PPR 10 discusses whether HFO ban will prevent VLSFO spills in the Arctic

A ban on the use and carriage of heavy fuel oil (HFO) as fuel by ships in Arctic waters is due to take effect on July 1, 2024.

The carriage ban is intended to protect the vulnerable Arctic environment from accidental HFO spills.

Last year, Norway and Iceland submitted a proposal to the Marine Environment Protection Committee to change the IMO’s regulatory definition of HFO to include an upper pour point limit. Their document, MEPC 78/14/1, highlighted that the very low sulphur fuel oil (VLSFO) blends that have been developed to meet the IMO 2020 0.50% sulphur limit are difficult to clean up in cold conditions because the paraffinic components solidify, preventing effective use of skimmers.

They speculated that once the HFO in the Arctic comes into effect, the density of VLSFO (and maybe 0.10% sulphur residual fuel grades known as ULSFO) can be adjusted by adding more paraffinic components, which in turn would make the pour point of the fuel higher and hence more difficult to clean up in the event of a spill in cold Artic waters. IBIA was among those questioning aspects of the proposal at MEPC 78, which was forwarded to the 10th session of the sub-Committee on Pollution Prevention and response (PPR 10) for further consideration.

Norway submitted a new document to PPR 10 with an alternative proposal to address the concerns about the nature of fuels carried for use in the Arctic, suggesting that instead of amending the IMO’s HFO definition, to define “polar fuel oils” that are acceptable to be used (or carried for use) as fuels in Arctic waters in a similar manner to the requirements implemented by Norway in the Svalbard Environmental Act.

IBIA was pleased to see Norway’s new take on the issue and told PPR 10 that we supported the proposal to develop a new definition for “polar fuel oils” in line with the Svalbard Environmental Act. “This would mean ships would not be allowed to use or have on board petroleum-based fuel with a higher viscosity, density or pour point than permitted for marine gas oil. We do believe this would be a better option than trying, right now, to change the definition of HFO,” IBIA’s Director and IMO Representative, Unni Einemo told PPR 10.

The proposal led to some interesting discussions, during which one delegation suggested that the bunker industry had failed to take into account the environmental damage new low sulphur fuel formulations would cause in the Arctic. Responding to this accusation, IBIA’s Einemo told PPR 10 that VLSFOs had been developed in response to the IMO 2020 sulphur limit to provide shipping with compliant and cost- effective fuels, and that sulphur was now the primary blend target. These fuels are produced for the purpose of being burnt in ship engines, not on the basis of how they behave when they end up in water, she pointed out. Einemo reminded PPR 10 about earlier fuel testing data IBIA had highlighted during previous discussions on the subject, showing that around 95% of VLSFOs in the market tested up to the end of February 2021 would be classified as HFO, mainly due to the density being higher than the maximum allowed for use and carriage in the Arctic. More recent data suggested maybe even less than 5% of VLSFOs currently in the market could be used once the HFO ban takes effect. She said that, hopefully, this would alleviate some of the concerns raised about the potential for VLSFOs to be used and accidentally spilled in the Arctic.

Einemo then pointed to an information document, PPR 10/ INF.12 by Australia, containing a study on responding to VLSFO spills, which highlights that spill responders must plan to use a variety of different equipment to deal with such spills and not rely solely on skimmers.

While IBIA was supportive of the proposal to develop a new definition for “polar fuel oils”, the Member States that spoke were not in favour. Nor did they want to amend the definition of HFO to include an upper pour point limit at this stage in light of the fact that the HFO use and carriage ban is due to take effect next year. It was seen as important to see the actual effects of the regulation before introducing any additional elements.

PPR 10 therefore agreed to revisit this matter in 2025 and to review documents MEPC 78/14/1 and PPR 10/10/1 again at PPR 12, when the HFO use and carriage ban will have been in effect for at least 7 months.

Moreover, PPR 10 invited Member States and international organisations to submit information to future sessions of the Sub-Committee on bunker fuel properties available for Arctic shipping, including any trends in viscosity, density and pour point in the lead up to 1 July 2024, and after that date.

While the HFO use and carriage ban takes effect next year, there are exemptions for ships with fuel tanks protected by double hulls, and waivers for ships flying the flag of countries with a coastline bordering on Arctic, that will allow these ships to continue carry HFO for use until 1 July, 2029.