IMO 2020 INSIGHT: High Levels of Noncompliance Unavoidable in 2020

Robin Meech, Managing Director, Marine and Energy Consulting Limited. Image Credit: Marine and Energy Consulting Limited

Over the next 15 months some 60,000 ships need to clean their bunker tanks to be compliant on 1 January 2020. What are the options:

• Clean at the next dry dock if before 2020 and use 0.50% fuels or MGO thereafter if 0.50% fuels are not available;
• Contract to clean tanks as near to the end of 2019 to avoid extra consumption of more costly lower sulphur fuels before 2020 but availability of tank cleaning services may be such that the cleaning can only take place earlier in the year, if at all – it may already be too late;
• Start using 0.50% fuels from mid-2019 expecting the tanks to be clean by 2020 assuming 0.50% bunkers can be sourced;
• Start using MGO in Q4 2019 in the expectation that the tanks will be clean by 2020 assuming charterers will pay for MGO during 2019?;
• Start using 0.50% from the end of 2019 with the hope of not being detected since it is unlikely that the fuel consumed will be under 0.50% until the tanks have been flushed a number of times. For larger vessels with multiple deep/wing bunker tanks this could take many months even if the crew clean the settling and day tanks.

This last option is likely to be the most prevalent if the industry follows its usual approach of wait and see.

All these options are costly, including off hire time and the last three, which are likely to be the most prevalent, may result in fines and detentions not only while the bunkers are being changed but the tanks will need cleaning before the vessel can depart compliantly. Tank cleaning services are not available in many ports.

Using lower sulphur bunkers to clean tanks can result in flushing of sludge and accumulated corrosive particles leading to blocked centrifuges and filter. Vessels with relatively low bunker consumption may be non-compliant for many months.

The use of Exhaust Gas Cleaning Systems with continual use of residual fuels avoids the need to clean tanks as well as avoiding the new 0.50% fuels where there is a consensus that in the early days some will present difficulties. It is likely that vessels with EGCS will be proportionally more likely to be compliant in 2020 than vessels without.

There needs to be some global recognition of this tank cleaning problem. IMO has been addressing this issue within the ship implementation planning for 2020 but it is now unavoidable that many ships will not be compliant during the first half of 2020. Enforcement agencies need to come to terms with this. One approach may be to not test fuel at any point on board until 2021 but ensure that vessels without EGCS purchase compliant fuel by inspecting the Bunker Delivery Notes.