North P&I Club has updated its guidance on the 2020 Sulphur Cap for operators. This aims to help them prepare for the big switch to compliance on 1 January 2020. After a programme of events, training sessions and publications which have been taking place over the past 12 months, North published three new guides to ensure safe and compliant operations.
The three guides regard the three main methods of achieving compliance:
- Using distillates (MGO/MDO);
- Using blended very-low-sulphur fuel oils (VLSFO);
- Installing exhaust gas cleaning systems (scrubbers).
North has looked at the importance of good planning, the risks associated with each option and contingencies in the event of non-compliance. It isn’t just technical – enforcement and contractual risks are also considered
The Club said.
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Tiejha Smyth, Deputy Director (FD&D) at North, also commented on the importance of suitable transition clauses in the time charterparty to facilitate a smooth transition. She added that it is crucial to ensure that the technical objectives of the transition plan are reflected in the charterparty. What is more, for ships fitted with scrubbers, there will be additional considerations.
The guides also examine some of the challenges in preparing to receive compliant fuels. Speaking on this, Mark Smith, Loss Prevention Executive, believes that proper planning is key, but when it comes to the switchover, it is important to do it safe and do it right.
In addition, tank cleaning is possible to be needed and this might mean multiple tank entries. Mr. Smith continued:
Too many people die in enclosed or confined spaces. Tank cleaning operations must be subject to a risk assessment and a permit-to-work system
Finally, if the tank and fuel system is not properly cleaned, it could contaminate several hundreds of tons of subsequently bunkered expensive fuel. It could also lead to enforcement action, delays and disputes.
