Carriage ban looming for ship owners and operators – IMO2020

The much reported MARPOL Annex VI regulation (a.k.a IMO2020) which was implemented to lower the current global limit for sulphur content of marine fuels from 3.50% to 0.50% came into effect on 1st January 2020..

This reduction in sulphur content is supposed to be achieved by way of

• Using low-sulphur compliant fuel oil;
• Using gas as a fuel as when ignited it leads to negligible sulphur oxide emissions;
• Using methanol as an alternative fuel as being used on some short sea services; or
• Using exhaust gas cleaning systems or “scrubbers”, which “clean” the emissions before they are released into the atmosphere

There is however another part of this regulation which is the “Carriage Ban” which comes into effect from 1st of March 2020..

This Carriage Ban which was adopted as a complementary MARPOL amendment prohibits the carriage of non-compliant fuel oil (heavy sulphur fuel) for purposes of propulsion or operation on board a ship unless the ship has been fitted with an exhaust gas cleaning system – EGCS commonly known as scrubber..

This amendment is expected to enter into force on 1st March 2020.. As from this date it will be considered an offense for any ship to be carrying fuel that contains sulphur content higher than 0.5 percent for purposes of propulsion or operation, unless the ship has a scrubber..

After this date, port state control of the various parties to the IMO have the full liberty to check the bunker tanks of ships for non-compliant fuel.. It will be easy for Port State Control (PSC) officers to track defaulting ships because ships using HSFO without scrubbers can be easily identified..

Some of the P&I clubs have advised their members of potential disputes and/or claims arising due to complaints about bunker quality, or if the bunker sample tests generate results which exceed the prescribed 0.50% limit..

The solutions that ship owners/operators have, is to ensure the fuel they use is compliant with the sulphur limits set out in MARPOL Annex VI, and ensure that the residual high sulphur fuel in the tanks does not push the limit above 0.50%..

Ship owners/operators are facing the need to de-bunker HSFO with sulphur content in excess of 0.5% m/m bearing in mind the timing of the removal of residual HSFO, effective cleaning of the fuel system (tanks, piping, service and storage tanks) prior to de-bunkering..

In view of the impending carriage ban, many ship owners/operators who have HSFO on board are left to identify options on how to dispose it off.. In order achieve compliance with the regulation, these ship owners/operators can choose between de-bunkering the HSFO or blending of the non-compliant fuels on-board..

De-bunkering comes with costs and potential losses whereas onboard blending could come with some red tape in terms of the ship being able to demonstrate that the blending has been done in such a way to produce compliant fuel..

As per BIMCO there are regulatory barriers hindering on board blending as found in regulation 18.5 and 18.6 of MARPOL Annex VI because the Bunker Delivery Note (BDN) which is the legal proof of the sulphur content of the fuel oil delivered to a ship may not be enough to provide above mentioned proof..

The punitive measures of the PSCs will only be applied on ships that use HSFO but don’t use scrubbers..

But to add to the above, apart from giving rise to several legal and operational implications, the Coronavirus (COVID-19) is also causing delays to the retro-fitting of scrubbers on various vessels before the 1st of March 2020 deadline..

This IMO2020 regulation including the Carriage Ban applies to all ships belonging to the flag states who have ratified MARPOL’s Annex VI which accounts for around 96% of the world’s fleet..

Each PSC determines the level of punitive measures to be imposed on defaulting ships including detention.. A PSC could also consider failure to maintain proper logs or bogus entries as a non-compliance even if exhaust emission levels are within limits..

In the end, compliance is the only option.. Will the IMO, which remained steadfast in its implementation of the IMO2020 regulation from 1st Jan 2020 also remain steadfast with the implementation of the “Carriage Ban” come 1st March 2020..?? Stay tuned..

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