Disruptive change facing the shipping industry is fast approaching in the form of the IMo Sulphur Cap regulation, which comes into force from 1 January 2020. although the picture is still far from clear, those in the know expect a number of vessels and operators to be non-compliant come January. where this leaves things and how authorities will react, only time will tell. and worryingly, is it already simply too late for some organisations to do what they need to do in time to ensure compliance?

Background

In October 2016, the International Maritime Organization (IMO) established a global limit for sulphur in fuel oil used on board ships of 0.50% m/m to apply from 1 January 2020. The implementation of this regulation is expected to have significant implications throughout the marine fuel supply chain and will require detailed consideration by all parties associated with the production, distribution, storage, handling and use of these fuels.

Responsibilities of fuel suppliers

Suppliers are expected to deliver a fuel which meets the parameters agreed between the supplier and the buyer. The fuel supplier is the party responsible for the delivered quantity and quality either directly or through subcontractors. Likewise, ‘meeting the needs of the ship’ means that the fuel supplied should be stable in regular handling, homogeneous across the entire delivery and fit for purpose after appropriate on-board treatment.

Quality control during production of bunkers

The bunker supplier should ensure control of individual blend component quality. This includes knowing the components’ individual properties through accurate data, and the component origins supported by relevant documentation as agreed between the buyer and seller of the components.

Transport, storage and transfer

The quality of a bunker fuel or blend components may change compared to its origin during transportation, transfers and storage. The supplier should oversee the transportation of the fuel, blend components and additives to make sure that product contamination does not take place in tanker ships, shore tanks, pipelines, road tankers or barges prior to delivery. The supplier is expected to have in place a QMS (ISO 9001 or equivalent) to monitor, manage and assess the quality of the products they are supplying throughout the above processes.

Delivery

If over one grade of bunker fuel is to be supplied, the order in which the grades are supplied should be agreed between the supplier’s representative and the ship’s master or officer in charge of the bunker operation. To prevent contamination of product during delivery, the report suggests that the lighter/lowest sulphur grade is supplied first, followed by the heavier/higher sulphur grade.

Sampling

Representative samples should be drawn during the bunker delivery for retention by both the receiving ship and the supplier, in addition to the MARPOL delivered sample which is a statutory requirement.

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