Standard Club: Regulation Update 2022/23

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The shipping industry is riding waves of regulatory change as sustainability has been at the forefront of decision-making of the International Maritime Organization (IMO).

The Standard Club provides an overview on some of the important IMO regulations that will enter into force in 2022 and 2023.

Regulations that came into force on 1 April 2022

Amendments to regulations 2, 14, 18, Appendix I and VI of MARPOL Annex VI – MEPC.324(75) – Fuel oil sampling and verification

To support consistent implementation and verification of the 0.50% sulphur limit, MARPOL Annex VI has been amended to introduce definitions distinguishing between ‘in-use’ and ‘on board’ fuel oil samples taken from a vessel.

To facilitate the need for taking ‘in-use’ samples, ships constructed before 1 April 2022 are required to designate or, if necessary, fit sampling points no later than the first IAPP renewal survey on or after 1 April 2023. For ships built on or after 1 April 2022, sampling points needs to be in place and designated upon delivery. These requirements are not applicable to a fuel oil service system for a low-flashpoint fuel, i.e., having a flashpoint less than 60oC.

Consequentially, Appendix I has been amended to update the International Air Pollution Prevention (IAPP) certificate to add a reference to sampling points and to note where there is an exemption to the provision for low-flashpoint fuel.

Appendix VI of MARPOL Annex VI has also been revised to simplify the verification procedure for ‘MARPOL delivered fuel oil sample’ and to add verification procedures for the ‘in-use’ and ‘on board’ samples. To avoid ships being unjustly fined for marginal excess in sulphur content beyond their control, 95% confidence will be allowed. This implies that when testing the ‘in-use’ and ‘on board’ samples, the acceptable sulphur limits are extended to 0.11% and 0.53% for 0.10% and 0.5% respectively.

For further details, please refer to the club’s article on ‘Guidelines for fuel oil sampling and designated sampling points’. Members are recommended to review their fuel oil sampling procedures to ensure that samples can be drawn safely from the ship’s fuel service system in compliance with these guidelines.

Amendments to regulations 20 and 21 of MARPOL Annex VI – MEPC.324(75) – Energy Efficiency Design Index (EEDI)

A new paragraph 3 under regulation 20 has been added, mandating reporting of the required and attained EEDI values and relevant information to the IMO.

Additionally, the Table 1 of regulation 21 on required EEDI has been replaced with a view to advance the starting date of EEDI Phase 3 from 1 January 2025 to 1 April 2022 for container ships, large gas carriers (>15,000 DWT), general cargo ships, LNG carriers and cruise passenger ships having non-conventional propulsion. A stepwise reduction requirement will apply to container ships, starting with a 30% reduction rate for small container vessels and increasing up to 50% for very large container ships.

The EEDI reference line for large bulk carriers (>279,000 DWT) will be constant, calculated based on 279,000 DWT, regardless of the actual DWT.

Members are recommended to take note of these requirements as there are a number of technical and operational measures that needs to be considered for the reduction of green-house gas (GHG) emissions.

Click HERE to read about the other IMO regulations to will come into force in 2022 and 2023.

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Source: The Standard Club 

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