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 of 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 of 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 of 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 on 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 open 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 KrishnakumarSenior Technical Advisorsunil.krishnakumar@ics-shipping.orgwww.ics-shipping.org

@icsshipping