Emission Control Areas – Ultra Low Sulphur Fuel Oil Change-over Procedures

Introduction Fuel Storage

From 1 January 2015, for ships without an approved Before January 2015, Ultra Low Sulphur Fuel (ULS-
and effective exhaust gas scrubber operating within an MGO/MDO) was only used for auxiliary engines and
Emission Control Area (ECA), the sulphur content of boilers when at berth in ECAs, and only a limited
fuel oil used should not exceed 0.10% by mass (10 amount of such fuel was needed. When ULS-
ppm). All main and auxiliary engines and boilers are MGO/MDO is also required for the main engine, vessels
affected by the Regulation, meaning that vessels using travelling in and out of ECAs will have to consider their
heavy fuel oil must have completed the change-over consumption and be sure to have a sufficient amount of
process and operate on ultra-low sulphur fuel upon ULS fuel on board. For vessels without a scrubber that
entering an ECA. spend all of their time in ECA operation, using 0.1%
sulphur content fuel is mandatory, and fuel tanks must
(Note: Prior to 1 January 2020, the sulphur content limit
therefore be properly prepared. Simply emptying the
of fuel oil shall not apply to ships operating in the North
tanks and filling them with the new fuel may not be
American ECA or the United States Caribbean Sea
effective.
area that were built on or before 1 August 2011 and are
powered by propulsion boilers that were not originally It is very important that any 0.1% sulphur content fuels
designed for continued operation on marine distillate are not mixed with HFO. Supplies of ULS fuel will be
fuel or natural gas.) very close to the 0.1% limit, so even a little high-sulphur
fuel mixed in may render the new fuel non-compliant.
Ships operating within the European ECA have become
The supplier is responsible for seeing that the fuel
familiar with existing European legislation where the
sulphur level complies when delivered, but if the sample
maximum sulphur content of fuels used by ships at
taken during bunkering shows sulphur content
berth has not been allowed to exceed 0.10% by mass in
compliance and the sample taken at the engine inlet
EU ports since the 1 January 2010 unless the vessel
shows non-compliance, it will become the vessel that is
was:
held responsible.
 Due to be at berth in a port that lies outside of the Switching Fuels
ECA for less than two hours;
 Planned to use only a shore based power supply. Switching from one type of fuel to another is an
operation that does have risks. Therefore, vessels
From January 2015 Members choosing to continue to trading between areas with different sulphur limitations
trade within an ECA and who have not fitted an exhaust are required by MARPOL to have detailed change-over
gas scrubber will have to consider important factors procedures readily available on-board the vessel. The
including, the calorific value, decreased viscosity and crew needs to be well trained and aware of any risks
lower flash point of distillate fuel such as MGO in associated with the change-over – otherwise they risk
comparison to IFO. engine failure, power loss or even blackout. A full Risk
Assessment should be conducted by all involved in the
procedure. www.steamshipmutual.com/Risk-
Alerts/RA40RiskAssessment0514.pdf
Members should be aware that new ‘lighter’ fuel will
have a solvent-like effect on tanks, lines, pumps and
filters and may tend to dislodge any accumulated
residues. Not only could this impair the outcome of
sampling to indicate non-compliance, but could also
lead to leakages at pumps and seals, even sometime
following change-over. The engine manufacturer
should be consulted for any guidance.
MGO/MDO is prone to bacterial growth and an
inspection should be made following tank cleaning to
ensure that water does not enter the storage tanks.

RA44 – One of a series of Steamship Mutual Loss Prevention Bulletins produced by the Ship Safety Trust Page 1 of 2
For further information please contact the Loss Prevention Department Email: [email protected]
Steamship Insurance Management Services Ltd. Tel: +44 (0)20 7247 5490 www.steamshipmutual.com/loss-prevention/
Suggestions/Recommendations  Boilers cannot sustain use of MGO during normal
operation to meet the normal demand without
The manufacturers of the engines, boilers and/or control
modifications.
system should be consulted regarding possible
modification. Modern boilers may not have been  Explosion can take place due to incorrect
originally designed to burn lighter fuel types such as operations such as improper purging before ignition.
MGO and may need modification of the burners and  Following flame failure fuel may fall on hot surfaces
control systems requiring, if applicable, approval of the leading to explosion. All possible causes of flame
class society. failure, including actual change-over of fuel types
should be considered.
 Steam atomisation may not be suitable leading to
flame instability, improper combustion, and possibly
flame failure.
 Use of MGO may cause coke deposits on rotary
cup types of burners. Protective heat shields may
be necessary to prevent coke build up.
 Existing burners may have to be modified or burner
assemblies suitable for both HFO and MGO may
need to be fitted.
 Existing piping used for heated HFO from the pump
to the boiler may not be suitable for MGO.
 Where a boiler is designed to burn HFO instead of
MGO, a flame failure may occur when the fuel is
changed over to MGO.
 HFO is more viscous than MGO and existing pumps
may have difficulties with suction of the lighter oil.
As HFO has better lubrication properties than MGO,
overheating of pumps could occur.
If the Member is satisfied that, modifications to the
vessels’ installed equipment and systems are not All equipment manufacturers concerned should be
required then evidence of such an evaluation should be consulted to determine the necessary safeguards. A
carried on-board to satisfy the safety requirements of detailed fuel change-over operation manual should be
ISM, Port State Control and possibly Charterers. readily available for the operating crew on board.
Considerations in such an evaluation may include, but
are not limited to the following;
For further information on this or other Loss Prevention
topics please contact the Loss Prevention Department,
Steamship Insurance Management Services Ltd.

Tel: +44 (0)20 7247 5490

Email: [email protected]

RA44 – One of a series of Steamship Mutual Loss Prevention Bulletins produced by the Ship Safety Trust Page 2 of 2
For further information please contact the Loss Prevention Department Email: [email protected]
Steamship Insurance Management Services Ltd. Tel: +44 (0)20 7247 5490 www.steamshipmutual.com/loss-prevention/