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Sulphur oxides (SOx) – Regulation 14


SOx and particulate matter emission controls apply to all fuel oil, as defined in regulation 2.9, combustion equipment and devices onboard and therefore include both main and all auxiliary engines together with items such boilers and inert gas generators. These controls divide between those applicable inside Emission Control Areas (ECA) established to limit the emission of SOx and particulate matter and those applicable outside such areas and are primarily achieved by limiting the maximum sulphur content of the fuel oils as loaded, bunkered, and subsequently used onboard. These fuel oil sulphur limits (expressed in terms of % m/m – that is by weight) are subject to a series of step changes over the years, regulations 14.1 and 14.4:
 
 
Outside an ECA established to limit SOx and particulate matter emissions
Inside an ECA established to limit SOx and particulate matter emissions
 
4.50% m/m prior to 1 January 2012
 
1.50% m/m prior to 1 July 2010
 
3.50% m/m on and after 1 January 2012
 
1.00% m/m on and after 1 July 2010
 
0.50% 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 January 2025.
 
The ECA established are:
  1. Baltic Sea area – as defined in Annex I of MARPOL (SOx only);
  2. North Sea area – as defined in Annex V of MARPOL (SOx only);
  3. North American area (entered into effect 1 August 2012) – as defined in Appendix VII of Annex VI of MARPOL (SOx, NOx and PM); and
  4. United States Caribbean Sea area (expected to enter into effect 1 January 2014) – as defined in Appendix VII of Annex VI of MARPOL (SOx, NOx and PM).
Most ships which operate both outside and inside these ECA will therefore operate on different fuel oils in order to comply with the respective limits. In such cases, prior to entry into the ECA, it is required to have fully changed-over to using the ECA compliant fuel oil, regulation 14.6, and to have onboard implemented written procedures as to how this is to be undertaken. Similarly change-over from using the ECA compliant fuel oil is not to commence until after exiting the ECA. At each change-over it is required that the quantities of the ECA compliant fuel oils onboard are recorded, together with the date, time and position of the ship when either completing the change-over prior to entry or commencing change-over after exit from such areas. These records are to be made in a logbook as prescribed by the ship’s flag State, in the absence of any specific requirement in this regard the record could be made, for example, in the ship’s Annex I Oil Record Book.
 
The first level of control in this respect is therefore on the actual sulphur content of the fuel oils as bunkered. This value is to be stated by the fuel oil supplier on the bunker delivery note and hence this, together with other related aspects, is directly linked to the fuel oil quality requirements as covered under regulation 18 – see below. Thereafter it is for the ship’s crew to ensure, in respect of the ECA compliant fuel oils, that through avoiding loading into otherwise part filled storage, settling or service tanks, or in the course of transfer operations, that such fuel oils do not become mixed with other, higher sulphur content fuel oils, so that the fuel oil as actually used within an ECA exceeds the applicable limit.
 
Consequently, regulation 14 provides both the limit values and the means to comply. However, there are other means by which equivalent levels of SOx and particulate matter emission control, both outside and inside ECA, could be achieved. These may be divided into methods termed primary (in which the formation of the pollutant is avoided) or secondary (in which the pollutant is formed but subsequently removed to some degree prior to discharge of the exhaust gas stream to the atmosphere). Regulation 4.1 allows for the application of such methods subject to approval by the Administration. In approving such equivalents an Administration should take into account any relevant guidelines. As of October 2010 there are no guidelines in respect of any primary methods (which could encompass, for example, onboard blending of liquid fuel oils or dual fuel (gas / liquid) use). In terms of secondary control methods, guidelines (MEPC.184(59)) have been adopted for exhaust gas cleaning systems which operate by water washing the exhaust gas stream prior to discharge to the atmosphere, in using such arrangements there would be no constraint on the sulphur content of the fuel oils as bunkered other than that given the system’s certification.