Category Archives: Regulatory News

Stricter Sulphur Limits in ECAs

On 1 January 2015, the sulphur requirements in Emission Control Areas will be reduced to just 0.10%.

Although air pollution from ships does not have the direct cause and effect associated with, for example, an oil spill incident, it causes a cumulative effect that contributes to the overall air quality problems encountered by populations in many areas, and also affects the natural environment, such as though acid rain.

MARPOL Annex VI, first adopted in 1997, limits the main air pollutants contained in ships exhaust gas, including sulphur oxides (SOx) and nitrous oxides (NOx), and prohibits deliberate emissions of ozone depleting substances.

SOx and particulate matter emission controls apply to all fuel oil, as defined in regulation 2.9, combustion equipment and devices onboard and therefore include both main and all auxiliary engines together with items such boilers and inert gas generators. These controls divide between those applicable inside Emission Control Areas (ECA) established to limit the emission of SOx and particulate matter and those applicable outside such areas and are primarily achieved by limiting the maximum sulphur content of the fuel oils as loaded, bunkered, and subsequently used onboard. These fuel oil sulphur limits (expressed in terms of % m/m – that is by weight) are subject to a series of step changes over the years, regulations 14.1 and 14.4:

Outside an ECA established to limit SOx and particulate matter emissions:
4.50% m/m prior to 1 January 2012
3.50% m/m on and after 1 January 2012
0.50% m/m on and after 1 January 2020

Inside an ECA established to limit SOx and particulate matter emissions:
1.50% m/m prior to 1 July 2010
1.00% m/m on and after 1 July 2010
0.10% m/m on and after 1 January 2015

The ECA established are:
1. Baltic Sea area
2. North Sea area
3. North American area (which extends up to 200 nm from the coasts of the continental US & Canada
4. United States Caribbean Sea area

Most ships which operate both outside and inside these ECA will therefore operate on different fuel oils in order to comply with the respective limits. In such cases, prior to entry into the ECA, it is required to have fully changed-over to using the ECA compliant fuel oil, regulation 14.6, and to have onboard implemented written procedures as to how this is to be undertaken. Similarly change-over from using the ECA compliant fuel oil is not to commence until after exiting the ECA. Compliance can also be obtained by using ECA compliant fuel at all times.

Ship owners should be aware that MARPOL Annex VI Reg 4.1 allows the use of alternative compliance measures provided that the vessels flag administration certifies that these installations are “at least as effective in terms of emissions reductions as that required”.

Within 200 miles of shore, strict emission limits of exhaust gas are supported by EU and US EPA regulators and enforcement will be carried out by various governmental organizations.

The new compliance rules will apply to all vessels operating within any ECA. For ship owners there are two options to meet the requirements of the SOx emissions regulations:

Option 1: Switch to an alternative fuel with the correct sulphur content
Option 2: Install a scrubber to remove sulphur from the exhaust fumes following combustion

Scrubbing systems remove the sulphur content of fuel from the exhaust gases after they’ve been burnt, meaning vessels can go on using their existing fuel.

The process of scrubbing exhausts has been used since the 1930s in industrial plants and marine vessels. The scrubbing process uses a fluid containing alkaline material which can absorb SOx and neutralise it. After this process the clean exhaust gases are released and the resulting waste product, or sludge, is stored on board and transferred on shore.

Further reading:

Ballast Water Management

Ballast Water Management – Deadline 31.12.2014

Since the introduction of steel hulled vessels around 120 years ago, water has been used as ballast to stabilize vessels at sea. Ballast water is pumped-in to maintain safe operating conditions throughout a voyage. This practice reduces stress on the hull, provides transverse stability, improves propulsion and manoeuvrability, and compensates for weight lost due to fuel and water consumption.

While ballast water is essential for safe and efficient modern shipping operations, it may pose serious ecological, economic and health problems due to the multitude of marine species carried in ships’ ballast water. These include bacteria, microbes, small invertebrates, eggs, cysts and larvae of various species. The transferred species may survive to establish a reproductive population in the host environment, becoming invasive, out-competing native species and multiplying into pest proportions.

The problem of invasive species in ships’ ballast water is largely due to the expanded trade and traffic volume over the last few decades and since the volumes of seaborne trade continue to increase the problem may not yet have reached its peak. The effects in many areas of the world have been devastating. The spread of invasive species is now recognized as one of the greatest threats to the ecological and the economic well-being of the planet.

After more than 14 years of complex negotiations between IMO Member States, the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention) was adopted by consensus at a Diplomatic Conference held at IMO Headquarters in London on 13 February 2004.

The Convention requires all ships to implement a Ballast Water and Sediments Management Plan. All ships have to carry a Ballast Water Record Book and are required to carry out ballast water management procedures to a given standard.

The specific requirements for ballast water management are contained in regulation B-3 Ballast Water Management for Ships and differ according to the age of the vessel and the ballast water capacity.

BWM Standards

There is a ballast water exchange standard and a ballast water performance standard.

Regulation D-1 Ballast Water Exchange Standard – Ships performing Ballast Water exchange shall do so with an efficiency of 95 per cent volumetric exchange of Ballast Water. For ships exchanging ballast water by the pumping-through method, pumping through three times the volume of each ballast water tank shall be considered to meet the standard described. Pumping through less than three times the volume may be accepted provided the ship can demonstrate that at least 95 percent volumetric exchange is met.

Regulation D-2 Ballast Water Performance Standard – Ships conducting ballast water management shall discharge less than 10 viable organisms per cubic metre greater than or equal to 50 micrometers in minimum dimension and less than 10 viable organisms per millilitre less than 50 micrometres in minimum dimension and greater than or equal to 10 micrometers in minimum dimension; and discharge of the indicator microbes shall not exceed the specified concentrations.

Other methods of ballast water management may also be accepted as alternatives to the ballast water exchange standard and ballast water performance standard, provided that such methods ensure at least the same level of protection to the environment, human health, property or resources, and are approved in principle by IMO’s Marine Environment Protection Committee (MEPC).

Ships constructed before 2009 with a ballast water capacity of between 1500 and 5000 have until 31.12.2014 to adopt regulation D-2 the Ballast Water Performance Standard.

By 31.12.2016 all ships will have to comply with regulation D-2

Further reading: