The clock is ticking: How will the IMO sulphur 2020 limit affect you?

The 1 January 2020 deadline for MARPOL Annex VI regulation 14.1.3 is fast approaching which will mandate ships to burn fuel with sulphur content less than 0.50% outside Emission Control Areas (ECA-SOx). We know from conversations with customers that many ship operators have already put the preparatory plans in place and are busy working on their Ship Implementation Plans (SIPs), ready for the deadline.

On the regulatory side, some important decisions are being made by the IMO that are shaping the discussions and impacting the choices being made by various stakeholders. The supply industry is also preparing itself for this change by announcing the availability of 0.50% sulphur fuels in various ports around the world. Based on this information, several market surveys indicate that the majority of shipowners and operators intend to comply with the MARPOL Annex VI regulation 14.1.3 by burning 0.50% Very Low Sulphur Fuel Oil (VLSFO).

To support those preparing for this change, specifically shipowners and operators, we have put together a summary of the most frequently asked questions:

Is a Ship Implementation Plan (SIP) mandatory?

As per MEPC.1-Circ.878, a SIP is not mandatory, though it is ship-specific and owners and operators are recommended to prepare one as it provides an opportunity for technical staff on board to review the ship’s fuel management procedures in view of the expected variability in quality of 0.50% sulphur fuels. Moreover, this exercise will help technical staff set timelines for the vessel when taking necessary operational, design, and system amendments in the run-up to 1 January 2020. LR continues to support customers with fuel change management procedures before this regulation comes into force, and is helping customers prepare ship-specific SIPs for when they transition from HSFO to VLSFO. Contact your local LR office for more information.

Should there be a comprehensive tank cleaning before 1 January 2020?

Each ship is different with regards to their machinery management procedures, bunker tank design, and the quality of Heavy Fuel Oil (HFO) they have consumed. Hence an assessment should be performed on the condition of each HFO bunker tank and a decision needs to be made on the appropriate course of action. There are a few options being considered by the ship operators such as:

• Flushing tanks with distillate ultra-low sulphur fuels to naturally flush the tanks, piping and fuel system components of high sulphur fuel oil and sediment
• Using one or more bunkerings of 0.50% fuels well before the enforcement date, again having a flushing effect
• Use of a specialist additive dosed over several bunker loads before the first 0.50% is loaded to clean the tanks. (Note: this approach may require at least six months, if not more, to be effective)
• Manual / physical cleaning
• A combination of any of the above

The effectiveness of these approaches would depend on the final condition of the tank and how well it is executed. When first using 0.50% fuels, crews are also recommended to carry out sulphur sample checks from the system periodically to provide indications of the tank’s compliance condition.

What are the major quality concerns with 0.50% fuels?

Some of the main challenges and risks with the new 0.50% fuels are:

• Compatibility between fuels from different sources
• Long-term stability of the blends
• Significant variability of certain physical parameters from different sources such as viscosity and density
• Compliance (sulphur – blending to the limit)
• Cold flow properties (high pour point fuels and/or waxy fuels potentially causing blocked filters/sludging if handled at inappropriate temperatures)
• Combustion performance of new blends

Handling of these 0.50% sulphur fuels will become a bigger challenge if there is a lack of preparation and planning, which includes understanding the fuel properties and making necessary operational adjustments to ensure seamless operation. Crew training will be important because they are on the frontline handling various technical challenges and ensuring resilient ship operations. It is well recognised, however, that there are many thousands of ships that have not yet truly experienced operations on much else other than high-sulphur residual fuel oils and only the occasional switch to distillates, this would suggest that the lessons learnt by some from the switch in 2015 will have to be learnt by many more for 2020 and the same technical and operational warnings will need to be reinforced.

We expect that an increasing number of vessels will start trialling these 0.50% fuels in the second half of 2019. LR’s Fuel Oil Bunkering Analysis Advisory Service (FOBAS) team is monitoring the situation closely and, as soon as there is significant take up, we will build the 0.50% sulphur fuel characterisation matrix.

What is the update from ISO?

The work on the ISO/PAS 23263:2019 guidelines for fuel suppliers and users regarding marine fuel quality, considering the implementation of maximum 0.50% sulphur in 2020, is currently undergoing a balloting process as per ISO procedures. It is expected that the ISO/PAS 23263 will be finalised and available as reference for ship operators and suppliers by the end of September this year.

The ISO working group’s primary focus has been to address the 0.50% sulphur fuels’ stability and compatibility, for example being able to protect against unstable fuels and providing better indicators as to the compatibility between one fuel and another. Informative Annexes include additional guidance on the composition, general requirement, stability and comingling of fuels. Furthermore, CIMAC WG7 for fuels will be coming out with a more detailed technical document covering fuel stability and compatibility.

How are discussions shaping up at IMO?

Most discussions are revolving around the consistent implementation of MARPOL Annex VI regulation 14.1.3. At MEPC 74, held recently at IMO’s headquarters in London, draft guidelines for the consistent implementation of the MARPOL Annex VI Regulation 14.1.3 were completed and a revision of the Annex for approval and adoption was proposed. The consistent implementation guidelines will be released as a resolution in due course and include the committee’s understanding of the matters relating to the safety and management concerns expressed on the use of 0.50% fuels. The guidelines will also address areas such as key technical preparatory considerations, control measures by port states, control on fuel oil suppliers, and fuel oil non-availability, including a FONAR template and handling non-compliant fuel scenarios.

Draft amendments to the MARPOL Annex VI have been approved by MEPC 74 to be adopted later by MEPC 75. The terms ‘in-use sample’ and ‘on-board sample’ have been defined. One of the major changes has been the amendments to the Sulphur Verification Procedure (Appendix VI) to handle accuracy and precision of test results of both the current MARPOL sample, as well as ‘in-use’ and ‘on-board’ sample. The MARPOL Annex VI (as delivered) sample test result would be considered as having ‘not met the requirement’ above 0.50% after following the verification procedure. However for the ‘in-use’ and ‘on-board’ samples the fuel will not have met the requirement if the test result exceeds 0.53%. These final results will then be evaluated by the competent authority.

The guidelines for port state control are developed to handle scenarios such as when there is discrepancy between the Bunker Delivery Note (BDN) and independent ship results indicating noncompliant fuel has been loaded despite the declaration on the BDN stating otherwise. Moreover, it was recognised that there will be a wide range of scenarios to address resulting in non-compliant fuel being on board, such as after application of a FONAR, including by port and ship; the discretion ultimately remains with the inspection authority on a final decision. The emphasis is on the ship making every attempt to avoid putting itself into such a position. The guidance on best practice for member states/coastal states adds to the previously completed guidance for fuel purchaser/ users and suppliers, mainly providing guidance for contingency measures for addressing non-compliant fuel oils. The guidance also focuses on the expectations on suppliers to ensure fuel quality is acceptable for the receiving ship. MEPC 74 also worked on the guidance document in case of failure of a single monitoring instrument and recommended actions to take if the exhaust gas cleaning system fails to meet the provision of the guidelines.

To facilitate the consistent implementation, MEPC 73 agreed a carriage ban of high sulphur fuels that exceed 0.50% on ships not fitted with an exhaust gas cleaning system (EGCS), often referred to as scrubbers, from 1 March 2020.