Gard Encourages Ship Operators to Prepare for IMO 2020

Leading marine insurer Gard is warning its clients to make firm plans for compliance in advance of the IMO 2020 sulfur rule, which will take effect on January 1 of next year. Some port states have already made clear that they intend to enforce the new 0.5 percent sulfur limit with the same vigor that they pursue other forms of environmental noncompliance - like Singapore, where the maximum theoretical penalty for a violation is up to two years in prison. 

In an update Thursday, Gard lawyer Sammy C. Smallbone suggested that owners and charterers should take some basic steps to ensure that problems are minimized. These include:

- Using the BIMCO 2020 fuel transition and marine sulfur contract clauses, which were published in December 2018. According to Gard, these standard clauses provide a "fair" apportionment of liability between parties for some of the possible scenarios related to the transition. 

- Preparing, carrying out and documenting a ship implementation plan (SIP) for the transition. This plan should provide the crew with guidance on how to segregate different fuel grades, how and when to carry out compatibility testing, and how and when to carry out tank cleaning.

- Making plans between charterers/owners for cleaning all tanks and purging all pipework in advance of the transition date. 

- Identifying sources of compliant fuel from reliable suppliers, and checking with the engine manufacturer if advice is needed about technical compatibility. 

- Making sure that the master and crew understand the importance of the switch and the tasks they'll need to carry out to ensure compliance. 

"This deadline will not be put back," warned Smallbone. "To make sure that you are properly prepared we would encourage you to adopt some of the suggestions set out above."