Home » Breaking News, Maritime » Bunker delivery note amendments come into force as IMO2020 looms

Amendments to the bunker delivery note relating to the supply of marine fuel oil to ships that have fitted alternative mechanisms to address sulfur emission requirements entered into force on January 1, 2019, according to the International Maritime Organization (IMO).

This as the shipping industry counts down to January 1, 2020, when the limit for sulfur in fuel oil will be reduced to 0.50% m/m outside emission control areas (ECAs), from 3.5% currently. The new limit under IMO’s MARPOL (International Convention for the Prevention of Pollution from Ships) treaty will have significant benefits for the environment and human health.

In ECAS, the limit will remain at 0.10% m/m.

The amendments to Appendix V of MARPOL Annex VI intend to address situations where the fuel oil supplied does not meet low sulfur requirements, but has been supplied to a ship using a permissible alternative compliance method to reduce the sulfur oxide emissions of the ship in order to comply with MARPOL requirements. An equivalent means may be abatement technology such as an exhaust gas cleaning system (“scrubber”), if accepted by the flag state of a ship as an alternative means to meet the sulfur limit requirement.

The bunker delivery note shall include a declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied conforms to regulation 18.3 of MARPOL Annex VI. The declaration also states that the sulfur content of the fuel oil supplied does not exceed the following:

  • the limit outside ECAS (currently 3.50%, falling to 0.50% from January 1, 2020) under regulation 14.1;
  • the limit in emission control areas (0.10% m/m) under regulation 14.4;  or
  • the purchaser’s specified limit value, based on the purchaser’s notification that the fuel oil is intended to be used in combination with an equivalent means of compliance; or is subject to a relevant exemption for a ship to conduct trials for sulfur oxides emission reduction and control technology research.

It can be recalled that in October 2018, IMO’s Marine Environment Protection Committee (MEPC) adopted a further amendment to MARPOL Annex VI, which will prohibit a ship from carrying non-compliant fuel oil for combustion purposes for propulsion or operation, unless the ship has an equivalent compliance method.

This amendment is expected to enter into force on March 1, 2020, and will (among other things) amend the form of the International Air Pollution Prevention Certificate so that it specifies that, for a ship without an approved equivalent arrangement, the sulfur content of fuel oil carried for use on board the ship shall not exceed 0.50% m/m as documented by bunker delivery note.

Data collection on fuel oil consumed

IMO also stated that from January 1, 2019, data collection on fuel oil consumption has begun. This means ships of 5,000 gross tonnage and above need to start collecting data on their fuel oil consumption, under the mandatory data collection reporting requirements which entered into force in March 2018.

The MARPOL Annex VI regulation on collection and reporting of ship fuel oil consumption data requires ships of 5,000 gross tonnage and above to collect consumption data for each type of fuel oil they use, as well as other, additional, specified data including proxies for transport work.

The data collection system is one of the measures taken to support the implementation of IMO’s initial strategy on reduction of GHG emissions from ships, adopted in 2018. The ships covered by the regulation represent about 85% of the total CO2 emissions from international shipping.

The data collection system is intended to support the three-step approach towards addressing CO2 emission from international shipping: data collection, data analysis, followed by decision-making on what further measures, if any, are required.

At the same time, the 2017 set of amendments (04-17) to the International Maritime Solid Bulk Cargoes Code (IMSBC Code) cargoes similarly entered into force on January 1, 2019.

The amendments include requirements for the shipper to declare whether or not a solid bulk cargo, other than grain, is harmful to the marine environment.

Other amendments include updated carriage requirements for a number of specific cargoes, and amendments to highlighting the responsibility of the shipper for ensuring that a test to determine the transportable moisture limit of a solid bulk cargo is conducted.

Photo: SkyPixels

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