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Monday, December 11, 2017

INTERTANKO’s position on sulphur fuel

European moves to reduce sulphur emissions into the atmosphere, while praiseworthy in their intent, could create logistical and operational difficulties for ship owners and could actually pose a significant safety risk for ships.

INTERTANKO members are conscious that air emissions from ships need to be reduced and are therefore fully supportive of the international legislation aimed at reducing emissions which are noxious to the atmosphere. Indeed it has been, and still is, deeply involved in finding solutions to a number of environmental issues including inter alia other air pollution, ballast water management, antifouling paints, dirty ballast, ship recycling. The INTERTANKO-promoted VOCON operational procedure aims dramatically to reduce volatile organic compound emissions from cargo tanks during oil transportation at sea.

However INTERTANKO believes that Europe’s moves on sulphur emissions are counter-productive to a more rapid implementation of MARPOL Annex VI and are going against what tanker operators can reasonably and safely achieve.

The European Commission’s proposed amendments to the Directive on Sulphur Content in Marine Fuel 1999/32 include a provision imposing mandatory use of fuel with a sulphur content of maximum 0.2% for ships while at berth.

“INTERTANKO is concerned at the potential consequences for international shipping if the EU Directive were to be adopted as it stands,” says INTERTANKO managing director Peter Swift, “and is keen to assist the EU in a redrafting of the Directive.”

INTERTANKO strongly recommends that the 0.2% sulphur provision be deleted from the proposals, pointing to major difficulties that would arise if such a deletion were not made.

The first difficulty is that this grade of fuel is not a standard marine fuel and may not be available in sufficient quantities for all ships to use. A secure supply of quality fuel needs to be guaranteed to ensure vessels’ safety.

Second, this proposal will mean substantial engine room modifications on many ships. Marpol Annex VI already specifies the use of 1.5% sulphur fuel in designated Sulphur Emissions Control Areas (SECAs). This fuel has to be carried separately from the standard fuel (average 2.6% sulphur) used by ships while in international trade.

Mandatory use of 0.2% sulphur fuel while ships are at berth means that a third grade of fuel has to be segregated on board, which will require an increase in the number of bunker tanks on ships, changes in vessels’ ability to segregate different fuels (and lubricating oils compatible with those fuels) and modifications to engine room pipeline arrangements, some of which would need to be effected while the vessel is in drydock. In addition, engines not needing modification to satisfy Marpol Annex VI may require modification to accommodate the EC proposal.

 “This is would be an unacceptable and unfair situation, particularly for newer engines which are installed onboard ships after 1st January 2000” says INTERTANKO’s Technical Director Dragos Rauta. “All these engines are certified by Flag Administrations as being in compliance with the MARPOL Annex VI requirements for NOx emissions. According to Annex VI, any modification of these engines would necessitate re-certification which can only be done through complex and time-consuming testing”

Third, the proposal gives no time allowance to achieve compliance. INTERTANKO suggests that, if the EC will insist on pursuing its current proposal, then its application  be applied on completion of a vessel’s first drydock after the regulation comes into force.

Fourth, vessels coming from non-EU ports will not have 0.2% sulphur fuel on board. Nor is there any time allowance given to take on board the fuel necessary for a EU port visit. INTERTANKO suggests at least six hours time allowance, which could be reduced if such fuel could be provided directly from shore tanks.

Fifth, there is no time allowance given for the necessary cooling of engine mechanisms between heavy fuel operation and 0.2% gasoil operation. Safety could be compromised if fuel changeover were hurried, resulting in possible engine fuel starvation and blackout of the vessel. INTERTANKO suggests a six hour allowance.

Sixth, the use of 0.2% gasoil in boilers designed to burn higher viscosity fuels will create unsafe conditions and unsafe working environments when switching from heavy to lighter fuel when the boiler is on load and the furnace is hot. INTERTANKO proposes a specific dispensation for boilers, which are used by most tankers to power cargo pumps, heat cargo and moor the vessel.

Seventh, INTERTANKO points to potential conflicts in timing between the entry into force of the Directive and the entry into force of Marpol Annex VI.

Lastly, from a legal point of view, it may be the case that the physical changes to the vessel required by this proposal can actually only be legally imposed by amending the international treaties governing the relevant design, construction and equipment features. Any unilateral regulation and enforcement in this field could potentially trigger violations of the rights of ships flying the flag of other nations being parties to, and operating in full compliance, with the provisions of, MARPOL 73/78.

INTERTANKO stresses that the best, maybe the only, solution safely and effectively to reduce emissions from ships is through a global regulatory system and not through regional arrangements with different standards and requirements. It also suggests that the quality and adequacy of fuel delivered to ships is more important than legislation, which targets the ships themselves.

Click here to download INTERTANKO’s position paper on sulphur fuel

Click here to download INTERTANKO’s comments to EP amendments to sulphur in fuel

Contacts:

Dragos Rauta  +1 703 373 2269   Mobile +1 202 320 0457

Bill Box  +44 20 7623 4311  Mobile +44 774 380 1487