Sulphur Limits 
      For Ships in EU Ports
 
                
From 1st January 2010 the
    
    European Parliament Directive2005/33/EC came into force. As 
    well as reinforcing the limits of sulphur for vessels operating 
    in SECAs, and limiting the sulphur content of fuels used ashore 
    in the EU, it also introduced legislation governing the maximum 
    sulphur content of fuels used by inland waterway vessels and 
    ships at berth in Ports which are part of the European 
    Community. The limit placed is 0.1% Sulphur, which is the 
    maximum sulphur content of Gas Oil
The rules state that the 
    limit applies for ships at berth in EU ports allowing sufficient 
    time for the crew to complete any necessary fuel change over 
    operation as soon as possible after arrival at the berth and as 
    late as possible before departure. The change over must be 
    recorded in  ships log books.
It does not apply to 
    ships in port for less than 2 hours, to vessels who "cold iron" 
    i.e. change over to shore power in port. Certain vessels 
    operating in the territory of the Hellenic Republic are exempt 
    until 1st January 2012.
Some confusion has arisen 
    over the interpretation of the Directive. It does not mean that 
    the main engine has to be changed over to gas oil, but the 
    generator engines must be changed over "as soon as possible".
    
    MIN 376 issued by the MCA as an interim measure
gives guidance on this 
    point for ships at UK ports.  Because the directive states 
    that ships at berth for up to two hours are exempt it can be 
    inferred that a reasonable time for change over can be 
    considered as 1hour after arrival and 1hour before the ship 
    sails.
The MIN also gives 
    guidance on the definition of "at berth", and states it applies 
    to ships at anchor within port limits. Outside port limits, then 
    Annex VI of MARPOL applies.
 Because the limit 
    will also apply to boiler fuel used whist alongside, Companies 
    have applied for exemptions until their boiler burners can be 
    adapted to burn gas oil. This affects not only burner design but 
    also purge times for the boiler.
Vessels must arrive at 
    the port with supplies of the 0.1% sulphur fuel on board. They 
    cannot arrive and then take on the fuel.
some companies have 
    misinterpreted the directive and have issued instructions to 
    change over to 0.1% sulphur fuel on entry to a SECA.
It does not apply to 
    ports within a SECA but outside the EU (for example ST 
    Petersburg) although individual countries outside the EU may 
    have their own regulations. It also applies to ports within the 
    EU but outside a SECA  (for example Lisbon).
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