IMO 2020: Looking beyond the horizon Sunil Krishnakumar Senior - - PowerPoint PPT Presentation

Sunil Krishnakumar Senior Technical Advisor

IMO 2020: Looking beyond the horizon

About ICS

 The global trade association for merchant shipowners and operators formed in 1921  First shipowner NGO granted IMO consultative status (1961)  Membership comprises world’s national shipowner associations, representing all sectors and trades and over 80% of world merchant fleet

IMO Work on 2020

ICS Work at IMO

 Proponents of the concept of carriage ban on non-complaint fuels  Vital role in the development of IMO template on ship implementation plans  Substantial contribution to the IMO suite

• f 2020 guidance

 Proactive participant in discussions related to fuel quality and safety

ICS Work - Guidelines

 ICS guidance on Preparing for Compliance with the Global Sulphur Cap  Joint industry guidance on supply and use

• f 0.50% fuel

 Participation in fuel quality and safety initiatives e.g. Amsterdam Rotterdam Antwerp (ARA) fuel quality working group, CIMAC WG7 on fuels etc.

ICS Guidance on Compliance

 For ships choosing to comply using fuel oils with sulphur content of 0.50% m/m or less  Updated to take account of latest IMO decisions  Available free of charge via ICS web site

Contribution to external work

Challenges remain

 Global availability of safe & compliant fuel  Consistent and fair verification and enforcement by member States  Maintaining level playing field

Availability

 Positive signs from major bunkering hubs  Concerns remain about smaller ports  Especially concerning for ships on tramp trades

Safety

 Incompatibility between different batches of fuels  Very little operational experience

Safety

 Fuel safety a huge concern  Fuel supply side still largely unregulated

Verification and enforcement

 Due consideration to ships that have prepared in advance in good faith  Differentiation between accidental and wilful non-compliance  Fuel Oil Non Availability Reports

Verification and enforcement

➢ Wilful non-compliance = enforcement action ➢ Ships do not have control over sulphur content

• f fuel as supplied

➢ Documentation is key - Bunker Delivery Note is a statutory document

Verification and enforcement

Sampling for compliance verification ➢ MARPOL delivered sample ➢ In use sample ➢ On board sample

Verification and enforcement

MARPOL delivered sample ➢ Previously known as MARPOL Sample ➢ Non-compliance proves supplier’s fault ➢ Should prove which party is responsible for exceedance of the sulphur limit of the ship’s

• n board and/or in-use fuel oils

Verification and enforcement

In use sample ➢ the sample of fuel oil the ship is using at the time of sampling ➢ All ships required to have these points ➢ Location is “safety critical” ➢ Non compliant result should be followed up by checking MARPOL delivered sample to confirm responsibility

Verification and enforcement

On board sample ➢ The sample of fuel oil intended to be used on board that ship ➢ Set up to address enforcement of carriage ban ➢ Storage tanks are not designed for representative sampling ➢ Non compliant result only applicable for fuel at the point of sampling!

Verification and enforcement

Verification standards – MEPC.1/Circ.882

ECA compliance

Concentrated Inspection Campaign (CIC) on MARPOL Annex VI by Paris MoU and Tokyo MoU ❖ Number of inspections: 4,304 ❖ Detentions related to CIC topic: 7 ❖ Overall CIC-topic detention rate: 0.2%

Level playing field

 Carriage ban on non-complaint fuel  Similar standards for all methods of compliance  Very high premium for non-compliance

EGCS as a compliance option

➢ Grandfathering ➢ ICS list of ports prohibiting discharge from

• pen loop scrubbers

➢ Equivalent standards for equivalent systems ➢ Guidance to members on steps to take following EGCS malfunction – MEPC.1/Circ.883

Conclusions

ICS confident that IMO 2020 will be a success Scale of this “regulatory game changer” not to be underestimated Availability of compliant fuel and consistent and fair enforcement will be key

Sunil Krishnakumar Senior Technical Advisor sunil.krishnakumar@ics-shipping.org www.ics-shipping.org @icsshipping