At its latest Marine Environment Protection Committee (MEPC 73), IMO approved, among others, the guidance on the development of a ship implementation plan outlining how the ship may prepare in order to comply with the required sulfur content limit of 0.50% by 1 January 2020 (IMO 2020 sulfur cap) under MARPOL Annex VI.

IMO's 2020 Sulfur cap, which will take effect from 1 January 2020, requires that ships must run on fuel containing no more than 0.5% m/m of sulfur, unless having scrubbers installed.
Namely, the options available for ship-operators to achieve compliance are:

• The use of low-sulfur fuel
• Installation of scrubbers
• The use of LNG
• The use of other new developed fuels 

In this context, MEPC 73 in October 2018 agreed that Administrations should encourage ships flying their flag to develop implementation plans, outlining how the ship may prepare, in order to comply with the regulation.
The plan could be complemented with a record of actions taken by the ship in order to be compliant by the applicable date.

Administrations and Port State control authorities may take into account the implementation plan when verifying compliance with the 0.50% sulfur limit requirement. A ship implementation plan is not a mandatory requirement. A lack of a ship implementation plan or an incomplete ship implementation plan should not be considered as "clear grounds" for a more detailed PSC inspection.

It is advised that ship operators schedule for each of their managed vessels a compliance plan in order to achieve compliance prior of 31st of December 2019 in respect of % content in emissions.

Under the new guidance, the ship implementation plan for 2020 could cover various items relevant for the specific ship, including, as appropriate, but not limited to:

• Risk assessment and mitigation plan (impact of new fuels)
• Fuel oil system modifications and tank cleaning (if needed)
• Fuel oil capacity and segregation capability
• Procurement of compliant fuel
• Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulfur compliant fuel oil)
• Documentation and Reporting 

 Issues relating to use of sulfur compliant fuel oil

All fuel oil supplied to a ship shall comply with regulation 18.3 of MARPOL Annex VI and chapter II/2 of SOLAS. Meanwhile, operators could consider ordering fuel oil specified in accordance with the ISO 8217 marine fuel standard.

The following potential fuel-related issues may need to be assessed and addressed by ships in preparation for and implementation of the 0.50% sulfur limit requirement:

• Technical capability of ships to handle different types of fuel (e.g. suitability of fuel pumps to handle both higher and lower viscosity fuels, restrictions on fuels suitable for use in a ship's boilers, particularly the use of distillate fuels in large marine boilers)
• Compatibility of different types of fuels e.g. when paraffin and aromatic fuels containing asphaltenes are commingled in bunkering or fuel oil changeover
• Handling sulfur non-compliant fuels in the event of non-availability of sulfur compliant fuels
• Crew preparedness including possible training with changeover procedures during fuel switching from residual fuel oil to 0.50% compliant fuel oils. 

Additionally, the ship implementation plan could be used as the appropriate tool to identify any specific safety risks related to sulfur compliant fuel oil, as may be relevant to the ship, and to develop an appropriate action plan for the organization to address and mitigate the concerns identified.

Examples should include: 

• Procedures to segregate different types of fuel and fuels from different sources
• Detailed procedures for compatibility testing and segregating fuels from different sources until compatibility can be confirmed
• Procedures to changeover from one type of fuel to another or a fuel oil that is known to be incompatible with another fuel oil
• Plans to address any mechanical constraints with respect to handling specific fuels, including ensuring that minimum/maximum characteristics of fuel oil as identified in ISO 8217 can be safely handled on board the ship
• Procedures to verify machinery performance on fuel oil with characteristics with which the ship does not have prior experience.

​Click here for the relevant IMO guidance MEPC.1/ Circ.878 (Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulfur limit under MARPOL Annex VI).

Do not hesitate to contact us for any clarifications you may need on the above.