GUIDANCE ON THE DEVELOPMENT OF A PLAN FOR THE
CONSISTENT IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT
UNDER MARPOL ANNEX VI
To facilitate compliance, the IMO has developed guidelines that include an indicative template for a Ship Implementation Plan (SIP) specific to each individual ship, which shipping companies are recommended to use.
The plan is not mandatory and is not subject to endorsement by the flag state or a recognized organization (RO).
However, PSC may consider the preparatory actions described in the SIP when verifying compliance.
The plan addresses issues related to the use of compliant fuel oil and how to identify any safety risks associated with such fuels.
Items covered by the plan can include, as appropriate, but are 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% sulphur compliant fuel oil)
- Documentation and reporting
Issues relating to use of sulphur 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% sulphur 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 paraffinic and aromatic fuels containing asphaltenes are commingled in bunkering or fuel oil changeover;
- handling sulphur non-compliant fuels in the event of non-availability of sulphur compliant fuels; and
- 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 sulphur 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.
- 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; and
- procedures to verify machinery performance on fuel oil with characteristics with which the ship does not have prior experience.