MARPOL Annex VI: the Club s perspective

Transcription

1 MARPOL Annex VI: the Club s perspective Capt Yves Vandenborn Director of Loss Prevention The Standard Club

2 Contents 01 Requirements under MARPOL Annex VI 02 Existing & Potential Emission Control Areas 03 Global & ECA Sulphur limits 04 Enforcement in the EU 05 Enforcement in the US 06 Ship s Documents for Compliance 07 Loss Prevention Advice 08 Prevention Culture 09 Conclusion 2

3 Requirements under MARPOL Annex VI w.e.f. 1 Jan 2015, ships trading in designated emission control areas (ECA) have to use fuel oil with sulphur content 0.10% this includes use of fuel oil for the main and auxiliary engines as well as the boilers prior to entry into ECA, it is required to have fully switched-over from any high sulphur fuel in use to the ECA compliant marine fuel to have on board implemented written procedures as to how the switch-over is undertaken recording quantities of the ECA compliant fuel oils on board at each change-over, together with date, time & position in a logbook prescribed by the ship s flag state 3

4 Existing & Potential Emission Control Areas 4

5 Global & ECA Sulphur limits Outside an ECA Inside an ECA 4.50% m/m prior to 1 January % m/m prior to 1 July % m/m on and after 1 January % m/m on and after 1 July % m/m on and after 1 January 2020* 0.10% m/m on and after 1 January 2015 * depending on the outcome of a review, to be concluded in 2018, as to the availability of the required fuel oil, this date could be deferred to 1 Jan

6 Enforcement in the EU Key amendments to EU 2012/33 aligns the EC Directive with revised Annex VI The 0.5% limit outside EU-SECAs will apply in EC waters from 1st January 2020, regardless of the outcome of the IMO fuel availability (review of which is due by 2018) Strict enforcement & inspection by PSC in all EU ports (particularly by German MARPOL police), where they check change-over against FOBAS calculator If non-compliance is noted then the authority may ask ship to: 6 - present a record of the actions taken to attempt to achieve compliance; and - provide evidence that it attempted to purchase ECA compliant marine fuel Level of fines is yet to be ascertained; BUT Fines are specifically aimed to deprive the economic benefits derived from the infringement. Fines are to gradually increase for repeated infringements

7 Enforcement in the US More extensive than EU-SECA (cover SOx, NOx and PM emissions) USCG has authority to detain vessel on MARPOL violation Violations under MARPOL Annex VI may result in civil or criminal penalties EPA may impose a civil penalty of $25,000 per violation. If the violation continues there will be an additional penalty of $25,000 per day Within Californian waters, ships also need to comply with the CARB-OGV fuel rule Two differences between NA-ECA & CARB-OGV fuel rule: - MARPOL does not specify the type of fuel to be used other than stipulating sulphur content 0.1%. CARB-OGV requires use of distillate fuel oil (not residual fuel oil) - MARPOL permits the use of alternative emission control technologies (exhaust gas scrubbers). CARB-OGV does not recognize the use of such technology 7

8 Ship s Documents for Compliance Vessels need to retain on board: Oil Record Book Bunker samples Bunker quotation/correspondence Voyage plan Bunker Delivery Note (BDN) Fuel Quality Test report Notification to Flag, Port Authority & PSC (if obtaining compliant fuel may cause deviation or delay) 8

9 Loss Prevention Advice To comply, members must plan ahead to: Ensure sufficient storage arrangements for quantity and segregation of fuel grades Check quality of ECA compliant fuel Check machinery operation when changing fuel for issues relating to lubrication of pumps and nozzles, generator starting problems, fuel oil leakage, and delayed pick-up (engine speed) Plan when to switch fuel types, due to risk for potential loss of power (i.e. blackout) Document switch-over and quantities of fuel grades prior entering ECA Further information on specific technical requirements is recommended to check with Recognized Organization/Class and relevant Flag/Port State authority 9

10 Prevention culture Produce procedures and guidance for ships Implement Zero pollution culture throughout the company Strengthen company s Environmental Compliance Policy Continuous training onboard & ashore Brief crew on implications related to falsification of records and Marpol violations Establish a robust monitoring regime Report incidents which may result in a penalty 10

11 Conclusion Increase in the number of incidents and fines related to MARPOL violations As requirements are becoming more strict there are more vessels being detained MARPOL violations: discretionary cover 11

12 Regulatory status The Standard Club Ltd is regulated by the Bermuda Monetary Authority. The Standard Club Ltd is the holding company of the Standard Club Europe Ltd and the Standard Club Asia Ltd. The Standard Club Europe Ltd is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. The Standard Club Asia Ltd is regulated by the Monetary Authority of Singapore. Charles Taylor Services Limited (CTS) is authorised and regulated by the Financial Conduct Authority to carry out general insurance mediation activities for commercial clients. For more details please see or call the FCA on CTS is a wholly owned subsidiary of Charles Taylor Holdings Limited. The ultimate parent and controlling company is Charles Taylor plc.

13 @StandardPandI The Standard P&I Club Charles Taylor plc