Maritime

Sulphur Cap 2020 – HSFO carriage ban only weeks away

Now, with the new global 0.50% sulphur limit in force, next on the regulatory timeline is the carriage ban effective from 1 March. From this date, high-sulphur fuel oil (HSFO) cannot be carried in the fuel oil tanks unless the vessel is fitted with an approved equivalent arrangement. More about the carriage ban in this statutory news.

Relevant for ship owners and managers.

The carriage ban

After deciding on, and adopting, the new global sulphur limit for fuel oil, the discussion started on how to ensure a level playing field and enforcement on the high seas. The solution is the so-called "carriage ban” meaning that unless you have an exhaust gas cleaning system (EGCS), the ship is not allowed to carry any fuel exceeding 0.50% sulphur in the fuel tanks. The rational for the ban is that if you are not allowed to use the fuel, there is no reason to carry it.

Regulation 14.1 of MARPOL Annex VI will now read: The sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m.

While the new sulphur limit took effect on 1 January, the carriage ban will be effective from 1 March 2020. The two-month time gap is by no means introduced as a grace period. The reason for the gap is solely due to the IMO process of adopting new regulations.

The International Air Pollution Prevention Certificate (IAPP)

As part of the MARPOL amendments, the standard format of the IAPP certificate will also change from 1 March. A new tick-off box with the following text will be included in the supplement: For a ship without an equivalent arrangement approved in accordance with regulation 4.1 as listed in paragraph 2.6, the sulphur content of fuel oil carried for use on board the ship shall not exceed 0.50% m/m as documented by bunker delivery notes.

The IAPP certificate is required to be re-issued in the new format no later than the first IAPP survey after 1 March, being the annual, intermediate or renewal survey. If, for other reasons, the certificate is to be re-issued after this date, it will be in the new format.

Sample verification

With the carriage ban in place, PSC will have the opportunity to sample and verify the sulphur content of fuel carried for use to verify compliance with the new sulphur limit.

When verifying the sulphur content of samples taken on board, as opposed to the MARPOL sample taken during bunkering, a 95% confidence interval has been given. This means that a sulphur content of up to 0.53% may be accepted as compliant when testing such samples. This is to ensure that ships are not unjustly penalized for marginal excess in sulphur content beyond their control. (MEPC.1/Circ.882).

Recommendations

Compliance is the only option
For vessels without any approved equivalent arrangements in place, in case of any remaining HSFO from before 1 January, this needs to be dealt with before 1 March. In case removing the fuel in time isn’t feasible, flag and ports state should be contacted to agree on contingency measures (ref. MEPC.1/Circ.881).

References

Global Sulphur Cap 2020 webpage  

All MEPC documents available on DNV GL’s sulphur cap pages

  • MEPC.305(73) Amendments to MARPOL Annex VI 
  • MEPC.1/Circ.881 Contingency Measures for Addressing Non-Compliant Fuel Oil 
  • MEPC.1/Circ.882 Early Application of the Verification Procedures for a MARPOL Annex VI Fuel Oil Sample

Contact

  • For customer: 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
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