Organisations such as the Standard Club and BIMCO are offering advice to owners on dealing with HSFO remining on board when the ban on carriage except for scrubber fitted vessels comes into effect in March.
On its website, the Standard Club highlights that with the IMO 2020 sulphur cap now in force as of 1 January 2020, the shipping industry faces a new set of issues. The carriage ban of non-compliant fuel oil is on the horizon; from 1 March 2020, ships not fitted with scrubbers will not be permitted to carry fuel over the 0.50% m/m limit. Members with ships without scrubbers and having HSFO remaining onboard are faced with a question of how to dispose of it before this date.
Standard’s previous update discussed issues related to the de-bunkering of non-compliant fuel. However, the cost of this operation and potential loss of value of HSFO has triggered queries from some of the club’s members as to whether onboard blending of the non-compliant fuel is permitted to achieve compliance with the regulation.
For such situations, the club would like to direct members to BIMCO’s interpretation on regulatory aspects and suggests referring to the ship’s Flag State for issuance of an equivalence in accordance with regulation 4.1 of MARPOL Annex VI.
BIMCO’s detailed advice is limited to members of the organisation but in the public area of its site, BIMCO points to potential problems with blending saying the regulatory barrier hindering on board blending is found in regulation 18.5 and 18.6 of MARPOL Annex VI, since the Bunker Delivery Note (BDN) is the legal proof of the sulphur content of the fuel oil delivered to a ship. In the event of being challenged by PSC officials over compliance with the new rules, ships may not be able to demonstrate that the blending resulted in a compliant fuel.
Some specialists have also highlighted that blending could result in unstable fuel.