Guidance on ship implementation planning approved by the IMO last week will assist ship owners in preparing for the use low sulphur fuels to comply with the 2020 sulphur limit. IBIA is pleased to have contributed to the practical advice contained in two appendices to the ship implementation plan (SIP) in the MEPC circular, regarding tank cleaning and impact on machinery systems.
The SIP, which is not mandatory, can be filled in by ship owners/operators to help them plan and demonstrate the steps taken by ships to prepare for compliance with the 0.50% sulphur limit on 1 January 2020. Elements covered include a risk assessment and mitigation plan regarding the impact of new fuels; fuel oil system modifications and tank cleaning (if needed); fuel oil capacity and segregation capability; and bunkering plans in the lead-up to the compliance date.
In addition to the SIP, the appendix addressing the impact on machinery systems contains advice on how to prepare for use of distillates, fuel oil blends, or both. This was developed at the intersessional working group (ISWG) on consistent implementation in July this year based on a document submitted by India. However, elements relating to tank heating arrangements were left out. IBIA felt these should be included as this information will help all the concerned stakeholders in retaining ships’ operational flexibility. Subsequently, IBIA worked with India and IPTA on a proposal to MEPC 73 to enhance this appendix.
Following India’s introduction of the proposal, IBIA added: “We would like to reiterate the importance of ensuring that ship owners have all relevant information to hand when planning and preparing ships for compliance with the 0.50% sulphur limit. Ships that are equipped to deal with a multitude of fuel types, by having multiple segregated tanks and the ability to heat or not heat fuels in each tank, will be in the best position to deal with the market reality in 2020. It is therefore prudent to inform owners that even distillates may need heating during operations in cold climates and hence tank heating capacity should be retained.”
The proposal in joint submission was supported in plenary at MEPC 73 and the changes to the appendix accepted.
A second appendix to the SIP relates to tank cleaning, and is a shortened version of a document submitted by IBIA to the ISWG in July describing options available for cleaning fuel oil tanks and systems.
IBIA’s document highlighted the safety and compliance risks associated with the option of simply “flushing through” fuel systems for ships that have used high viscosity high sulphur fuel oil (HSFO), as remaining HSFO residues sticking to various surfaces would dissolve/dislodge and could cause problems with excessive sludge and also contaminate compliant fuel making it above the sulphur limit.
However, some shipping organisations felt that the appendix needed to mention that options for preparing HSFO tanks for compliance include flushing through fuel systems (i.e. not cleaning tanks first) until they are sufficiently clean. Other options, described in detail in IBIA’s submission to the ISWG in July, include manual cleaning of tanks during dry docking, manual cleaning during service, and cleaning tanks in service with specialised additives.
The 73rd session of the IMO’s Marine Environment Protection Committee approved a draft MEPC circular which will contain the IMO’s Guidance on ship implementation planning, including the SIP and the two appendices.
Report by Unni Einemo: firstname.lastname@example.org