At MEPC 73 last week, the IMO confirmed that carriage of non-compliant fuel will be prohibited once the 2020 cap on sulphur levels comes into effect.
An amendment to support consistent implementation of the forthcoming 0.50% limit on sulphur in ships fuel oil was adopted and will come into effect on 1 March 2020. The short time lapse is due to the fact that treaties cannot be amended until provisions have actually come into effect. The new 0.50% limit (reduced from 3.50% currently) on sulphur in ships' fuel oil will be in force from 1 January 2020.
The complementary MARPOL amendment will prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship - unless the ship has an exhaust gas cleaning system ("scrubber") fitted. Installing a scrubber is accepted by flag States as an alternative means to meet the sulphur limit requirement.
The amendment does not change in any way the entry into force date of the 0.50% limit from 1 January 2020. It is intended as an additional measure to support consistent implementation and compliance and provide a means for effective enforcement by States, particularly port State control.
To assist ship operators and owners to plan ahead for the 0.50% sulphur 2020 limit, the MEPC approved guidance on ship implementation planning. The guidance is part of a set of guidelines being developed by IMO for consistent implementation of the MARPOL regulation coming into effect from 1 January 2020.
The ship implementation planning guidance includes sections on:
- risk assessment and mitigation plan (impact of new fuels);
- fuel oil system modifications and tank cleaning (if needed);
- fuel oil capacity and segregation capability;
- procurement of compliant fuel;
- fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil); and
- documentation and reporting.
The MEPC also approved Guidance on best practice for fuel oil suppliers intended to assist fuel oil purchasers and users in assuring the quality of fuel oil delivered to and used on board ships, with respect to both compliance with the MARPOL requirements and the safe and efficient operation of the ship. The guidance pertains to aspects of the fuel oil purchase up to the loading of the purchased fuel oil on board.
Following a discussion related to a proposal on gaining experience in meeting the new lower sulphur limit, MEPC invited concrete proposals to MEPC 74 in May 2019 on how to enhance the implementation of regulation 18 MARPOL Annex VI which covers fuel oil quality and availability. The regulation requires member states to "take all reasonable steps to promote the availability of fuel oils which comply with this Annex and inform the Organization of the availability of compliant fuel oils in its ports and terminals". Parties are also required to notify IMO when a ship has presented evidence of the non-availability of compliant fuel oil.