Shipowners, ship operators, bunker suppliers and other interested groups are encouraged to make use of guidelines developed by the IMO relating to the 0.50% sulphur limit taking effect on 1 January 2020. These comprehensive guidelines include a template for a “Fuel Oil Non-Availability Report (FONAR)” and an appendix on the potential safety implications of bunker fuels.
The guidance, finalised and adopted at the 74th session of the IMO’s Marine Environment Protection Committee (MEPC 74) in May 2019, follows guidance on the development of a ship implementation plan (SIP) which was adopted at MEPC 73 in October last year (MEPC.1/Circ. 878). The SIP is not mandatory, but 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, and may be taken into account by port State control officers when inspecting ships for compliance. IBIA contributed to the practical advice contained in two appendices to the ship implementation plan regarding tank cleaning and impact on machinery systems.
The “2019 Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI” contain the following parts:
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. IBIA specifically contributed to this section regarding fuel oil sample analysis to ensure sulphur verification is performed in a consistent way by qualified laboratories, and that 95% confidence is applied when verifying the sulphur content of in-use and onboard samples. There are more detailed instructions on checking ships for compliance in the “2019 Guidelines for port State control under the revised MARPOL Annex VI” (updating the 2009 version) adopted at MEPC 74.
Fuel oil non-availability – this part includes guidance on information sharing, consistent evidence and investigations of FONARs, and there is a FONAR template set out in Appendix 1.
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. The information in the appendix is no different from potential safety implications of the bunker fuels used today.
The complete “2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI” adopted by resolution MEPC.320(74) are available here.