Applying from 1 January 2020, the legal framework will require from merchant ships globally to use fuel with a sulphur content of less than 0.50% or use alternative mitigation technologies.

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The ICS guidance contains the latest IMO decisions addressing issues like fuel oil non-availability reporting, fuel safety and fuel quality. The updated guidelines will also help ships avoid port state control difficulties that might come up, through no fault of the operator, and allow shipowners and ships' crews to address the practical challenges due to this multi-fuel scenario.

The report 'Compliance with the 2020 'Global Sulphur Cap', includes details of the new requirements to enable on board sampling to verify fuel oil compliance. It also incorporates a new section on managing different fuels, an updated FAQ and a new appendix with the IMO standard template Fuel Oil Non-Availability Report (FONAR).

Selection of Compliant Fuel

Regarding the selection of compliant fuels, shipowners and operators are therefore recommended to ensure that ISO 8217:2017 is specified as the required standard when ordering 0.50% Smax fuels for use after 1 January 2020.

To address the anticipated fuel characteristics and properties of the marine fuels that will be placed on the market to meet the 2020 sulphur requirements, ISO is developing a Publicly Available Standard (PAS): ISO PAS 23263. ISO PAS 23263 will provide additional guidance to the existing ISO 8217 specification for fuels for use in marine diesel engines and boilers; for example, compatibility and stability of new blends of fuel oil. ISO PAS 23263 is expected to be published in the last quarter of 2019.

Ship Specific Implementation Plans

The ship specific Implementation Plan will need to consider when and where any new 0.50% Smax fuels will be bunkered and the designated tanks into which they will be loaded. Shipowners and operators will need to decide between:

  • Cleaning tanks designated for the bunkering of compliant fuel;
  • Loading compliant fuel into designated tanks on top of the remnants of 3.50% Smax fuel as part of a dilution/flushing process, commencing this within an appropriate period of time before 1 January 2020 to ensure all non-compliant fuel is out of the system before this date. This process should be carried out carefully keeping in mind the possible associated risks resulting from incompatibility between the two fuel grades.

Once the Implementation Plan has been developed, shipping companies are recommended to approach the ship’s flag State and classification society and request that it reviews the Plan for adequacy and completeness or as deemed appropriate by the flag State. This may prove helpful should problems emerge during any PSC inspections.

Risk Assessment and Mitigation Plan

The risk assessment should take into consideration the fuel oil properties detailed in Sections 3 and 4 of this ICS Guidance. Appropriate action plans should be developed in order to address and mitigate any specific safety risks identified. These plans could include the following examples:

  • 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.

Fuel Oil Non-Availability

IMO has developed a standard format for reporting fuel oil non-availability. The following factors should be considered before deciding whether to bunker non-compliant fuels:

  • Shipowners, operators and charterers are expected to take into account any logistical constraints, including the availability of compliant fuel at berths within the port, as well as terminal or port policies when planning for bunker delivery. It should be noted that having to change berth or moving to anchor within a port in order to obtain compliant fuel is very unlikely to be considered by Administrations/PSC as undue delay to the ship;
  • A Fuel Oil Non-Availability Report (FONAR) should not be considered as exemption from the relevant sulphur limit requirements. According to Regulation 18.2 of MARPOL Annex VI, it is up to those Administrations that receive the FONAR to take into account all relevant circumstances and the evidence presented to determine the appropriate action to take, including not taking control measures;
  • The higher cost of compliant fuel will not be considered as a valid basis for claiming non-availability. In any case, the cost difference between compliant and non-compliant fuels may be relatively small compared to the cost and effort that may be involved in cleaning a fuel tank and associated systems after a voyage using non-compliant high sulphur fuel;
  • Ships will be expected to bunker and use all types of 0.50% Smax compliant fuels. Exceptions to this option may be accepted by Port State Control authorities following consideration of the ability of the ship’s fuel oil system to safely store, process and consume a particular type of compliant fuel and the need for cleaning out the tanks of all remaining fuel residue prior to loading non-compatible alternatives into the same tank. In such cases, ship operators should ensure these considerations are included as part of the Ship Implementation Plan and ensure availability of documentary evidence on board to prove the above limitations during the subsequent inspections following the issuance of a FONAR;
  • Shipowners and operators should give careful consideration to the quantity of non-compliant fuel bunkered where there is non-availability of compliant fuel. In these situations, the minimum possible quantity should be bunkered as it is possible that any remaining non-compliant fuel will be required to be debunkered once compliant fuel has been obtained.

Whilst considering an individual FONAR report, Administrations may take into consideration the following:

  • The ship’s voyage plan;
  • The number of FONARs a ship has submitted to the Administration in the past 12 months;
  • Whether the quantity of non-compliant fuel bunkered is reasonable;
  • Any other evidence that would indicate the shipowner or operator has not planned effectively and taken all reasonable steps to ensure compliant bunkers will be available in the planned bunkering port.

If compliant fuels are not available and the ship has to bunker a non-compliant fuel:

  • A FONAR should be sent as soon as it is determined that the ship will be unable to procure compliant fuel oil and preferably before the ship leaves the port/terminal where compliant fuel cannot be obtained.
  • All FONARs are to be sent to the flag Administration and to the competent authorities in the relevant port(s) of destination. A copy of the FONAR should be kept on board for inspection for at least 36 months.
  • In order for Port State Control and flag States to verify the attempts made to obtain compliant fuel, documentary evidence of communications between the ship and fuel suppliers should be retained on board (e.g. emails to and from suppliers). If the charterer is responsible for providing the ship’s compliant fuel, then copies of the communications between the charterer and bunker suppliers should be provided to the ship and should also be retained on board;
  • If non-compliant fuel has been bunkered due to concerns that the quality of the compliant fuel available would cause operational or safety problems on board the ships, the concerns should be thoroughly documented.

Speaking about the new guidelines, Guy Platten, Secretary General of ICS said:

These new regulations are good for human health and good for the environment. With just six months to go before implementation these free ICS guidelines will help shipping companies with the vital task of preparing for compliance. We strongly recommend that shipowners prepare an Implementation Plan for each of their ships using the template agreed by IMO

He also added that the industry is focused on moving forward, but uncertainty remains about the availability of safe and compliant low sulphur fuels, and the operational challenges related to their use. For this reason, he believes that it is very important for everyone involved, including governments, oil producers and bunker suppliers, to redouble their efforts in order to make sure that safe and compatible fuels will be available in every port worldwide.

The updated guidelines have been produced with the support of ICS’s regional partners, the Asian Shipowners' Association (ASA) and the European Community Shipowners' Associations (ECSA).

You may check them in the PDF below