North America: Fuel change-overs, loss of propulsion risks and fuel availability


Published: 20 January 2015

Following the coming in to effect of the new ultra low sulphur fuel requirements for the North American Emission Control Area, concerns have been raised about possible loss of propulsion issues relating to fuel changeovers. Concerns are also raised about compliant fuel availability.

The development

The New Orleans sector of the USCG has published a Marine Safety Information Bulletin (reproduced alongside this advisory) which informs that a number of parties have expressed concerns about the possible risk of loss of propulsion events which may be linked to fuel change-over procedures, particularly while navigating in ports or other restricted waters.

The advice of the US Coast Guard is that vessels should seek to complete all necessary fuel change-over procedures well before they are due to enter the lower Mississippi River.

It is reported, however, that due to some vessels lacking sufficient quantities of MARPOL compliant fuel on arrival or not having any available at all, they had to source the fuel post arrival and then engage in a fuel change-over.

Availability of MARPOL compliant fuel

There is anecdotal evidence of some vessels not having been able to obtain compliant fuel, i.e.: fuel of no more than 0.10 % sulphur mass, or insufficient quantities of such fuel being available.

Members are reminded that should they find themselves in such a situation then they will need to ensure that a FONAR (Fuel Oil Non Availability Report) is filed in due time and with full disclosure. It is worth remembering that US FONAR reports come with a penal notice against false reporting that will be taken very seriously. Further information on the issue of penalties can be found in "North American ECA zones and compliance".

For members' reference, attached are the EPA's interim FONAR Guidance and the FOND instructions for the filing of a report.

Important request: Should members encounter difficulty in obtaining sufficient quantities of MARPOL compliant fuel, they are asked to advise the same to the Association, in addition to ensuring they are filing the necessary report with the appropriate authorities.

Loss prevention advice

The Association has previously advised in detail about the possible risks involved with fuel change-overs which may lead to a loss of power / propulsion of the vessel, see "Thermal shock and fuel change-over procedures".

In addition the US Coast Guard New Orleans sector has stated that if a vessel needs to conduct a fuel change-over from normal to ultra low sulphur (ECA compliant) fuel after entering the traffic service of the Lower Mississippi Area (as defined in 33 CFR 161.65(a) then it has the following three options:

  1. utilise, for the duration of their operation while in the Vessel Traffic Service Lower Mississippi River Area, the fuel being used upon entering the VTS Area;
  2. employ tugs of adequate horsepower to the satisfaction of the attending pilot, to assist in case of any problems, if the NA-ECA fuel change-over takes place while underway;
  3. conduct and fully complete any required NA-ECA fuel changeover operations dockside or at anchorage.

Important notice: The US Coast Guard cautions that should a vessel choose to enter and operate on the Vessel Traffic Service Lower Mississippi River Area using non-compliant fuel, the COTP will notify the EPA and take "appropriate enforcement action". In other words, be careful before you choose option "1".

Assistance in the US

Members trading to and from the US should note that Skuld has a fully staffed claims service office in New York, available to assist 24 hours a day. If a fuel related issues arises, members are asked to make urgent contact so that the situation can be evaluated and appropriate assistance rendered.

Members should also contact their regular Skuld business unit for vessel specific enquiries.

The Association is grateful to Messrs. Murphy, Rogers, Sloss & Gambel for assisting with this update.