Manifold Times is publishing the second of five articles attributed to BIMCO in regards to five IMO-submissions the latter co-wrote to IMO this week:

It is a daunting task so prepare a fleet of ships for the sulphur regulations. Therefore, BIMCO has, together with the partners behind a new IMO-proposal, made a draft for an implementation plan for achieving compliance with the 0.5% global sulphur cap. The plan has the additional purpose of showing the good faith of the ship operator during inspections.

The proposal and draft plan was submitted to IMO in advance of the Intersessional Meeting on sulphur implementation July 9-13 together together with Norway, Panama, ICS, BIMCO, INTERCARGO, INTERTANKO and WSC.

BIMCO suggest that IMO members states encourage the ships flying their flags to develop written implementation plans, to help member states adopt a practical and pragmatic approach when verifying compliance with the requirements of sulphur regulation.

Priority on willful non-compliance
The implementation plan could voluntarily be submitted to authorities, and ships carrying an implementation plan along with a detailed description of how it is being followed should be met with a practical and pragmatic approach during inspections, according to the IMO-submission.

This pragmatic implementation approach would be for a period of three months after 1 January 2020 for those ships which are in possession of an implementation plan.

“The priority of compliance inspections in ports should be on wilful non-compliance with the regulations. Where ships experience technical or operational issues that may lead to accidental and unintended non-compliance, this should be considered differently than wilful non-compliance, and such ships should not face severe measures or penalties,” the submitting countries and organisations additionally said in the proposal.

The draft implementation plan includes planning and preparation for structural modifications (if needed), how many bunker tanks are designated to store low-sulphur fuel and details of purchasing procedure to source compliant fuels, to name a few.

The proposal and draft implementation plan submitted to IMO are as follows:

• Based on the above discussion, the co-sponsors consider that a standard template for developing ship-specific implementation plans would be of benefit to both ship operators and Administrations. The co-sponsors therefore provide a draft standard template that could be used for the development of a ship-specific implementation plan as provided in the annex to the draft MEPC circular included in the annex to this document.
• Shipowners and operators could select those sections from the template that are applicable to their ship(s) and use the template to develop their own ship-specific implementation plans. They could then submit these plans for review and endorsement by Administrations.
• Implementation plans complemented by a record of related actions taken to achieve timely compliance should be used by PSCOs to ascertain how a ship has prepared for compliance and the necessity for detailed inspections. There should be practical and pragmatic approach to verifying compliance on these ships considering that these ships have acted in good faith by doing their utmost to ensure a timely implementation of the 0.50% m/m global sulphur limit.
• The co-sponsors would stress that submitting the implementation plan for review and endorsement by the Administration should be voluntary. However, it is also recognized that those ships which are not in possession of an implementation plan supplemented by a detailed record of how the plan was followed, will be subject to more detailed inspections in order to verify that the sulphur content of the fuel oil used on board the ship meets the requirement of regulation 14.1.3.

Related: BIMCO proposes changes in sulphur sampling points

Photo credit: International Maritime Organization
Published: 6 July, 2018