USA - California Ocean Going Vessel Fuel Rule - Reminder
Following the introduction of the amendments to MARPOL Annex VI, mandating the use of fuel oil containing no more than 0.5% sulphur or compliance by means of approved equivalent measures since the 1st January 2020, the California Air Resources Board (CARB) has published Marine Notice 2020-01 as a reminder of the requirements of the Ocean-Going Vessel (OGV) Fuel Regulations, which are separate and differ from both MARPOL and the North American Emission Control Area requirements.
The Club continues to see issues where entered vessels have been penalised for non-compliance with the OGV Fuel Regulations, which requires the use of distillate fuels, either Marine Gas Oil (MGO) or Marine Diesel Oil (MDO) with a maximum sulphur content of 0.1% in main engines, generators and boilers in all waters within 24’ of the land.
Although at first glance the North American Emission Control Area (ECA) and CARB OGV requirements appear similar with a maximum fuel oil sulphur content of 0.1%, the CARB OGV Fuel Regulations do not permit the use of residual fuels such as Ultra Low Sulphur Fuel Oil (ULSFO), nor the use of alternative means of compliance, such as the use of scrubbers. Within Californian waters compliance with the local legislation can only be achieved by use of MGO or MDO with a 0.1% sulphur content.
Members requiring any further advice or assistance should contact the Loss Prevention department.