Use of low sulphur fuel oil by ships entering SECA

Since 1 January 2015, the sulphur content of fuel oil used by ships operating within the MARPOL Annex VI Sulphur Emission Control Area (SECA) shall not exceed 0.10% m/m, unless the ship is fitted with an alternative means approved for being at least as effective in terms of emission reductions, such as an exhaust gas cleaning system. These areas include the Baltic Sea, North American area, and United States Caribbean Sea area. In most cases, vessels entering the SECAs will have to change over from high sulphur heavy fuel oil to low sulphur distillate fuel / diesel oil to comply with the regulations.
Furthermore, come 1 January 2020, there will be enforcement of 0.50% m/m global sulphur cap on fuel oil used on board ships trading worldwide except when traveling in the designated SECAs with 0.10% m/m limits.
In recent years since 2013, and in particular in 2017, Singapore ships had experienced a rise in the number of PSC detentions related to non-compliance of the sulphur cap of fuel oil when the ships operate in SECA.
Based on our investigation of these detentions, the probable root causes of the deficiencies often relate to the fuel change over from high sulphur heavy fuel oil to low sulphur distillate fuel / diesel oil or vice versa:
  • Inadequate time given for the fuel change over for the service system to be fully flushed of all fuel oils exceeding the applicable sulphur content prior to entry into a SECA;
  • Procedure for the fuel change over not strictly adhered to and properly implemented - this could lead to contamination of the low sulphur fuel oil tanks;
  • Procedure for the fuel change over could be inadequate;
  • Engineering officers were not well-trained and experienced in carrying out the fuel change over;
  • Inadequate supervision by senior officers to ensure proper fuel change over.

Notice to Companies and Best Practices

We urge ship operators to pay closer attention to ensuring proper and efficient fuel change over operations on board ships in order to avoid any PSC problems when ships call at ports in the SECA.
  • Changing over of fuel at the right time is important - an early change over from high to low sulphur fuel would lead to higher consumption of low sulphur fuel which is quite expensive; a delayed change over may lead to violation of the MARPOL Annex VI requirement.
  • Each ship should have a documented fuel change over procedure that is ship-specific and takes into account the recommendations of the engines' manufacturer on how to change over. This is also a requirement of MARPOL Annex VI, Regulation 14(6) for ships entering and leaving a SECA.
  • The ship staff should be adequately trained and well-versed in the fuel change over procedure. The change over should be carried out properly and in accordance with the manufacturer's instructions.
Chief Engineers and their engineering staff should also closely monitor and supervise the operations of the fuel change over, including temperature change of the fuel inlet to the fuel pumps.