All Philippine-registered ships plying in the domestic trade should comply with the global 0.50% sulfur cap on marine fuel oil by January 1, 2025
All newly constructed ships and all imported brand-new and second-hand vessels should also comply with the 0.50% per mass by mass (m/m) fuel oil sulfur content limit on January 1, 2025
All Philippine-registered ships in the domestic trade should also develop a Ship Specific Implementation Plan to be submitted by 2022 to MARINA for approval
Ships installed with an approved exhaust gas cleaning system or scrubber can use and carry fuel oil with a sulfur content that is more than 0.50% per m/m
All Philippine-registered ships plying the domestic trade should comply with the global 0.50% sulfur cap on marine fuel oil by January 1, 2025, according to the Maritime Industry Authority (MARINA).
In addition, all newly constructed ships and all imported brand-new and secondhand vessels should also comply with the 0.50% per mass by mass (m/m) fuel oil sulfur content limit on January 1, 2025, according to MARINA Circular (MC) No. SR 2020-06, which takes effect on March 4, 2021.
Applications for non-compliant imported ships will be disapproved by MARINA, MC SR 2020-06 noted.
MC SR 2020-06 is issued in compliance with the International Maritime Organization (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 enforced 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.
Exemptions to sulfur policy
Under MC SR 2020-06, fuel oils to be used on board ships for propulsion or operation should have a maximum sulfur content of 0.50% per m/m including all gas, petrol, distillates, residual and blended fuels.
There are, however, exemptions from compliance such as when a ship is acting to secure the safety of the ship or to save a life at sea, or obtains a fuel oil non-availability report due to non-availability of fuel from 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, which may include carrying out repair works or switching to compliant fuel.
Ships that are operating an approved EGCS should be able to 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.
Ship implementation plan
All Philippine-registered ships in the domestic trade should also develop a Ship Specific Implementation Plan (SIP), which is based on MARINA’s Phase-in LSFO (low-sulfur fuel oil) Implementation Plan. The SIP should be complemented with a record of actions taken by the ships in order to be compliant by the applicable dates.
The ships must submit the SIP to MARINA for approval not later than January 1, 2022. All existing ships may also 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 the consistent interpretation and implementation of the use of the LSFO under MARPOL 73/78 Annex VI, shipowners, operators, charterers, and International Association of Classification Societies/recognized organizations should use the IMO Marine Environment Protection Committee (MEPC) approved MEPC.1/Circ.878 (guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulfur limit under MARPOL Annex VI) and its subsequent amendments.
Proper fuel discharge
Ships, upon complying with MC SR 2020-06, should properly discharge any fuel that has a sulfur content of more than 0.50% per m/m.
Non-compliant fuel oil can be de-bunkered to another ship to be carried as cargo, or to an appropriate shipboard or land-based facility.
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 is in conformity with the sulfur content limit.
Aside from the installation of EGCS, MARINA also allows alternative measures for compliance, such as the use of alternative fuel like liquefied natural gas (LNG), 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 found to have violated or contravened MC SR 2020-06, particularly for using fuel oil with more than the prescribed sulfur content, stands to face an administrative fine of P3 million plus suspension of Authority to Operate. – Roumina Pablo