2019 is a busy year in terms of adopted International Maritime Organization (IMO) regulation with the forthcoming SOLAS amendments, significant milestones for the fuel oil consumption data collection system (DCS), along with the EU’s Monitoring, Reporting and Verification (MRV) regulation, and the MARPOL Annex VI global sulphur limit coming into force in January 2020. Andrew Sillitoe explains why these regulations are important to shipowners and operators.
Amendments to SOLAS Chapter II-1 on damage stability
Amendments to SOLAS Chapter II-1 to harmonise cargo ship and passenger ship damage stability came into force in 2009. These made probabilistic damage stability the main method for calculating damage stability for passenger ships and general cargo ships. Once the amendments came into use, the need for a number of revisions became apparent, so the IMO undertook a major review of the subdivision and damage stability requirements in Chapter II-1 of SOLAS. Significant changes include, amongst others:
- Requiring limiting stability information to include trim.
- Modifying the required subdivision index, R, for passenger ships.
- Amending the calculation for S factor.
- Providing limits on the distance between small wells and the keel line unless a damage stability check is made and introducing a minimum limit for the vertical damage extent. Permitting a butterfly valve at the collision bulkhead on cargo ships.
- Requiring testing of watertight hatches.
- Requiring air pipes which terminate in a superstructure to be considered unprotected openings unless fitted with a watertight means of closure.
- Removing the possibility of leaving watertight doors open.
These amendments need to be taken into account in the design of ships contracted from 1 January 2020.
Monitoring and reporting of fuel oil consumption and CO2 emissions
2019 brings significant milestones in both the EU’s MRV regulation and the IMO’s fuel oil consumption DCS requirements under MARPOL Annex VI. For EU MRV, the first year of monitoring ended in 2018 and the first reporting is taking place in early 2019. For IMO DCS, 2019 is the first monitoring period. In order to comply with the IMO DCS requirements, each affected existing vessel’s Ship Energy Efficiency Management Plan (SEEMP) will by now have been updated with a new Part II to provide the ship-specific methodology and processes to be followed for the data collection. New ships will need to have this upon delivery. After verified data has been reported, it will be transferred to the IMO Ship Fuel Oil Consumption Database where it will be kept anonymised. This will help the IMO to produce annual reports and evaluate the need for further technical and operational measures for enhancing the energy efficiency of international shipping.
For ships subject to the EU MRV regulation, the first monitoring period has now finished and the collected monitoring reports need to be submitted for verification. For LR clients, all documentation (monitoring plans and emission report evidence packs), except emission reports, should be submitted to CO2 Verifier. The regulation requires that clients submit emission reports directly to THETIS-MRV, which is operated by the European Maritime Safety Agency (EMSA). As the accredited verification body, LR will then retrieve the reports from THETIS-MRV for verification and upload them to CO2 Verifier along with related LR deliverables.
Global fuel sulphur limit reduction to 0.50% and associated carriage ban
From 1 January 2020, MARPOL Annex VI will require all new and existing ships to comply with the new global 0.50% sulphur limit using the most appropriate method for that ship. The options include low sulphur fuels and alternative fuels, or alternative arrangements such as an exhaust gas cleaning system (also known as scrubbers). The global limit means that this applies to all areas outside of Emission Control Areas (ECAs). Unless a ship has an alternative arrangement such as a scrubber, shipowners and managers will need to consider debunkering any high sulphur fuel oil that is not used up before 1 January 2020. The IMO has also adopted a requirement to prohibit ships from carrying fuel oil with a sulphur content above 0.50% if its purpose is for combustion for propulsion or operations on board, unless the ship has an approved equivalent arrangement in place. This is to help support full global compliance. Due to the IMO procedural requirements for amendments to MARPOL, this will enter into force on 1 March 2020, but it is worth clarifying that this does not change the sulphur limit reduction date.
For further information about these or any other upcoming regulatory changes, please visit www.lr.org/imo where you can also subscribe to receive our email updates of IMO agendas, reports and our forthcoming legislation document.
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