MARPOL Annex VI Fuel Changeover and Sulphur Compliance Log

This template records the fuel changeover event, the vessel’s position at the time of changeover, and the bunker delivery note cross-check required for sulphur compliance. It is meant to create a clear trail showing when compliant fuel was in use before entering an Emission Control Area. It also helps the crew note any exceptions, delays, or verification steps tied to the changeover.

Use it before the vessel enters an ECA or any other area where a lower sulphur limit applies. It is also useful during voyage planning when the master or chief engineer wants a documented changeover schedule. If the vessel is not entering a regulated area, the log may not be needed for that leg.

The chief engineer or another designated DRI should usually own the log, with the bridge team supporting position verification and timing. On some vessels, the master may review or co-sign the record as part of the voyage compliance process. The important point is that one person is clearly accountable for completion and follow-up.

Complete it for each fuel changeover tied to ECA entry, and repeat it whenever the vessel switches back to compliant fuel for a later regulated transit. It is not a daily housekeeping log unless the voyage pattern requires frequent zone crossings. The recurrence should match the vessel’s route and operating profile.

No. The bunker delivery note remains a separate document, and this template only captures the operational cross-check against it. The log helps confirm that the fuel on board and the changeover timing align with the documentation, but it does not replace supplier records or statutory retention requirements.

Common mistakes include recording the wrong position, logging the changeover too late, and failing to verify that the fuel in use matches the sulphur limit for the area. Another frequent issue is treating the log as a formality instead of a verification step. This template makes each item independently checkable so gaps are easier to spot.

Yes. You can add vessel-specific fields such as tank identifiers, engine room handover notes, or internal approval steps. You can also adapt the wording to match your company’s SMS, while keeping the core compliance checks intact. The key is to preserve the changeover time, position, and BDN verification fields.

It can sit alongside voyage planning, engine room handover, and compliance reporting workflows. Many operators link it to a broader inspection or runbook process so the DRI can complete the log before arrival in the regulated zone. It also works well as a review item during internal audits or port state inspections.