The IMO has agreed to start work to develop a ban on the use and carriage of heavy fuel oil (HFO) for combustion purposes by ships in Arctic waters, but first it needs to define what is meant by ‘HFO’ as it isn’t clear what type of fuel the ban might apply to. Fuel blends complying with the upcoming 0.50% sulphur limit may contain both distillate and HFO blend components, so it will be critical to have a clear definition.
The decision was made at the 72nd session of the IMO’s Marine Environment Protection Committee (MEPC 72), following majority support for a ban under the agenda item on “Development of measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters” which was added to the organisation’s work programme at MEPC 71.
A group of countries put forward a proposal to MEPC 72 to ban HFO use and carriage for use as fuel by all ships to which MARPOL applies when operating in Arctic waters no later than 2021, with a five-year delay in implementation for ships that have fuel tank protections in place. The ban would not apply to HFO carried as cargo.
Such a ban was resisted by some countries which were ready to identify measures to reduce and mitigate the risk HFO fuel spills, but not a carriage ban. There was also discussion on the potential impact of such a ban on maritime trade, in particular on Arctic communities and economies. MEPC 72 agreed that this should be assessed before adopting a future ban.
MEPC 72 agreed on the scope of work for the Sub-committee on Pollution Prevention and Response (PPR), which meets for 6th session in February 2019. PPR 6 has been tasked to develop a definition of HFO; prepare a set of guidelines on mitigation measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters; and on the basis of an assessment of the impacts, develop a ban on HFO for use and carriage as fuel by ships in Arctic waters, on an appropriate timescale.
What is ‘HFO’?
It has been widely reported that the use and carriage of HFO is already banned in the Antarctic (including as cargo). This is not strictly speaking correct: the Antarctic ban in Regulation 43 of MARPOL Annex I applies to heavy grade oil (HGO), which is defined as follows:
.1 crude oils having a density at 15°C higher than 900 kg/m3 ;
.2 oils, other than crude oils, having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s; or
.3 bitumen, tar and their emulsions
PPR 6 has been instructed to take Regulation 43 of MARPOL Annex I into account when developing a definition of HFO. The key would be .2 in Regulation 43 (above).
For bunker fuels, the current HGO ban in the Antarctic would not apply to products with a density at 15°C below 900 kg/m3 or a kinematic viscosity at 50°C below 180 cSt.
This means all the grades meeting current ISO 8217 marine distillate (DM) specifications would be allowed for carriage and use in the Antarctic, while residual grades (RM) have a maximum density limit under ISO 8217 in excess of 900 kg/m3, which would not be allowed.
However, a number of RM grades sold today are below 180 cSt and it is possible that, despite a density limit above 900 kg/m3 at 15°C, some of these fuels could in fact have densities below this threshold.
With extensive blending of various components to meet the 0.50% sulphur limit in 2020, it is anticipated that many products will have viscosity below 180 cSt. Density may also be lower than we see for most RM grades today, though most fuels designated as RM grades would most likely have densities above the 900 kg/m3 at 15°C threshold.
If the IMO agrees to use the current HGO definition for the Antarctic ban to define what constitutes ‘HFO’, density would become the key differentiator between fuels that can be used globally, including the Polar regions, and fuel that cannot be used or carried for use in the Arctic.
Report by Unni Einemo