Preparing for the 2020 Low Sulphur Limit

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The IMO’s Marine Environment Protection Committee (MEPC) has decided the 1st of January 2020 as the enforcement date for the 0.50% m/m global sulphur cap on marine fuel at its 70th session held on 24th – 28th October 2016.  

In preparation for this implementation extensive work has been carried out by IMO by its Intersessional Working Group that met during 9th -13th July 2018.

Proposed implementation plan

A Draft Guidance for a consistent implementation plan on 0.50% sulphur limit under MARPOL Annex VI was finalized at the IMO’s intersessional meeting.

The MEPC 73 (22-26 October 2018) is due to approve and issue it as soon as possible. The guidance includes sections on:

  • Risk assessment and mitigation plan (impact of new fuels)
  • Fuel oil system modifications and tank cleaning (if needed)
  • Fuel oil capacity and segregation capability
  • Procurement of compliant fuel
  • Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil)
  • Documentation and reporting

The meeting agreed to recommend MEPC 73 to invite the Maritime Safety Committee (MSC 100) to develop industry guidance on safety concerns and possibly develop a training material.

Also, they carried out works on developing a range of other guidance, on the impact of fuel on machinery systems resulting from new fuel blends or fuel types; verification issues and control mechanism and actions, including port State control and samples of fuel oil used onboard; a standard reporting format for fuel oil non-availability; and safety implications relating to the option of blended fuels.

Apart from the guidance on safety, there were draft amendments developments to update the 2009 Guidelines for port State control under revised MARPOL Annex VI (resolution MEPC.181(59)) and Guidelines for onboard sampling for verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864). These will be further developed and finalized during the next PPR 6 session in February 2019.

Exception for scrubbers

The MEPC 73 is also expected to consider for approval, with a view to adoption draft amendments to MARPOL Annex VI to prohibit the carriage of non-compliant fuel oil.

The exception would be for ships fitted with scrubbers, which would allow ships to continue to use “heavy” high sulphur fuel oil.

For a ship without an approved equivalent arrangement, should not carry fuel oil used or for use on board with sulphur content beyond 0.50%.

Exception

Consistent implementation of the 0.50% sulphur limit for all ships will ensure a level playing field is maintained, with the result that the expected improvement of the environment and human health will be achieved.

Although, the limit will remain at 0.10% in the four internationally designated Emission Control Areas (ECAs): the Baltic Sea area; the North Sea area; the North American area (covering designated coastal areas off the United States and Canada); and the United States Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

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Source: UK P&I