“IMO 2020” requirements for ships to cut sulphur oxide emissions enter into effect in just over one month’s time. This will significantly reduce air pollution from ships with positive benefits for human health and the environment.
The new requirement means that the global limit for sulphur in fuel oil used on board ships will be reduced to 0.50% m/m (mass by mass). Within designated emission control areas (ECAs), the limit will remain at 0.10%. The new limit will be mandatory, under a regulation in Annex VI of IMO’s MARPOL convention for the prevention of pollution from ships.
Both the Organization and the shipping sector – as well as refineries and fuel (bunker) suppliers – have been rigorously preparing for the new limit. For most ships this will mean a switch to new types of compliant fuel oils, so-called very low sulphur fuel oil (VLSFO), or marine gas/diesel oil. The VLSFO blends are new to the market.
IMO has issued comprehensive guidance (outlined in IMO 2020 leaflet), and the shipping industry has developed guidance, including IMO 2020 ICS Guidance on compliance for shipping companies and crews, Joint Industry Guidance on supply and use of 0.50% sulphur marine fuel and INTERTANKO 2020 Practical Guide Training videos are also available (Sulphur 2020 training package including video, free to download).
Preparedness for this major change for the shipping sector was highlighted at a roundtable industry meeting hosted by IMO at its London Headquarters (18 November), following a previous meeting in June. An IMO symposium on IMO 2020 and alternative fuels in October also brought together stakeholders, including Member States, the shipping and refineries sector, who confirmed a general readiness to meet the sulphur 2020 requirement.
The roundtable meeting saw increasing confidence towards consistent implementation resulting from significant efforts to date by all stakeholders and emphasized the continued need for awareness-raising efforts as the deadline looms.
Availability of compliant fuel oil
Views were exchanged on the general availability of fuel to meet the 0.50% limit. It was felt supply would generally be available, with some exceptions. There was some indication that whilst heavy fuel oils continued to be loaded, due to the proximity to the deadline, more ship operators and owners are beginning to gain experience of compliant fuels as bunker suppliers move their storage infrastructure and bunker barges to be 0.50% compliant fuel oil ready.
Information on compliant fuel oil specification
The IMO Secretariat encouraged the sharing of information on any testing of fuel oils meeting the 0.50% limit.
In addition to the IMO 2020 ICS Guidance, Joint Industry Guidance and INTERTANKO 2020 Practical Guide, attention was also drawn to the recently-published “CIMAC Guideline: Marine fuel handling in connection to stability and compatibility”, issued by the International Council of Combustion Engines (CIMAC).
Enforcement and compliance
Consistent enforcement by port State control was once again recognised as essential to ensure a level playing field and to ensure that ships would not be disproportionately impacted
MARPOL Annex VI, which contains the sulphur limit regulation, has 95 Parties, who between them register 96.71% or world merchant shipping by tonnage. Flag States have jurisdiction over the ship and issue the International Air Pollution Prevention Certificate (IAPP) to ships of 400 gross tonnage and above.
However, port States need to be a Party to Annex VI to exercise port State control in relation to the sulphur 2020 limit. The number of Parties to the Annex varies in different port State control regions.
Concerns were raised by some attendees on the preparedness of the PSC regimes to enforce the 2020 sulphur limit, however the IMO Secretariat confirmed the Organization’s readiness to support PSC regimes, in particular, with capacity building and training, and highlighted workshops delivered with the support of Denmark and the World Maritime University (WMU). Specific training to support port State control for the implementation of MARPOL Annex VI could be provided. An IMO Workshop for PSC MoU/Agreement Secretaries and Database Managers will be convened in 2020, which would provide a further opportunity to promote the harmonization of enforcement measures.
Fuel oil non-availability report (FONAR)
Roundtable participants raised concern about possible inconsistent approaches in relation to the fuel oil non-availability report (FONAR). The report is not intended as an exemption but is a standardised template to report non-availability of compliant fuel oil. The IMO Secretariat reminded participants that IMO has issued the 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI (MEPC.320(74) here), which includes a standardised FONAR.
Participants agreed on the need to continue to raise awareness about the sulphur 2020 limit and the need for further preparation by all stakeholders, including the IMO Secretariat, PSC regimes, Member States, shipowners/operators, charterers, fuel suppliers and others, in order to ensure consistent implementation of the sulphur 2020 limit by 1 January 2020. In this regard, it was agreed that the IMO Secretariat would communicate to all relevant parties on the continuing need to prepare for the entry into force of the sulphur limit.
IMO web page on Sulphur 2020 answers frequently asked questions and includes an IMO leaflet (download here) which outlines the requirement, answers the most frequently asked questions about the rule and provides a list of the IMO instruments supporting implementation, best practice guidance, port State control and sampling guidelines and others.
IMO has published a compilation of all related guidance, best practices and so on, as a single IMO publication (hard copy and electronic formats). (IMO 2020: Consistent Implementation of MARPOL Annex VI, 2019 Edition I666E, Price £22, ISBN 978-92-801-17189) .
Presentations from the IMO symposium on sulphur 2020 and alternative fuels can be downloaded here.
A Videotel training package package is free to download and includes video information on the regulations and how to comply. Download: https://landing.videotel.com/sulphur2020
An open source free to access e-learning course is being developed with Videotel through the joint industry project, for free use by seafarers and others. The course will offer three modules and is expected to be available soon.
Roundtable meeting participants
The roundtable meeting was attended by representatives from IMO Secretariat and: International Chamber of Shipping (ICS); International Organization for Standardization (ISO).; BIMCO; International Association of Classification Societies (IACS); Oil Companies International Marine Forum (OCIMF); International Association of Independent Tanker Owners (INTERTANKO); International Association of Dry Cargo Shipowners (INTERCARGO); IPIECA; The Institute of Marine Engineering, Science and Technology (IMarEST); International Bunker Industry Association (IBIA).