Requirement of MARPOL Annex VI

DGS guidelines on compliance with the provisions of MARPOL Annex VI Regulation.

Director General of shipping, GOI vide<a  href=” https://www.dgshipping.gov.in/writereaddata/ShippingNotices/201908280416058978387Eng_Cir_02of2019.pdf” >Engineering circular no. 02 of 2019</a> has provided guidance and requirements for of MARPOL Annex VI Regulation 14 As per MARPOL Annex VI, regulation 14, the sulphur content of any fuel oil used on board ships outside Emission Control Areas shall not exceed 0.50% m/m on or after 1 January 2020. The interpretation of ‘fuel oil used on board’ includes fuel oil used in all emission sources including emergency equipment.

The regulation 14 also prohibits carriage of fuel oil with sulphur content more than 0.5% m/m for use on board ships on or after 1 March 2020. However, the prohibition on the carriage does not apply to ships fitted with ‘equivalent’ means of compliance permitted by MARPOL Annex VI, Regulation 4, such as exhaust gas cleaning system (EGCS). Also the prohibition does not apply to carriage of fuel oil with sulphur content more than 0.5% m/m as cargo.

The Supplement to IAPP Certificate is revised vide Resolution MEPC. 305(73) by addition of a new paragraph 2.3.3 to include compliance with above prohibition. The revised certificate will be annotated to state that “This Certificate will be effective from 01/03/2020.

MARPOL Annex VI, Regulation 18 provides that in cases where compliant fuel is not available, a ship is not expected to deviate from the intended route or unduly delay the voyage to procure compliant bunker fuel. Further (due to said reasons despite its best efforts to procure compliant fuel oil), the ship can undertake intended voyage after bunkering non-compliant fuel oil, provided the Master/Owner/operator informs the ship’s Flag State and the port State of next port of call well in advance. To standardize this information, FONAR (Fuel Oil Non-Availability Report) has been developed and provided in MEPC 320(74).

Instructions to ship Owners:

i. MEPC.1/Circ.878-Guidance on development of a ship implementation plan for consistent implementation of 0.5% sulphur limit under MARPOL Annex VI. The ship implementation plan is not a mandatory requirement, however Administrations and Port State Control authorities may consider the ship implementation plan as an evidence of due diligence by the ship owner when verifying compliance with 0.5% sulphur limit requirement.

ii. Cleaning of bunker tanks, pipelines, filters etc, may be considered to prevent compatibility and stability. It is to be noted that any modification in the fuel oil system is to be approved by the vessel’s classification society. Also any changes/ modification to engines is to be approved by the engine manufacturer.

v. Owners/operators are advised to be guided by MEPC.1/Circ.875 which provides guidance on best practice for fuel oil purchaser/users for assuring the quality of fuel oil used onboard ships.