Members will already be aware of the Regulations concerning the low sulphur fuel requirements in specified Emission Control Areas (ECA), including Shanghai, Ningbo – Zhoushan, Suzhou, Nantong and all ports in Zhejiang, as outlined in previous News Alerts (click here).
As from 01.10.2018, vessels are required to use low sulphur content fuel not exceeding 0.5%m/m;
- when entering the Shanghai port area;
- when entering the Yangtze River Delta ECA if vessel’s destination is Ningbo or Zhoushan port;
- when entering the Suzhou and Nantong ECA area.
Further information on the applicable areas and requirements is set out in the Correspondent’s Circulars, which can be accessed by clicking here and here.
In addition to the above, the Correspondent, Huatai Insurance Agency & Consultant Service Limited, reports that the local MSA can designate a sampling company to attend on board the vessel to take samples in order to check a vessel’s fuel is in compliance. To protect the vessel’s interests and to minimise the risk of the imposition of penalties, the Correspondent recommends that Members designate a crew member to accompany the MSA officer throughout their attendance to ensure compliance with the sampling procedures set out in the IMO Guidelines for the Verification of Sulphur in Fuel and that a sample is retained by the vessel. Amongst other things, the Guidelines provide that "the sample or samples should be collected in a sampling container or containers and should be representative of the fuel oil being used. The sample bottles should be sealed by the inspector with a unique means of identification installed in the presence of the ship's representative. The ship should be given the option of retaining a sample. The label should include the following information:
- sampling point location where the sample was drawn;
- date and port of sampling;
- name and IMO number of the ship;
- details of seal identification; and
- signatures and names of the inspector and the ship's representative".
For a full copy of the IMO Guidelines, click here.
Finally, Members should review their bunkering and fuel changeover arrangements to ensure compliance with the ECA Regulations. Members should also ensure that documentary records are in order (along with the retention of samples – as discussed above) to show compliance, which should help to avoid delays and penalties being imposed.