What is the current status?
First things first, from 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated Emission Control Areas will be reduced to 0.50% m/m (mass by mass). This will significantly reduce the amount of sulphur oxides coming from ships and should have major health and environmental benefits for the world, and especially for populations living close to ports and coasts.
According to a study on the human health impacts of SOx emissions from ships, submitted to IMO’s MEPC in 2016 by Finland, if we don’t reduce the SOx limit for ships from 2020, the air pollution from ships would contribute to more than 570,000 additional premature deaths worldwide between 2020-2025.
When the sulphur cap enters into place, IMO estimates that there will be significant reductions in Stroke; Asthma; Cardiovascular disease; Lung cancer; Pulmonary disease. In addition, cutting sulphur emissions helps prevent acid rain, which means less harm to crops, forests and aquatic species and tackling ocean acidification.
From January 1st and onwards
When the sulphur cap enters into place, shipping industry should bear in mind another significant date in relation to the ‘’carriage ban’’, coming into force on 1st March 2020. The carriage ban prohibits the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship, unless the ship has a scrubber installed.
The ban mandates that fuel oil used on board ships must not exceed 0.50% sulphur limit. Therefore, carriage of fuel oil for use on board ships will be prohibited from 1 March 2020 if the sulphur content is more than 0.50%. The provision will not apply to fuel oil being carried as cargo.
How to comply
Well, the options, as of now, are two: either use of compliant fuels, i.e. fuels with a sulphur content of no more than 0.5%, such as LNG, or biofuels or scrubbers. However, operators must be aware that many ports worldwide have banned the use of open-loop scrubbers, with Malaysia and Panama being the latest.
A quick checklist for compliance
The Shipowners' Club recommends the following checklist in order operators to ensure compliance with the upcoming MARPOL convention changes:
- Have you developed a ship specific implementation plan, in accordance with IMO guidance?
- In case that any structural modifications are necessary, have these been added to the ship specific implementation plan and approved by the flag state and/or classification society as applicable?
- Has a risk assessment for compliance been conducted and is it available on board?
- Has crew and shore side personnel training been carried out with appropriate records available?
- If the ship is more than 400GT, is the IAPP) Certificate or related exemption documentation available on board?
- Are the Oil Record Book and any other required records available and up to date?
- Do records note the condition of tanks, pipelines and other associated bunkering equipment?
- Do the Bunker Delivery Notes clearly verify whether the fuel oil sulphur content is above 0.50% m/m?
- Have you taken precautions to avoid comingling of supplied bunkers with fuel already on board the vessel?
- If comingling of fuel is unavoidable, have you made sure that clear fuel test documentation is available for each batch of fuel?
- Have you made preparations for entry into ECAs in sufficient time to allow for complete flushing of the fuel system or effective operation of the scrubber system?
- If so, are written changeover procedures available to crew and the necessary associated records available and maintained on board the vessel?
When it comes to the selection of compliant fuels, shipowners and operators should make sure that ISO 8217:2017 is specified as the required standard when ordering 0.50% Smax fuels for use after 1 January 2020. What’s more, ISO has published the 'ISO/PAS 23263:2019 to address quality considerations that apply to marine fuels ahead of the 2020 sulphur cap and the range of marine fuels that will be placed on the market in response to the international statutory requirements to reduce exhaust gas emissions.
Risk Assessment and Mitigation Plan
According to ICS, appropriate action plans should be developed in order to address and mitigate any specific safety risks identified. These plans could include the following:
- Procedures to segregate different types of fuels from different sources;
- Procedures for compatibility testing and segregating fuels from different sources until compatibility can be confirmed;
- Plans to address any mechanical constraints with respect to handling specific fuels, including ensuring that minimum/maximum characteristics of fuel oil as identified in fuel standards such as ISO 8217 can be safely handled on board the ship;
- Procedures to verify machinery performance using fuel oil with characteristics with which the ship has no prior experience.
Scrubbers with HSFO
Ships with scrubbers should be aware about the sulphur levels of the purchased fuels, in order to make sure that the scrubber can operate effectively to reduce the emissions to those equivalent of running a compliant fuel. In some locations, it is possible that the average sulphur content of HSFO could increase, Shell Marine warns.
It is possible that despite best efforts, a ship could not obtain compliant fuel. In these cases, the ship must complete a Fuel Oil Non-Availability Report (FONAR). However, a FONAR is not a ‘’free-pass’’ for non-compliance. Namely, ships must provide evidence that they attempted to obtain compliant fuel oil, as their voyage plan stated, but the fuel was not available. In addition, they must prove that attempts were also made to find alternative sources for such fuel oil, and that despite best efforts to obtain compliant fuel oil, no such fuel oil was available.
In order to determine if a ship complies with the new regulation, UK P&I Club warns that PSC inspectors will give emphasis on documents and procedures maintained on board. What is more, in certain jurisdictions PSC inspectors will carry portable sulphur testing kits; if the results of these tests are inconclusive or indicate possible non-compliance, then further sampling will take place for verification ashore. Key documents that must remain on board are:
- Bunker Delivery Notes and Fuel Sampling;
- Procedures for fuel change-over;
- Shipboard Implementation Plan;
- ECDIS and navigation charts.
Additionally, to ensure compliance with the 2020 sulphur cap, many PSC regimes are investing in training and education of their inspectors. However, inspectors can make mistakes, while others may not be well prepared for their new inspection tasks. Crewmembers must be aware of such a possibility and be prepared. This calls for proper on board procedures and a well prepared and attentive crew, which could change the outcome of a case that has been wrongly inspected.
A Disruptive but Necessary Change
Without a doubt, IMO 2020 will be disruptive for the shipping sector, and the global refining system and related refined product supply. However, according to OPEC, the good news is that it will be ‘’less severe’’ than expected.
Coming to add another positive aspect, Edmund Hughes, Head of air pollution at the IMO, confirmed that the industry will always have a great availability on IMO-compliant fuels.
Nevertheless, despite these positive indications, operators must not think that the job is done and should ensure compliance. As David Balston, the Director of Policy for the UK Chamber of Shipping, stated on BBC: ‘’I think is very important to ensure that we have a very strong implementation regime that countries do monitor emissions very strictly.’’