PRS reports on sulphur content limits in oil fuels

Polish Register of Shipping presents the conditions and requirements related to the implementation of the IMO maximum sulphur content limit of 0.5% in marine oil fuels from 2020.

The International Maritime Organization (IMO)

in its landmark decision, both in relation to the marine environment and human health, set 1 January 2020 as the deadline for implementation for reducing the sulphur content of oil fuels used by ships in global shipping to a maximum level of 0.5% of the sulphur content, in accordance with MEPC.280(70). According to the new global limit specified in Regulation 14.1.3 of Annex VI to MARPOL, all ships operating outside Emission Control Areas (ECA) will be required to use oil fuels with a maximum sulphur content of 0.5%, as compared to the current limit of 3.50%.

The new global requirement

does not change the sulphur limits applicable within the limits of the SOx Emission Control Areas (ECA) established by the IMO, which as of 1 January 2015 amount to 0.10%. The Emission Control Areas established under MARPOL Annex VI for SOx are: the Baltic Sea area; the North Sea area; the North American area (including the designated coastal areas of the United States and Canada); and the Caribbean Sea area of the United States (around Puerto Rico and the Virgin Islands of the United States).

Vessels may comply with the new requirements by

Transition from high sulphur oil fuel (HSFO) to diesel fuel (MGO) and use of low sulphur oil fuel,
use of alternative fuels (liquefied natural gas (LNG), liquefied petroleum gas (LPG), etc.),
the use of alternative technologies such as exhaust gas cleaning systems – scrubbers (in which case this equivalent solution must be approved by the Administration of the flag State of the ship).
At the same time, as of 1 March 2020, IMO introduced a ban on transporting fuels which do not comply with the current 0.5% sulphur limit on ships and which are used for propulsion and operational purposes, unless they are equipped with alternative exhaust gas cleaning systems. These requirements are introduced by MEPC.305(73) – Amendments to MARPOL Annex VI (prohibition on the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship).

Taking into account the impact of the use of 0.50% sulphur oil fuels

on the correct operation of shipboard machinery and systems, the Polish Register of Shipping encourages all shipowners to develop an IMO recommended Plan for the consistent implementation of the 0.50% sulphur limit on board ships in accordance with the provisions of Annex VI to the MARPOL Convention (the Coherent Implementation Plan).

The Consistent Implementation Plan should be reviewed by PRS sufficiently in advance and as soon as possible in order to verify the ship’s capability to meet the 0.50% sulphur limit from 01.01.2020.

Guidelines containing recommendations for the development of the Consistent Implementation Plan are set out in IMO Circular MEPC.1/Circ.878.

The Plan should be complemented

by a record of the actions taken on board to comply with the rules within a specified period of time.
The Polish Register of Shipping approves oil fuel system diagrams, where fuel sampling points should be designated to verify sulphur content. Guidelines for on-board sampling for the verification of the sulphur content of marine oil fuel used on board ships are set out in IMO Circular MEPC.1/Circ.864.

PRS recalls that on every ship of 400 gross tonnage or more engaged in international navigation, a fuel delivery note shall be kept on board for a period of three years after the delivery of fuel to the ship and relevant oil fuel samples shall be kept on board for a period of not less than 12 months in accordance with Regulation 18 of Annex VI to MARPOL. Guidelines for oil fuel sampling and storage are laid down in IMO Resolution MEPC.182 (59).

Relief (PRS)