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The early days of the IMO 2020 inception are seeing a few disruptions in the bunkering supply chain. The club has been notified by a few concerned members on the non-availability of the compliant fuel at certain ports. As reported in The Hindu Business Line, the lack of low-sulphur compliant fuel oil may halt ship operations on east coast of India. Reuters has reported tightening in bunker supply even at some of the main bunkering hubs in Europe, Asia & United States, which has caused an escalation in the price of the compliant fuel. In order to avoid backlog and delays in bunker supply, members are advised to plan ahead and arrange bunker supply in advance of ship’s arrival at the port.
Documentation
In the event of unavailability of compliant fuel, members are required to document and evidence all steps taken to achieve compliance (Regulation 18.2.1.2). This requires the vessel to inform its flag state (Regulation 18.2.4) and to complete a Fuel Oil Non-Availability Report (FONAR). Regulation 18.2.2 provides that, 'ships should not be required to deviate or unduly delay the voyage in order to achieve compliance'. However, whilst this regulation could potentially act as mitigating circumstances, it is not an exception to compliance. Members are reminded that completion of a FONAR is 'not a free pass'. Port state control 'shall take into account all relevant circumstances and the evidence presented to determine the appropriate action to take' (Regulation 18.2.3), but the ship will be de facto in breach of MARPOL Annex VI.
IMO’s FONAR guidance on investigating and evidencing procedures can be found on the right. Members are also recommended to refer to the club’s guidance on this matter.
