Applicability: Owners and operators of ships that are subject to air emission controls under MARPOL Annex VI

The International Maritime Organisation (IMO) has published guidance for the recommendation that ships prepare a ship implementation plan outlining the key activities the ship needs to carry out to ensure ships meet its 0.50% sulphur limit for marine fuels used outside emissions control areas (ECAs), on 1 January 2020.

This guidance for shipowners, managers, charterers and other stakeholders, given in the circular (MEPC.1/Circ.878), is aimed at encouraging ships to itemise the critical tasks that need to be carried out. These include fuel change risk assessments, switch-over timing, any structural tank or fuel system modifications, cleaning of tanks and crew awareness programmes along with addressing new bunker compatibility challenges and cold flow storage considerations.

Although the plan is a recommendation and not a statutory requirement, and does not require approval by the flag Administration or the classification society, it will help in the smooth transition towards the use of low sulphur fuels and validate the compliance processes adopted onboard.  ln preparing the plan, you may find the need for modification of tanks/piping. Some adjustment of the engines and boilers may also be necessary. Any modifications are to be submitted for review and approval by LR.

Background information

Use of 0.50% sulphur fuel outside ECAs was an element of the 2008 amendments to the MARPOL Convention in resolution MEPC.176(58) and entered into force on 1 July 2010. The implementation date of 1 January 2020 for the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI was confirmed by resolution MEPC.280(70) and adopted in October 2016.

To enforce these requirements, the IMO Marine Environment Protection Committee’s 2018 session (MEPC 73) also adopted a “carriage ban” of non-compliant fuel. This will enter into force on 1 March 2020. By that time, any unused non-compliant fuel not fully consumed prior to 1 January 2020, but kept onboard, has to be de-bunkered.

In addition, further supplemental guidelines will be finalised by IMO’s PPR 6 meeting scheduled for February 2019 for final approval by MEPC 74, scheduled for May 2019. Updates on these discussions will be published here

For further information contact your local Lloyd's Register Group Office 

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