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DNV GL WARNS ABOUT UPCOMING HSFO CARRIAGE BAN

Friday, February 7, 2020 

DNV GL has drawn the industry's attention to the forthcoming 'carriage ban' meaning that ships without an exhaust gas cleaning system (EGCS) are not allowed to carry any fuel exceeding 0.50% sulphur in the fuel tanks.

The rationale for the ban is that if such fuel is not permitted, there is no reason to carry it. Regulation 14.1 of MARPOL Annex VI will now read: "The sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m".

While the new sulphur limit took effect on 1 January, the carriage ban will be effective from 1 March 2020. The two-month time gap is by no means introduced as a grace period. The reason for the gap is solely due to the IMO process of adopting new regulations.

As part of the MARPOL amendments, the standard format of the IAPP certificate will also change from 1 March. A new tick-off box with the following text will be included in the supplement: "For a ship without an equivalent arrangement approved in accordance with regulation 4.1 as listed in paragraph 2.6, the sulphur content of fuel oil carried for use on board the ship shall not exceed 0.50% m/m as documented by bunker delivery notes."

The IAPP certificate is required to be re-issued in the new format no later than the first IAPP survey after 1 March, being the annual, intermediate or renewal survey. If, for other reasons, the certificate is to be re-issued after this date, it will be in the new format.

With the carriage ban in place, Port State Control will have the opportunity to sample and verify the sulphur content of fuel carried for use to verify compliance with the new sulphur limit.

When verifying the sulphur content of samples taken on board, as opposed to the MARPOL sample taken during bunkering, a 95% confidence interval has been given. This means that a sulphur content of up to 0.53% may be accepted as compliant when testing such samples. This is to ensure that ships are not unjustly penalised for marginal excess in sulphur content beyond their control. (MEPC.1/Circ.882).

DNV GL recommends that compliance is the only option. For vessels without any approved equivalent arrangements in place, in case of any remaining HSFO from before 1 January, this needs to be dealt with before 1 March. In case removing the fuel in time is not feasible, flag and ports state should be contacted to agree on contingency measures (ref. MEPC.1/Circ.881).

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