Fuel sampling set to rise. Image Credit: Gard
With the spot sampling of bunkers to verify their sulfur content expected to increase significantly from January 1, 2020 when the new global 0.50% sulfur cap comes into force, Gard has advised shipowner/operators to prepare for Port State Control (PSC) to make mistakes when enforcing the new rules.
When they do, proper onboard procedures and a well prepared and attentive crew can be crucial in avoiding unwarranted penalties, it says.
"There is no doubt that PSC will play an important role in the enforcement of the 2020 global 0.50% sulphur cap," Gard writes as part of its advice on the matter.
"However, while many PSC regimes are investing heavily in training and education of their inspectors ahead of the regulatory changes, others may not be equally well prepared for their new inspection tasks come 1 January 2020."
without proper evidence, the chances of the shipowner losing the claim in a disputed case are high
Gard notes two historical cases where its members were incorrectly found to be noncompliant with the current sulfur regs.
In one instance, the PSC inspector's sampling report was incomplete, but because poor procedure led to the ship's Master and Chief Engineer signing the inspector's report it became very difficult for the shipowner to argue his case.
In another case where the sample was found to be off-spec, good procedure allowed the crew to quickly show the sample contained hydraulic oil and the fine was cancelled.
Gard says there are several steps that vessels can take to avoid problems and erroneous fines, including the appropriate training of relevant members of the engine crew all and making sure all MARPOL Annex VI documentation is complete and up-to-date prior to a port entry.
"Remember, without proper evidence, the chances of the shipowner losing the claim in a disputed case are high," says Gard.
The full advise notice can be found here: http://www.gard.no/web/updates/content/27554374/prepare-crews-for-psc-spot-sampling-of-ships-fuel