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
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