Maritime

Sulphur Cap 2020 – HSFO carriage ban only weeks away

Now, with the new global 0.50% sulphur limit in force, next on the regulatory timeline is the carriage ban effective from 1 March. From this date, high-sulphur fuel oil (HSFO) cannot be carried in the fuel oil tanks unless the vessel is fitted with an approved equivalent arrangement. More about the carriage ban in this statutory news.

Relevant for ship owners and managers.

The carriage ban

After deciding on, and adopting, the new global sulphur limit for fuel oil, the discussion started on how to ensure a level playing field and enforcement on the high seas. The solution is the so-called "carriage ban” meaning that unless you have an exhaust gas cleaning system (EGCS), the ship is not allowed to carry any fuel exceeding 0.50% sulphur in the fuel tanks. The rational for the ban is that if you are not allowed to use the fuel, there is no reason to carry it.

Regulation 14.1 of MARPOL Annex VI will now read: The sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m.

While the new sulphur limit took effect on 1 January, the carriage ban will be effective from 1 March 2020. The two-month time gap is by no means introduced as a grace period. The reason for the gap is solely due to the IMO process of adopting new regulations.

The International Air Pollution Prevention Certificate (IAPP)

As part of the MARPOL amendments, the standard format of the IAPP certificate will also change from 1 March. A new tick-off box with the following text will be included in the supplement: For a ship without an equivalent arrangement approved in accordance with regulation 4.1 as listed in paragraph 2.6, the sulphur content of fuel oil carried for use on board the ship shall not exceed 0.50% m/m as documented by bunker delivery notes.

The IAPP certificate is required to be re-issued in the new format no later than the first IAPP survey after 1 March, being the annual, intermediate or renewal survey. If, for other reasons, the certificate is to be re-issued after this date, it will be in the new format.

Sample verification

With the carriage ban in place, PSC will have the opportunity to sample and verify the sulphur content of fuel carried for use to verify compliance with the new sulphur limit.

When verifying the sulphur content of samples taken on board, as opposed to the MARPOL sample taken during bunkering, a 95% confidence interval has been given. This means that a sulphur content of up to 0.53% may be accepted as compliant when testing such samples. This is to ensure that ships are not unjustly penalized for marginal excess in sulphur content beyond their control. (MEPC.1/Circ.882).

Recommendations

Compliance is the only option
For vessels without any approved equivalent arrangements in place, in case of any remaining HSFO from before 1 January, this needs to be dealt with before 1 March. In case removing the fuel in time isn’t feasible, flag and ports state should be contacted to agree on contingency measures (ref. MEPC.1/Circ.881).

References

Global Sulphur Cap 2020 webpage  

All MEPC documents available on DNV GL’s sulphur cap pages

  • MEPC.305(73) Amendments to MARPOL Annex VI 
  • MEPC.1/Circ.881 Contingency Measures for Addressing Non-Compliant Fuel Oil 
  • MEPC.1/Circ.882 Early Application of the Verification Procedures for a MARPOL Annex VI Fuel Oil Sample

Contact

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23 February 2021

IMO DCS reporting deadline on 31 March 2021 – be prepared

Now with the second DCS reporting year recently ended, it is again time for reporting data on fuel oil consumption to your DCS verifier. To ensure a Statement of Compliance (SoC) is issued in due time before 31 May 2021 as required, the deadline in MARPOL for reporting 2020 data for verification is 31 March 2021. This statutory news is a reminder on how to stay compliant with regulation 22A of MARPOL Annex VI.

  • Maritime
20 October 2020

PSC inspections during COVID-19: Are we back to normal?

During the first six months of the COVID–19 pandemic, Port State Control (PSC) regimes reduced the number of PSC inspections to a minimum with a focus on high-risk ships. Now, and despite the upheaval of the pandemic, some PSC regimes or single countries are coming back to performing almost the same number of inspections as before the pandemic. This PSC news provides an overview of the actual inspection activity in different PSC regimes, a situation which may change quickly.

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