant IFO worldwide meeting the 3.5%S cap - 12 Jan 2012
Almost two weeks into 2012 we thought we would give you an update on Global developments with regards to the availability of IFO with a maximum suplhur content of 3.5% to comply with legislation brought into force by on the 1st of January 2012 by Marpol Annex VI. The below map denotes in green the areas where Global Vision Bunkers can supply (subject cargo avails) Marpol Compliant fuel that meets the required maximum sulphur content.
Under Marpol Annex VI there is no provision for a period of grace as to the implementation of the 3.50 % limit. Furthermore there is no policy or period of grace as to vessels using up their stocks of fuel greater than 3.50 % beyond this date. Therefore in the absence of such clarity with respect to periods of grace, we therefore expect that authorities will take a zero tolerance approach to non conformities beyond the 1st January 2012 and recommend to all our customers that they take steps now in order to comply.
We further caution the practice of onboard blending of IFO’s to reduce the sulphur content without adequate compatibility checks and due to the added complications of creating a homogenous blend onboard the vessel prior to treatment and consumption.
0.1%S MGO legislation comes into force at berth in EC without technical exemptions - 1 Jan 2010
The European Commission (EC) has issued detailed advice on regulations that require ships at berth in European Union (EU) ports to use only fuels with a maximum 0.1% sulphur content from January 2010.
A Question and Answers (Q&A) document provided by the EC on the subject points to a strict interpretation of Directive 2005/33/EC, often referred to as the EU Sulphur Directive.
"The Directive does not allow for delay, nor for exemptions other than those already included and therefore it cannot be postponed," the EC said.
Approved exemptions to the 0.1% sulphur at berth rule only applies to ships which "according to published timetables" are due to be at berth for less than two hours; until January 1, 2012 for specific vessels listed in an Annex that operate exclusively within the territory of the Hellenic Republic; and to ships which switch off all engines and use shore-side electricity while at berth.
It said a ship would not be exempted in case the changeover of fuel is unsafe because the necessary modifications to the ship have not yet been implemented.
"The time that has been available to prepare [since 2005] does not justify such claim for exemption based on alleged emergency situations," the EC stated.
In recent days, however, the shipping community and maritime administrations have been waiting EC for advice on potential lenience shown for ships that cannot comply for technical reasons. In the Q&A document, the EC did say it would take special action to allow LNG-carriers to use a mixture of boil off gas and heavy fuel oil (HFO) to comply with the Directive, by defining it as a an approved equivalent emission abatement technology.
"The Commission is of the opinion that the technology to use both LNG and HFO does constitute such equivalent, provided that the mixture is such that the resulting emissions of sulphur dioxide are equal to or lower than when only burning 0.1% sulphur fuel.
"The Member States will decide on this matter in a designated Committee, which will be called together at the earliest convenience."
The EC's published advice also answered questions about where and how the Directive applies, as there has been some confusion about that too.
It said the 0.1% sulphur fuel requirement applies only to ships which are "securely moored or anchored in port" and "does not apply to ships manoeuvring or on their way to enter or leave the port".
Norway, which is not an EU member State, will apply the 'at berth' requirement in Directive 2005/33/EC from the new year. Norway and Iceland are both members of the European Economic Area (EEA), and enjoy free trade with the EU. The EEA agreement also calls on them to enact legislation similar to that passed in the EU. Market sources say the EU Sulphur Directive will not be implemented in Iceland in foreseeable future.
1. As part of the Member States enforcement actions against ships which fail to comply with the requirement to use fuels with a maximum permitted sulphur content of 0,1 % while at berth, Member States should request those ships to provide detailed evidence of the steps they are taking to achieve compliance. This should include a contract with a manufacturer and an approved retrofit plan which should be approved by the ship's classification society or, for ships flying the flag of a Member State, by the organisation having recognition in accordance with Regulation (EC) No 391/2009 of the European Parliament and of the Council ( 1 ). The retrofit plan should clearly state the date of completion of the adaptation and certification process.
2. Member States may consider the existence of an approved retrofit plan when assessing the degree of penalties to be applied to non-complying ships.
3. Member States should take appropriate measures to raise awareness among owners, operators and seafarers of the safety risk related to fuel changeover in the absence of any necessary technical adaptation to a ship’s fuel system and the necessity for training to be provided.
The EC's official Recommendation would still leave interpretation of penalty differentiation entirely up to the relevant administrations in individual Member States.
Draft revision of ISO 8217 published - 27 August 2009
The first draft of the fourth revision of the international marine fuel standard, ISO 8217, is now available and is in the 'public comment' stage, Bunkerworld has learned. The draft, ISO/DIS8217, is subject to change and may not be referred to as an international standard until the ongoing process is completed.
The International Organization for Standardization (ISO) working group in charge of the ISO 8217 revision has been working to a tight deadline due to pressure from the International Maritime Organization (IMO) to ensure the fourth edition is ready for publication by July 2010.
IMO has asked ISO to develop a marine fuel oil specification that would meet the needs of MARPOL Annex VI, and address air quality, ship safety, engine performance and crew health. This has led to a number of important and significant changes in the ISO 8217 draft revision compared to the current edition, ISO 8217:2005. Bunkerworld has now identified many of the potential differences.
Dag Olav Halle and John Stirling of global fuel testing agency DNV Petroleum Services (DNVPS), who are involved in the ISO 8217 revision process, told Bunkerworld that this draft is more likely to be altered than the draft versions of previous revisions.
They said this is the time for interested parties to look at the draft and comment on any concerns they may have to their relevant National Bodies. The voting period for the ISO/DIS8217 draft towards ISO ends on December 17, 2009 and as such the National Bodies will be voting soon.
The next step will be for the ISO 8217 working group (ISO/TC28/SC4/WG6) to discuss feedback after the balloting period, before producing a final draft in March, which will then be circulated for what is hoped to be a final vote in May.
New in the draft ISO 8217 revision for both distillate marine fuels and residual marine fuels are suggested limits for hydrogen sulphide (H2S), strong acid number and acid number. Sulphur limit values are no longer included in the draft ISO 8217 standard at all, leaving it up to the bunker buyer to specify the maximum sulphur content of fuels to the supplier in line with statutory requirements for regulated areas.
The reasoning is that statutory requirements on sulphur content, either for IMO's MARPOL Annex VI areas, EU, national or even local emission control areas (ECAs, including sulphur), may be subject to changes during the lifetime of the fourth edition of ISO 8217. For marine distillates, stability, to do with oxidation, and lubricity for ultra-low sulphur quality, to ensure distillate fuels do not have an adverse effect on engines, have been added as parameters.
Other new parameters introduced for residual marine fuels are Calculated Carbon Aromaticity Index (CCAI) as an indicator of ignition delay, and a limit on sodium content.
Moreover, limits for some elements have been modified. The draft suggests a reduction of the current limits for aluminum plus silicon (Al+Si), also know as cat fines. The current Al+Si limit in residual fuels is 80 mg/kg (ppm), and 25 mg/kg for DMC grade distillate fuel. DMC distillate fuel has moved from the distillate table to the residual fuel table in the draft ISO 8217 to become a new grade, RMA 10, and keeps the 25 mg/kg Al+Si limit.
Al+Si limits for the other residual fuel grades proposed in the new standard range from 40 mg/kg in the lower viscosity grades to 60 mg/kg in the higher viscosity grades.
The draft standard also proposes an expansion of RMG and RMK residual fuels to include additional viscosity grades, while RMF and RMH categories have been removed.
As previously reported on Bunkerworld, the ISO has already faced questions from the IMO's Marine Environment Protection Committee (MEPC)
the ISO 8217 working group is aware that its proposed changes may not meet with full approval from the IMO as it has already faced tough questions from the MEPC about the choice of CCAI to measure ignition quality, and the proposed H2S limit of 2 ppm. It has also admitted it is not yet able to include parameters to limit biodiesel contamination of marine fuels, due to the lack of an internationally accepted test method. Fuel testing agencies do test for a range of chemical contaminants today, but these methods are currently 'in-house' and not defined in an ISO standard.
Halle and Stirling told Bunkerworld that work is underway at both CIMAC (the International Council on Combustion engines) and ISO working groups to identify suitable test methods so other contaminants can be addressed in future revisions of ISO 8217. DNVPS are active in both, and believe that these are the best forums for further development of these important issues.
IMO plans expansion of sulphur monitoring - 19 August
The International Maritime Organization (IMO) is planning, according to Bunkerworld, to expand its monitoring of the global average sulphur content in bunker fuel to all marine fuels. The IMO currently monitors the average sulphur content of residual fuel oils for use on ships with input from three providers of bunker sampling and testing services.
The 59th session of the IMO's Marine Environment Protection Committee (MEPC 59) adopted revised guidelines for monitoring the worldwide average of sulphur last month. It also held discussions on expanding the scope sulphur monitoring programme.
The technical group considering amendments to MARPOL Annex VI held a "lengthy debate" both on whether to continue the sulphur monitoring programme, and whether it should be expanded to other types of marine fuels.
One of the arguments for expansion of the monitoring was that the "revised Annex VI indeed addressed all marine fuels," the technical group said in its report. It recommended that the Bulk Liquids and Gases Sub-Committee (BLG) be instructed to "immediately start revising the guidelines to address the expansion to all marine fuels with a preferred completion date of 2010."
It also suggested "taking into account grouping into the different sulphur limits" required by the revised MARPOL Annex VI, which is due to enter into force on July 1, 2010.
The IMO committee meeting also discussed whether to take into account the quantity of each bunker delivery when calculating a global sulphur average. Currently, the average sulphur content is calculated on the basis of the number of samples tested, and does not take into account the quantity per bunkering. The IMO has said this calculation method may give a false global average sulphur value.
Suppliers prepare for North American ECA - 15 June
Global marine fuel supplier Chemoil says it is "well-positioned to meet increased demand" for low sulphur marine fuels generated by any regulatory changes in the United States and Canada. The company was referring to the possibility of the coastal waters of the US and Canada becoming an Emissions Control Area (ECA) following a joint application by the two countries to the International Maritime Organisation (IMO).
Under IMO regulations, the sulphur limit for fuels used within an ECA will drop from 1.50% at present to 1.00% in July 2010, and then to 0.10% from January 2015.
The North American ECA could enter into force as early as August 2012, depending on the process at the IMO. In addition, ship operators in Californian waters will face the application of the first "substantial ruling" for reduced sulphur in marine fuels in North America already next month.
From July 1, a California Air Resources Board (ARB) regulation will require shipowners operating within 24 miles of the California coastline to burn either marine gas oil (MGO), with a maximum of 1.5% sulphur, or marine diesel oil (MDO), with a maximum of 0.5% sulphur in their main engines, auxiliary engines or boilers. Beginning January 1, 2012, vessel operators will be required to use MGO or MDO with a maximum 0.1% sulphur in their main and auxiliary engines under the ARB regulation. Operators who fail to comply with the rules would be subject to fines, penalties and potential exclusions from the ports of California.
In addition to its extensive and diversified global sourcing capabilities, one company has recently completed the expansion of its Carson Terminal in Los Angeles to provide additional storage for cleaner products and continues with its plans to increase storage capacity to support this business at its Long Beach Marine Terminal.