ENGINE SPARE PARTS AND THE IMO´S GHS STRATEGY

Posted by Bruno Monteiro
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AND THE IMO’S GHG STRATEGY

The identification and availability of appropriate spares is not only about safeguarding the vessel and personnel against maritime risks, but also about safeguarding the environment. Namely, controlling GHG emissions. An optimal combustion process and thus reduced emissions, is of course the holy grail and the components that play the most important roles are the fuel being burned and the engine which burns it. When the spares are used, the vessel must still meet
the IMO emission limits and as the regulations become increasingly complex and stringent, so too does the owner’s burden increase.

Thus, a rather large aspect of shipping is now 
dealing with environmental requirements and in this regard the IMO has made its vision clear. In 2018 it adopted an ambitious resolution detailing its strategy
on reducing GHG emissions from ships. It aims for a 40% reduction in CO2 emissions by 2030 and will pursue a 70% reduction by 2050 (compared to 2008 levels). Additionally, it is aiming for a 50% reduction in total GHG emissions by 2050 with a vision to phase them out completely.

It is MARPOL’s (International Convention for the Prevention of Pollution from Ships) Annex VI
that deals with air pollutants including sulphur oxides and nitrous oxides. Regulation 13 provides NOx limits through a tiered system dependent on ship construction date and operation in an Emissions Controlled Area (ECA). This is supplemented by the NOx Technical Code 2008 determining the emission value for diesel engines. Regulation 14 then deals with SOx emissions, applying to all fuel oil but also combustion equipment, therefore including main and auxiliary engines. The limits here again depend on whether a vessel is operating inside or outside an ECA and have been progressively reduced.

When considering spares, a natural starting place would be the ship’s Safety Management System (SMS)

DR ANNA-MARI ANTONIOU
Lecturer, Maritime and Commercial Law, University of Essex

Engine Spare Parts

One would assume that there is only one important aspect when dealing with spare parts for a vessel and that it is a practical matter, making sure that critical spares are available instantly and non-critical can be sourced easily. However, it is increasingly becoming a legal matter, with a secondary aspect that is now also intrinsic to the issue. That is, the environmental aspect. As we shall see, this is particularly important when it comes to engine spare parts

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which should have been developed with the IMO’s
ISM Code in mind, stating the minimum spares
and tools required for safe operation, considering
both manufacturer recommendations for the engine
and those given by the Classification Society. This practical aspect meets the environmental when ship operators need to ensure that any spares used in
the engine must result in continued compliance with the IMO limits. In the UK, these IMO requirements have been incorporated into domestic law through the Merchant Shipping Regulations 2008 and the accompanying Merchant Shipping Notices. A Technical File

is required for every marine diesel engine identifying
the engine’s components, settings or operating valves which influence exhaust emissions. This file must contain “specifications of those spare parts/components which, when used in the engine…will result in continued compliance of the engine with the NOx emission limits”. It is thus impossible to separate the issue of spare parts from the environmental issue.

How then do we balance these two aspects? It seems logical to start with a list of absolute essentials for the engine and as this is a practical issue, there is no better person to ask than someone who has experience of the day-to-day operations. We talked to Leonardos P. Andrelos, Superintendent Engineer at Victoria Steamship Co. who has 40 years experience in the industry. If we had to narrow down to just the top three essential parts, depending on the engine of course, Mr Andrelos included one or two extra pistons, one or two extra liners and fuel oil system spares, such as fuel pumps and fuel valves. When asked which spares are in fact those most frequently used, Mr Andrelos noted the fuel oil system parts, particularly so because of the change-over of fuels.

To combine this with the environmental aspect, the Technical File and SMS must thus include spares for the

articularly when one considers the plethora of agencies imposing them such as the IMO and ISM and ISPS Codes, the Classification Society, Port State Control, etc. There is no doubt that developing comprehensive regulations serve both the maritime industry and the public at large but one must remember that piling more and more paperwork on the ship operators may take away time from actual ship operations and create an overwhelming workload. A balance is required and a broad perspective, considering all stakeholders.

Perhaps the way to look at this is a shift in thinking entirely – rather than ever increasing demands on existing fuel consumption and engines, investment and research into inherently low emission alternatives instead. For example, there are several companies developing and enhancing wind technologies such as rotor
sails, harnessing the power of the wind to
propel ships, for use in merchant vessels. Some have already been installed on bulk carriers. Installation of technologies such as this, across the global fleet, can lead to sustainable shipping and companies who have used the technologies suggest they are also easy for the crew to operate. For us all to shift at once is impossible, so this must be done in stages. But perhaps
this is the point, at this stage, we decrease emissions by making slight alterations to existing regulations and allowing crew time to adjust, without an unmanageable burden of paperwork. In the meantime, planning for the stage where the fleet moves to alternative sources and investing and researching these areas. There must be a balance for all aspects to be protected and prosper and ever-increasing demands may not be the way to go.

As things stand, on board engineers need to ensure they have access to correct spares, that is, the parts required, a suitable number of each and of the right quality, to maintain the vessel’s GHG emission levels. Critical spares

must be accessible immediately and non-critical can be sourced. The supply chain for spares is also changing, however. Additive manufacturing, more commonly known as 3D printing is a

game changer. Currently, to meet demand, the spare parts industry must make, store and then ship required spares to customers. This is time consuming and costly, particularly if the part needed is quite obscure. 3D printing, building

a product layer by layer, allows companies to supply spares on an on-demand basis and to
do so locally. Spares are made to order; storage costs are therefore low but so are transportation costs as production is located close to the customer. The supply chain is simplified. Although the technology is still in its infancy, it
is growing and becoming more sophisticated day by day. In fact, a PWC survey suggests that 85% of spare part suppliers will incorporate 3D printing into their businesses in the next few years. This is not some theoretical advancement either. GE Aviation, the world’s largest jet engine manufacturer, has been using 3D printing since 2015 to make its fuel injection nozzle which used to be assembled from 18 different parts. Now,

it is one piece, 25% lighter and five times more durable. The shipping industry must also take note, perhaps we are on the verge of another shift and companies that invest in this area, may gain a sustainable competitive advantage.

It seems that the maritime industry needs to keep looking forward and at least some traditional aspects may be changing quite dramatically in the next decade, whether it is use of biofuels, rotor sails or 3D printing for parts. These
changes will be good for the industry in the long term, and good for the public too, with GHG emission reduction as a result. We should not forget however that, according to the IMO itself, statistically, shipping is the least environmentally damaging mode of transport, considering its productive value and that it transports about
90% of global trade. Not too bad a place to start.

The supply chain for spares is
also changing, however. Additive manufacturing, more commonly known as 3D printing is a game changer. Although the technology is still in its infancy, it is growing and becoming more sophisticated day by day. In fact,

a PWC survey suggests that 85% of spare part suppliers will incorporate 3D printing into their businesses in the next few years

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