IMO has discussed various issues pertaining to global shipping in the recently concluded MEPC74 meeting which was being held in its headquarters in London. From it emerged some guidance for shipowner and operators, as made available by them on their website.
Here’s a list of those guidelines and directives.
Ship tank configuration and fuel system
- The viscosity of most of these blended residual fuels is such that they cannot be used in distillate fuel-only systems and machinery, as they require heating for cleaning and combustion. A fully segregated fuel system for both distillate fuels and these new fuels is recommended.
- Tank cleaning is recommended when using a residual fuel tank for storing these new
fuels. This is to prevent sludge that has built up in these tanks from entering the fuel system. - Further information on tank cleaning is set out in appendix 3 of MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI.
Heating requirements
Due to the cold flow properties of most of these new fuels, permanent heating of the fuel may be necessary to minimize the risk of wax formation, also in storage. This is especially important in colder regions.
Fuel treatment system
Some of these new fuels may contain cat fines and/or sediments and therefore need on board cleaning. Separator temperature and settings should be adjusted to the fuels’ viscosity and density. Please refer to recommendations from OEM and fuel supplier.
Considering that many of these new fuels have lower viscosities compared to conventional residual fuels, care should be taken to ensure no overheating occurs.
ISO Standard for residual fuels
- The bunker market uses ISO 8217:2017 specifications to ensure that the properties
of the fuels it delivers conform to a standard that mean they comply with MARPOL Annex VI. - The existing ISO 8217:2017 specification for marine fuels takes into consideration
the diverse nature of marine fuels and incorporates a number of categories of distillate orresidual fuels, even though not all categories may be available in every supply location it covers all marine petroleum fuel oils used today as well as the 0.50% Sulphur fuels of 2020. - The General requirements, in the ISO 8217:2017 specification for marine fuels and characteristics, included in table 1 and 2 of ISO 8217:2017 identified safety, performance and environmental concerns and further takes into consideration the onboard handling requirements, including storage, cleaning and combustion aspects of all fuel oils used today and the anticipated fuel blends of 2020, irrespective of the sulphur content of the fuel oils.
- It is important that any new standards address and do not preclude the use of renewable and alternative non-fossil crude-derived products, so long as they comply with the chemical properties specified for these fuel oils.
Cylinder lubrication
The choice of cylinder lubricating oils will often follow the fuel type in use. So, when
changing to VLSFO operation from RM operation the choice of appropriate cylinder lubricating oil should be considered in accordance with the recommendations of the engine manufacturer.
Verification issues and control mechanism and actions
Survey and certification by Administrations
- When undertaking a survey in accordance with regulation 5 of MARPOL Annex VI,
the Administration should conduct a survey of a ship to verify that the ship complies with the provisions to implement the 0.50% sulphur limit. In particular, the Administration should check whether the ship carries compliant fuel oils for use, based on the Bunker Delivery Note (BDN) on board, any other document or fuel oil samples as appropriate consistent with the provisions of regulation 18 of MARPOL Annex VI. - If carriage of HSHFO for use is identified, the Administration should check whether regulation 3.2, regulation 4 of MARPOL Annex VI are applied to the ship, or if the ship encountered a fuel availability problem and is operating pursuant to regulation 18.2 of MARPOL Annex VI.
- When an Administration decides to analyse a fuel oil sample to determine compliance
with the sulphur limits in regulation 14.1 or 14.4, the final analysis should be carried out in accordance with ISO 8754:2003 by a laboratory that is accredited for the purpose of conducting the test in accordance with ISO/IEC 17025 or an equivalent standard. - The test results should be in accordance with ISO 8754 reporting protocol, meaning a tested value at or above 0.10% sulphur should be reported with no more than two decimal places.
- According to regulation 11.4 of MARPOL Annex VI, the Administration shall investigate any report of an alleged violation and thereafter promptly inform the Party which made the report, as well as the Organization, of the action taken. When informing the Organization, the MARPOL Annex VI GISIS module should be used.
Control measures by port States
Port States should take appropriate measures to ensure compliance with the 0.50%
of sulphur limit under MARPOL Annex VI, in line with the regulation 10 of MARPOL Annex VI
and the 2019 Guidelines for port State control under MARPOL Annex VI (resolution MEPC.321(74)) (2019 PSC Guidelines).
Specifically, the port State should conduct initial inspections based on documents and other possible materials, including remote sensing and portable devices. Given “clear grounds” to conduct a more detailed inspection, the port State may conduct sample analysis and other detailed inspections to verify compliance to the regulation, as appropriate.
Regulation 18.2.3 of MARPOL Annex VI requires a Party to take into account all
relevant circumstances and the evidence presented to determine the action to take, including not taking control measures. Administrations and port State control authorities may take into account the implementation plan when verifying compliance with the 0.50% sulphur limit requirement.
Inspections based on documents
During the port State control and other enforcement activities, the port State should
investigate whether a ship carries either compliant fuel oils or HSHFOs for use, based on the documents listed in paragraph 2.1.2 of the 2019 PSC Guidelines additionally records required to demonstrate compliance should also then be viewed.
Results from remote sensing could be used to trigger inspections and portable devices could be used during the initial inspections, as appropriate.
Remote sensing and portable devices are, however, of indicative nature and should not be regarded as the evidence of non-compliance, but may be considered clear grounds for expanding the inspection.
Port state should determine if regulations 3.2, 4 or 18.2.3 apply together with retained
bunker delivery notes and IAPP Certificate when considering the status of any HSHFO being
carried for use on board.
Fuel oil sample analysis
- When the port State identifies clear grounds of suspected non-compliance of a ship
based on initial inspections, the port State may require samples of fuel oils to be analysed. - The samples to be analysed may be either the representative samples provided with BDN in accordance with regulation 18.8.2, MARPOL delivered samples or samples from designated sampling points in accordance with the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1) (in-use fuel oil samples) or other samples obtained by the port State.
- Where the MARPOL delivered sample is taken from the ship a receipt should be
provided to the ship. The outcome of the analysis undertaken with appendix VI of MARPOL Annex VI should be advised to the ship for its records. - In detecting suspected non-compliance, the sample analysis should be conducted in
a uniform and reliable manner as described in paragraph 4.1.2. The verification procedure for MARPOL delivered samples should be in accordance with appendix VI7 of MARPOL Annex VI. - For other samples taken on board the ship, the in-use and onboard sample, the sample should be deemed to meet the requirements provided the test result from the laboratory does not exceed the specification limit +0.59R (where R is the reproducibility of the test method) and no further testing is necessary.
- Notwithstanding the above process, all possible efforts should be made to avoid a ship being unduly detained or delayed. In particular, sample analysis of fuel oils should not unduly delay the operation, movement or departure of the ship.
- If a non-compliance is established, consistent with regulation 18.2.3 the port State may prevent the ship from sailing until the ship takes any suitable measures to achieve compliance which may include de-bunkering all non-compliant fuel oil.
- In addition, the port State should report the information of the ship using or carrying for use non-compliant fuel oil to the Administration of the ship and inform the Party or non-Party under whose jurisdiction a bunker delivery note was issued of cases of delivery of non-compliant fuel oil, giving all relevant information.
- Upon receiving the information, the Party detecting the deficiency should report the information to the MARPOL Annex VI GISIS module in accordance with paragraph 3.4 ofthese Guidelines.
- The Parties (the port and flag States), however, may permit, with the agreement of the destination port authority, a single voyage for bunkering of compliant fuel oil for the ship, in accordance with regulation 18.2.4 of MARPOL Annex VI. The single voyage should be one
- Amendments to MARPOL VI, Appendix VI, Verification procedures for a MARPOL Annex VI fuel oil sample (regulation 18.8.2 or regulation 14.8), expected to be adopted in Spring 2020 and set out in annex 11 to document MEPC 74/18 way and minimum for bunkering, and the ship proceeds directly to the nearest bunkering facility appropriate to the ship.
- In the case that the parties permit a single voyage of a ship, the port State should confirm that the Administration of the ship has advised the authority at the destination port of the approval for a single voyage including information on the ship granted with the approval and the certified record of analysis of the sample as the evidence.
- Once confirmation has been provided the port State should permit the ship to sail as agreed.
- If the port State is made aware that a ship is carrying non-compliant fuel oil, which is
- not for use through an equivalent method under regulation 4 or a permit under regulation 3.2 of MARPOL Annex VI, the port State should take action to confirm the fuel is not being used.
- Action to confirm should include, but is not limited to the examination of the oil record bookand the record of tank soundings. Where necessary the port State may require tank soundings to be undertaken during the inspection. Where it is determined that the fuel has been used the control action in paragraph 4.2.4.5 should be applied.
Other open-sea compliance monitoring tools:
- fuel oil changeover calculator;
- data collection system for fuel oil consumption of ships (resolution MEPC.278(70)); and
- continuous SOX monitoring.
Control on fuel oil suppliers
- Designated authorities should, if deemed necessary, take a sample and test fuel oils
from bunker barges or shore bunker terminals. - Sampling of fuel oils in bunker barges or shore bunker terminals can be taken and tested in the same manner that the MARPOL delivered fuel oils are tested by the PSC.
- All possible efforts should be made to avoid a ship being unduly detained or delayed.
- If a sample is analysed, sample analysis of fuel oils should not unduly delay the operation, movement or departure of the ship.
- If non-compliance, such as issuance of an incorrect BDN or a BDN without measurement of sulphur content, was found, the designated authorities should take appropriate corrective measures against the non-compliant supplier.
- In such case, the designated authorities should inform the Organization for transmission to the Member States of the non-compliant supplier, in accordance with the regulation 18.9.6 of MARPOL Annex VI and paragraph 4.4 of these Guidelines.
Sharing Non-compliance Information
- When a Party finds a non-compliance of a ship or a fuel oil supplier, the information
of the non-compliance should be reported to the MARPOL Annex VI GISIS module
(regulation 11.4). - Publication of information on non-compliant ships/fuel oil suppliers or a reporting
scheme to IMO to be registered on centralized information platforms are proposed as elements of an effective enforcement strategy. - Various PSC regimes have successfully used the publishing of information related to substandard ships/fuel suppliers as a deterrent to non-compliance.
- Port States also need to report detentions of ships to IMO which may affect the future PSC targeting of the ship.
- The IMO GISIS database already makes available certain
information related to non-compliances with the MARPOL Annex VI regulations.
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Source: Resolution MEPC.320(74)
