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Web Alert: IMO's Guidance on Ship Implementation Plan for 2020 Global Sulphur Cap

11 January 2019

IMO’s Marine Environment Protection Committee (MEPC), during its seventy-third session (22-26 October 2018) agreed that Administrations should encourage ships flying their flag to develop implementation plans, outlining how the ship may prepare in order to comply with the required sulphur content limit of 0.5% by 1 January 2020.

Consequently, attached guidance (MEPC.1/Circ.878) on the development of a Ship Implementation Plan (SIP) for the consistent implementation of the global sulphur cap under Marpol Annex VI was issued.

Administrations and Port State Control authorities, under Regulation 18.2.3 of MARPOL Annex VI, may take into account the implementation plan when verifying compliance with the 0.5% sulphur limit requirement. However, as SIP is not a mandatory requirement, its absence or incorrect entries should not form the basis for a PSC deficiency.

The SIP can be helpful for the ship owners and operators when planning and demonstrating the actions taken by their ships to ensure compliance by the applicable date.

The SIP could cover various items relevant for the specific ship, including, as appropriate, but not limited to:

  • risk assessment and mitigation plan (impact of new fuels)
  • fuel oil system modifications and tank cleaning (if needed)
  • fuel oil capacity and segregation capability
  • procurement of compliant fuel
  • fuel oil changeover plan (conventional residual fuel oils to 0.5% sulphur compliant fuel oil)
  • documentation and reporting.

The plan could be complemented with a record of actions taken by the ship in order to be compliant, which would serve to facilitate the documentation check by inspectors.