Sulphur Limits
For Ships in EU Ports
From 1st January 2010 the
European Parliament Directive2005/33/EC came into force. As
well as reinforcing the limits of sulphur for vessels operating
in SECAs, and limiting the sulphur content of fuels used ashore
in the EU, it also introduced legislation governing the maximum
sulphur content of fuels used by inland waterway vessels and
ships at berth in Ports which are part of the European
Community. The limit placed is 0.1% Sulphur, which is the
maximum sulphur content of Gas Oil
The rules state that the
limit applies for ships at berth in EU ports allowing sufficient
time for the crew to complete any necessary fuel change over
operation as soon as possible after arrival at the berth and as
late as possible before departure. The change over must be
recorded in ships log books.
It does not apply to
ships in port for less than 2 hours, to vessels who "cold iron"
i.e. change over to shore power in port. Certain vessels
operating in the territory of the Hellenic Republic are exempt
until 1st January 2012.
Some confusion has arisen
over the interpretation of the Directive. It does not mean that
the main engine has to be changed over to gas oil, but the
generator engines must be changed over "as soon as possible".
MIN 376 issued by the MCA as an interim measure
gives guidance on this
point for ships at UK ports. Because the directive states
that ships at berth for up to two hours are exempt it can be
inferred that a reasonable time for change over can be
considered as 1hour after arrival and 1hour before the ship
sails.
The MIN also gives
guidance on the definition of "at berth", and states it applies
to ships at anchor within port limits. Outside port limits, then
Annex VI of MARPOL applies.
Because the limit
will also apply to boiler fuel used whist alongside, Companies
have applied for exemptions until their boiler burners can be
adapted to burn gas oil. This affects not only burner design but
also purge times for the boiler.
Vessels must arrive at
the port with supplies of the 0.1% sulphur fuel on board. They
cannot arrive and then take on the fuel.
some companies have
misinterpreted the directive and have issued instructions to
change over to 0.1% sulphur fuel on entry to a SECA.
It does not apply to
ports within a SECA but outside the EU (for example ST
Petersburg) although individual countries outside the EU may
have their own regulations. It also applies to ports within the
EU but outside a SECA (for example Lisbon).
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