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Thursday, May 2, 2019 

Norwegian risk management specialist Gard reminds shipowners that they must prepare for more spot sampling of fuel after January 2020.

Gard's latest Insight article says that onboard spot sampling of ships’ fuel is nothing new. Since the 0.10% sulphur cap entered into force in EU ports and the designated ECAs, spot sampling and analysis of ships’ fuel have been common as a means for port state control (PSC) to verify the actual sulphur content of the fuel in use.

It is anticipated that the frequency of PSC requests to take spot samples of ships’ fuel oil will increase significantly after 1 January 2020 and shipowners should prepare accordingly. The IMO’s prohibition on the carriage of non-compliant fuel oil from 1 March 2020 is expected to further drive the requirements for sampling by PSC.

There is no doubt that PSC will play an important role in the enforcement of the 2020 global 0.5% sulphur cap. However, while many PSC regimes are investing heavily in training and education of their inspectors, others may not be equally well prepared. Cases reported to Gard demonstrate that even PSC inspectors make mistakes from time to time. And when such mistakes are the reason for ships being penalised - proper onboard procedures and a well prepared and attentive crew can make a big difference in changing the outcome of a case.

For the vast majority of ships that plan to meet the 2020 requirement by burning low sulphur fuel, PSC has essentially two methods of establishing whether a ship is compliant:

  1. Verify the sulphur content of the ship’s fuel, e.g. by reviewing procedures, bunker delivery notes, log book recordings, analyse the MARPOL delivered sample, and taking additional samples at different locations of the fuel oil system.
  2. Measure the sulphur content in the ship’s exhaust gas

Gard believes that the use of remote sensing equipment and portable handheld fuel analysers is likely to become increasingly common during initial inspections by PSC. As an example, the Danish Maritime Authorities recently announced that a sulphur-sniffing drone is already in use to check emissions from ships in Danish waters.

Shipowners still face a range of uncertainties and potential operational risks post-2020. Fuel prices in 2020 are a big unknown. Compatibility between fuel batches is a serious safety concern, and so is the long-term stability of some of these new fuels. One thing is certain: PSC will start enforcing the cap from 1 January 2020, whether the industry is ready or not.

Hence, when preparing fleets and crews for compliance with the 2020 global sulphur cap:

  • Do not forget to revisit ships’ procedures for fuel sampling.
  • Make sure the procedures describe acceptable and safe sampling methods for a ship’s fuel oil system, both with respect to location of sampling points, handling of the samples, and record keeping.
  • Train the relevant members of the engine crew and emphasise the importance of escorting the attending sulphur inspector at all times while onboard.
  • Consider if the recommendations contained in existing, as well as coming IMO sampling guidelines should be implemented in a ship’s procedures. The European Maritime Safety Agency’s (EMSA) “Sulphur Inspection Guidance” provides useful advice and information on the PSC’s approach to the inspection of ships and how they ascertain a vessel’s compliance with applicable sulphur in fuel requirements.
  • Remember, without proper evidence, the chances of the shipowner losing the claim in a disputed case are high.

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