The Maritime Industry Authority reminded domestic ship owners to submit their plan on mandatory use of 0.5% mass per mass sulphur in fuel oil not later than January 1, 2022
The ship-specific plan should be complemented with actions taken for compliance
Ships already using compliant fuels should still inform MARINA in writing
The Maritime Industry Authority (MARINA) is reminding domestic ship owners to submit their ship-specific implementation plan (SIP) on mandatory use of 0.5% mass per mass (m/m) sulphur in fuel oil in compliance with the International Maritime Organization’s (IMO) sulfur cap policy.
The SIP should be submitted to MARINA not later than January 1, 2022 as provided under MARINA Circular (MC) No. MS-2020-06, according to MARINA Advisory (MA) No. 2021-58 dated October 15 and published on November 3.
Ships already using compliant fuels should immediately inform MARINA in writing, the advisory added.
Under MC MS-2020-06, all Philippine-registered ships plying the domestic trade and all newly constructed shops and imported brand-new and second-hand vessels should comply with the global 0.50% m/m sulfur cap on marine fuel oil by January 1, 2025.
All domestic ships plying the domestic trade should also develop an SIP, which is based on MARINA’s Phase-in LSFO (low-sulfur fuel oil) Implementation Plan. The plan should be complemented with a record of actions taken by the ships to become compliant by the applicable dates.
These actions are in compliance with the IMO International Convention for the Prevention of Pollution from Ships (MARPOL Convention) Annex VI. The Philippines ratified MARPOL Annex VI in 2018.
The MARPOL Convention annex requires all ships in non-emission control area zones to limit the sulfur content of their fuels from 3.50% to 0.50% by January 1, 2020.
The regulation applies to all ships, whether on international voyages between two or more countries, or on domestic voyages solely within the waters of a party to the MARPOL Annex.
The sulfur cap policy, also known as IMO 2020, aims to reduce the amount of sulfur oxides emanating from ships for global health and environmental benefits, particularly of populations living close to ports and coasts.
The policy has been in force on foreign-flagged ships and Philippine-flagged vessels plying international trade since January 1, 2020, in compliance with the global implementation schedule.
For domestic ships, MARINA earlier said implementation would be in phases to help ease the cost impact on domestic shipping companies and give oil suppliers time to acquire their supplies of compliant fuels.
MARINA Shipyards Regulation Service director Ramon Hernandez earlier noted that according to IMO, “it’s up [to] the flag state” how it would implement the policy.
Under MC SR 2020-06, fuel oils to be used on board ships for propulsion or operation, including all gas, petrol, distillates, residual and blended fuels, should have a maximum sulfur content of 0.50% per m/m.
There are, however, exemptions such as when a ship is acting to secure its safety or to save a life at sea, or obtains a fuel oil non-availability report because fuel was not available at the port of origin.
Also an exemption is when a ship fitted with an exhaust gas cleaning system (EGCS) experiences unintentional damage, resulting in emissions exceeding the sulfur limit. When this happens, the ship is expected to take all reasonable steps to reduce emissions, including carrying out repair works or switching to compliant fuel.
Ships operating an approved EGCS can use and carry fuel oil with a sulfur content that is more than 0.50% per m/m. An EGCS or scrubber is a device used to remove particulate matter and harmful components from the exhaust gases in order to implement pollution control. These harmful components, such as sulfur oxides and nitrogen oxides, are generated as a result of combustion processes in marine engines.
All existing ships may start being retrofitted with EGCS or may voluntary use the compliant fuel to comply with IMO 2020 upon the effectivity of MC SR 2020-06.
MARINA, however, must check and approve the EGCS to be used. The ship’s crew must also be trained to use the system to ensure it is kept in good working order, its maintenance is up to date, and monitoring devices are fully operational.
For monitoring purposes, specific information should be included in the bunker delivery note to be provided to MARINA and other enforcing agencies. These include, among others, a declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied conforms to the sulfur content limit.
Aside from installing an EGCS, MARINA also allows alternative measures for compliance, such as the use of alternative fuel like liquefied natural gas, or compliant marine diesel oil that has sulfur content of 0.50% per m/m or less.
MARINA may also approve other alternative measures in accordance with IMO requirements to reduce sulfur oxide emissions, provided the resulting emissions are equivalent to 0.50% per m/m.
A company or person that violates or contravenes MC SR 2020-06, particularly by using fuel oil with more than the prescribed sulfur content, stands to face an administrative fine of P3 million plus suspension of the Authority to Operate. – Roumina Pablo