The world’s largest shipping association, BIMCO, has called upon the International Maritime Organization to adopt more accurate sulfur verification procedures and an effective implementation plan for compliance to the IMO 2020 rule.
This comes as an intersessional meeting of the IMO on sulfur implementation is being held over July 9-13.
The IMO rule on the 0.5% limit on sulfur in marine fuels, compared with 3.5% now, will take effect January 1, 2020. It applies outside designated emission control areas where the limit is already 0.1%.
The introduction of the 0.5% global sulfur cap is the most significant change since the introduction of liquid bunkers as some 60% of the bunkers will have to switch from high sulfur fuel oil to low sulfur grade overnight, according to some industry sources.
“The current IMO verification procedure contained in Appendix VI to MARPOL Annex VI is a mash-up of some elements from the ISO verification procedure, making the outcome random and difficult for ship operators and PSC authorities to understand,” BIMCO said in a statement made available to S&P Global Platts late Monday.
“BIMCO and its partners firmly believe the current verification procedure fails to be statistically sound,” it added.
In this context, it has submitted a paper to the IMO, proposing ways to secure a uniform and more accurate way of interpreting results when measuring the level of sulfur in fuel oil, BIMCO said.
The aim of the proposal is to secure easy-to-understand, easy-to-implement and uniform verification procedures of test results for both MARPOL samples and in-use fuel oil samples, it said.
One of the proposals in the document calls for the IMO to replace Appendix VI with an appropriate reference to the ISO 4259 standard, it said.
ISO 4259-1:2017, for example, specifies the methodology for the design of an inter-laboratory study and calculation of precision estimates of a test method specified by the study.
The document submitted by BIMCO also includes proposals to add a definition of sulfur content in regulation 2 of MARPOL Annex VI and to unify verification procedures for both MARPOL samples and in-use fuel oil samples, it said.
Separately in another statement, BIMCO said it had also, along with its partners, submitted a draft proposal to the IMO for an implementation plan for achieving compliance with the 0.5% global sulfur cap.
This is significant as widespread compliance to the IMO 2020 rule still remains of great concern because of the magnitude of the change this rule entails and its associated costs.
A marine industry survey conducted by ExxonMobil last year, for example, noted that the route to compliance with the IMO global sulfur cap was unclear for many vessel operators, with 70% of respondents saying that they do not believe the industry was ready for the deadline.
BIMCO said it wanted IMO member states to encourage the ships flying their flags to develop written implementation plans, to help member states adopt a practical and pragmatic approach when verifying compliance with the requirements of sulfur regulation.
The implementation plan could voluntarily be submitted to authorities, and ships carrying an implementation plan along with a detailed description of how it is being followed should be met with a practical and pragmatic approach during inspections, it said, adding that “this pragmatic implementation approach would be for a period of three months after January 1, 2020 for those ships which are in possession of an implementation plan.”
“The priority of compliance inspections in ports should be on willful non-compliance with the regulations. Where ships experience technical or operational issues that may lead to accidental and unintended non-compliance, this should be considered differently than willful non-compliance, and such ships should not face severe measures or penalties,” it said.
The draft implementation plan includes planning and preparation for structural modifications, if required, detailing the number of bunker tanks designated to store low sulfur fuel as well as the purchasing procedure to source compliant fuels, among other aspects, it said.