IMO has set a global limit for sulphur content in fuel oil used on board ships of 0.50% m/m (mass by mass) from 1 January 2020. Many ships are expected to comply with the 2020 regulatory framework by choosing to use 0.50% m/m sulphur content compliant fuel oils.
In order to ensure consistent implementation of the 2020 sulphur content limit, IMO’s intersessional working group on air pollution (ISWG-AP1) is developing a single set of new 2020 Guidelines and draft amendments to MARPOL Annex VI. The Intersessional Working Group will report the outcome to the IMO’s Sub-Committee on Pollution Prevention and Response (PPR) and Maritime Environment Protection Committee (MEPC).
Following the IMO PPR’s 5th meeting in February 2018, industry associations decided to work together and to develop a series of joint submissions with a view to assisting the Intersessional Working Group in developing new Guidelines and amendments to MARPOL Annex VI. INTERTANKO played an active and leading role in these efforts.
The following five papers have been developed and submitted to the ISWG-AP1:
1. Implementation Plan (sponsored by Norway and Panama)
A draft MEPC Circular is proposed encouraging:
- ship operators to develop written implementation plans for 2020, and
- PSCs to adopt a practical and pragmatic approach for shops that have an implementation plan onboard when verifying their compliance with the 2020 sulphur content limit requirements for the 3 month period from January to March 2020.
Note that the purpose of the submission is to assist the ship operators’ task of planning a timely implementation before 1 January 2020.
2. Fuel Oil Non-Availability Report (FONAR, sponsored by Panama)
A standardized reporting format is proposed for both 0.10% m/m and 0.50 % m/m sulphur fuel non-availability
3. Sulphur content testing and verification (sponsored by Panama)
Concrete textual proposals and reasoning to address the INTERTANKO’s concerns on PSC’s sulphur content verification procedures, following its two previous submissions to IMO PPR 5 (Feb 2018). A comprehensive set of draft amendments to Appendix VI of MARPOL Annex VI is provided. According to the proposals, the 95% confidence upper limit above the absolute limit (0.50% m/m) should be given to in-use fuel oil sampling test verification. A standard reporting and rounding protocol is also proposed.
4. Mandatory designated sampling point(s) for in-use fuel oil sulphur content sampling (sponsored by Norway)
IACS provided the first draft proposal. Industry associations took part in further developing the draft amendments to MARPOL Annex VI and the 2016 on-board fuel oil sampling guidelines. The draft text reads that one or more sampling points shall be fitted or designated for the purpose of taking representative samples of the fuel oil being used on board the ship taking into account the different fuel oil grades being used.
5. Safety implications associated with 2020 fuels and their respective challenges (sponsored by Liberia and the Marshall Islands)
To address one of the ISWG-AP1’s terms of reference, “impact of new fuel on the machinery systems”, industry associations developed a paper highlighting safety implications and proposing possible ways to address the identified concerns in the new 2020 Guidelines.
INTERTANKO will be represented by the Secretariat and Member(s) of the Bunker Sub-Committee at the ISWG-AP1. Members are invited to note the joint submissions and share their thoughts with us so as to enable us to continue to play a leading role.