2020 Sulphur Cap updates
09 July 2019 | C19029
The global 0.50% m/m limit for sulphur in fuel oil used on board ships established by Regulation 14.1.3 of MARPOL Annex VI shall enter into force on January 01, 2020 and this Circular contains updates concerning this new Regulation.
Ship Owners/ Managers/ Operators | Surveyors/Auditors
The Marine Environment Protection Committee at its 74th session approved and adopted a comprehensive set of guidance and guidelines to support the consistent implementation of the lower 0.50% limit on sulphur in ships’ fuel oil, which will enter into effect from January 01, 2020.
Dromon has already released the first updates concerning the 2020 Sulphur Cap compliance through C19006.
MEPC.1/Circ.795/Rev.4 – Unified Interpretation to MARPOL Annex VI
The interpretation of regulation 14.1 of MARPOL Annex VI for the prohibition on carriage of non-compliant fuel oil should be applied to the fuel oil of emergency equipment.
MEPC.1/Circ.864/Rev.1 – 2019 Guidance for on board sampling for the verification of the Sulphur content of the fuel oil used on board ships
In accordance with the revised regulation 14 of MARPOL Annex VI each ship subject to survey and certification under MARPOL Annex VI shall be fitted or designated with sampling point(s) for the purpose of taking representative samples of the fuel oil being used on board the ship. This is not applicable to a fuel oil service system for a low-flashpoint fuel for combustion purposes for propulsion or operation on board the ship.
MEPC.1/Circ.881 – Guidance for Port State Control on contingency measures for addressing non-compliant fuel oil
The Circular provides guidance for port State control on contingency measures for addressing non-compliant fuel oil. The guidance covers possible actions to be taken, following discussions between ship, flag State and port State, when a ship is found to have on board non-compliant fuel oil either as a consequence of compliant fuel oil being not available when the ship bunkered fuel oil or the ship identifying through post bunkering testing that the fuel oil on board is non-compliant.
MEPC.1/Circ.883 – Guidance on indication of ongoing compliance in the case of the failure of a single monitoring equipment, and recommended actions to take if the exhaust gas cleaning system (EGCS) fails to meet the provisions of the 2015 Guidelines (Res. MEPC.259(68))
The Guidelines include information:
- for system malfunction that leads to emission exceedance;
- short terms exceedances of the applicable Emissions Ratio; and
- interim indication of ongoing compliance in the case of sensor failure.
Any EGCS malfunction that lasts more than one hour or repetitive malfunctions should be reported to the flag and port Stateʹs Administration along with an explanation of the steps the ship operator is taking to address the failure. EGCS malfunction shall be recorded in the EGCS Record Book.
At their discretion, the flag and port State’s Administration could take such information and other relevant circumstances in to account to determine the appropriate action to take in the case of an EGCS malfunction, including not taking action.
MEPC.320(74) – 2019 Guidelines for consistent implementation of the 0.50% Sulphur limit under MARPOL Annex VI
The Committee adopted 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI – with sections on the impact on fuel and machinery systems resulting from new fuel blends or fuel types; verification issues and control mechanism and actions, including port State control and samples of fuel oil used on board; a standard reporting format for fuel oil non-availability (fuel oil non-availability report (FONAR); and possible safety implications relating to fuel oils meeting the 0.50% sulphur limit.
BIMCO and Intertanko joint Guidance: Contractual issues for scrubber-fitted ships
BIMCO and Intertanko have jointly produced Q&A, which focus on the potential contractual issues that parties should be aware of when chartering scrubber-fitted ships. The objective is to highlight and address the relevant clauses and concepts charterers and owners should take into consideration during their negotiations.
Ship owners / Managers / Operators should take into consideration the above guidelines and urged to develop their implementation plan and take, outlining how the ship may prepare in order to comply with the required sulphur content limit of 0.50% by 1 January 2020.
Source: IMO, CSC, BIMCO & Intertanko