Commercial Vessel Compliance

03/03/2015: Safety alert – ultra low sulfur fuel oil, compliance with MARPOL requirements

The Coast Guard issued marine safety alert 02-15 as a reminder to vessel owners and operators about the importance of establishing effective fuel oil changeover procedures to comply with MARPOL Annex VI emission regulations.

Recently, there have been several reported incidents involving substantial machinery space fuel leakages while vessels were switching fuel oil to ensure compliance. Although such leakages were contained, fuel releases of any kind may result in pollution, injury or death of personnel and shipboard engine room fires. Moreover, many losses of propulsion have occurred in different ports and have been associated with changeover processes and procedures.

The Coast Guard strongly recommends that vessel owners and operators:

  • Ensure fuel oil switching is accomplished outside of busy traffic lanes and the emission control area, or ECA. Generally the ECA is 200  nautical miles from the North American Coast and 50 miles from the U.S. Caribbean coast (e.g., the Commonwealth of Puerto Rico and the U.S. Virgin Islands);
  • Utilize their technical resources to develop safe operations and maintain full compliance with emission requirements;
  • Consult with engine and boiler manufacturers for fuel oil changeover guidance and to determine if system modifications or additional safeguards are necessary;
  • Consult fuel suppliers for proper fuel selection;
  • Ensure all sensors, controls and alarms – pressure, temperature, viscosity, differential pressure, flow indicators, etc., are operational and function as designed;
  • Ensure system piping, seals, gaskets, flanges, fittings, brackets, etc., are maintained;
  • Ensure detailed system schematics are available;
  • Review and update fuel oil changeover procedures as needed;
  • Establish a fuel oil system inspection and maintenance schedule;
  • Review and update fuel changeover procedures based on lessons learned;
  • Provide initial and periodic crew training for accomplishing safe, effective and leak-free fuel switching;
  • Remember that the energy content of a given volume of ULS fuel oil may differ from residual fuel, such that existing throttle settings may not give the desired propeller shaft RPM or generator loads and performance/speed trials on ULS fuel oil may need to be conducted and;
  • Anticipate that there may be many technical challenges for operators when beginning to use ULS fuel oil as a matter of routine and compliance. These range from excessive leakages of fuel system components, increased wear and tear on these components, lack of lubricity of the fuels and the need for possible changes in maintenance schedules, operational methods, etc. The links below provide additional information on these topics.

 

View the marine safety alert for full details.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.