IBIA INSIGHT: Overview of IMO's 2020 Implementation Guidelines

Unni Einemo, Director & IMO Representative, IBIA

The IMO has developed a comprehensive package of guidelines to assist industry and Administrations to effectively and uniformly implement the 0.50% sulphur limit that takes effect form 1 January, 2020. Guidelines developed by the 6th meeting of the IMO's Sub-Committee on Pollution Prevention and Response (PPR 6) in February will be sent for approval by the Marine Environment Protection Committee in May (MEPC 74). Here is an overview.

Consistent implementation guidelines

The main part of the package is the so-called Guidelines on consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. These guidelines consist of the following sections:

Definitions. This section helps to clarify the language for fuel oils, referring to distillate marine (DM) and residual marine (RM) fuels as specified in ISO 8217, as well as defining fuels by sulphur content. Fuels at or below 0.10% sulphur are defined as ULSFO, fuels with maximum 0.50% sulphur as VLSFO, and any fuels with sulphur above 0.50% as HSHFO. These are largely in line with nomenclature previously explained by IBIA (click here for details).

Ship implementation planning for 2020. This was already finalised at MEPC 73 as MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. This includes an appendix on tank cleaning based on a submission from IBIA, and an appendix addressing the impact on machinery systems with advice on how to prepare for use of a variety of fuels, which IBIA also contributed to (click here for more information).

Impact on fuel & machinery systems. This section contains advice on handling various fuels (DM, RM, DM containing FAME), and repeats messages seen in the SIP regarding impact on machinery systems.

Verification issues and control mechanism and actions. This section deals with how administrations should undertake ship inspections, possible compliance monitoring tools, sulphur analysis, controls on fuel oil suppliers and sharing of information about non-compliant ships and suppliers.  

Fuel oil non-availability.  This section is about how to deal with situations where a ship could not, despite its best efforts, obtain compliant fuel oil and about who this information needs to be shared with. PPR 6 agreed on a Fuel Oil Non-Availability Report (FONAR) format the ship should use and , and set out guidelines for how a Party should investigate FONARs.  (Click here for more information)

Possible safety implications relating to 0.50%S fuels. This section lists parameters that have been identified as a potential cause for concern, including stability, compatibility, cold flow properties, acid number, flash point, ignition and combustion quality, cat fines, low viscosity, and unusual components. There is an appendix that sets out more information on each of these. Reference is also made to general industry guidance.

In this context, PPR 6 was provided with an update on progress of the Joint Industry Project which is developing a comprehensive set of guidelines on potential safety and operational issues related to the supply and use of fuel oils with a 0.50% sulphur limit. This will be made available to all industry stakeholders once the relevant ISO Publicly Available Specifications (PAS) have been released, so the JIP document can incorporate appropriate references to it.

The PAS is being developed by the ISO 8217 working group to provide detailed guidance to fuel suppliers and users on the type of fuel blends that are anticipated to dominate the global bunker market in 2020. The PAS and the JIP guidance are anticipated to be ready during the second half of 2019. The JIP, which is organised by OCIMF and IPIECA, has broad participation from marine fuel industry experts across a range of organisations, including IBIA.

Additional guidelines associated with 2020

PPR 6 drafted several MEPC Circulars associated with ensuring sulphur limits are met. They include the following:

Draft circular on delivery of compliant fuel oil by suppliers.  This will be a joint MSC-MEPC circular addressing the delivery of compliant fuel oil by suppliers, for approval at MEPC 74 in May and at the Maritime Safety Committee (MSC 101) in June. The draft circular is aimed at Members States to take appropriate action against suppliers under their jurisdiction to ensure they deliver compliant fuel oil. They are also told to urge fuel oil suppliers to take into account, as relevant, Guidance developed by the IMO on best practice for fuel oil suppliers and fuel oil purchasers/users for assuring the quality of fuel oil delivered to and used ships.  (Click here for more information)

Draft amendments to on board sampling guidance. PPR 6 agreed draft 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships, updating the current version, MEPC.1/Circ.864, which will be superseded if the update is approved by MEPC 74.

Draft 2019 port State control guidelines. PPR 6 agreed, in principle, to draft 2019 Guidelines for port State control under MARPOL Annex VI, updating the 2009 guidelines, for MEPC 74 to adopt. There are, however, some areas that were not fully resolved. One is regarding the situation when a ship has BDN that says the fuel is compliant, but the ship's own test results suggest it is not. This is not covered by the FONAR because the ship thought it had procured compliant fuel oil. Also not resolved was how to deal with non-compliant fuel oil remaining onboard a ship, hence interested parties have been invited to submit proposals to MEPC 74.  (Click here for more information)