30 April 2019

Guidance on complying with IMO 2020

From 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated emission control areas will be reduced to 0.50% m/m (mass by mass) in accordance with MARPOL Annex VI.

As an organisation committed to improving maritime safety and environmental sustainability, RightShip actively supports the safe and complete implementation of this international regulation.

Change Management Process

This new regulation represents a significant change and requires a robust change management process. All stakeholders in the fuel custody chain are expected to ensure they are compliant in all respects and have made adequate preparations to ensure their chosen compliance option is safely implemented.

Mitigating risk in the selection of the available compliance options

A range of compliance options exist and each must be evaluated carefully by the ship operator with respect to managing operational risk and safety as required by the ISM code.

This requires a comprehensive process to manage these risks through the whole supply chain, including the correct procurement, logistics and fuel management on board.

Ship operators must also ensure they complete and provide a ship-specific implementation plan well in advance of the due date to allow for familiarization and training on board and in the office. See link below for more details.

Verification, compliance & effect on RightShip ratings

Verification of compliance will primarily be carried out by class, Flag, Port State Control and local regulatory regimes.

In instances where non-compliance with IMO2020 is discovered or reported to RightShip, such incidents will impact negatively on the vessels risk rating – particularly where a lack of proper implementation of the required compliance measures, company support and inadequate training on board is found.

It is anticipated that the (extra) electrical power required to fuel the scrubber will be provided by the auxiliary engines. This therefore does not translate into an increase in the EEDI / EVDI and will not affect a vessel’s GHG Rating.

 

IMO website references:

Frequently Asked Questions: http://www.imo.org/en/mediacentre/hottopics/pages/sulphur-2020.aspx

Ship Implementation Plan: http://www.imo.org/en/OurWork/Environment/PollutionPrevention/Documents/MEPC.1-Circ.878.pdf

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