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.
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.
Tank cleaning is basically done for the following reasons:
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. .
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.
Class do not approve it, but DNVGL maritime advisory offer to review ship implementation plans. A request can be directed to ShipImplPlan@dnvgl.com.
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.
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.
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.
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.
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.
The sluphur content stated on the BDN is still the official as per MARPOL. In case independent test results indicate a Sulphur content exceeding the MARPOL limit and the BDN the master should document that through a notification to the flag Administration with copies to the authority of the relevant port of destination.
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.
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.
Regulations 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 of the fuel in use. Please note that local requirements may apply for use of incinerators.
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.
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.
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.
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.
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.
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.
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).
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.
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.
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. Also issues with measurement sensors and the scrubber control system have been reported.
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.
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.
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).
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.
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.