i. All shipping companies are advised to develop a ship specific implementation plan for transition to usage of fuel oil with Sulphur content not more than 0.50% m/m taking into consideration MEPC.1/Circ.878-Guidance on development of a ship implementation plan for consistent implementation of 0.5% sulphur limit under MARPOL Annex VI. The ship implementation plan is not a mandatory requirement, however Administrations and Port State Control authorities may consider the ship implementation plan as an evidence of due diligence by the ship owner when verifying compliance with 0.5% sulphur limit requirement.
ii. All vessels registered under Merchant Shipping Act 1958 are advised to start using fuel oil with maximum sulphur content not exceeding 0.50% m/m prior to 1st January 2020 unless fitted with EGCS. Also the Administration has advised that ships not fitted with EGCS are made free of non-compliant fuel oil by 01/01/2020 instead of waiting until 01/03/2020.
iii. Cleaning of bunker tanks, pipelines, filters etc, may be considered to prevent compatibility and stability issues during change over as Port State Control Inspectors may verify compliance through sampling and testing. It is to be noted that any modification in the fuel oil system is to be approved by the vessel’s classification society. Also any changes/ modification to engines is to be approved by the engine manufacturer.
iv. Indian ships faced with non-availability of compliant fuel oil are required to forward FONAR to the PSC Cell of the Directorate and the competent authority of the port of destination as soon as it is determined or becomes aware that it will not be able to procure and use compliant fuel oil. Also the quantity of non-compliant fuel-oil that will remain on ship after completion of the voyage with the procedure to deal with non-compliant fuel is to be reported to the PSC Cell. Foreign flag ships coming to an Indian port with non-compliant fuel are also required to send FONAR to the PSC Cell of the Directorate and jurisdictional Mercantile Marine Office at least 48 hours prior arrival.
v. Owners/operators are advised to be guided by MEPC.1/Circ.875 which provides guidance on best practice for fuel oil purchaser/users for assuring the quality of fuel oil used onboard ships.
a. SOx Emission Compliance Plan (SECP) approved by RO on behalf of Administration detailing the method of compliance for all fuel oil combustion machinery installed on board.
b. SOx Emission Compliance Certificate (SECC) issued by RO on behalf of Administration.
c. EGCS Technical Manual for Scheme A (ETM-A) or EGCS Technical Manual for Scheme B (ETM- B) as applicable duly approved by RO on behalf of Administration.
d. An On-board Monitoring Manual (OMM) prepared to cover each EGCS unit provided for the fuel oil combustion equipment.
e. An EGC Record Book prepared by manufacturer and approved by RO.
f. A data recording and processing device meeting the requirements detailed in MEPC. 259(68).
Wash water resulting from exhaust gas cleaning systems are not to be discharged into the sea, including enclosed ports, harbours and estuaries unless the wash-water meets the criteria set out in Resolution MEPC.259(68) and applicable local regulation.
iii. Indian ships faced with EGCS breakdown are advised to report malfunction that lasts more than one hour or repetitive malfunctions to the PSC Cell of the Directorate along with an explanation of the steps the ship operator is taking to address the failure. The ship operator to follow the process to identify and remedy the malfunction in the EGCS as per the approved EGCS Technical Manual or in other documentation provided by the EGCS manufacturer. Foreign ships coming to India are required to report all such cases to jurisdictional Principal Officer and the ship is to change over to compliant fuel oil within 4 hours of arrival.
i. Approved bunker suppliers are required to be guided by MEPC.1/Circ.875/Add.1-Guidnace on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.
ii. No fuel oil with sulphur content exceeding 0.5% m/m is to be supplied to any ship (Indian or Foreign) without keeping a copy of Supplement to IAPP Certificate indicating equivalent compliance for records.
iii. No fuel oil with sulphur content exceeding0.50% m/m is to be supplied to any ship (Indian or Foreign and claiming to have a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research in accordance with Regulation 3.2 of MARPOL Annex VI) without concurrence of the competent authority in DGS, GOI.
iv. Each case of supply of fuel oil with sulphur content exceeding 0.5% m/m will be specially audited by Auditors during Annual/ Renewal Bunker Suppliers audits for compliance to above requirements.
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.