Implementation of the sulphur regulation
IMO work commenced in 2018
In July 2017, the IMO agreed to a scope of work to assist with the transition to the new requirement. This work started in February 2018 with the IMO’s pollution subcommittee considering:
- Preparatory and transitional issues that may arise with a change to the sulphur content limit.
- Impact on fuel and machinery systems from using compliant fuel.
- Verification issues and control mechanisms and actions to ensure compliance and consistent implementation.
- Development of a draft standard format (a standardised system) for reporting fuel oil non-availability as provided in regulation 18.2.4 of MARPOL Annex VI. This may be used to provide evidence if a ship is unable to obtain fuel oil compliant with the provisions stipulated in regulations 14.1.3 and 14.4.3 (limits for outside and inside emission control areas).
- Development of guidance that may assist countries and stakeholders in assessing the sulphur content of fuel oil delivered for use on board the ship. This is based on the consideration of ways to encourage verification that fuel oils supplied to ships meet the specified sulphur limit as stated on the bunker delivery note.
- Request to ISO to consider the framework of ISO 8217 with a view to keeping consistency between the relevant ISO standards on marine fuel oils and the implementation of regulation 14.1.3 of MARPOL Annex VI.
- Any consequential regulatory amendments or guidelines necessary to ensure consistent application of regulation 14.1.3 of MARPOL Annex VI.
Guidelines for consistent implementation
The IMO agreed that a single set of guidelines should be developed that addresses all of the above identified aspects of the transition. The guidelines will focus on:
- Preparatory and transitional issues—for example the use of compliant fuel, crew awareness and training.
- The impact on fuel and machinery systems of implementing the regulation.
- Compliance and enforcement considerations.
- The non-availability of compliant fuel oil (e.g. a format for reporting non-availability and information sharing between countries).
- Other useful guidance and information to assist all stakeholders to implement the regulation. Including fuel management, guidance on new types of fuels and blends, and information on quality assurance and supply chain integrity.
Ban on carriage for use
The IMO agreed a new regulation to ban the use, and carriage for use, of non-compliant fuel.
Amendments were made to the instrument that regulates air emissions from ships (the International Convention for the Prevention of Pollution from Ships (MARPOL)). The IMO Marine Environment Protection Committee (MEPC) agreed the amendments in April 2018.
If adopted by the next session of the MEPC (October 2018), this ban will be effective from 1 March 2020.
Outcomes from the Intersessional Working Group Meeting
As part of the IMO’s work on the transition to the new requirement, a working group meeting was held by the IMO from 9-13 July 2018.
The tasks were to:
- Develop the single set of guidelines to support the consistent implementation of the sulphur regulation.
- Draft amendments to MARPOL Annex VI to support the agreed implementation measures.
- Draft amendments to existing guidelines:
- 2009 Guidelines for port State control under the revised MARPOL Annex VI;
- 2010 Guidelines for monitoring the worldwide average sulphur content of fuel oils supplied for use on board ships) and guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships.
- Draft amendments to MARPOL Annex VI to require a dedicated sampling point.
Work progressed on all these items, with focus given to the development of Ship Implementation Plans (SIPs), as requested by MEPC in April 2018.
The group agreed ‘Guidance on Ship Implementation Plans for consistent implementation of the 2020 0.50% sulphur limit’. This Guidance includes information on transition planning and preparation. Examples of this include:
- structural and machinery modifications and tank cleaning
- fuel oil storage capacity
- procurement of compliant fuel
- the fuel changeover plan
- documentation and reporting
- the impact on machinery systems.
The guidance also includes a template for use by ships to develop a SIP if they choose. The working group agreed that these plans should be non-mandatory and ships that do not carry a SIP onboard should not be subject to further inspection purely on that basis.
The guidance on SIPs will be reported to MEPC 73 in October for consideration and approval.
The safety aspects identified by the working group will also be directed to MEPC. It is recommended that MEPC direct these issues to the IMO’s Maritime Safety Committee to be addressed. This means that these issues should be considered by that Committee in December 2018.
In addition, the Oil Companies International Marine Forum (OCIMF) and the International Petroleum Industry Environmental Conservation Association (IPIECA), along with organisations such as the Energy Institute and International Organization for Standardization (ISO) are set to develop industry guidance.
This guidance will provide information about:
- The impact of new fuel blends or fuel types on fuel and machinery systems
- The handling, storage and use of such fuels, amongst other things.
Industry expect that the guidance will be ready in early 2019.
All other issues considered by the working group have been directed to the pollution subcommittee for consideration in February 2019. They will then be considered and finalised by MEPC in May 2019. This includes information related to fuel oil non-availability reporting.