Nick Browne, the Global Director at GAC Bunker Fuels, on Friday (28 June) published an article which discusses the management of various complexities that IMO 2020 introduce. The article, shared with Manifold Times, first appeared in GAC WORLD magazine, Issue No.3 of 2019. You can download your copy at www.gac.com/magazine/
On 1 January 2020, the International Maritime Organisation’s (IMO) new sulphur limit for marine fuels will come into force.
Sulphur emissions are the main source of acid rain. They also acidify waterways and corrode buildings and infrastructure. Noxious sulphur particles affect the respiratory health of every human that lives near a shipping channel or port. The IMO’s new sulphur limit for bunker fuels is just 0.5%, giving us all a clear message about the seriousness of the sulphur emission problem. For the majority of shipping companies that are still burning fuel with 3.5% sulphur content, it’s going to be a big adjustment, affecting costs and equipment.
The IMO has been working to reduce the harmful impacts of shipping on the environment since the 1960s; think ballast contaminants and anti-fouling rules. The upcoming lowering of sulphur oxide emissions is expected to have a significant benefit on the environment and on human health, particularly for people living in port cities and coastal communities. The Yale School of Forestry & Environmental Studies reckons that once the new sulphur cap takes effect, it will prevent roughly 150,000 premature deaths and 7.6 million childhood asthma cases globally each year.
The essential points
· From 1 January 2020, vessels taking on fuel oil for use on board must obtain a bunker delivery note stating the sulphur content of the fuel oil supplied.
· Samples may be taken for verification.
· Vessels must have an International Air Pollution Prevention (IAPP) Certificate issued by their Flag State.
· The certificate must include a section stating that the fuel oil’s sulphur content does not exceed the applicable limit.
The switch over is a complex matter since a lot of transitional issues need to be taken into consideration by both Owners and Charterers. Among these issues are two that I believe are critical:
1. Where the burden of responsibility lies for ensuring a vessel is compliant
2. What to do if no compliant fuel is available in the port where you are calling.
Customer is responsible
Since 1 January 2019, changes have been made to the Bunker Delivery Note (BDN) through Marpol Annex VI appendix V. There is now a declaration required, signed by the fuel oil supplier’s representative, to certify that the fuel oil supplied by the supplier conforms with the regulation 14(1) or (4)(a) and regulation 18 (1) within the Annex. This implies that the bunker supplier is responsible for getting confirmation that the vessel has an approved Exhaust Gas Cleaning System (EGCS) but this is not the case. Notification is required but no proof.
This means that the weight of responsibility for compliance rests with the vessel owner/charterer, not the supplier. This doesn’t preclude the supplier or bunker trader from enhancing its own Know Your Customer (KYC) process and asking for evidence that there is an approved EGCS on board.
What if the fuel you need is not available?
Although more and more suppliers are confirming availability of the new 0.5% fuel oil, some shipowners will discover that compliant fuel may not be available in their chosen bunkering port.
The good news is that the IMO has thought this issue through. The bad news is that the solution requires substantial documentation via the IMO Fuel Oil Non Availability Report (FONAR). The IMO states:
‘The ship shall present a record of the actions taken to attempt to achieve compliance; and provide evidence that it attempted to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made available where planned, that attempts were made to locate alternative sources for such fuel oil and that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for purchase.’
The point to be taken from all the challenges involved in the new sulphur cap is that a cautious and quality approach is required to deal with all the complexities in an ordered fashion.
GAC Bunker Fuels has been in deep discussions with our clients regarding the various options and timings for complying with the new sulphur content rules. We are now working with clients on their bespoke Fuel Changeover Plans. We may act as consultants or work directly with providers to arrange key services such as de-bunkering, tank cleaning and re-bunkering with compliant fuel.
If you think you might benefit from a conversation with us about the 2020 sulphur cap or your bunker procurement needs, drop us a line at firstname.lastname@example.org.
Photo credit: GAC Bunker Fuels
Published: 2 July, 2019
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