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  • 2007 August 9

    Entry into Force of the North Sea & English Channel SECA

     

    The IMO decided that the North Sea SOx Emission Control Area (SECA) will enter into force in 2007. At the same time, the European Union has included the North Sea SECA regulations in their amended low sulphur directive EC 2005/33.

    While the North Sea SECA will become effective on November 22 in accordance with IMO's MARPOL Annex VI, the EU Directive EC 2005/33 has set the implementation date as August 11.

    Based on a round of inquiry and feedback from EU member states, it is evident that majority of the EU member states in and around the North Sea Area consider the implementation of the North Sea SECA to be on August 11, and they will enforce it accordingly.

    However, some port states have indicated that they will give warnings and not fines before November 22.

    DNVPS therefore recommends that shipowners consider 11 August 2007 as the enforcement date for the North Sea SECA.

    Geographical extent of the North Sea SECA

    The North Sea SECA is identical to the North Sea Area defined in MARPOL Annex V (Prevention of Pollution by Garbage) and

    includes the North Sea and the English Channel, bound by the following coordinates:

    (i) North Sea southwards of latitude 62° N and eastwards of longitude 4° W;

    (ii) Skagerrak, the southern limit of which is determined east of Skaw by latitude 57°44.8' N;

    (iii) English Channel and its approaches eastwards of longitude 5° W and northwards of latitude 48°30' N.

    Generally speaking, the western boundary is the longitude extending from Brest (France) to Falmouth (U.K.) and further northwards from Strathy Point east of the Orkney Islands (U.K).

    The northern boundary is the latitude extending from Vågsøy (Norway) to Thorshavn (Faroes). Further, the area is bound by the latitude extending from Skaw to Gothenborg (i.e. entry to the Baltic SECA).

    Required actions from shipowners and crew

    Upon entry into the regulated area, the ship crew has to ensure that fuel used in any consumer onboard has a sulphur level not exceeding 1.50%.

    Completion of fuel change-over has to be recorded in an appropriate log book with respect to date, time and position, as well as the volume of low sulphur fuel oil remaining in each tank.

    INTERTANKO has recommended that similar details are also recorded at the commencement of change-over.

    Although not required by MARPOL Annex VI, DNVPS strongly recommends that shipowners provide crew with documented change-over procedures. Should you require assistance with this, please contact DNVPS.

    Please note that for ships with single service and settling tanks, the fuel change-over can take 2-4 days.

    In relation to MARPOL Annex VI, the ship crew has to ensure that they:

    - Receive and file compliant Bunker Delivery Notes (BDN) from suppliers for minimum 3 years;

    - Receive and store a compliant MARPOL sample from suppliers until the fuel has been substantially consumed but not less than 12 months.

    Unless the Port State in question has ruled otherwise, the MARPOL sample is to be taken at the ship manifold, using a continuous drip sampler

    throughout the duration of the bunkering;

    - Maintain a record of MARPOL samples.

    For more details, please refer to the DNVPS FQT Instruction manual found in each sampling kit.

    Non-compliance According to IMO's Port State Control Guideline, in the event of any detected non-compliance related to MARPOL sampling and BDNs,

    a Notification should be sent to the ship's Flag State, the bunker Port State Administration, and preferably to the supplier as well. A Notification should also be sent if the BDN specifies a sulphur level of 1.50% or below while the tested sulphur value indicates that it is above.

    IMO updates

    Please note that IMO has interpreted the SECA sulphur limit to be 1.50%.

    The IMO has also clarified that it is the actual sulphur content that is to be included in the BDN, i.e. the use of "maximum 1.50%" or "LT 1.50%" is not acceptable.

    EU updates with respect to distillates We have previously informed that the EU low sulphur directive 2005/33/EC is an amendment to the previous 1999/32/EC.

    One of the amendments is related to maximum allowable sulphur levels in marine distillates. The previous directive specified that this limit was 0.2% for both marine diesel oil and gas oil.

    This has been amended such that now only marine gas oil (ISO Grades DMA and DMX) is required to have a maximum sulphur

    level of 0.2% (0.1% as of 1 January 2008). In terms of marine diesel oil, the limits follow MARPOL Annex VI, i.e. 1.50% within SECA. The exception is passenger vessels in regular trade between EU ports, which always have to use 1.50% sulphur fuel.

    The limits apply regardless of applications onboard, covering main engines, auxiliary engines, boilers, diesel engines for power packs, inert gas generators and other equipment.

    Last but not least, it is important for shipowners bunkering marine diesel oil (ISO grades DMB or DMC) to ensure that this product is reflected in the Bunker Delivery Notes.

     

    Alexander S.Beday

    Customer Service Manager DNV Petroleum Services

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