With no experience building phase, here's what IMO 2020 actually says

IMO's MEPC has rejected calls for an experience building phase following introduction on ban of high sulfur fuel IMO's MEPC has rejected calls for an experience building phase following introduction on ban of high sulfur fuel IMO

OCTOBER 25, 2018 — IMO's Marine Environmental Protection Committee this week rejected calls from leading flag states, supported by the U.S., for an "experience building phase" following the January 1, 2020 introduction of the 0.5% limit on the sulfur content of marine fuel. 

And a ban on the carriage of higher sulfur fuel by ships not equipped with scrubbers is in the works, though that would likely not come into effect until March 1, 2020.

Most shipowners have been steeling themselves for this. Containership operators have been devising formulae for passing the added costs of compliant fuels on to their customers. Scrubber sales have been going through the roof. And the adoption of LNG as a marine fuel is accelerating.

Still, it is useful to remind ourselves of what the IMO 2020 regulation actually says and
BIMCO released the following quick guide earlier this week.

As of 1 January 2020, all ships are required to burn fuel with a sulfur content of no more than 0.5% (Regulation 14.1.3, MARPOL Annex VI) unless fitted with an exhaust gas emissions cleaner (scrubber) capable of reducing sulfur emissions to 0.5% or less (Regulation 4, MARPOL Annex VI). Regulation 4 also allows for the use of alternative fuels. This means that before midnight on 31 December 2019, ships must take on board enough 0.5% fuel to be able to reach their next bunkering port after the new regulation comes into force.

The carriage ban

Apart from ships that have scrubbers, all other ships that have "residual" fuel with a sulfur content higher than 0.5% on board will have to remove it. A total ban on the carriage of residual fuel (excluding ships operating scrubbers) will come in to force during the first half of 2020 – most likely on 1 March. After this date port state control will check ships' bunker tanks for non-compliant fuel.

The scrubbers

Scrubbers are permitted by Regulation 4 of MARPOL Annex VI, but no technical requirements are given. Three main designs are available: open, closed and hybrid. Open loop scrubbers use and discharge seawater as part of the scrubber process and their use may be restricted in some waters. This means that a ship will need to carry a stock of compliant 0.5% fuel when the scrubber cannot be used.

The enforcement

The 2020 global cap will apply to all ships flying the flag of a state that has ratified MARPOL Annex VI and/or calling at a port or passing through the waters of a state that has ratified the Convention. In real terms this means that the sulfur cap will apply to 96% of the world's fleet. How the cap will be enforced will vary from jurisdiction to jurisdiction and it will be left to each port state to determine the level of fines imposed and if ships will be detained. Ships should monitor and maintain a log of exhaust emissions. A failure to properly maintain the log or make false entries is likely to be considered a non-compliance by port state control and other authorities, even if exhaust emission levels are within limits. After the ban on ships carrying fuel with a sulfur content greater than 0.5% comes into force in 2020, port state control is likely to survey bunker tanks to check compliance.

What to keep in mind

Developing a ship-specific implementation plan is necessary to prepare for 1 January 2020. Such a plan should cover issues such as:

  • Having a minimum quantity of 0.5% fuel on board by the end of December 2019
  • Fuel management on board the ship – co-mingling, compatibility and separation
  • Availability of compliant fuel
  • Tank cleaning after switching to new fuels
  • De-bunkering of non-compliant and residual fuel before the carriage ban
  • Monitoring and logging emissions
  • Charter party issues



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