Manifold Times is publishing the third of five articles attributed to BIMCO in regards to five IMO-submissions the latter co-wrote to IMO last week:
BIMCO drafts standard documentation for ships unable to get compliant fuel in 2020
BIMCO has drafted a standard form which can provide documentation for shipowners unable to buy compliant fuel in a port. The standard will be discussed at the Intersessional meeting the International Maritime Organization (IMO) in July.
BIMCO submitted the draft standard to IMO together with CLIA, ICS, INTERTANKO, INTERCARGO, Panama and WSC.
The standard Fuel Oil Non-Availability Report (FONAR) should provide documentation that every effort to obtain compliant fuel was made before bunkering non-compliant fuel.
It is important to stress that the FONAR will not work as an excuse for not doing the utmost to obtain compliant fuel. The FONAR should document that everything possible actually has been done, and can be verified by the authorities.
The draft standard is part of BIMCO’s and the co-sponsor’s efforts to ensure a practical implementation of the 2020 sulphur cap. The format is inspired by other similar documents currently used in the U.S. and the EU.
The form allows the ship to, for example, describe any operational constraints that prevented the ship from using available compliant fuel oil, such as issues with non-compliant flashpoints.
The availability of compliant fuel – particularly outside of the big bunkering ports – is currently one of the big uncertainties before the sulphur cap enters into force on 1 January 2020. A clear process for reporting non-availability will therefore be of great benefit to ships and shipowners.
“At the time of this writing, fuel oils with a maximum content of 0.50% m/m are not widely available or introduced to the market. It is therefore not possible, at this stage, to precisely predict quality parameters and limits for these fuel oils,” the co-sponsors write in the submission.
Shipowners may, for example, get fuel oil, which complies with the low sulphur requirements, but doesn’t comply with other fuel oil parameters.
The co-sponsors agree that ships will be expected to bunker and use other compliant
fuels including 0.1% sulphur distillates, in cases where 0.5% sulphur compliant
fuels are unavailable, according to the submission.
However, the ships will also have to carefully consider, on a case by case, if the ship can safely store, process and consume the fuel, and whether they need to clean their tanks of all residual fuels, before they load non-compatible alternatives to the same tank.
Related: BIMCO suggests sulphur implementation plan for ships
Related: BIMCO proposes changes in sulphur sampling points
Photo credit: International Maritime Organization
Published: 9 July, 2018
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