To support anyone preparing for the 2020 sulphur cap, and specifically shipowners and operators, LR has created and answered a set of the most frequently asked questions:
Is a Ship Implementation Plan (SIP) mandatory?
Mr. Usman says that a SIP is not mandatory, but it is ship-specific and owners and operators should prepare one as it provides a chance for technical staff on board to review the ship's fuel management procedures ahead of the new 0.50% sulphur fuels. This will also assist technical staff to establish timelines for the ship when conducting operational, design, and system changes.
Should there be a comprehensive tank cleaning before 1 January 2020?
An assessment must be carried out on the base of each HFO bunker tank and a decision has to be made on the necessary course of action. There are little options being considered by the ship operators like:
- Flushing tanks with distillate ultra-low sulphur fuels to flush the tanks, piping and fuel system components of high sulphur fuel oil and sediment;
- Using one or more bunkerings of 0.50% fuels prior to the enforcement date;
- Use of a specialist additive dosed over various bunker loads before the first 0.50% is loaded to clean the tanks;
- A combination of the above.
When first using 0.50% fuels, LR suggests crewmembers to perform sulphur sample checks from the system periodically to provide indications of the tank's compliance condition.
What are the major quality concerns with 0.50% fuels?
Some of the key challenges and risks regarding the new 0.50% fuels are the following:
- Compatibility between fuels from different sources;
- Stability of the blends;
- Variability of certain physical parameters from different sources like viscosity and density;
- Cold flow properties;
- Combustion performance of new blends.
In addition, a lack of preparation and planning will make these challenges worse. For this reason, crew training is crucial as they are on the frontline handling several technical challenges and ensuring resilient ship operations.
What is the update from ISO?
The work on the ISO/PAS 23263:2019 guidelines for fuel suppliers and users regarding marine fuel quality is going through a balloting process as per ISO procedures. Currently, it is expected that the ISO/PAS 23263 will be available by the end of September 2019.
The ISO working group’s main target is to address the 0.50% sulphur fuels' stability and compatibility. Informative Annexes also contain further guidance on the composition, general requirement, stability and comingling of fuels. Moreover, CIMAC WG7 for fuels will launch with a more detailed technical document regarding fuel stability and compatibility.
How are discussions shaping up at IMO?
Most discussions regard the consistent implementation of MARPOL Annex VI regulation 14.1.3, Mr. Usman noted. MEPC 74 launched guidelines for the implementation of the MARPOL Annex VI Regulation 14.1.3, and they will be released as a resolution in due course.
They will also address areas like key technical preparatory considerations, control measures by port states, control on fuel oil suppliers, and fuel oil non-availability, including a FONAR template and handling non-compliant fuel scenarios.
One of the big changes was the amendments to the Sulphur Verification Procedure (Appendix VI) to handle accuracy and precision of test results of both the current MARPOL sample, along with 'in-use' and 'on-board' sample. The MARPOL Annex VI sample test result would be considered as not meeting the requirement more than 0.50% after following the verification procedure. On the other hand, for the 'in-use' and 'on-board' samples the fuel will not have met the requirement if the test result is more than 0.53%.
Additionally, the guidelines for port state control aim to handle scenarios like when there is discrepancy between the Bunker Delivery Note (BDN) and independent ship results presenting non-compliant fuel has been loaded despite the declaration on the BDN stating otherwise. It was also recognised that there will be various scenarios to mitigate non-compliant fuel being on board, such as after applying a FONAR. Here, the guidance gives emphasis on the ship making every attempt to avoid putting itself into such a position.
What is more, the guidance also expects suppliers to ensure that fuel quality is acceptable for the receiving ship. MEPC 74 also worked to produce guidance in the event of failure of a single monitoring instrument and suggested measures if the scrubber fails to meet the provision of the guidelines.
Finally, LR mentioned that, in order to facilitate the consistent implementation, MEPC 73 agreed to ban the carriage of high sulphur fuels that are over 0.50% on vessels not equipped with a scrubber, from 1 March 2020.