Now we are getting down to the nitty-gritty of the IMO’s 2020 sulphur cap. In the months leading up to the start of this global ban on sulphur emissions the business of tank-cleaning is just one of the pressing issues ship owners and operators need to tackle. Although the regulations are determined, there are areas that need to be addressed and most importantly understood in relation to the new compliant fuels. Vessels using any of the new fuel blends available to maritime shipping from January 1 2020 will need to have more than faith in bunkering to remain compliant once the IMO 2020 global sulphur cap comes into force.

Bunker delivery notes will now need to state the sulphur content of the new fuels supplied and this is just one of the concerns for ship owners, managers and operators according to Olivier Baiwir, CEO of Aderco.

“To keep within the regulations all bunker delivery notes will have to state the sulphur content of the fuel oil supplied. This can be verified by taking samples and the International Air Pollution Prevention (IAPP) certificate issued by the vessel’s flag state (registry) will need to state that the ship uses a fuel with the accepted new regulatory sulphur content. This will need to be within the applicable limits or uses an approved equivalent method to be compliant.

As we have been saying for many months, the availability of the new fuel and its bunkering has been one of the prime concerns since the formal announcement of the cap. Yet bunkering ports which are located in countries which are not parties to Annex VI, have no direct requirement to comply with Regulation 18: ship owners should, therefore, when ordering bunkers, insert clauses to the effect that the fuel oil supply process is to be in accordance with the requirements of Annex VI and with specified maximum sulphur content appropriate to the particular intended future area of operation. This will ensure they remain compliant with the cap.”

Certain regions such as in the Middle East and Australia believe they are small markets that will initially struggle to find the right amount of compliant fuel. But the reality is that ships will simply not use ports that cannot offer compliant fuels after January 1 2020. The clock moves on and so do the regulations: keep reading; keep planning and keep searching.

Regulation 18 MARPOL Annex VI

Regulation 18 Fuel oil availability and quality Fuel oil availability I Each Party shall take all reasonable steps to promote the availability of fuel oils that comply with this Annex and inform the Organization of the availability of compliant fuel oils in its ports and terminals. 2.1 If a ship is found by a Party not to be in compliance with the standards for compliant fuel oils set forth in this Annex, the competent authority of the Party is entitled to require the ship to: 1 present a record of the actions taken to attempt to achieve compliance; and 2 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. 2.2 The ship should not be required to deviate from its intended voyage or to delay unduly the voyage in order to achieve compliance. 2.3 If a ship provides the information set forth in paragraph 2.1 of this regulation, a Party shall take into account all relevant circumstances and the evidence presented to determine the appropriate action to take, including not taking control measures. 2.4 A ship shall notify its Administration and the competent authority of the relevant port of destination when it cannot purchase compliant fuel oil. 2.5 A Party shall notify the Organization when a ship has presented evidence of the non-availability of compliant fuel oil.