- An increasing number of shippers are opting for FONAR, the ports and ship owners have been warned not to use it as a free pass.
- FONAR is merely a reporting mechanism to report non-compliance at the discretion of the port state control to decide on what actions they may take
- FONAR must be supported with evidence that shows full and proper voyage planning with proper documentation.
- If proof is not available, shippers have to produce a communication log with each supplier and their full contact details.
According to an article published in the Ship and Bunker News, the fuel choices for ships have been broadly made, suppliers have developed plans which are being announced to the market, the focus is shifting to buyers and their final preparations for next year.
Utilization of FONARs
There is a focus on the unfortunate situations that will occur from time to time and
require the market to utilize FONARs (Fuel oil non-availability reports). With ~119 working days to go, how prepared are shippers buying process and procedures to comply and support FONAR submission when compliance is genuinely not possible?
Key findings related to FONAR’s
- A FONAR is merely a reporting mechanism to report your non-compliance, it is then at
the discretion of the port state control to decide on what actions they may take, which
may include taking no action at all. The quality of the report and evidence used to support it will be key in helping the port state decide what action to take. - A FONAR must be supported with evidence that shows full and proper voyage planning.
Do your procedures produce documentary evidence that a fuel plan covering all supply
options and ports was considered pre, post-fixture and after any subsequent voyage
changes? Do you have a full, independent and accurate database of global bunker
supply options? - When submitting a FONAR, all previous FONARS from the previous 12 months for the same port state and same owner/operator must also be submitted.
- Where the non-availability reason is selected for FONAR, extensive evidence is required to support this. Produce a communication log with each supplier and their full contact details (this level of detail is required rather than just highlighting a back to back trader that may have been used).
P&I cover validity/seaworthiness
Many clubs have made the following statement – accidental non-compliance subject to terms maybe covered whereas cover for fines and detention would not be covered where it is a result of inaccurate/inadequate record-keeping reinforcing the need for improved planning and evidence gathering.
Commercial considerations
Price/Credit is not considered a valid reason for a FONAR – it is clear that traders will not
have the adequate working capital to support the entirely new market and owners will have to establish their own credit lines. Fortunately, in the wake of the OW collapse and
the uncertainty this brought, physical suppliers are more open than ever to considering direct credit where they may secure the debt against a ship and adding protection for the buyer also against double payment risk.
It is clear that full detailed voyage planning and record keeping are key to ensuring compliance and having the right evidence readily available to comply from 1st January. For our part, we have made amendments to our working practices to ensure we will always have the right information available quickly to support our customers in the planning stage with tools
They have also developed an operating system to record all supplier communications and provide an auditable trail of all suppliers responses to a bunker enquiry and be easily imported into the FONAR template to help owners make a full and high-quality report.
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Source: Ship&BunkerNews
