ICS’ free guidance on preparing for Sulphur Cap

(Posted on 20/09/18)

To assist shipping companies prepare for implementation of the UN IMO global sulphur cap for ships’ fuel oil, the International Chamber of Shipping (ICS) has produced – free of charge – some comprehensive guidance on implementation planning, to help ensure compliance across the shipping industry with this regulatory game changer.

The free ICS guidance has been prepared for the vast majority of ships that will comply after 1 January 2020 using fuel oils with a sulphur content of 0.50% m/m or less.

ICS Secretary General, Guy Platten, explained: “Shipping companies may need to start ordering compliant fuels from as early as the middle of 2019, and they are strongly recommended to commence developing implementation plans as soon as possible.”

Apart from the significant additional cost of compliant fuel, ICS says that implementation of the global cap will be far more complex than for the previous introduction of Emission Control Areas. This is because of the sheer magnitude of the switchover and the much larger quantities and different types of fuel involved, as well as continuing uncertainties about the availability, safety and compatibility of compliant fuels in every port worldwide.

ICS argues that if a ship – as now recommended by IMO – has a suitably developed implementation plan, then the ship’s crew should be in a better position to demonstrate to Port State Control that they have acted in ‘good faith’ and done everything that could be reasonably expected to achieve full compliance.

“This need to demonstrate good faith could be particularly important in the event that safe and compliant fuels are unavailable in some ports during the initial weeks of implementation” said Mr Platten. “And IMO has provisionally agreed that Port State Control authorities may take into account the ship’s implementation plan when verifying compliance with the 0.5% sulphur limit.”

The new ICS guidance explains that the implementation process will need to address the possibility that some ships may need to carry and use more than one type of compliant fuel in order to operate globally. This could introduce additional challenges such as compatibility between different available grades of fuel that could have significant implications for the safety of the ship as well as its commercial operation.

While ICS is committed to helping to make the 2020 sulphur cap a success, the global trade association stresses that the full implementation picture is far from complete, and that primary responsibility for ensuring that compliant and compatible fuels will be available rests with oil suppliers, as well as those IMO Member States which have collectively agreed to implement this major regulatory change in 2020.

ICS also wants to see more progress by governments on addressing outstanding safety issues, including serious concerns about the fuel quality of new blended fuel oils, at the next meeting of the Maritime Safety Committee in December 2018.

‘Provisional Guidance to Shipping Companies and Crews on Preparing for Compliance with the 2020 Global Sulphur Cap’ can be found free of charge on the ICS website.