A second roundtable industry meeting hosted by IMO at its London Headquarters in November saw more optimism about the general readiness to meet the sulphur 2020 requirement than the first such meeting, which was held in June this year. IBIA had a delegation attending both the June 21 and November 18 roundtable meetings, which were initiated by the IMO Secretariat to share information and exchange views.
During the first roundtable meeting in June, representatives for shipping organisations expressed doubts about the necessary supply being made available, disappointment about lacking and/or highly priced supply of fuels complying with the 0.50% limit to gain experience, and ongoing concerns about the safe use of compliant fuels. IBIA explained at the time that limited spot market availability of very low sulphur fuel oil (VLSFO) blends produced to meet the 0.50% limit was a function of a corresponding lack of demand. More widespread supply could only be expected once more demand was manifesting. Citing intentions expressed by suppliers around world; IBIA told the meeting in June that supply of VLSFO would likely become much more readily available during the fourth quarter of 2019.
The roundtable meeting in November saw increasing confidence as significant efforts to date by all stakeholders to achieve effective implementation was recognised. It was felt supply of compliant fuels would generally be available, with some exceptions. While heavy fuel oils continued to be loaded, it was noted that more ship operators and owners are beginning to gain experience of compliant fuels, while bunker suppliers were in the process of moving their storage infrastructure and bunker barges to be 0.50% compliant fuel oil ready. As IBIA said during an Symposium on IMO 2020, supply of VLSFO meeting the 0.50% sulphur limit has been announced with increasing frequency, in particular since late September, and was already available in various locations across Asia, Middle East, Africa and the Americas as of mid-October with more and more set to become available, either during October or during November/December.
Consistent enforcement by port State control was once again recognised as essential to ensure a level playing field and to ensure that ships would not be disproportionately impacted.
MARPOL Annex VI, which contains the sulphur limit regulation, has 95 Parties, who between them register 96.71% or world merchant shipping by tonnage. Flag States have jurisdiction over the ship and issue the International Air Pollution Prevention Certificate (IAPP) to ships of 400 gross tonnage and above.
However, port States need to be a Party to Annex VI to exercise port State control in relation to the sulphur 2020 limit. The number of Parties to the Annex varies in different port State control regions.
Concerns were raised by some attendees on the preparedness of the PSC regimes to enforce the 2020 sulphur limit, however the IMO Secretariat confirmed the Organization’s readiness to support PSC regimes, in particular, with capacity building and training, and highlighted workshops delivered with the support of Denmark and the World Maritime University (WMU). Specific training to support port State control for the implementation of MARPOL Annex VI could be provided. An IMO Workshop for PSC MoU/Agreement Secretaries and Database Managers will be convened in 2020, which would provide a further opportunity to promote the harmonization of enforcement measures.
Fuel oil non-availability report (FONAR)
Roundtable participants raised concern about possible inconsistent approaches in relation to the fuel oil non-availability report (FONAR). The report is not intended as an exemption but is a standardised template to report non-availability of compliant fuel oil. The IMO Secretariat reminded participants that IMO has issued the 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI (MEPC.320(74) here), which includes a standardised FONAR.
Participants agreed on the need to continue to raise awareness about the sulphur 2020 limit and the need for further preparation by all stakeholders, including the IMO Secretariat, PSC regimes, Member States, shipowners/operators, charterers, fuel suppliers and others, in order to ensure consistent implementation of the sulphur 2020 limit by 1 January 2020. In this regard, it was agreed that the IMO Secretariat would communicate to all relevant parties on the continuing need to prepare for the entry into force of the sulphur limit.
The roundtable meeting was attended by representatives from IMO Secretariat and: International Chamber of Shipping (ICS); International Organization for Standardization (ISO).; BIMCO; International Association of Classification Societies (IACS); Oil Companies International Marine Forum (OCIMF); International Association of Independent Tanker Owners (INTERTANKO); International Association of Dry Cargo Shipowners (INTERCARGO); IPIECA; The Institute of Marine Engineering, Science and Technology (IMarEST); International Bunker Industry Association (IBIA).