Article: Preparations intensify as IMO 2020 global sulphur cap looms
03 December 2019
With less than a month to go for the impending IMO 2020 global sulphur cap, the club has started witnessing dispute cases relating to the measurement of sulphur content in the fuel.
Under MARPOL Annex VI, it is a statutory requirement that a bunker delivery note (BDN) includes at least the stipulated information and declaration, and this must be provided by the supplier to the ship. With regard to the sulphur content, the supplier must state the actual sulphur content, rather than advising that the sulphur constitutes <X%. It is important that the supplier delivers accurate information so that the ship operator can characterize the fuel supplied and take the appropriate initial steps in setting up procedures for the handling, treatment and use of that fuel.
Within the marine fuel (ISO 8217) standard, the repeatability and reproducibility are defined according to ISO 4259 that enable a 95% confidence limit to be applied. However, these rules do not apply to Sulphur & Flash Point test specifications due to the statutory requirements.
Sulphur is a MARPOL related issue and Flash Point is a SOLAS related parameter hence do not apply. This means the fuel is considered to be off-spec if the sulphur or flash point is greater than the specification limit regardless without any tolerance values.
MARPOL delivered sample would be considered 'off-limit' if the sulphur limit is found above 0.50%. As per the 95% confidence limit, the fuel oil suppliers should aim to match 0.47% sulphur content so that the tolerance may range from 0.44% to 0.50%.
As highlighted in the club’s article published earlier this year (which can be found in the link on the right), the 'in-use' and 'onboard' samples when taken by the PSC for verification of compliance, a sulphur content of up to 0.53% could be accepted as compliant, based on similar 95% confidence limit or test tolerance range.
In accordance with IMO MEPC.320(74), if non-compliance, such as issuance of an incorrect BDN or a BDN without measurement of sulphur content, was found, the designated authorities should take appropriate corrective measures against the non-compliant supplier. In such case, the designated authorities should inform the IMO for transmission to the Member States of the non-compliant supplier.
Further, as per IMO MEPC.321(74), if the BDN shows compliant fuel, but the master has independent test results of the fuel oil sample taken by the ship during the bunkering which indicates non-compliance, the master may have documented that through a notification to the shipʹs flag administration with copies to the competent authority of the relevant port of destination, the administration under whose jurisdiction the bunker deliverer is located and to the bunker deliverer.
Lastly, IMO has issued a press briefing (on 25 November 2019) reminding industry stakeholders of the many publications including guidelines, best practices, FAQs, presentations, etc which are available as they make preparations to meet the new lower sulphur limit in their fuels. Links to all these resources are provided in the IMO’s Briefing.