Compliance with the Provision necessitates assessments on safety and operational impacts for using low sulphur fuel oils on ships. Ships’ installations have generally been designed and manufactured to be used with residual fuels (HFO). Currently ships can only comply with these rules by using Marine Gas Oil (MGO) defined as DMA grade in Table 1 of ISO 8217:2005 (standard for marine fuels), which has a low (0.1%) sulphur content (“LSMGO”).
The differences between the composition and physical criteria of LSMGO and HFO make significant differences with regard to the safe operation and specific operational instructions for the ship’s crew. Therefore, operators will need to undertake a risk assessment process and, based on the result, consider the need for modification to equipment as well as updating instructions and training for the crew.
INTERTANKO has produced this Guide, supported by OCIMF to provide a simple check list of items which should be part of a Risk Assessment and a Hazard Identification (HAZID) assessment, for boiler systems in oil tankers covering the switching to and long term operations on LSMGO. It is also recommended that this assessment is conducted in cooperation with the equipment/installations manufacturers or experienced entity and the classification society of each system type.
Classification societies should be consulted to determine what survey and approval are required for modifications. This may include requirements for documentation to be submitted for approval, certification of components and materials, survey and testing onboard.
Ship owners should document that they have initiated the upgrading process, that necessary modifications have been planned for and are in progress and that its completion is foreseeable and dependent on supply of solutions, parts and class approvals, as appropriate.
BACKGROUND FOR ASSESSMENTS – USE OF DIFFERENT FUEL TYPES
Author INTERTANKO and OCIMF Guidelines December 2009