On 25 September 2018 AMSA and MIAL presented the fourth joint Roundtable discussion on the sulphur regulation, hosted by Viva Energy at their facilities in Gore Bay, Sydney.
AMSA provided an update on recent IMO meetings on the implementation of the regulation, including an intersessional sulphur working group meeting (July 2018) which developed guidance for a non-mandatory Ship Implementation Plan that can aid ships in planning for the transition to the regulation. The meeting also considered safety issues associated with the use of low sulphur fuels, which will be considered by the IMO’s Maritime Safety Committee in December 2018, including compatibility, stability of blended fuels, cold-flow properties and catalytic fines.
It was noted that OCIMF & IPIECA with ISO, CIMAC and the Energy Institute, are developing industry guidance that addresses the impact of new fuel blends or fuel types on machinery systems, as well as guidance on handling, storing and using these fuels. This industry guidance should be made available to the 6th session of the IMO Pollution Prevention and Response Sub-Committee (PPR 6 – February 2019).
In relation to categorisation of new fuels, MIAL and AMSA noted that ISO has advised that 0.50% fuel oils will be categorised within the existing ISO 8217 Standard. ISO is currently updating the standard accordingly, however, as this will not be ready until late 2020, ISO will release a Publically Available Specification (PAS) in 2019 which will provide guidance on the application of ISO 8217 to low sulphur fuels.
It was noted that several key issues would be considered at the October meeting of the IMO Marine Environment Protection Committee (MEPC 73):
- For adoption – a ban on the use and carriage for use of non-compliant fuel, to support compliance with the 0.50% m/m sulphur standard (Note: This was adopted at MEPC 73 and will enter into force 1 March 2020)
- An ‘experience building phase’ including voluntary data collection and a focus on addressing issues with compliance without penalisation (Note: This did not gain support at MEPC 73)
- Encouraging reporting on the availability of compliant fuels through IMO’s Global Integrated Shipping Information System (GISIS) prior to 1 January 2020 through an MEPC resolution (Note: This was supported but will be promulgated through an IMO Circular rather than a resolution)
The group discussed the fuel options to achieve compliance with the regulation, including the use of Marine Gas Oil; 3.50% sulphur fuel (HSFO) when the ship has in use an exhaust gas cleaning system (i.e. scrubber); and 0.50% m/m blended fuels, noting that supplies of the latter can be secured under contractual arrangements with the supplier.
The group discussed the compliance approach in Australia and elsewhere from 1 January 2020. AMSA noted that the existing port State control inspection regime for determining compliance will continue to operate post 1 January 2020. AMSA is currently assessing the potential use of indicative tools to detect non-compliance, such as sniffer tools and hand held analysers. It was noted that exhaust gas cleaning systems (as an equivalent to the use of low sulphur fuel to comply with the regulation) will be permitted under the MARPOL Convention and Commonwealth legislation, however, there may be restrictions on the discharge of waste water from the system to comply with State/NT water quality regulations.
In recognising the uncertainty associated with compatibility of engines and compliant fuel, members of the group provided information on their transitional plans for 1 January 2020. This included trialling compliant fuels in engine systems to identify any issues that need to be rectified, particularly associated with compatibility; consideration and cost comparisons for the installation of scrubbers; and communications with clients related to expected increases in costs with the global implementation of the regulation.
In relation to the availability of compliant fuels, the benefits of enhancing the fuel oil suppliers list maintained by AMSA was also discussed. It was suggested that enhancing this list could support the identification of where in Australia compliant fuel is available and, potentially, ports where poor quality fuel has been delivered, which could be made public through the IMO Global Integrated Information System (GISIS) or the fuel oil suppliers list. It was also noted that it is a requirement to be listed on AMSA’s fuel oil supplier list if providing marine fuel. If you are currently providing fuel to the maritime industry, but are not registered, please contact firstname.lastname@example.org.
The group also discussed that it would be beneficial for there to be a publically available list of ships that have an approved scrubber installed so that fuel oil suppliers can check this against requests for non-compliant fuels in an effort to assist with compliance. This is something that AMSA will investigate further.
The group noted the work to be undertaken by AMSA to gather information to assess the case, or otherwise, for an IMO designated Emission Control Area (ECA), to inform future decision making on air emissions in Australian waters. AMSA noted this was for research purposes only.
It was suggested that the next Sulphur roundtable take place in late January, ahead of the meeting of the next IMO Pollution Prevention and Response Sub-Committee meeting in February (PPR 6).