The
global sulphur cap, a MARPOL Annex VI requirement, enters into force on 1
January 2020, less than nine months away. In this short article we provide
recommendations for managing the transition where the strategy is to use
conventional compliant fuel, that is to transition from HSFO to a low sulphur
fuel oil or distillate.
The cap
means that the sulphur content of fuel oil used on board commercial ships
trading globally must not exceed 0.50% m/m. This is a reduction from the
current global limit of 3.50% m/m that applies outside of designated emission
control areas (ECAs). However, the 0.10% sulphur limit shall continue to apply
inside ECAs and for ships at berth in EU ports.
Ships can
meet the 2020 sulphur cap requirement by using:
·
conventional compliant fuel such as sulphur
controlled distillates or residual fuel oils;
·
alternative fuel types that meet the sulphur
limits, such as LNG, methanol or hydrogen, some biofuels and synthetically
manufactured fuel oils; or
·
an equivalent means to remove sulphur oxides from
post-combustion exhaust emissions, such as an exhaust gas cleaning system
(EGCS), more often referred to as a “scrubber”.
To assist
global implementation of the sulphur limits Regulation 14.1 of MARPOL Annex VI
prohibits the carriage of non-compliant fuel oil from 1 March 2020 unless the
vessel is fitted with a scrubber.
The
“compliance strategy”, which is primarily a choice between stemming compliant
fuel or using a scrubber, is a commercial decision for shipowners and
charterers.
Ready, steady... 2020!
Owners
and charterers should work with their counterparties to do some or all of the
following to manage the transition to low sulphur fuels:
·
Use the BIMCO 2020 clauses. The 2020 Fuel
Transition Clause for Time Charter Parties and the 2020 Marine Fuel Sulphur
Content Clause for Time Charter Parties were published on 10 December 2018 and
provide an objectively ‘fair’ approach to apportionment of liability for some
of the key issues arising out of the change in regulation.
·
Prepare a Ship Implementation Plan (SIP) and carry
it out. Maintain a record of its implementation onboard. IMO guidance on
the use of SIPs was approved during MEPC73 in October 2018 and has been
issued as MEPC.1/Circ.878. As a minimum, the plan
should provide guidance on
o how to
segregate different fuel grades,
o how and
when to carry out compatibility testing, and
o how and
when to carry out tank cleaning.
·
Work with your counterparty. If your
charterparty is going to straddle the 1 January 2020 deadline, begin a
conversation now with your owner/charterer. Come to an agreement as to how you
will handle the cleaning of tanks, and the purging of all pipework and the fuel
oil service system, of all HSFO residues.
·
Decide how and when tank cleaning will take place.
Will it be during dry dock or whilst the vessel is in service? If you
intend to dry dock, make sure that it is booked well in advance of the 1
January 2020 deadline.
·
Identify what type of compliant fuel you intend to
use and begin to source reliable suppliers. Seek advice from engine
manufacturers prior to ordering and using new/unfamiliar types of fuel.
·
Brief the Master and crew. Make sure they are
prepared for the 1 January 2020 deadline change and the processes that will
need to be put in place in advance of that date. Make sure they understand
the importance of the entire ship’s system being purged of any HSFO residues.
Have a plan in place for any unforeseen breaches and make sure your Master and
crew know what to do and how to complete any necessary paperwork, including the
IMO Draft Report on Compliant Fuel Non-Availability.
The
MARPOL 0.50% sulphur regulation change will come into force on 1 January
2020. This deadline will not be put back. To make sure that you are
properly prepared we would encourage you to adopt some of the suggestions set
out above. MEPC 74 is scheduled to take place between 13 – 17 May, to
finalise the IMO’s response to some of the still unresolved 2020 issues. A
further Gard update will follow publication of the report of that
meeting. In the meantime, if you require further advice or guidance,
please contact your Gard representative who will be able to assist you further.
http://www.gard.no/web/updates/content/27391956/the-final-countdownthe-2020-sulphur-cap
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