In light of the fast approaching 2020 sulphur cap, in January 1st 2020, Lloyd’s Register provides some critical questions a charterer, or a shipowner may wish to address, providing them with greater confidence that their vessel is equipped with all necessary measures in line with the regulation, mitigating the possibility of a vessel’s detention.
Firstly, it is crucial to be sure that the fuel supplied to the ship is within the operational quality boundaries of the ship and is compliant for sulphur emission control.
The CharterParty is the one that deals with the respective responsibilities and liabilities of the owner and charterer for complying with MARPOL 0.5% sulphur regulations; Thus, existing and new charterparty clauses should be updated, in line with the new regulations.
The questions focus on the onboard capability and management of fuels.
#1 Charter period and history
- Does the charter period cover voyages outside the existing ECA?
- If the ship has existing problems with compliance how will those impact on its ability to comply with the 0.50% max sulphur (S) requirements? Are those problems a result of external (i.e. poor fuel oil quality as supplied) or internal (i.e. inadequate fuel oil management onboard) factors?
#2 Ship Implementation Plan status
- Has the ship completed a Ship Implementation Plan (SIP) for switchover to 0.50% max S fuel oils, with consideration given to the guidance of IMO MEPC.1/ CIRC 878?
- Has the fuel oil switchover process, as given by that SIP, commenced?
- Have unforeseen problems arisen in implementing that SIP?
#3 Fuel oil specifications and bunkering
- What fuel oil specification(s) – ISO 8217 / year and grade(s) – does the shipowner normally require to be supplied?
- Are charterer supplied fuel oils only to be loaded into essentially empty tanks (i.e. only unpumpables remaining) thus addressing the risk of incompatible fuels being commingled at the bunkering stage?
- Has the supplier’s Bunker Delivery Note format been updated to the current style – as given by MEPC.286(71)?
- Does the ship intend to use EGCS outside ECA?
- Which combustion devices onboard will not be connected to an EGCS?
Every provision should be considered by the ship as to the most likely components to fail and what spares can be carried to enable the crew to bring the EGCS back on line within the IMO MEPC.1/Circ.883 prescribed time of one hour before the ship must report its failure. Alternatively, considerations to carry so many days of compliant fuel to facilitate a longer period of repairs should be considered.