Maritime

FAQ - General

What are the sulphur limits for fuel in use under MARPOL?

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With the adoption in 2008, 1 January 2020 was given as the effective date for the 0.50% global sulphur cap, with an option to later defer the date until 1 January 2025, taking into account the global market supply and demand. In 2016, the IMO decided, based on information provided, to stick with the 1 January 2020 date. Hence, from 1 January 2020, the global sulphur limit will be reduced from 3.50% to 0.50%. For vessels operating in Sulphur Emission Control Areas (SECA) under MARPOL, the limit, which will remain unchanged, has been 0.10% since 1 January 2015.

FAQ - Preparation

How can I best prepare for 2020?

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The IMO has developed a “Guidance on the Development of a Ship Implementation Plan (SIP) for the Consistent Implementation of the 0.50% Sulphur Limit under MARPOL Annex VI”. Making a ship-specific SIP is considered a good starting point for preparing, as the plan will cover the expected challenges. The plan is not mandatory and is not subject to endorsement by the flag state or a recognized organization (RO). However, port state control (PSC) may consider the preparatory actions described in the SIP when verifying compliance. DNV GL has prepared a Web-based SIP application which is free of charge and available in the DNV GL Veracity marketplace

DNV GL has also developed a checklist which contains an overview of the critical activities to be reviewed, and implemented, before the end of 2019. The checklist is available here.

Do I have to clean my bunker tanks before switching to compliant fuel?

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Tank cleaning is basically done for the following reasons: 

  • To avoid operational issues with purifiers and filters, as new fuel blends and distillates may, due to their physical properties, be prone to dissolve and dislodge sludge and sediment build up in the fuel oil storage and service tanks 
  • To avoid separation and sludge formation due to incompatibility with remaining tank content, as new FO blends may carry a higher risk of incompatibility
  • To avoid contamination of the LSFO, potentially exceeding the required sulphur content 

The decision on tank cleaning should be taken based on the amount of sediments inside the tank and the type of fuel to be used. An alternative to manual tank cleaning may be using ship-specific changeover procedures to load on top and gradually flush through the fuel system until the sulphur content is within the compliant level. Another alternative is to gradually clean the sediments and asphaltic sludge from HSFO tanks and the fuel system by dosing additives to the HSFO used prior to the switch. . 

If we still use only MGO as a bunker, should we prepare Ship Implementation Plan?

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The purpose of the voluntary SIP is for preparing the ship in order to comply with the required Sulphur content limit of 0.50% by 1 January. If solely using fuel with less than 0.50% Sulphur, the vessel is already compliant and there is no need to prepare a SIP.

Can we submit the Ship Implementation Plan (SIP) for approval even it’s not mandatory?

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Class do not approve it, but DNVGL maritime advisory offer to review ship implementation plans. A request can be directed to ShipImplPlan@dnvgl.com.

What is the proper way to record in the Oil Record Book (ORB) residues from fuel tanks during tank cleaning in preparation for the IMO 2020 sulphur cap?

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Residues from fuel oil tanks collected in, for instance, the fuel oil drain tank for subsequent disposal or transfer by using the sludge pump, are to be recorded in the ORB Part I using code (C) 11.4 “Quantity of residues collected by manual operation”. Solid residues removed from fuel tanks, in for instance “big-bags” to be landed ashore, may be recorded as operational waste in the garbage record book, or as “Additional operational procedures and general remarks” under code (I) in the oil record book. In either case, a receipt detailing the quantity of residues delivered, together with the time and date of the delivery, should be obtained from the receiver.

In case excess HSFO can’t be disposed of prior to 1 March 2020, is transfer to a sludge tank an alternative?

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From a MARPOL point of view, there is nothing prohibiting adding fuel to a sludge tank, and by doing so it will be considered sludge. However, the transfer evident by the ORB may raise attention with PSC, especially if the “sludge” has been incinerated on board and not disposed of to a reception facility, as this may be seen as undermining the 0.50% sulphur limit. Additionally, the sludge tank capacity is limited, and the minimum required volume is approved based on the type of machinery and length of voyage, which again will be compromised in case of excessive fuel oil transfer to the sludge tanks.

In an ideal world, all fuel exceeding the 0.50% sulphur limit should be consumed before 1 January. If this is not possible, the remaining fuel should be disposed of to a reception facility before 1 March. If non-compliant fuel remains on board after 1 March, it is advisable to follow MEPC.1/Circ.881, consulting the port state and flag state to agree on a solution.

Is it mandatory to have a statement from class confirming that our engines and boilers can operate using low-sulphur fuels?

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No, there is no statutory or class requirement for such a statement; however, a third-party (vetting, charterer, etc.) may request such a statement. DNV GL offers a third-party service/statement on the witnessing of the changeover and/or operations of machinery running on low-sulphur fuel, the sulphur content of which is documented by a bunker delivery note. This is a vessel-specific service, consequently requiring the attendance of a surveyor on board the vessel. Please see our Recommended Practice DNVGL-RP-0506 “Witnessing of low-sulphur fuel changeover and operations”. It is also recommended that engine/boiler and fuel system manufacturers are consulted for information on whether the equipment/system is suitable for the intended types of fuel.

FAQ - Operational

What will be the implication of having fuel exceeding 0.50% sulphur remaining on board after 1 January 2020?

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Unless the vessel is fitted with a scrubber (Exhaust Gas Cleaning System [EGCS]), fuel oil exceeding 0.50% sulphur can’t be used after 1 January 2020. All remaining HSFO must be de-bunkered before 1 March 2020 when the carriage ban for HSFO enters into force. To avoid having non-compliant fuel on board on 1 January 2020, it is important to work out a bunkering strategy ahead of the 2020 deadline.

For a vessel fitted with an EGCS and using HSFO instead of compliant fuel, will there be any restrictions on incineration of sludge generated from HSFO after 2020?

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No, the use of an incinerator to burn oil residues (sludge) generated on board, e.g. from the purification of fuel oil, is permitted under MARPOL, regardless of the sulphur content of the fuel in use. However, there may be local restrictions on the use of incinerators in some ports. On-board incineration of residues/sludge generated by the EGCS is, however, prohibited by MARPOL Annex VI Regulation 16.2.6.

Is the carriage ban for non-compliant fuel also applicable to emergency equipment?

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Yes, the prohibition on carriage of non-compliant fuel oil should be applied to the fuel oil of emergency equipment, e.g. lifeboats and emergency generators.

What about excessive non compliant fuel after a FONAR situation?

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Contingency measures as per MEPC.1/Circ.881 to be considered between ship and port state. Non-compliant fuel oil may have to be de-bunkered or retained on board, as acceptable to the Port State.

Will there be a grace period in early 2020 where there will be no Sulphur content controls of fuel in use?

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No, from 1st of January 2020 only compliant fuel may be used, any excess HSFO after this date has to be de-bunkered prior to 1 March 2020 when the carriage ban takes effect. Having a strategy for consuming all HSFO by 1st of January is recommened.

What if the sulphur analysis resulting from a commercial analysis does not match the bunker delivery note?

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Where there is a discrepancy between what’s stated on the Bunker Delivery Note and what shown on commercial test reports from samples taken during bunkering, the flag should be informed as per MARPOL Annex VI regulation 18.9.6. The flag will then inform IMO which will make it publicly available on the IMO GISIS web site. For all practical purposes, it’s still the Sulphur content stated on the BDN which is the legally binding under MARPOL. If it’s a substantial difference in Sulphur content between the BDN and the commercial test report, the flag may require the MARPOL delivered sample to be analyzed.

Is the >0.5% sulphur carriage ban as of 1 March 2020 making exceptions for scrubbers and if where is this regulated?

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Yes, vessels with an equivalent arrangement approved in accordance with regulation 4.1 of MARPOL Annex VI (e.g. a scrubber) that is at least as effective in terms of SOx emission reductions as compared to using max 0.50% sulphur fuel, can still carry fuel exceeding 0.50% sulphur after 1 March 2020. This will be reflected in the new IAPP certificate form to be used after 1 March 2020, where a new tick of box is added for ships without equivalent arrangements, stating that the Sulphur content of fuel oil carried for used shall not exceed 0.50%. The new IAPP certificates will be issued no later than the first IAPP periodical survey after 1 March 2020.

What is the risk of bunkering incompatible fuel?

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When mixing e.g. an aromatic fuel with a paraffinic fuel there is a risk of experiencing incompatibility causing excessive sludge formation which again can block filters and separators. New bunkers should be loaded into empty tanks to the extent possible.

Are Incinerators subject to the MARPOL Sulphur requirements?

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Regulation 14 of MARPOL Annex VI applies to all fuel oil used onboard. Hence it will apply to the incinerator pilot fuel. Sludge on the other hand is not considered fuel and may be incinerated as per regulation 16 of MARPOL Annex VI regardless of the Sulphur content. Please note that local requirements may apply for use of incinerators, therefore it is advisable to consult with the coastal authority before any incineration occurs.

In case of any excess HSFO after 1 January 2020 can that be diluted onboard with sufficient low sulphur fuel to achieve compliance?

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No, mixing fuel exceeding the Sulphur requirement with compliant fuel in order to “make” compliant fuel on board is not an option as the sulphur content of the fuel is documented through the BDN issued by the fuel supplier. Any mixing to achieve compliance with reg.14 is to be done by the fuel oil supplier only. We expect BDNs will have a high focus with PSC after 1 January. Hence, our recommendation is to have a strategy for consuming all HSFO before 1 January.

FAQ - Enforcement

What control measures will be in place to enforce the 0.50% global sulphur requirements from 2020?

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PSC will typically check the IAPP certificate, together with the Bunker Delivery Notes (BDNs), filed on board. If there are “clear grounds” to do so, PSC may conduct a more detailed inspection, including on-board sampling or analysing of the MARPOL sample following the BDN. “Clear grounds” may be indications from remote sniffing devices or portable sulphur content measuring devices that the fuel used on board may be non-compliant.

What may be the consequence of failing to comply?

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Using non-compliant fuel without an EGCS in use, or failing to provide the necessary evidence that fuel oil was not available at the port of bunkering (Fuel Oil Non-Availability Report [FONAR]), may result in fines, detention and de-bunkering. As sanctions are established by the individual states, the imposed sanctions will vary from port to port.

When can the MARPOL delivered sample be claimed by PSC for analysis.

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The sample may be claimed if PCS has reason to believe that the BDN is not representative for the fuel oil delivered or has information indicating that the ship may be non-compliant, e.g. by remote SOx sensing surveillance or portable fuel oil Sulphur content measuring devices. If the MARPOL delivered sample is claimed for analysis, a written statement should be provided to the ship stating which State claimed the sample and the reasons. If a port State claims the MARPOL delivered sample, the flag State should be informed.

What will be role of PSC inspectors post 2020 January 01 in respect of compliance with fuels and emissions?

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The enforcement of the new Sulphur requirements will primarily be by PSC. An initial inspection would typically include checking documentations such as the IAPP certificate, record books, BDNs, FONARs, fuel change over procedures and the Ship Implementation Plan (SIP) if available. If there are “clear grounds” to do so based on the initial inspection, PSC may conduct a more detailed inspection, including on-board sampling or analyzing of the MARPOL delivered sample. For vessels fitted with scrubbers PCS may check that the system is working and operated properly, using the approved documentation.

FAQ - EGCS

Can fuel exceeding 0.50% sulphur be used for testing of scrubbers e.g. during sea trail and commissioning after 2020?

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For EGCS approved according to Scheme B of MEPC.259(68) there is no requirement for commission testing with fuel oils exceeding 0.50% sulphur. In principle the system can be tested and commissioned with low sulphur fuels and the IAPP including the EGCS can be issued. In case the EGCS is to be approved according to Scheme A of MEPC.259(68) or the ship operator requires testing and commissioning with fuel oils exceeding 0.50%, flag state needs to be contacted on a case-by-case basis asking for exemption.

Are there any limitations on the fuel Sulphur content when using a scrubber?

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For scrubbers under Scheme B compliance is demonstrated by continuous exhaust gas monitoring, so as such there is no limit on the fuel sulphur content as long as the system can cope and all parameters are within the limits. For scrubbers under scheme A, using parameter check, the Sulphur content should not exceed the certified maximum Sulphur content, which can be found in the approved Sulphur Emission Compliance Plan (SECP).

How to deal with EGCS failure at sea?

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IMO has developed guidelines for this, MEPC.1/Circ.883. A malfunction which can’t be rectified is considered an accidental breakdown. The ship should then switch to compliant fuel if the scrubber can‘t be repaired within one hour. In case the vessel doesn’t have compliant fuel or sufficient amount of compliant fuel on board, a proposed course of action, in order to bunker compliant fuel our carry out repair works, should be communicated to relevant authorities including the ship’s administration, for their agreement. The flag and port State’s will determine the appropriate action to take.

What to do in case of EGCS sensor failure?

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A sensor failure doesn’t necessarily qualify as malfunction as long as the EGCS performance can be verified by other parameters. In such case, records of interim indication for demonstrating compliance should be kept. Please see MEPC.1/Circ.883 for all details.

What operational hick-ups have DNV GL experienced from use of scrubbers?

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Rapid corrosion in the wash water overboard piping, especially the spool piece after the overboard valve has been seen, e.g. due to if wrong material used or the corrosion protection has been damaged or poorly installed. Due to this challenge, DNV GL introduced in January 2017 a requirement that it shall be documented during the annual class survey that the distance piece has not diminished in thickness. This documentation may be UTM measurements done by a level II qualified operator in the three months leading up to the survey. Alternatively, if divers have performed an underwater inspection during that period and have been able to inspect the condition of the entire distance piece up to the overboard valve, their report can be accepted as documentation.

Also issues with measurement sensors and the scrubber control system have been reported.

For a ship using a scrubber, what is the time allowed being out of compliance if the scrubbers fails, before it is being brought up to service or switch to compliant fuel?

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The ship should change over to compliant fuel oil if the EGCS cannot be put back into a compliant condition within one hour, please see MEPC.1/Circ.883. If the ship does not have compliant fuel oil or sufficient amount of compliant fuel oil on board, a proposed course of action, in order to bunker compliant fuel oil or carry out repair works, should be communicated to relevant authorities including the shipʹs administration, for their agreement.

Are vessels with EGCS installed required to have a compliant fuel onboard in case of EGCS failure?

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No, a vessels fitted with an approved EGCS is not required to have any compliant fuel onboard in case of EGCS failure. In case of any failure MEPC.1/Circ.883 gives guidance how to react.

What is the procedure for the issuance of IAPP certificate including the exhaust gas cleaning (EGC) system?

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  1. Upon receipt of drawings DNV GL inform flag that EGC system will be installed
  2. Approval of statutory documents according to statutory requirements is carried out
  3. Site survey at quay for EGC system installation carried out by DNV GL surveyor
  4. Closing of pending comments as per approval letters (to be closed by Surveyors or Approval engineer as applicable)
  5. Sea trial and witness of sampling of wash water by DNV GL surveyor or remote survey (if applicable)
  6. In case there are no pending items or open comments (except for nitrate report) issuance of full term IAPP (short term or interim may apply depending on specific flag state instructions) with items 2.3.1.2, 2.3.2.2 and 2.6 ticked off
  7. Review of nitrate report
  8. In case nitrate report is not meeting the limits a Condition of Authority maybe issued or new IAPP without items 2.3.1.2, 2.3.2.2 and 2.6 to be issued
  9. DNV GL inform Flag that IMO GISIS to be updated

Please note the EGCS will not be mentioned in the IAPP until all comments are closed and scrubber related findings dealt with (with the exception of nitrate report).

Are there any special requirements from the US Coast Guard?

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DNV GL is not authorized to perform approvals for the US Coast Guard and/or VGP. VGP applies within 3 nm from the US coast. Under VGP regulations, the pH limit for the washwater effluent shall not be less than 6.0, while for the IMO (resolution MEPC.259[68]) the pH limit for the washwater effluent is to be no less than 6.5, measured at the overboard discharge or at a position 4 m from the overboard discharge point. Therefore, the owner needs to check with the vendor whether the EGCS on board is VGP compliant. If it is compliant, then the ship may operate the EGCS within 3 nm of the US coast but will need to carry out the annual sampling and analysis tests and submit the results in the annual VGP report. Most of the installed EGCS are not VGP compliant, and ships need to switch to MGO before approaching the 3 nm limit.

Please also note that California does not accept operation of scrubbers with non-distillate fuel oils and Connecticut prohibits EGCS discharge water.

Can fuel used for Inert Gas (IG) systems, which use a flue gas scrubber, on tankers exceed 0.50% sulphur?

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“Any fuel used on board a ship” includes fuel used for cargo operations, meaning the fuel used for the IG systems also needs to comply with regulation 14 of MARPOL Annex VI, implying a max. sulphur content of 0.50% outside ECAs and 0.10% inside ECAs. In order to use fuel exceeding the given limits, the IG system’s scrubber has to be accepted and approved as equivalent to low-sulphur fuel and comply with MEPC.259(68), including the wash water criteria.

In the case of a flue gas system (aux. boiler exhaust used as IG), unless the IG uptake valves are located downstream of a compliant EGCS scrubber, the above also applies to the flue gas scrubber.

FAQ - FONAR

What happens if compliant fuel cannot be obtained in the port of bunkering?

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A Fuel Oil Non-Availability Report (FONAR) shall be submitted to the flag state, with a copy to the port of destination, as soon as it is determined that compliant fuel oil will not be available. The standard FONAR form can be found in Appendix 1 of MEPC.320(74).

FAQ - Sampling

When are we required to install the “in use“ sampling points?

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The amendments to MARPOL requiring sampling points for the purpose of taking representative samples of the fuel oil in use, is expected to enter into force on 2021-09-01. This implies that for vessels keel laid before 2021-09-01 sampling points shall be fitted or designated no later than the first IAPP renewal survey after 2022-09-01.

Will fitting of sampling point be subject to approval?

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A formal approval will not be required unless any modifications are done to the piping system other than fitting the sampling points, e.g. if additional drainage is needed for the sampling arrangement. The number and location of the sampling points will however be confirmed by the attending surveyor according to IMO Guidelines (MEPC.1/Circ.864/Rev.1) at the first IAPP renewal survey on or after 2022-09-01. The designated sampling points will be reflected in the new IAPP certificate issued on completion of the renewal survey.

What are the allowable margins for the sulphur content for 2020 LSFO?

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The requirement is max 0.50% sulphur, and there are no margins as such, except when it comes to the lab testing of certain samples.

The fuel verification procedure for MARPOL Annex VI fuel oil samples are given in Appendix VI of MARPOL Annex VI.

Up to now, only the procedure for verifying the MARPOL-delivered sample taken during bunkering has been given in Appendix VI. Now, with two new samples to be introduced under MARPOL Annex VI, namely the “In-use” sample and the “On board” sample for the purpose of verification by PCS, amendments to the verification procedure have been accepted, providing an agreed verification method also for the “In-use” sample and the “On board” sample. Please see MEPC.1/Circ.882.

Please note that for the “In-use” sample and the “On board” sample, a 95% confidence interval has been given. This implies that a sulphur content of up to 0.53% may be accepted as compliant when testing the “In-use” sample and the “On board” sample. This is to ensure that ships are not unjustly penalized for marginal excess in sulphur content beyond their control. However, the fuel ordered/delivered to the vessel must still not exceed 0.50%.

GUIDANCE PACKAGE: Global Sulphur Cap 2020

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