IMO 2020 tools & guidelines
As the clock ticks down to 1 January 2020 and the most significant regulatory change most of us have ever experienced, IBIA presents an overview of some of the tools and guidelines that are available to help guide us through the implementation of the 0.50% sulphur limit under MARPOL Annex VI.
TECHNICAL SUPPORT FOR MANAGING ANTICIPATED FUEL CHALLENGES:
CIMAC Guideline: Marine fuel handling in connection to stability and compatibility. It is available on the CIMAC website via this link.
ISO/PAS 23263:2019 Petroleum products — Fuels (class F) — Considerations for fuel suppliers and users regarding marine fuel quality in view of the implementation of maximum 0,50 % sulphur in 2020 is available to purchase from the ISO website on this link: https://www.iso.org/standard/75113.html
Joint Industry Guidance on the supply and use of 0.50% – sulphur marine fuel. It provides stakeholders across the marine fuels and shipping industries, from fuel blenders and suppliers to end users, with great tools to manage IMO 2020. It is available free of charge on IBIA’s website using this link.
IMO 2020 GUIDELINES
The following are some of the IMO guidelines issued to help industry and authorities with consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.
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Ship Implementation Plan – (MEPC.1/Circ. 878).
Issued in November 2018 to assist ships in preparatory work including tank cleaning and planning for compliance, this should be completed by now, but may still be of use as reminders.
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2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI – MEPC.320(74)This is the most comprehensive set of guidelines and are aimed at assisting both industry and authorities. They include:- Definitions – descriptions of types of fuel oil for use by ships.
– Impact on fuel and machinery systems – addressing specific concerns around the use of distillate fuels, distillate fuels with FAME, and residual fuel oil blends. It also describes key technical considerations for ship tank configurations and fuel systems, and a note on the use of the ISO 8217:2017 marine fuel specifications.
– Verification issues and control mechanisms and actions – relating to what actions can be taken by MARPOL Annex VI signatory states to check ships and suppliers for compliance, enforcement actions, and sharing information.
– Fuel oil non-availability – this part includes guidance on information sharing, consistent evidence and investigations of FONARs. IMO has also developed a standardised Fuel Oil Non-Availability Report (FONAR) set out in appendix 1 of Resolution MEPC.320(74)
– Possible safety implications relating to fuel oils meeting the 0.50% sulphur limit – this section makes references the SIP which already has information on the subject and to general industry guidance. There is also a “Technical review of identified possible potential safety implications associated with the use of 2020 compliant fuels” set out in appendix 2.
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2019 Guidelines for Port State Control under the revised MARPOL Annex VI (amending 2009 version) – MEPC.321(74)
This is aimed at PSC officers to enhance uniform enforcement. It helps understand what to expect during a PSC inspection.
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Guidance for port State control on contingency measures for addressing non-compliant fuel oil – MEPC.1/Circ.881
Describes a hierarchy of ways to deal with any non-compliant fuel oil remaining on a ship in order to ensure the ship will become compliant as soon as possible.
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MEPC circular on Early application of the approved amendments to the verification procedures for MARPOL Annex VI fuel oil samples – MEPC.1/Circ.882
Calls for member states to apply these amendments prior to entry into force, as these amendments will not enter into force until the second force of 2021.
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MEPC circular on Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the EGCS fails to meet the provision of the Guidelines – MEPC.1/Circ.883
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IMO BEST PRACTICE GUIDANCE
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Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships (MEPC.1/Circ.875)
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Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships (MEPC.1/Circ.875/Add.1)
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Guidance for best practice for Member State/coastal State (MEPC.1/Circ.884)
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Delivery of compliant fuel oil by suppliers (MSC‑MEPC.5/Circ.15)
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Interim recommendations to enhance the safety of ships relating to the use of oil fuel (MSC.465(101))
The IMO has advised that Member State and industry queries and updates and experience with implementation can be sent to the IMO Secretariat, at the dedicated email address: imo2020@imo.org
Unni Einemo
unni@ibia.net