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1: Sulphur limits for fuel in use under MARPOL
With the adoption in 2008, 1 January 2020 was given as the effective date for the 0.50% global sulphur cap, with an option to later defer the date until 1 January 2025, taking into account the global market supply and demand. In 2016, the IMO decided, based on information provided, to stick with the 1 January 2020 date. Hence, from 1 January 2020, the global sulphur limit will be reduced from 3.50% to 0.50%. For vessels operating in Sulphur Emission Control Areas (SECA) under MARPOL, the limit, which will remain unchanged, has been 0.10% since 1 January 2015.
2: Preparation for jan 2020
The IMO has developed a “Guidance on the Development of a Ship Implementation Plan (SIP) for the Consistent Implementation of the 0.50% Sulphur Limit under MARPOL Annex VI”. Making a ship-specific SIP is considered a good starting point for preparing, as the plan will cover the expected challenges. The plan is not mandatory and is not subject to endorsement by the flag state or a recognized organization (RO). However, port state control (PSC) may consider the preparatory actions described in the SIP when verifying compliance. DNV GL has prepared a Web-based SIP application which is free of charge and available in the DNV GL Veracity marketplace.
DNV GL has also developed a checklist which contains an overview of the critical activities to be reviewed, and implemented, before the end of 2019. The checklist is available here.
3: How to clean bunker tanks before switching to compliant fuel.
Tank cleaning is basically done for the following reasons:
4: In case excess HSFO can’t be disposed of prior to 1 March 2020, is transfer to a sludge tank an alternative.
From a MARPOL point of view, there is nothing prohibiting adding fuel to a sludge tank, and by doing so it will be considered sludge. However, the transfer evident by the ORB may raise attention with PSC, especially if the “sludge” has been incinerated on board and not disposed of to a reception facility, as this may be seen as undermining the 0.50% sulphur limit. Additionally, the sludge tank capacity is limited, and the minimum required volume is approved based on the type of machinery and length of voyage, which again will be compromised in case of excessive fuel oil transfer to the sludge tanks.
In an ideal world, all fuel exceeding the 0.50% sulphur limit should be consumed before 1 January. If this is not possible, the remaining fuel should be disposed of to a reception facility before 1 March. If non-compliant fuel remains on board after 1 March, it is advisable to follow MEPC.1/Circ.881, consulting the port state and flag state to agree on a solution.
With the adoption in 2008, 1 January 2020 was given as the effective date for the 0.50% global sulphur cap, with an option to later defer the date until 1 January 2025, taking into account the global market supply and demand. In 2016, the IMO decided, based on information provided, to stick with the 1 January 2020 date. Hence, from 1 January 2020, the global sulphur limit will be reduced from 3.50% to 0.50%. For vessels operating in Sulphur Emission Control Areas (SECA) under MARPOL, the limit, which will remain unchanged, has been 0.10% since 1 January 2015.
2: Preparation for jan 2020
The IMO has developed a “Guidance on the Development of a Ship Implementation Plan (SIP) for the Consistent Implementation of the 0.50% Sulphur Limit under MARPOL Annex VI”. Making a ship-specific SIP is considered a good starting point for preparing, as the plan will cover the expected challenges. The plan is not mandatory and is not subject to endorsement by the flag state or a recognized organization (RO). However, port state control (PSC) may consider the preparatory actions described in the SIP when verifying compliance. DNV GL has prepared a Web-based SIP application which is free of charge and available in the DNV GL Veracity marketplace.
DNV GL has also developed a checklist which contains an overview of the critical activities to be reviewed, and implemented, before the end of 2019. The checklist is available here.
3: How to clean bunker tanks before switching to compliant fuel.
Tank cleaning is basically done for the following reasons:
- To avoid operational issues with purifiers and filters, as new fuel blends and distillates may, due to their physical properties, be prone to dissolve and dislodge sludge and sediment build up in the fuel oil storage and service tanks
- To avoid separation and sludge formation due to incompatibility with remaining tank content, as new FO blends may carry a higher risk of incompatibility
- To avoid contamination of the LSFO, potentially exceeding the required sulphur content
4: In case excess HSFO can’t be disposed of prior to 1 March 2020, is transfer to a sludge tank an alternative.
From a MARPOL point of view, there is nothing prohibiting adding fuel to a sludge tank, and by doing so it will be considered sludge. However, the transfer evident by the ORB may raise attention with PSC, especially if the “sludge” has been incinerated on board and not disposed of to a reception facility, as this may be seen as undermining the 0.50% sulphur limit. Additionally, the sludge tank capacity is limited, and the minimum required volume is approved based on the type of machinery and length of voyage, which again will be compromised in case of excessive fuel oil transfer to the sludge tanks.
In an ideal world, all fuel exceeding the 0.50% sulphur limit should be consumed before 1 January. If this is not possible, the remaining fuel should be disposed of to a reception facility before 1 March. If non-compliant fuel remains on board after 1 March, it is advisable to follow MEPC.1/Circ.881, consulting the port state and flag state to agree on a solution.
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