IMO Finalizes Sulfur Cap Consistency Guidelines Draft
The IMO Sub-Committee on Pollution Prevention and Response (PPR 6) met last week and finalized draft guidelines for the consistent implementation of 2020 sulfur cap.
The 0.50 percent limit for sulfur content in ships’ fuel oil will take effect on January 1, 2020, and the guidelines include 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 percent sulfur limit.
MEPC 74 (May 2019) is expected to adopt the guidelines.
Opening the meeting, Secretary-General Kitack Lim said the most important item on the agenda was the consistent implementation of the sulfur cap, highlighting the need to finalize the guidelines. “2019 will be crucial for the implementation of the reduced upper limit of the sulfur content in ships’ fuel oil. This is a landmark decision for the environment and human health, and it demonstrates IMO’s continuing commitment to ensuring that shipping meets its environmental obligations.”
The IMO has already issued ship implementation planning guidance, to help shipowners prepare.
Draft circular on delivery of compliant fuel oil by suppliers
The Sub-Committee agreed a draft joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 and at the Maritime Safety Committee (MSC 101). The draft circular says that Members States should urge fuel oil suppliers to take into account: MEPC.1/Circ.875 Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships; and MEPC.1/Circ.875/Add.1 Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered to ships.
The Sub-Committee agreed draft amendments to MARPOL Annex VI, for approval by MEPC 74 and subsequent adoption by MEPC 75 (Spring 2020), with an expected entry force date of mid-2021. These include amendments to definitions related to the sulfur content of fuel and its sampling. Regulation 14 is being amended to add new paragraphs to require one or more sampling points to be fitted or designated for the purpose of taking representative samples of the fuel oil being used or carried for use on board the ship.
Draft amendments to onboard sampling guidance
The Sub-Committee agreed draft guidelines for onboard sampling for the verification of fuel sulfur content. MEPC 74 (May 2019) is expected to approve these guidelines.
The Sub-Committee agreed, in principle, to draft 2019 Guidelines for port state control under MARPOL Annex VI, updating the 2009 guidelines. MEPC 74 (May 2019) is expected to adopt these guidelines.
The Sub-Committee developed draft interim guidance for port State control on contingency measures for addressing non-compliant fuel oil and invited concrete proposals to MEPC 74. The draft interim guidance covers possible actions to be taken, following discussions between ship, flag state and port state, when a ship is found to have non-compliant fuel oil either as a consequence of compliant fuel oil being not available when the ship bunkered or the ship identifying through post bunkering testing that the fuel oil on board is non-compliant.
MEPC 74 (May 2019) is expected to consider these draft interim guidelines further.
Draft unified interpretation
The Sub-Committee agreed a draft unified interpretation to regulation 14.1 of MARPOL Annex VI, for submission to MEPC 74 for approval, which confirms that regulation 14.1 of MARPOL Annex VI for the prohibition on carriage of non-compliant fuel oil should also be applied to the fuel oil of emergency equipment.
Reducing risks of heavy fuel oil in Arctic waters
The Sub-Committee began its work to develop measures to reduce the risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters. A working definition for heavy fuel oil was noted, which says that “heavy fuel oil means fuel oils having a density at 15ºC higher than 900 kg/m3 or a kinematic viscosity at 50ºC higher than 180 mm2/s.”
A draft methodology for analyzing impacts of a ban on heavy fuel oil for the use and carriage as fuel by ships in Arctic waters was agreed. The Sub-Committee invited submissions to PPR 7, especially those by Arctic States. The methodology sets out five steps to assess the impact of a ban. Specific analyses that are detailed include: determination of the study area; assessment of the costs to Arctic indigenous and local communities and industries; assessment of the benefits of an HFO ban to Arctic indigenous and local communities and ecosystems; and consideration of other factors that could either ameliorate adverse impacts of a ban or accommodate specific situations.
Meanwhile, a correspondence group was instructed to develop guidelines on measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters. The guidance could include sections on navigational measures; ship operations; infrastructure (onshore and offshore) and communications; enhanced preparedness for emergencies of oil spills, early spill detection and response; drills and training; and economic assessment of potential measures.