Measures to improve control on fuel quality provided by bunker suppliers have once again been discussed at the IMO. This time, it resulted in some instructions for member states on what can be done as part of IMO guidelines to encourage consistent implementation of the 0.50% sulphur limit, as well as a draft joint MSC-MEPC circular expected to be approved by both committees at their next respective meetings.
The idea up for discussion at the 6th meeting of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 6) last month is not new at the IMO, but was this time put into the context of guidelines for 2020. The proposal was to carry out tests on an ad-hoc basis on fuel prior to delivery to ships to prevent delivery of fuels that do not comply with MARPOL regulations – both with regards to sulphur and Regulation 18.3 pertaining to fuel safety.
During discussions at PPR 6, there was support from various parties that a lot more should be done, but also warnings that a scheme calling for systematic pre-testing would create a significant administrative burden for the designated competent authorities. Many parties stressed that the frequency of such pre-delivery testing should be left up to each administration as they see fit.
IBIA pointed out to PPR 6 that fuels supplied to ships are already tested in the supply chain, which is why most fuels supplied are in fact compliant. Nevertheless, doing spot checks when there is a cause for concern could be way forward.
The question of how to address this was further discussed in the Working Group on Air Pollution during PPR 6, where text was developed for the guidelines on consistent implementation calling for designated authorities to take samples from bunker barges or shore bunker terminals as deemed necessary, but avoiding as far as possible causing operational delays for ships due to sample analysis. It also contains instructions to take corrective measures against non-compliant suppliers and share the information with the IMO.
These guidelines are expected to be approved at the Marine Environment Protection Committee in May (MEPC 74).
PPR 6 also developed a joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 in May and at the Maritime Safety Committee (MSC 101) in June. The draft circular is aimed at Members States to take appropriate action against suppliers under their jurisdiction to ensure they deliver compliant fuel oil. They are also told to urge fuel oil suppliers to take into account, as relevant Guidance developed by the IMO on best practice for fuel oil suppliers and fuel oil purchasers/users for assuring the quality of fuel oil delivered to and used ships.
Concrete proposals regarding a bunker supplier licencing scheme have also been invited to MEPC 74.
IBIA is in principle supportive of licensing schemes as it helps promote a level playing field for suppliers that adhere to best practices. However, if a supplier licencing scheme was to be made mandatory, it would need to be limited in scope to issues pertaining to IMO regulations in order not to go beyond the scope of member states’ obligations. This may include measures to ensure suppliers to adhere to MARPOL Annex VI requirements regarding fuel quality (Regulation 14 and 18.3) and SOLAS, and that they provide the correct associated documentation and representative samples as required by IMO regulations.