Technical and Operational for Bulk Carriers 2

INTERCARGO

International Association of Dry Cargo Shipowners

Technical and Operational Update for Bulk Carriers March 2006 Issue One

Photograph front cover courtesy of Bocimar

INTERCARGO

Technical and Operational Update for Bulk Carriers

March 2006 Issue One

INTERCARGO International Association of Dry Cargo Shipowners

Acknowledgement INTERCARGO is grateful to the Members of its Safety, Technical and Environmental Committee (CASTEC) for contribution in the drafting process of this publication. Appreciation also goes to the INTERTANKO Safety, Technical and Environmental Committee (ISTEC) for the comments and suggestions received. The valuable information from the following source is unique and relevant to many common interest issues: http://www.intertanko.com All rights reserved. No part of this publication may be reproduced in any material form (including photocopying or storing it in any medium by electronic means and whether or not transiently or incidentally to some other use of this publication) without the written permission of the copyright owner. Applications for the copyright owner’s written permission to reproduce any part of this publication should be addressed to the publisher. © INTERCARGO 2006 Whilst every effort has been made to ensure that the information contained in this publication is correct, neither the authors nor INTERCARGO can accept any responsibility for any errors or omissions or any consequences resulting therefrom. No reliance should be placed on the information contained in this publication without independent verification.

www.intercargo.org

INTERCARGO St Clare House, 30-33 Minories, London EC3N 1DD Tel: + 44 (0) 20 7977 7030 Fax: +44 (0) 20 7977 7031 Email: [email protected]

Contents

Page Air Pollution Prevention - MARPOL Annex VI………….

5

Ballast Water Management………………………………

12

Bunkers - MARPOL Annex VI and EU Directive ………

8

Cargoes - Dangerous…………………………………….

30

Cargoes - Direct Reduced Iron…………………………..

32

Cargoes - Petcoke………………………………………..

19

Cold Ironing………………………………………………..

10

Emergency Towing……………………………………….

33

Entry into Force ………………………………………….

1

IACS Common Structural Rules………………………...

28

Lifeboats……………………………………………………

9

MARPOL Special Areas………………………………….

27

Oily Water Separators ……………………………………

40

Particularly Sensitive Sea Areas………………………..

9

Pilotage - Denmark ………………………………………

34

Reception Facilities - Baltic………………………………

21

Ship Recycling…………………………………………….

37

Index of Abbreviations…………………………………….

42

INTERCARGO International Association of Dry Cargo Shipowners

FOREWORD It gives me great pleasure to be associated with Intercargo’s initiative to publish a summary of regulatory developments and other useful guidance designed to promote safety in the bulk carrier sector. Many countless hours have been spent in developing Regulations and Conventions, both nationally and in the main international fora of the IMO and IACS. “Best practice” examples are increasingly being communicated to industry through international and national shipping associations. Although the result of this regulation and self-regulation has seen a markedly safer bulk carrier industry, re-emphasising these new developments will undoubtedly increase the knowledge base of the dry bulk supply chain. This document, which will be published regularly after the introduction of significant developments at both IMO and IACS, is equally commended to Technical Departments and those providing commercial and strategic direction in the industry as a means of understanding the interlinking nature of issues. I commend the foresight in producing a published record suitable for the bulk carrier sector and look forward to the issuance of future editions.

March 2006

Tom Allan Former Chairman of the IMO Maritime Safety Committee

INTERCARGO

Technical and Operational Update for Bulk Carriers

Entry into Force - Index of New Requirements to be Implemented

The index contains currently available requirements and regulations relevant to bulk carriers with entry into force dates from 19 May 2005 to 1 Jan 2009. It will be updated periodically with new items of requirements and regulations when they are adopted and their entry into force dates are fixed.

19 May 2005: entry into force 1.1 MARPOL Annex VI: Air Pollution Prevention.

The dry bulk cargo residue will be treated as garbage. The residue and cargo hold wash water should be treated carefully in accordance with the relevant national, regional and international requirements and regulations. Relevant information: Intercargo Guide on compliance with MARPOL Annex V. Contact [email protected] for more information.

Relevant information: 1 Jan 2006: entry into force Circular IMO MEPC/Circ.472 on Guidelines for Port State Control under MARPOL Annex VI (Resolution MEPC.129(53)). It is available for download from http://www.imo.org/home.asp. Intercargo Guide on C125 ompliance with MARPOL Annex VI - Air pollution prevention. Contact [email protected] for the full text of an up to date version. 22 Jul 2005: entry into force 2.1 Resolution MEPC.130(53) - Guidelines for On-Board Exhaust Gas-SOx Cleaning Systems. Contact [email protected] for the source of the document.

1 Aug 2005: entry into force 3.1 Revised MARPOL Annex IV on Regulations for the prevention of pollution by sewage from ships, adopted by Resolution MEPC.115(51). Contact [email protected] for the source of the document. Annex IV may cause difficulties for ships without a holding tank in certain ports, such as in Korea and the Black Sea region. IMO may develop relevant port State control guidelines for the implementation of Annex IV in the future. 3.2 MARPOL Annex V: Amendments to MARPOL Annex V on “cargo residues” to the Form of the Garbage Record Book contained in the Appendix to MARPOL Annex V on Regulations for the prevention of pollution by garbage from ships, adopted by Resolution MEPC.116(51). Contact [email protected] for the source of the document.

4.1 Amendments to SOLAS chapter II-1 concerning means of access for inspections within spaces in the cargo area of oil tankers and bulk carriers, adopted by Resolution MSC.151(78). Contact [email protected] for the sources of the document. 4.2 Amendments to the Technical Provisions for Means of Access for Inspections, adopted by Resolution MSC.158(78). Contact [email protected] for the source of the document. Relevant information: IACS Unified Interpretations (UI) SC 191for the application of amended SOLAS regulation II-1/3-6 (Resolution MSC.151(78)) and revised Technical Provisions for Means of Access for Inspections (Resolution MSC.158(78)). Contact [email protected] for the source of the document. 4.3 Revised NAVTEX Manual. The relevant circular MSC/Circ.1122 on the Revised NAVTEX Manual is available for download from http://www.imo.org/ home.asp. 4.4 Early implementation and guidance on safety during abandon ship drills using lifeboats and the Guidelines for simulated launching of free-fall lifeboats. MSC 79 urged Member Governments to give effect to the amendment to SOLAS regulation III/19.3.3.3, adopted by Resolution MSC.152(78), prior to 1 July 2006 (which is the amendment’s entry into force date) and approved MSC circular MSC/Circ.1127 on Early Implementation of Amendment to SOLAS Regulation

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III/19.3.3.3 adopted by Resolution MSC.152 (78). Contact [email protected] for the source of Resolution MSC.152(78). The relevant circular MSC/Circ.1127 is available for download from http://www.imo.org/ home.asp.

1 Jul 2006: entry into force 5.1. Amendments to SOLAS Chapter III, adopted by Resolution MSC.152(78). Refer to 4.4 above. Resolution MSC.152(78) adopted amendments to: - Chapter III Life-Saving Appliances and Arrangements in: Regulation 19 - Emergency training and drills Regulation 20 - Operational readiness, maintenance and inspections Regulation 32 - Personal life-saving appliances (An immersion suit shall be provided for every person on board the ship). - CHAPTER IV Radiocommunications in: Regulation 15 - Maintenance requirements. 5.2 Amendments to SOLAS Chapter XII (Additional Safety Measures for Bulk Carriers). Contact [email protected] for the source of the revised Ch XII. In relation to the entry into force of the revised Ch XII, the following Resolutions have the same entry into force date: Resolution MSC.168(79) - Standards and Criteria for Side Structures of Bulk Carriers of Single-Side Skin Construction; and Resolution MSC.169(79) - Standards for Owners’ Inspection and Maintenance of Bulk Carrier Hatch Covers. Contact [email protected] for the source of the MSC.169(79) and MSC.168(79). Relevant circulars (effective when issued and available for download from http://www.imo.org/home.asp): Circular MSC/Circ.1135 on As-Built Construction Drawings to Be Maintained On Board the Ship and Ashore, 15 December 2004; Circular MSC/Circ.1143 on Guidelines on Early Assessment of Hull Damage and Possible Need for Abandonment of Bulk Carriers; and

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Circular MSC/Circ.1145 on Precautionary Advice to Masters When Undertaking Ballast Water Exchange Operations. 5.3 The adopted amendments to SOLAS chapters II-1, by Resolution MSC.170(79). Contact [email protected] for the source of Resolution MSC.170(79) and the amendments. The amendments were made in: • Regulation 2 - Definitions of bulk carrier; • Regulation 18 - Construction and initial tests of watertight doors, sidescuttles, etc., in passenger ships and cargo ships; and • Regulation 45 - Precautions against shock, fire and other hazards of electrical origin 5.4 Amendment to SOLAS Chapter III (Life-Saving Appliances and Arrangements) The following new paragraph 1.8 is added after the existing paragraph 1.7: “1.8 Notwithstanding the requirements of paragraph 1.1, bulk carriers as defined in regulation IX/1.6 constructed on or after 1 July 2006 shall comply with the requirements of paragraph 1.2.”. 5.5 Amendments to Chapter V (Safety of Navigation) In paragraph 2.5 of Regulation 19 (Carriage requirements for shipborne navigational systems and equipment), the existing text of subparagraph .1 is replaced by the following: “.1 a gyro compass, or other means, to determine and display their heading by shipborne non-magnetic means, being clearly readable by the helmsman at the main steering position. These means shall also transmit heading information for input to the equipment referred in paragraphs 2.3.2, 2.4 and 2.5.5;” The following new paragraph 2, regulation 20 (Voyage data recorders) is added after existing paragraph 1: “2 To assist in casualty investigations, cargo ships, when engaged on international voyages, shall be fitted with a VDR which may be a simplified voyage data recorder (S-VDR) as follows: .1 in the case of cargo ships of 20,000 gross tonnage and upwards constructed before 1 July 2002, at the first scheduled dry-docking after 1 July 2006 but not later than 1 July 2009; .2 in the case of cargo ships of 3,000 gross tonnage and upwards but less than 20,000 gross tonnage con-

INTERCARGO

Technical and Operational Update for Bulk Carriers

structed before 1 July 2002, at the first scheduled drydocking after 1 July 2007 but not later than 1 July 2010; and

were adopted by Resolution MSC.194(80). Contact [email protected] for the source of annex 1 to Resolution MSC.194(80). The amendments are in:

.3 Administrations may exempt cargo ships from the application of the requirements of subparagraphs .1 and .2 when such ships will be taken permanently out of service within two years after the implementation date specified in subparagraphs .1 and .2 above.”

Regulation 3-2: Corrosion prevention of seawater ballast tanks in oil tankers and bulk carriers (This regulation applies to oil tankers and bulk carriers constructed on or after 1 July 1998);

5.6. Unified interpretation of SOLAS Chapter XII MSC 80 agreed to the need to provide ship designers with interpretations of the revised SOLAS chapter XII, before its entry into force. At its twenty-fourth regular session of the IMO Assembly (A24), the unified interpretations of the regulations 6.5.1 & 6.5.3 were adopted. IMO circular SLS.14/Circ.250 with the unified interpretations is available for download from http://www.imo.org/home.asp. Note: The IACS Common Structural Rules will be implemented to tankers and bulk carriers contracted for construction on or after 1st April 2006. IACS believe that the objective of removing competition on scantlings for each ship type has been achieved. The IACS Council also endorsed a long-term harmonisation plan between the tanker and bulk carrier rule sets at its meeting in Dec 2005.

Regulation 3-7: The amendment includes Construction drawings maintained on board and ashore; Regulation 3-8: Towing and mooring equipment; and Regulation 23-3: Water level detectors on single hold cargo ships other than bulk carriers. 7.2 Amendments to the Guidelines on the Enhanced Programme of Inspections during Surveys of Bulk Carriers and Oil Tankers (Resolution A.744(18), as amended) by Resolution MSC.197(80). Contact [email protected] for the source of Resolution MSC.197(80). 7.3 The revised MARPOL Annex II, as adopted by Resolution MEPC.118(52), is expected to enter into force on 1 January 2007. Contact [email protected] for the source of Resolution MEPC.118(52).

22 Nov 2006: amendment of entry into force

1 Jan 2008: amendment of entry into force

6.1 Amendments to MARPOL Annex VI and the NOx Technical Code by Resolution MEPC.132(53). Contact [email protected] for the source of the Resolution MEPC.132(53).

8.1 Under the terms of the ASF Convention (International Convention on the Control of Harmful Anti-fouling Systems on Ships ), by 1 January 2008 (effective date), ships shall either:

Amendments to MARPOL Annex VI are the introduction of the Harmonized System of Survey and Certification (HSSC) and the introduction of the North Sea as a new SOx Emission Control Area (SECA), (Regulation 14(3) (a)). 6.2 Amendments to the revised Survey Guidelines under the Harmonized System of Survey and Certification (Resolution A.948(23)) for the purpose of MARPOL Annex VI by Resolution MEPC.128(53). The Resolution MEPC.128(53) was adopted on 22 July 2005. IMO invited Governments to apply the Guidelines, as soon as possible. Contact [email protected] for the source of Resolution MEPC.128(53).

From 1 January 2007: amendment of entry into force 7.1 Amendments to SOLAS chapter II-1 parts A-1 and C. The amendments to SOLAS chapter II-1 parts A-1 and C

(a) not bear such compounds on their hulls or external parts or surfaces; or (b) bear a coating that forms a barrier to such compounds leaching from the underlying noncompliant anti-fouling systems.

1 Jan 2009: amendment of entry into force 9.1 Amendments to SOLAS chapter II-1 parts A, B and B-1, II-2, VI, IX, XI-1, XI-2. The amendments to SOLAS chapter II-1 parts A, B and B-1, II-2, VI, IX, XI-1, XI-2 were adopted by Resolution MSC.194 (80). Contact [email protected] for the source of Resolution MSC.194(80). The reasons for the entry into force date: As the revised SOLAS chapter II-1 introduces a fundamental change to the way ships are designed and would have a significant effect on March 2006 Issue One ■ 3

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Technical and Operational Update for Bulk Carriers

shipbuilders and ship operators, there is a need for sufficient time before the revised chapter II-1 enters into force in order that shipbuilders and ship operators can develop and optimize new designs before such entry into force; and

10.2 circular MSC/Circ.1142 - MEPC/Circ.425 on Marking the ship’s plans, manuals and other documents with the IMO ship identification number. The circular is available for download from http:// www.imo.org/home.asp.

The time period between the adoption of amendments to SOLAS chapter II-1 and their entry into force should be sufficient for the DE SubCommittee to deal with consequential amendments to SOLAS chapter III, in particular to SOLAS regulation III/21.1.2, so that the draft amendments to SOLAS chapter II-1 under consideration at this session and proposed amendments to SOLAS chapter III, when developed by the DE Sub-Committee and adopted by MSC, could enter into force simultaneously.

10.3 Resolution MSC.200(80)- Amendments to the revised recommendation on testing of life-saving appliances. Contact [email protected] for the source of Resolution MSC.200(80).

9.2 Annex 2 to Resolution MSC.198(80) - Amendments to the Format and Guidelines for the Maintenance of the Continuous Synopsis Record (CSR). Contact [email protected] for the source of Resolution MSC.198 (80). The amendments require the use of Registered Owner ID Number and Company ID Number. 9.3 Resolution MSC.194(80) - Amendments to SOLAS Ch XI-1include a new regulation 3-1 Company and Registered Owner ID number. Contact [email protected] for the source of Resolution MSC.194(80). 9.4 Resolution MSC.195(80) - Amendments to ISM Code: Company Identification Number to be added in the DOC and SMC Certificates. Contact [email protected] for the source of Resolution MSC.195(80). 9.5 Resolution MSC.196(80)- Amendment to ISPS Code: Company identification number to be added in the Ship Security Certificates. Contact [email protected] for the source of Resolution MSC.196(80).

Voluntary requirements 10.1 Resolution MSC.160(78) on “Adoption of the IMO unique company and registered owner identification number scheme” requires voluntary implementation before the requirements are made mandatory from 1 Jan 2009. Contact [email protected] for the source of Resolution MSC.160(78). MSC 78 adopted the IMO unique company and registered owner identification number scheme for implementation on a voluntary basis. The Resolution recommends Governments concerned to voluntarily implement the scheme as far as is practicable, and to inform IMO of measures taken in this respect.

Governments are recommended to apply the amendments to the Revised recommendation on testing of life-saving appliances (Resolution MSC.81(70)), when testing life-saving appliances. IMO Circulars (available for download from http:// www.imo.org/home.asp): MSC/Circ.1140 - MEPC/Circ.424 on Transfer of ships between States. Amendments to the FAL/MEPC/MSC circular FAL/Circ.90 - MEPC Circ.368 - MSC Circ.946 on list of certificates and documents to be carried on board ships. MEPC/Circ.472 on Guidelines for Port State Control under MARPOL Annex VI (Resolution MEPC.129(53)). MEPC/Circ.469 on Revised consolidated format for reporting alleged inadequacy of port reception facilities - an effort to improve the rate of reporting of alleged reception facility inadequacies so that the problem can be tackled more effectively. MSC/Circ.1108 on Guidelines for assessing the longitudinal strength of bulk carriers during loading, unloading and ballast water exchange. MSC/Circ.1114 on Guidelines for periodic testing of immersion suit and anti-exposure suit seams and closures. MSC/Circ.1115 on Prevention of accidents in high free-fall launching of lifeboats. MSC/Circ.1117 on Guidance for checking the structure of bulk carriers. STCW.7/Circ.14 on Guidance for masters on keeping a safe anchor watch. SN/Circ.245 on Amendments to the Guidelines for the installation of a shipborne automatic identification system (AIS) (SN/Circ.227). MSC/Circ.1145 on Precautionary advice to masters when undertaking ballast water exchange operations. MSC/Circ.1159 on Guidelines on the provision of stability-related information for bulk carriers. MSC/Circ.1119 on Ship/Terminal Interface Improvement for Bulk Carriers. MSC/Circ.1135 on As-Built Construction Drawings to Be Maintained On Board the Ship and Ashore, 15 December 2004.

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INTERCARGO

Technical and Operational Update for Bulk Carriers

Air Pollution Prevention - Guide on Compliance with MARPOL Annex VI

1. Background MARPOL Annex VI was adopted in 1997 and entered into force on 19 May 2005. In the 8 years since the adoption of Annex VI, there have been significant technical advances in the control of harmful emissions from diesel engines, including marine engines. Since 2000, virtually all new ship engines have met or exceeded Annex VI requirements for nitrogen oxides (NOx). There has been an MEPC project on monitoring the worldwide average of sulphur content of residual fuel oil ever since MEPC 45 (2-6 Oct 2000). The information of the project for 2004 as provided by the Netherlands (MEPC 53/4) has the conclusion that the three year (2002-2004) rolling average can be established as 2.67%, which is identical to the previous three years average. Subsequent to the entry into force of MARPOL Annex VI regulating emissions from ships, MEPC 53 agreed to delegate to the IMO Sub-Committee on Bulk Liquid and Gases (BLG) the revision of MARPOL Annex VI by April 2006 with the aim of reducing further the limits. The preliminary indications at MEPC 53 are that all current emissions limits would be subject to revision and, in addition, it is proposed that elements like Particulate Matters (PM) be added to the convention. The revision process would also aim to bring greater clarification through amendments to the current provisions, particularly to the NOx Technical Code. 2. Areas of possible difficulties and problems 2.1) What Masters are required to do. Vessels must retain the bunker sample for minimum of 1 year. The BDN (Bunker Delivery Note) must be retained on board for 3 years. If the vessel’s flag is a signatory State of MARPOL Annex VI, the vessel must comply with Annex VI regardless of where they purchase their fuel. Ship’s Master is to comply with: I. Regulation 14(1), which states that the sulphur content of any fuel used on board shall not exceed 4.5% m/m (mass of sulphur per mass of fuel); II. Regulation 14(4), which requires ships to demon-

strate that while the ship is passing through a SOx emission control area (SECA) it is either: (4) (a) using fuel which has a sulphur content not exceeding 1.5% m/m, or (4) (b) using an approved exhaust gas cleaning device or any other technological method which ensures that the total emission of sulphur oxide from the ship does not exceed 6.0 g SOx/kW h; III. Regulation 14(6) for those ships using separate fuels to comply with Reg14(4)(a) records must be kept on the completion of any fuel change-over procedure when entering and leaving a SECA to verify compliance. The records shall include the date, time and position of the ship when the fuel change-over is complete. It shall also record the quantity of the low sulphur fuel in each tank; IV. Regulation 18(4), which states that the ship is to retain the BDN, readily available for inspection, on board the ship for a minimum of 3 years; V. Regulation 18(6), which states that the Annex VI sample is to be retained under the ship’s control until the fuel is substantially consumed, but in any case for a period of not less than 12 months from the time of delivery; and VI. Resolution MEPC.96(47), which requires that the ship’s master should develop and maintain a system to keep track of the retained samples. 2.2) Bunker delivery notes and fuel samples. MEPC 53 endorsed that “it was clear that a ship, which has on board only non compliant fuels, would be asked to obtain compliant bunker fuels before leaving port.” As raised at the last Intercargo Safety, Technical and Environmental Committee (CASTEC) meeting in June 2005 in Hong Kong and the Follow-up Action No. 12 (FUA 12) , members are concerned about what will happen if the ship could not get the required sample and relevant documentation when receiving PSC inspection at ports of the 20 or so signatory States of MARPOL Annex VI. MEPC 53 recognized that Annex VI places requirements on ship owners in respect of bunker delivery notes and representative samples of the fuel delivered. If the country of fuel oil supply is not a Party to the 1997 Protocol, then the required bunker delivery note or the representative sample may not be available. It also noted the concern about problems relating to ships that cannot obtain the appropriate documentation - the bunker delivery note and the representative sample(s) of fuel delivered, when bunkering in ports and terminals under the jurisdiction of non-

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Party States to MARPOL Annex VI. Suppliers are to comply with: I. Regulation 18(7) (b), which states that the supplier is to provide a compliant BDN and a representative sample of the fuel oil delieved. This sample is to be used solely for determination of compliance with Annex VI by port state authorities; II. Resolution MEPC.96 (47) Guidelines for the sampling of the fuel oil, which requires that the IMO sample should be taken at the receiving ship’s bunker inlet manifold according to specified procedures; and III. Regulation 18 (1) (a) & (b), which requires the fuel to be of a specified quality. Suppliers need to be registered with the appropriate Authorities and are required to provide a mandatory sample. This is to be taken by either a: I. continuous drip sampler, II. time proportional automatic sampler, or III. flow proportional automatic sampler. The sample should be taken at the receiving vessel’s manifold in accordance with resolution MEPC.96(47). It must be a minimum of 400ml. The sample will be accompanied by a Bunker Deliver Note (BDN). The supplier is required to retain a copy of BDN’s for 3 years. 2.3) PSC Guidelines under Annex VI. MEPC 53 noted that a number of bunker providers operating under the jurisdiction of a MARPOL Annex VI non-Party State are issuing a “Bunker Certificate of Compliance” to receiving ships, in order to provide them with documentation of the fuel oil on board, in case the ship should be subject to port State control in the port of call under the jurisdiction of a MARPOL Annex VI Party. MEPC 53 confirmed that according to the application of regulations 14 and 18 of MARPOL Annex VI, it is the ship which is responsible for documenting compliance. Having considered the issue, MEPC 53 agreed that a Bunker Certificate of Compliance could not replace appropriate documentation issued by a bunker provider operating under the jurisdiction of a Party to MARPOL Annex VI. It was also agreed that it was at the discretion of the port State control Authority of a MARPOL Annex VI Party whether to accept the Certificate of Compliance or not and to take appropriate action. The IMO Secretariat has received many enquiries from both receivers and suppliers of bunker fuel oil. In response to the enquiries, the Secretariat has informed them that the issue is considered as a commercial issue

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between the supplier and the receiver, and that according to MARPOL Annex VI, the ship is responsible for documentation of the fuel oil quality on board and used. MEPC 53 agreed to urge countries, which are not Parties to MARPOL Annex VI, to institute relevant measures in order that ships are provided with the necessary bunker delivery note and representative samples of the fuel oil delivered. With regard to ships flying the flags of non signatory States to MARPOL Annex VI, those ships may have obtained a certification or document of compliance by a Classification Society, MEPC 53 noted that para 3.3 of the draft PSC Guidelines for MARPOL Annex VI stipulates that “……, the PSCO may take such documentation into account in the evaluation of the ship”. Paragraphs relating to the above Bunker Delivery Note issue in the PSC Guidelines are: Chapter 2: 2.1.1.8 any notification to the ship’s flag Administration issued by the master and the officers in charge of the bunkering operation crew together with any available commercial documentation relevant to noncompliant bunker delivery. 2.1.4bis In the case where the bunker delivery note or the representative sample as required by regulation 18 of this Annex presented to the ship are not in compliance with the relevant requirements, the master or the officers in charge of the bunkering operation should have documented that through a Notification to the ship’s Flag Administration with copies to the port authority under whose jurisdiction the ship did not receive the required documentation pursuant to the bunkering operation and to the bunker deliverer. A copy should be retained onboard the ship, together with any available commercial documentation, for the subsequent scrutiny of port State control. 2.3.2.3 the sulphur content of any fuel oil being used on board exceeds 4.5% m/m. 2.4) Letter of Protest. In event that either the BDN or the statutory sample, or both, have been found to be non-compliant, a Letter of Protest (LOP) should be issued in accordance with the ship’s standing instructions. It is recommended that the ship’s flag administration is consulted as to whether they have any procedural requirements for LOP. If no standing instructions exist then it is recommended that 4 or more copies of the LOP may be issued. One to the supplier, one to the port State Authority overseeing

INTERCARGO

the registration of the suppliers, another for the ship’s record and you may consider sending a further LOP to the ship’s Flag Administration. Issuing of the LOP will demonstrate the ship’s understanding of Annex VI requirements putting the onus on the supplier in the event that a port State Authority challenges any non-compliance identified. 2.5) Options to comply with Annex VI. I. II. III. IV. V.

The ship is not intending to operate in a SECA. All fuel on board is not to exceed the global sulphur maximum of 4.5% m/m. All heavy fuel oil (HFO) carried on board is to be less than 1.5% sulphur content. Dual fuel operation