Singapore Directives – Implementation of IMO 2020 Ships’ Fuel Sulphur Limit

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TECHNICAL UPDATE: 2018/12/31

MPA Singapore has issued notification / guidance /information in addition to requirements IMO MARPOL Annexe VI for Owners/Operators of the vessels calling Port Of Singapore on and from 01 January 2020 onwards, says the technical update from Viswa Group.

Notification Details

AA) Vessel SPECIFIC SHIP IMPLEMENTATION PLAN ( SIP ) to be available on board. It is that while the SIP is not mandatory it can be utilized by owners/operators to help them demonstrate the actions taken by the ship to prepare for compliance with 0.5%m/m Sulphur limit requirement and would serve to facilitate the documentation check by Port state inspectors.

BB) SHIPS CALLING PORT OF SINGAPORE and intending to change over to compliant fuel are strongly encouraged to follow the SIP and do so as early as possible to identify any issues that may come up and corrective action can be taken,

CC ) FUEL OIL NON AVAILABILITY REPORT FORM ( FONAR) – Ships calling into Singapore and submitting a FONAR would need to declare so in the Electronic Notification of Arrival (EPAN)or Electronic Notice of Arrival. Such ships would be required to bunker compliant fuel in Singapore. The remaining non-compliant fuel oil should be disposed to appropriate reception facility.

DD ) ENFORCEMENT FOR SHIPS CALLING SINGAPORE – EFFECTIVE 01 January ships calling at Singapore may be subjected to verification of compliance with Sulphur limit including carriage ban during PSC and Flag State control inspection.

The ship inspection will normally be carried out in three steps. Starting from step 1 , should there be clear grounds , escalating to step 2 and step 3.

Step 1 – Document check

Step 2 –  Indicative Fuel oil analysis

Step 3 – Detailed fuel oil analysis (Laboratory Test)

EE ) ELECTRONIC PRE-ARRIVAL NOTIFICATION ( EPAN ) – With effect from 01 January 2020, the following shall complete EPAN and submit it to MPA Singapore

  • Owners /Agents/Masters of Passenger ships including High Speed passenger crafts.
  • Cargo Ships including high speed crafts of 500 GT and above.
  • Mobile Offshore Units including Mobile Offshore Drilling Units.

Vessels other than above shall complete and submit ELECTRONIC NOTICE OF ARRIVAL (ENOA), EPAN/ENOA to be submitted to MPA at least 24 hours before the arrival ship’s arrival in Singapore or if passage from last port of departure is less than 24 hours, the information is to be sent immediately upon departure from the from such port.

Information Requirements

MPA Singapore requires following information to be submitted;

i)Specify the method of compliance with Reg 14 of MARPOL Annexe VI with regard to fuel oil 0.5%m/m Sulphur content limit throughout the vessel stay in Singapore –

  • If the vessel is fitted with a scrubber, please specify type of scrubber installed.
  • WASH WATER DISCHARGE FROM SCRUBBERS IS BANNED IN SINGAPORE which means that Open Loop scrubber will not be permitted. Such vessel will need to switch to compliant fuel. Vessel should have sufficient fuel on board for the total stay in Singapore.
  • Closed loop scrubber will be acceptable.
  • If Hybrid scrubber is installed, it should be operated only in Closed loop mode.

ii) If the vessel will be using compliant fuel, please specify the type of compliant fuel; Whether LSFO / MGO /LNG or other clean fuel (please specify)

iii) If none of the above has FONAR report been completed?

MPA Singapore has also advised that in accordance with requirements of IMO it is working on ensuring the following;

  1. Availability of Compliant fuels such as LSFO / MGO / LNG will be available in Singapore.
  2. Reception facilities for Hybrid/closed loop scrubber residue and such residue to be disposed to licensed collectors.
  3. Supply of Neutralizing agents for Hybrid/ Closed loop Scrubbers.

MPA Singapore will act vigorously to ensure that the vessels full coming into Singapore fully comply with IMO MARPOL requirements and directives issued by MPA to minimize emissions and it has warned that offenders can be prosecuted in court and penalized.

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Source: Viswa Lab