IBIA contributes to IMO plan to help ships prepare for 2020
An IMO working group meeting has developed a ship implementation plan (SIP) supported by information documents as part of the work to provide guidance on preparatory and transitional issues leading up the 0.50% sulphur limit for marine fuels from 1 January 2020.
It was agreed ahead of the intersessional working group (ISWG) meeting of the Sub-Committee on Pollution Prevention and Response (PPR) last week, tasked with developing guidelines to support the consistent implementation of the 2020 sulphur limit, that these aspects needed to fast-tracked so they can be approved by the IMO’s Marine Environment Protection Committee (MEPC) in October this year.
The SIP, which is not mandatory, can be filled in by ship owners/operators to help them plan and demonstrate the steps taken by ships to prepare for compliance with the 0.50% sulphur limit on 1 January 2020. This includes aspects such as modifications to fuel oil systems and tank cleaning if needed, fuel oil capacity and segregation capability, and bunkering plans in the lead-up to the compliance date.
In addition to the SIP itself, there is an appendix addressing the impact on machinery systems, containing advice on how to prepare for use of distillates, fuel oil blends, or both, as the compliance option for the 0.50% sulphur limit. The document focuses on any adjustments and changes that may be required or advisable on the ship ahead of the implementation date, rather than on-going operational aspects, which are expected to be detailed in guidance documents that are still under development.
A second appendix to the SIP relates to tank cleaning, which is based on a document submitted by IBIA to the ISWG describing options available for cleaning fuel oil tanks and systems.
IBIA’s document highlighted both operational risks to ships and the risk of non-compliance with the 0.50% sulphur limit if ships choose to simply load compliant fuels into tanks and that have held high viscosity high sulphur fuel oil (HSFO) because the compliant fuels could act as solvents causing HSFO sediments and asphaltenic sludge to rapidly dissolve.
Some shipping organisations at the meeting were concerned, however, that the document from IBIA, as submitted, could be seen as creating an expectation that tank cleaning is a pre-requisite, and wanted to make it clear that flushing through the fuel system with compliant fuels until it is sufficiently clean to be compliant is also an acceptable option.
They proposed a shortened version of IBIA’s tank cleaning guidance document as an appendix to the SIP set for approval at MEPC 73 in October. The appendix highlights that options for preparing HSFO tanks for compliance include flushing through fuel systems (i.e. not cleaning tanks first), manual cleaning of tanks during dry docking, manual cleaning during service, and cleaning tanks in service with specialised additives.