Concerns about the quality and regulatory compliance of fuel oil blends to meet the 0.50% sulphur limit are taken seriously at the International Maritime Organization, which has now issued a formal request to the International Organization for Standardization to consider the framework of ISO 8217 with a view to keeping consistency between the ISO marine fuel standard and the upcoming 0.50% sulphur limit for marine fuels.
That decision was taken at the 71st session of the Marine Environment Protection Committee last week, as part of the work to ensure consistent implementation of the 2020 sulphur regime, which will bring the limit for marine fuels used outside emission control areas (ECAs) down from the current 3.50% to 0.50% sulphur (unless using abatement technology to achieve an equivalent reduction in sulphur oxide emissions).
The scope of that work also includes several references to considering the impact on fuel and machinery systems, verification of sulphur limits, and at the behest of the IMO’s Maritime Safety Committee, an explicit reference to look at any safety issues relating to blending of fuels to meet the 0.50% sulphur limit.
Last week’s MEPC 71 meeting also supported a proposal submitted by Belgium and other European Union countries to develop guidance to address the quality of 0.50% sulphur fuel blends. The document, which painted a very positive picture of the smooth introduction of the 0.10% ECA sulphur limit in 2015, including experience with low sulphur fuel blends, acknowledged that the scale of the 2020 shift to 0.50% is much larger.
“The diverse range of 0.50% m/m fuel formulations expected will further elevate the importance of assuring sulphur compliance of the supplied fuels. The co-sponsors expect these fuels to be blended close to or on the 0.50% m/m limit, driven by the economic considerations of blending. Ship operators should request additional assurances that fuels supplied are consistently compliant,” the proposal said.
While making references to anticipated fuel blend quality issues, saying operators must be prepared to deal with more complex on-board fuel handling, the paper also said “there will be a greater expectation on suppliers having in place a robust and transparent supply chain assurance system, which adequately addresses all those factors that could affect the quality and sulphur content of the delivered fuel.”
Commenting on the actual proposal in the paper, IBIA said: “We think this is a constructive proposal and we support the development of awareness documents and technical guidance to help all stakeholders understand the various aspects related to the implementation of the 0.50% sulphur limit regarding fuel quality and sulphur content. These will help all stakeholders with a practical and pragmatic approach to dealing with anticipated issues.“
MEPC 71 agreed to forward the submission from Belgium & al to the next meeting of Sub-Committee on Pollution Prevention and Response (PPR 5) for consideration as part of the work to ensure consistent implementation of the 2020 sulphur regime. It also agreed that PPR 5 should take into account the Committee’s work on the development of best practice for fuel oil purchasers/users and Member States/coastal States.
With regard to those, the co-coordinator of the Correspondence Group (CG) on fuel oil quality, which IBIA participates in, presented the draft guidance best practice for fuel oil purchasers/users to MEPC 71. Although further work was done on the draft last week, the resulting document still needs refinement and MEPC 71 decided to invite proposals to MEPC 72 to rework the best practice document with a view to agreeing on a final version at that session.
As for draft best practice for Member State/coastal State, the draft presented to MEPC 71 was not sufficiently developed and work will continue in the CG on fuel oil quality. It was noted that the work on the development of this draft best practice would overlap with the work on consistent implementation of the 0.50% sulphur limit and, therefore, the further work on the best practice should be coordinated with these efforts. The aim is to have the best practice for Member State/coastal State in place before the 0.50% sulphur limit takes effect in 2020, so the CG has been instructed to take into account discussion at PPR 5 and submit a report to MEPC 73.
MEPC 72 and MEPC 73 have been tentatively scheduled to take place from 9 to 13 April 2018 and from 22 to 26 October 2018, respectively.
MEPC 71 also reiterated its request to the fuel oil supply industry to develop draft best practice for fuel oil providers and submit pertinent proposals to MEPC 72. The reason for this is that at MEPC 69 decided to drop the work within the IMO itself to develop best practice for fuel oil providers and instead encourage the fuel oil supply industry to develop it and present it to MEPC at a future session.
IBIA would encourage members that want to contribute to developing such best practice to contact our IMO representative; Unni Einemo on this address: firstname.lastname@example.org