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 1. What is the enforcement orcement date for this regulation?
A. From 1 January 2012, the MARPOL Annex VI global fuel sulfur limit for fuel oil will be reduced from 4.50% to 3.50%.
2. Who is responsible for the 3.50% limit? Is the onus on the supplier or the fuel user?
A. All bunker suppliers inclusive of those supplying fuel oils outside of ECAs will have to comply with the new limit.
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"I told you so" is such a nice feeling when almost everyone takes the opposing point of view and subsequent events prove you right. Here is the what happened recently.
A shipping company ordered bunker fuel. The test lab reported presence of styrene, alpha methyl styrene and DCPD at very high levels. This lab recommended that the fuel should not be used. The supplier disagreed and the buyer and the supplier agreed to subject this fuel to analysis at another well known lab for final resolution which should be accepted by both parties. This second lab also came up with very high values for styrene, DCPD, dihydro?DCPD and very high Indene as well. It was obvious that these were residues from Ethylene cracker from a petrochemical plant.
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 The new revision of MARPOL Annex VI includes a clause to prevent ships from being penalised for fuel quality non-compliance outside their control in
connection with Regulation 18.
There should be no penalty to ships that are unable to obtain the fuel necessary to comply with a given requirement under Regulation 14 (LSFO).
Ships must provide documentation proving that it could not get hold of compliant fuel, prior to entering an ECA, despite best efforts.
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 You have received two technical updates in the recent past, one about fuels containing several contaminants causing machinery damage to three vessels (2011/2/3 ) and the second technical update(2011/2/4) about a fuel supplied in Sevilla, Spain containing unacceptable high levels of contaminants. The question on your minds is likely to be "What protection do I have against supply of problem fuels?”
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 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.
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