 The present paper intends to inform DNV clients and other interested parties about potential consequences of the introduction of various international and regional regulations, specifi cally the EU Directive 2005/33/EC and new sections of the California Code of Regulation title 13/17.
Both of these regulations set forth limitations on the sulphur content of marine fuels used in specifi ed areas (EU ports and Californian waters)
The paper specifically aim at providing a summary of DNV’s and various industry stakeholders concerns regarding operations using fuels that comply with the abovementioned regulations general recommendations for safe operation.
The issues raised in this paper are of a general nature and it is important to note that the paper does not intend to address technical specialities of individual systems or components.
Furthermore, the new regulations may result in a need to modify both new and existing ships with regard to fuel oil systems and/or fuel oil consumers (primarily boilers and diesel engines). Such modifi cations are subject to approval and survey by the
vessel’s classifi cation society.
This includes requirements to documentation to be submitted for approval, certifi cation of components and materials and survey and testing onboard. These requirements are further described in Appendix A.
It is envisaged that not all required modifications will be completed by 1st January 2010 and there may be a need for owners to document that necessary modifi cations
have been planned for and are in progress.
Upon request, DNV may issue a statement to this effect, see Appendix B.
Whilst DNV’s present Rules for main class does not specifi cally address fuel quality, a voluntary class notation addressing this aspect may be assigned to new and existing
ships from beginning of 2010. A description of the voluntary class notation is given in Appendix C.
On the background of the possible adverse consequences of changing from the standard fuels the equipment were originally designed for, to low sulphur fuels as described in this paper, DNV reminds
Ship Owners/Managers of their obligation, through the ISM Code 1.2.2.2, to systematically analyse hazards involved for each particular ship, and to develop appropriate
maintenance (ISM 10) and operational procedures (ISM 7).
Should the necessary knowledge/competence not be available in-house, DNV recommends that the owners seek necessary advice by consultants, system designers and/or makers.
Appendix D outlines advisory services DNV may offer in this respect.
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