Maritime

Fuel oil non-availability report (FONAR) – what you need to know

With 1 January 2020 fast approaching, and with the uncertainty on compliant fuel oil availability worldwide, having a plan for dealing with a scenario of fuel oil non-availability can prove valuable. This statutory news contains some key aspects on what to consider, including access to a FONAR template.

Technical and regulatory news - DNV GL

Relevant for ship owners and managers as well as flag states.

Regulation 18.2 of MARPOL Annex VI describes what to do in case a ship is not able to get the required fuel as per MARPOL. This includes:

  • Notify your flag state and the port authority at the next port of call
  • Provide a description of actions taken to attempt to achieve compliance
  • Provide evidence that you attempted to purchase compliant fuel oil in accordance with the ship’s voyage plan and, if it was not made available where planned, that attempts were made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase

The FONAR (Fuel Oil Non-Availability Report) form was later developed by the IMO and is meant to capture the information above. The ship should not be required to deviate from its intended voyage or to delay unduly the voyage in order to achieve compliance.

It’s important to note, however, that filing a FONAR is not a carte blanche for using non-compliant fuel nor an exemption from using compliant fuel. It is still the port authorities in the port of destination, taking into consideration the FONAR and the evidence submitted, which will scrutinize the information provided and make the final decision, eventually deciding if any penalty is to be imposed.

Even if a FONAR is accepted, the disadvantages and hassle following a FONAR situation may in many cases outweigh possible benefits from using cheaper non-compliant fuel. For instance, with the carriage ban for fuel exceeding 0.50% sulphur taking effect on 1 March 2020, the handling of any excess non-compliant fuel after a FONAR situation will be subject to the discretion of the PSC in cooperation with the flag and ship (MEPC.1/Circ.881). In worst case, this could mean de-bunkering the ship, followed by tank cleaning, which can prove very costly and time-consuming.

The evidence provided with the FONAR that compliant fuel was not available will be essential. This will be documentation, statements and correspondence showing that all possibilities have been considered to obtain compliant fuel, including taking into account the voyage plan and all relevant fuel oil suppliers at hand. In case non-compliant fuel has been bunkered due to fuel oil quality concerns and with respect to potential safety and operational problems, such concerns need to be thoroughly documented, possibly supported by equipment or the engine manufacturer’s recommendations.

Recommendations

As soon as it becomes evident that compliant fuel will not be available for the next voyage, it is important to notify the next port of call and the flag administration directly (and not to class) without any delay about the situation and circumstances by submitting a FONAR. The FONAR shall provide the necessary evidence and justification for bunkering non-compliant fuel.

References

Contact

  • For customers:
    DATE – Direct Access to Technical Experts via My Services on Veracity.
  • Otherwise:
    Use our office locator to find the nearest DNV GL office.
31 July 2020

AMSA focused inspection campaign — Proper stowage and securing of cargo containers

As a result of several incidents where containers have been lost overboard, the Australian Maritime Safety Authority (AMSA) has decided to carry out a focused inspection campaign on cargo securing arrangements that will run from 1 August to 31 October 2020. This campaign is not included in the PSC inspection and its results will not be transmitted to regional PSC regime databases. However, in cases of non-compliance, the attending AMSA surveyor may proceed to a full PSC inspection.

  • Maritime
10 July 2020

Ballast water management - new type approval standard applicable from 28 October 2020

This statutory news provides information about the new IMO type approval standard of ballast water management systems (BWMS) applicable for systems installed on or after 28 October 2020. In addition, you receive recommendations on how to handle BWMS installation of the old IMO G8 type approval standard if installed prior to 28 October 2020, but that the commissioning survey is on or after that date.

  • Maritime
View all