The recently concluded MEPC74 meeting held in London last month has set a guideline report on what needs to be done in case of non-availability of compliant and how to report it in different ports during inspections. Here’s a detailed insight on that report as made public by the IMO.
About the Report
This report is to be sent to the flag Administration and to the competent authorities in
the relevant port(s) of destination in accordance with regulation 18.2.4 of MARPOL Annex VI.
- The report shall be sent as soon as it is determined that the ship/operator will be unable to procure compliant fuel oil and preferably before the ship leaves the port/terminal where compliant fuel cannot be obtained. A copy of the FONAR should be kept on board for inspection for at least 36 months.
- This report should be used to provide evidence if a ship is unable to obtain fuel oil compliant with the provisions stipulated in regulations 14.1 or 14.4 of MARPOL Annex VI.
Mandatory Observations Before Filing FONAR Report
- A fuel oil non-availability report is not an exemption. According to regulation 18.2 of
MARPOL Annex VI, it is the responsibility of the Party of the destination port, through its
competent authority, to scrutinize the information provided and take action, as appropriate.
- In the case of insufficiently supported and/or repeated claims of non-availability, the
Party may require additional documentation and substantiation of fuel oil non-availability
claims. The ship/operator may also be subject to more extensive inspections or examinations while in port.
- Ships/operators are expected to take into account logistical conditions and/or
terminal/port policies when planning bunkering, including but not limited to having to change berth or anchor within a port or terminal in order to obtain compliant fuel.
- Ships/operators are expected to prepare as far as reasonably practicable to be able
to operate on compliant fuel oils. This could include, but is not limited to, fuel oils with different viscosity and different sulphur content not exceeding regulatory requirements (requiring different lube oils) as well as requiring heating and/or other treatment on board.
Particulars of ship
- Name of ship: ______________________________________________________
- IMO number: ________________________________________________________
- Flag: _____________________________________________________________
- (if other relevant registration number is available, enter here): __________________
Description of ship’s voyage plan
Provide a description of the ship’s voyage plan in place at the time of entry into
“country X” waters (and ECA, if applicable) (Attach copy of plan if available):
Details of voyage:
- Last port of departure
- First port of arrival in “country X”
- Date of departure from last port (dd-mm-yyyy):
- Date of arrival at first “country X” (dd-mm-yyyy):
- Date ship first received notice that it would be transiting in “country X” waters
(and ECA, if applicable) (dd-mm-yyyy):
- Ship’s location at the time of notice:
- Date ship operator expects to enter “country X” waters (and ECA, if applicable)
- Time ship operator expects to enter “country X” waters (and ECA, if applicable)
- Date ship operator expects to exit “country X” waters (and ECA, if applicable)
- Time ship operator expects to exit “country X” waters (and ECA, if applicable)
- Projected days ship’s main propulsion engines will be in operation within
“country X” waters (and ECA, if applicable):
- Sulphur content of fuel oil in use when entering and operating in “country X” waters (and ECA, if applicable):
Evidence of attempts to purchase compliant fuel oil
- Provide a description of actions taken to attempt to achieve compliance prior to
entering “country X” waters (and ECA, if applicable), including a description of all attempts that were made to locate alternative sources of compliant fuel oil, and a description of the reason.
- why compliant fuel oil was not available:
- Name and email address of suppliers contacted, address and phone number and date
of contact (dd-mm-yyyy):
- Please attach copies of communication with suppliers (e.g. emails to and from suppliers)
In case of fuel oil supply disruption only
- Name of port at which ship was scheduled to receive compliant fuel oil:
- Name, email address, and phone number of the fuel oil supplier that was scheduled
to deliver (and now reporting the non-availability):
Operation constraints, if applicable
- If non-compliant fuel has been bunkered due to concerns that the quality of the
compliant fuel available would cause operational or safety problems on board the ships, the concerns should be thoroughly documented.
- Describe any operational constraints that prevented use of compliant fuel oil available
- Specify steps taken, or to be taken, to resolve these operational constraints that will
enable compliant fuel use:
Plans to obtain compliant fuel oil
- Describe availability of compliant fuel oil at the first port-of-call in “country X”, and
plans to obtain it:
- If compliant fuel oil is not available at the first port-of-call in “country X”, list the
lowest sulphur content of available fuel oil(s) or the lowest sulphur content of available fuel oil at the next port-of-call:
Previous Fuel Oil Non-Availability Reports
If shipowner/operator has submitted a Fuel Oil Non-Availability Report to “country X”
in the previous 12 months, list the number of Fuel Oil Non-Availability Reports previously
submitted and provide details on the dates and ports visited while using non-compliant fuel oil, as set out below:
- Date (dd-mm-yyyy):
- Type of fuel:
- Master/Company information
- Master name:
- Local agent in “country X”:
- Ship operator name:
- Shipowner name:
- Name and position of official:
- Email address:
- Address (street, city, country, postal/zip code):
- Telephone number:
- Signature of Master:
- Print name:
- Date (DD/MM/YYYY):
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