After the IMO Intersessional Working Group (ISWG) meeting last week concluded, IBIA said that it is positive that there is a significant support among IMO member States to ensure consistency in fuel oil testing and verification procedures. However, discussions on a number of agenda items were left with unresolved issues.
Namely, the working group meeting developed a ship implementation plan (SIP) supported by information documents to guide on preparatory and transitional issues leading up the 0.50% sulphur limit for marine fuels from 1 January 2020. The SIP, which is not mandatory, can be filled in by ship owners/operators to help them prepare for compliance with the 0.50% sulphur limit on 1 January 2020.
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In addition, IMO member States want to ensure consistency in fuel oil testing and verification procedures for the verification of compliance with MARPOL Annex VI sulphur limits through regulatory amendments. In fact, ISWG considered proposals to include a definition of “sulphur content” in Regulation 2 of MARPOL Annex VI.
While the proposals were to include the ISO test method in the regulatory text itself, the draft developed by the meeting placed it in a footnote due to unresolved questions about how ISO standards can be included in IMO regulations. The decision regarding the draft amendment is expected that such a regulatory change, if approved, would take effect in mid-2021.
As for the ISO 8217 marine fuel quality standard, confusion whether it will cover fuel blends produced to meet the 0.50% sulphur limit has been addressed, IBIA said.
One of the key concerns expressed is the stability of fuel blends, as some blend components would increase the risk of the final blend being unstable. ISO pointed out that fuel oil blenders and suppliers should take careful note of these consequences ensuring this fuel characteristic is not overlooked.
Nevertheless, one element that ISO 8217 cannot address is compatibility between different blends ordered by ships. Today, it will not be possible for suppliers to guarantee compatibility as blend formulations will vary widely. So ships will have to consider the risk of incompatibility. The ISO representative commented on this that:
Recognising that some degree of mixing of different fuel oils onboard the ship cannot be avoided, many ships today have already procedures in place to minimise co-mingling of fuel oils with bunker segregation being always the first option. We would therefore encourage ship operators to evaluate further their segregation policy.
What is more, many agenda items were left unresolved. One of these is the question of the exact nature of guidance to be provided to port State control (PSC) in enforcing MARPOL Annex VI sulphur limits. While some emphasise the need for PSC to be understanding of the problems faced by ships in meeting the 0.50% sulphur limit, others are concerned that such guidance could send the wrong signal.
In addition, discussions on what should be in a standard reporting format for fuel oil non-availability to be developed by IMO, generally referred to as a FONAR (fuel oil non-availability report) were not addressed properly.
Another challenge that was emerged was the discussion on how PSC should deal with reports of fuel-oil non-availability. While many believe the ship should be required to debunker, it was said that not all ports will provide discharge facilities for debunkered fuel.
In this matter, IBIA suggested that when a ship discovers through fuel testing, after leaving port, that the fuel it has lifted fails to meet the limit as stated on the bunker delivery note, might be an issue to cover in a FONAR as well, because the ship has unexpectedly and despite its best efforts found itself short of compliant fuel to complete its voyage.
These issues will be further discussed at PPR 6 in February 2019.
