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Prepare for the Global Sulphur Cap 2020 with the IMO Ship Implementation Plan

The IMO has agreed on 1 January 2020 as the date for switching to 0.50% sulphur fuel globally. Now, as ship owners face the daunting task of preparing for the fuel oil switch, proper planning is essential. The IMO Guidance for developing a Ship Implementation Plan (SIP) is a useful tool, and described further in this technical news.
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 TecReg 07, 2019

Relevant for ship owners/managers, charterers and flag states.

The Ship Implementation Plan (SIP) is an IMO Guidance which all ships are encouraged to prepare and implement to be ready for 1 January 2020. 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. 

The SIP addresses issues related to the use of compliant fuel oil and how to identify any safety risks associated with such fuels. Items covered by the plan include, as relevant:

  • Risk assessment and mitigation plan (impact of new fuels)
  • Fuel oil system modifications and tank cleaning (if needed)
  • Fuel oil capacity and segregation capability
  • Procurement of compliant fuel
  • Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil)
  • Documentation and reporting

It is also recommended that the plan is supplemented with a record of actions taken by the ship owner to be compliant by the applicable date. This will help monitor progress in the preparation period and can be used to prove that necessary actions have been taken, in case of PSC inspection.

DNV GL has prepared a Web-based application of the SIP: a user-friendly, step-by-step tool for ship owners and managers to prepare their their ship-specific implementation plans and maintaining an overview of their fleet. The SIP application is free of charge and available in My Services on the Veracity data platform.

DNV GL can also support shipping companies in the development of SIPs by offering risk assessment workshops and by also reviewing SIP plans. A tank cleaning remote verification and witnessing of low-sulphur fuel operation are also available services to support preparation for compliance.

Recommendations

To facilitate a smooth transition to the 0.50% sulphur cap, proper planning is necessary, and with 2020 approaching, time is limited. Preparing a good implementation plan will ensure compliance and serve as documentation towards charterers and authorities. Even though the SIP is not mandatory, it is recommended and indeed a useful tool.

References 

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21 May 2019

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