There is a confusion surrounding the International Maritime Organisation’s 2020 global sulphur cap and it isn’t coming from the IMO. It is all clear what the cap will mean, what it will entail and who it will benefit. The trouble is, in the slow paced ‘rush’ to accept the cap, many ship owners, operators and managers are perhaps failing to appreciate the preparations for accepting any new compliant fuels should start in 2019 and not at zero hour 2020!
Aderco, one of the world’s leading fuel treatment suppliers, has been recommending to its customers since the end of 2017 that tank cleaning needs to start no later than June 2019 to ensure they do not fall foul of the new regulations. This is the most pressing task before any new fuel blends can be introduces into their tanks and using a fuel treatment is the easiest, most cost effective and assured way of keeping a ship at sea and completing this vital task. The IMO’s Marine Environment Protection Committee (MEPC) will discuss proposals from Norway at their 73rd session in October covering implementation plans for ships to be developed according to an agreed IMO guidance and robust enough to ensure compliance by 1 January 2020. Among the proposal are for vessels to have a log of actions taken that records the first loading of compliant fuel, the fuel tank cleaning process and assessments of the new fuels on engines and machinery. This is not a task that can be adequately handled just a month before the first compliant bunkered fuel is taken on-board.
While much of the discussion about compliance with the new fuel cap has centred on scrubbers – despite the public pronouncements from some of the world’s biggest maritime players about their cost and effectiveness – it has caused many to focus their attention away from physical preparations when it comes to tank cleaning. As Olivier Baiwir, CEO of Aderco puts it:
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Those planning to switch away from HSFO to low sulfur fuels as part of their IMO 2020 compliance strategy should start their tanks cleaning no later than June 2019, Olivier Baiwir, CEO of Aderco, has advised.
Baiwir, whose company manufactures an assortment of fuel treatments including those used for tank cleaning, also advised that planning for the switch over should begin now.
“There is no time for ship owners, ship managers and operators to lose in getting their vessels ready for the IMO sulphur cap. The regulations come into force i little over 12 months but there have to be preparations well in advance of this to ensure compliance,” he says.
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John LaRese, marine fuels technical advisor at ExxonMobil, explains why vessel operators must plan well ahead to ensure they comply with the IMO’s 0.5% sulphur cap by the 2020 deadline
The International Maritime Organization’s (IMO) decision to implement a 0.5% cap on sulphur emissions has created uncertainty among passenger ship and other vessel operators. Questions are already being asked about how to comply with the changing emissions target, as well as what types of fuels will be available and where. However, ensuring compliance isn’t just about fuel selection; the actual switchover process from heavy fuel oil (HFO) to new, low-sulphur alternatives needs careful management. There are also implications for the selection of lubricants.
Vessel operators will need to take a series of important steps before bunkering a low-sulphur fuel; they will have to work out arrangements that meet the specific requirements of their vessels. Without careful preparation operators may jeopardise their sulphur compliance, which carries the risk of costly fines. They must also plan around fuel availability, given the possibility that some ports may be unable to meet the demand from the industry.
Unless a vessel is fitted with an exhaust gas cleaning system (scrubber), operators will need to ensure that their fuel tanks do not contain high-sulphur HFO by the IMO deadline. Fuel tanks will probably retain sediment from the existing HFO, which is likely to contain those higher levels of sulphur. If this is not removed, there is the risk that the compliant fuel will be contaminated, pushing its sulphur content above the 0.5% limit.
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Ensuring compliance with the IMO 2020 regulation isn’t just about fuel selection; the actual switchover process from heavy fuel oil to new, low-sulphur alternatives needs careful management, writes Luca Volta, Marine Fuels Venture Manager, ExxonMobil.
The International Maritime Organization’s (IMO) 0.50% sulphur cap will dramatically change the fuels landscape. Unlike the introduction of Emission Control Areas (ECA), the IMO’s latest emission regulations set a global limit that will require vessels to make a permanent change in fuel selection, unless operators opt to fit abatement technology
Vessel operators are asking how to comply by 1 January 2020 with the changing emissions target, what types of fuels will be available and where. However, ensuring compliance isn’t just about fuel selection; the actual switchover process from heavy fuel oil (HFO) to new, low-sulphur alternatives needs careful management. There are also implications for lubricant selection.
A number of important steps must occur prior to bunkering a low-sulphur fuel, so vessel operators will need to work out arrangements that meet the specific requirements of their vessels. Without prudent plans in place, operators run the risk of non-compliance and costly fines. They must also plan for fuel availability, given the possibility that some ports will initially be unable to meet industry demand. A high-sulphur fuel carriage ban is likely to come into force by 1 March 2020.
Unless a vessel is fitted with abatement technology, commonly known as a scrubber, operators will need to ensure that their fuel tanks do not contain high-sulphur HFO by the IMO deadline. Fuel tanks will probably retain sediment from the existing HFO, which is likely to contain those higher levels of sulphur. If this is not removed, there is the risk that the sulphur will contaminate compliant fuel, pushing its sulphur content above the 0.50% limit.
ExxonMobil expects that many compliant fuels entering the market will have a sulphur content very close to the 0.50% cap, so even very low levels of residual sulphur left in a fuel tank could tip a vessel over the IMO’s limit.
To minimise this risk, ExxonMobil recommends that vessel operators flush fuel tanks with a distillate-based product to help remove sludge deposits. This process may need to be repeated, depending on the amount of residue present. In some instances, tank bottoms may have to be manually cleaned.
The fuel used to flush tanks could contain damaging levels of cat fines, which will require on-board treatment. Vessel operators must factor in how long these processes could take and keep in mind that any sludge removed from the tanks will need to be disposed of properly.
Operators should remember that the storage, handling and treatment of 0.50% fuels will involve bunkering fuels of a wider variety of viscosities, types and formulations than seen today. On-board handling practices have to take into account likely changes in fuel types, including fuel segregation and routine compatibility testing.
Cylinder oil stock depletion
One benefit of the 0.50% cap is that vessels will be able to streamline their lubricant inventory as only one cylinder oil will be required. Vessels with scrubbers will continue to use HFO and high BN oils, while those who choose to switch to low-sulphur fuels will need correspondingly low BN formulations. These vessels must deplete their stocks of high BN cylinder oils prior to the IMO deadline to avoid waste and disposal costs.To ensure compliance, ExxonMobil recommends that vessel operators work with suppliers who have adopted the latest ISO 8217:2017 fuel standard and have the proven technical expertise to help them navigate the upcoming changes.
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There is one big issue concerning Sulphur 2020 that hasn’t been adressed enough until now.
The majority of ships are expected to use oil-based fuel oils for compliance with the 0.50% sulphur limit taking effect on 1 January 2020. Most of these ships will have been using high viscosity high sulphur fuel oil (HSFO) based primarily on residual fuel oils. Such fuels tend to stick to the inside of fuel tanks forming layers of semi-solid substances containing sediments and asphaltenic sludge.
It will therefore be necessary to clean ships’ fuel oil tanks and fuel oil service systems prior to 1 January 2020, as simply loading compliant fuel into empty fuel tanks that have not been cleaned could cause both operational risks to ships and risk non-compliance with the 0.50% sulphur limit.
Ship implementation planning for the 2020 sulphur cap is on the agenda at a week-long meeting set to take place at the International Maritime Organization in July according to IBIA. The intersessional working group (ISWG) will work on guidelines to ensure compliance and it has been agreed that guidelines pertaining to “preparatory and transitional issues” need to fast-tracked so they can be adopted by the IMO’s Marine Environment Protection Committee (MEPC) in October this year.
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