INTERTANKO Developing IMO 2020 Implementation Practical Guide

• Practical challenges with fuels availability and compatibility.
• Flag and Port States to implement the regulation uniformly and consistently.
• Scrubbers increasingly viewed as a vital solution to alleviate the pressure on low sulfur fuel oil demand as January 2020 approaches.
• Ships equipped with scrubbers will need to have compliant fuel on board to use in ports that have banned wash water discharge.
• Joint Industry Guidance should be read together with the ISO/ Publicly Available Specification (PAS) 23263.

According to a Platts report, INTERTANKO has told in an APPEC interview that it is developing a practical guide to assist its membership in their preparation and implementation of the International Maritime Organization’s low sulfur mandate.

IMO 2020 Implementation guide

Elfian Harun, environment manager and assistant regional manager Asia-Pacific, INTERTANKO, said that INTERTANKO is developing a practical guide to assist its membership in their preparation and implementation of the International Maritime Organization’s low sulfur mandate.

“We are grateful for the contingency measures developed at MEPC [Marine Environment Protection Committee] 74 (May 2019) for unforeseen and unavoidable cases that may occur despite the ship’s best efforts,” said Harun in an e-mail. He was also a speaker at the 35th Annual Asia Pacific Petroleum Conference in Singapore.

Implementation remains a challenge

There are indeed a number of practical challenges ships may encounter if fuels are not available or, if available, not compatible with each other, he said.

Consistent implementation and enforcement of IMO’s 2020 rule still remains challenging even though huge investments are being made by some shipowners to comply with the regulation, Harun said. 

Port authorities part

So there is a need for both Flag and Port States to implement the regulation uniformly and consistently, Harun said.

“We recognize that port authorities would have to decide how they could regulate bunker suppliers and what action they could take for those who are found to have supplied non-compliant fuel. We would wish this will happen very soon,” he said.

Look for scrubbers details 

• Scrubber is one of the solutions provided by the MARPOL regulations 
• They are being increasingly viewed as a vital solution to alleviate the pressure on low sulfur fuel oil demand as January 2020 approaches.

Some estimates shared by delegates at APPEC showed that the number of scrubbers operational worldwide will be over 3,000 in early 2020.

Harun said:

• Shipowners using scrubbers should work closely with the scrubber manufacturer to ascertain the sulfur content of fuel to optimal performance and full compliance.
• The operational manual, which scrubber manufacturers should provide, needs to include specific operational instructions to adjust the engine load so that the system keeps the sulfur oxides emission in compliance.
• It should also include a troubleshooting section to guide the operator to fix possible malfunctions as soon as possible.
• Ship operators should also review their charter party clauses as they would need to make provisions for compliance with emission control areas limits, the eventual ban on discharge of wash-water at certain ports and cases of scrubber malfunction.

“We encourage such owners to consider using INTERTANKO’s model clauses,” Harun said.

Open-loop scrubber discharge

With an increasing number of ports not allowing the discharge of wash water from open loop scrubbers, ships equipped with scrubbers will need to have compliant fuel on board to use in such ports, Harun said.

Should the scrubber break down, owners would also have to be familiar with IMO requirements on how to address the issues, he added.

More preparation needed

The Joint Industry Guidance published recently provides a comprehensive overview of the specific safety and operational challenges the industry is set to face with

• handling, 
• storage, 
• supply and 
• use of the 0.50% compliant fuels, among other details.

“It is recommended that the Guidance be read together with the ISO/ Publicly Available Specification (PAS) 23263 ‘Considerations for fuel suppliers and users regarding marine fuel quality in view of the implementation of maximum 0.50% S in 2020’ that will address key characteristics and properties of 0.50% m/m [mass by mass] sulfur content limit compliant fuel oils being placed on the market to meet the 2020 sulfur requirements,” Harun said.

Machinery systems pilot testing

“We are informed that many ships are testing their machinery systems using the 0.50% sulfur limit compliant fuel oils. This pilot testing before the end of this year is recommended,” he said.

To their best ability, shipowners need to anticipate their vessels’ trading pattern and seek information and possible agreements with bunker suppliers at the ports that ships may call, Harun said.

Importance of documentation

Accurate record keeping and documentation is very important. Hence, the crew on ship would need to be trained to understand the various regulatory requirements, he said.

Owners would also need to know their regulatory options and be familiar with all amendments, guidelines, best practices and circulars that have been/ will be issued by IMO, he added.

INTERTANKO, a recognized non-governmental organization, has observer status at the IMO, the United Nations Conference on Trade and Development and the International Oil Pollution Compensation Funds and contributes actively to their work.

Did you subscribe to our daily newsletter?

It’s Free! Click here to Subscribe!

Source: Platts

• 
• 
• 
• 
• 
• 
• 
•