The most awaited regulation of the decade for the maritime industry has been implemented from 1st January 2020. The implementation of 0.5% sulfur cap for marine fuel, popularly known as IMO 2020 will need strict compliance from the crew and shipowners, making it one of the most stringent regulations under MARPOL in the recent times.

Whenever any new regulations are implemented in the maritime industry, the first authorities to ensure ships are complying with them are the port state authorities.

Every port state authority will come onboard ships to check if the shipowners and the crew have done their part in making the new regulation effectively implemented onboard. Failing to do so will ask for hefty fines and even detention.

The IMO 2020 Regulation requires vessels to ensure ships machinery burns the fuel whose exhaust sulphur component by wt percentage is not more than 0.5%.

Needless to say, is extremely critical for the ships’ crews to be familiar with the new regulations, how it can be effectively implemented and all the associated documentation with it so that when a PSC inspector is onboard for checking the compliance, the ship can easily sail to the next port without any remarks or non-compliance.

How ship can prepare for IMO 2020 inspection by PSC?

The most important thing for the ship crew is to understand the requirements clearly. The fuel received onboard the ship will be considered as one of the most important evidence for any inspection.

Hence, with respect to the fuel oil, the crew must:

1. Ensure Bunker delivery note and Fuel Sample is kept onboard

As per the requirement, the BDN to be kept on board ship for three years from the date of issue. The BDN should be accompanied by a Representative Sample of the fuel delivered – the MARPOL Sample.

2. Correct Soundings Record:

Apart from the BDN, the PSC will check the soundings of the tanks where the low sulphur fuel is kept or where the HSFO is kept for ships with exhaust gas scrubber.

Any discrepancies in the value of the sounding may lead to suspicion and further investigation.

taking tank sounding

Credits: US Navy/Wikipedia.org

Ensure the officer in charge of sounding keeps all the records in place and the volume correction is done appropriately as per the temperature of the oil.

The sounding log books need to updated regularly and signed by the chief engineer and the officer taking the soundings.

Related Read: Fuel Oil Consumption Calculations For Ships: What Seafarers Should Know

3. Fuel Transfer Record:

The ship must keep ready the fuel oil transfer plan for LSFO and HSFO fuel. Along with that, the PSC may ask for a fuel oil line diagram for reference. The tanks dedicated to LSFO must clearly be shown in the line diagram.

Tank cleaning details and dates to store the LSFO must be present in onboard records, including Oil Record Book.

The bunker details with LSFO must be recorded in the Oil Record book and signed by both Master and Chief engineer.

All records of any internal transfer, retention, disposal etc related to fuel oil will be cross-checked by the port stat inspector, hence these records need to be properly maintained.

4. Fuel Transfer plan and Piping Diagram

The plan and piping diagrams are important too as the PSC inspector will ask them to study them to understand whether the fuel change-over has been done properly, by cross-referring the data in the BDN, LSFO record book and ORB.

The location of the tank, the number of tanks used, pipelines in play etc. will be studied from the piping diagram. Any modification done for the storage and transfer of LSFO must be indicated and have survey approval from relevant authorities.

Ships visiting Emission Control Areas must have a Fuel oil change over plan to use fuel with 0.1% sulphur content. The plan must be readily available in the engine room and ship staff must know the detailed procedure as PSC inspector may ask them the procedure and local regulations.

If the PSC has doubts about the fuel and the lab results are not available, they will take the sample from service and settling tank for their own oil analysis.

Related Read: Fuel Oil Change Over Procedure for Ship’s Main and Auxiliary Engines

5. IAPP Certificate:

As per the MARPOL Annex VI requirement, all 400GT and above ships are bound to carry a valid International Air Pollution Prevention Certificate and supplement as a confirmation that the ship is fulfilling the requirements of this Annex.

The Supplement of the IAPP certificate provides the details of Sulphur Oxides and Particular Matter and how the control of emissions from the ship is achieved. It also contains the sulphur content limit values for fuel for ships plying within the ECA.

Any additional equipment fitted to reduce the sulphur content within the required limit such as scrubber tower etc. are also specified in the supplement of the certificate. Thus Master must ensure the IAPPC and Supplement are valid and updated to indicate the compliance arrangements on board which will be checked by the PSC.

6. Scrubber System:

Most of the ships have adopted exhaust gas scrubber system to comply with the upcoming sulphur emission rule because of the ease of using heavy fuel oil.

The PSC will be having a keen eye for the EGB and following things to be taken care of:

  • The Data recorder must be operational and records the time, position, pressure, flowrate etc. of the wash water. The PSC will check all these details to establish the correct operation of the EGB
  • The data recording device should be robust, tamper-proof, read-only and able to record at a rate not less than 0.0035 Hz
    The data should be retained on board ship for 18 months
  • The ship officer must take out the recent data in readable format for Port state inspector in case he/she demands it
  • PSC inspector may ask and check the approved documentation relating to any installed exhaust gas cleaning systems
  • At each renewal survey, nitrate discharge data is to be available in respect of sample overboard discharge is drawn from each EGC system within the previous three months before the survey.
  • The nitrate discharge data and analysis certificate is to be retained on board the ship as part of the EGC Record Book and made available for PSC if requested

Closed Loop Scrubber System

Different port states have different regulations for the requirement of the open and closed-loop system. The ship officer must know if the port allows open scrubber or closed scrubber system to be operational in its territory and prohibit the discharge of effluent.

Related Read: 14 Technologies to Make the Ultimate Green Ship

The Port state inspector may demand to check the state of the wash water discharge pipe if it contains oil or not.

7. Record of Voyage:

The voyage records must be kept onboard as PSC inspector may demand to see the previous passages of the ship to know the time and coordinates for the entry in the port state or ECAs and if the ship has changed over to the compliant fuel in right time by cross-checking the data with ORB and other record books.

8. Fuel Oil Non-Availability Report:

If a ship is unable to acquire compliant fuel due to non-availability or any other reason, the master has to notify the flag state and other relevant authorities including the nearest or next port state.

This notification is called as FONAR or Fuel Oil Non-Availability Report.

This FONAR application and replies of the flag state respectively should be available for the PSC inspection. FONAR should be used only in case of extreme emergency and when all efforts fail to acquire a compliant fuel.

The PSC inspector will go through the report, correspondence and other details to accept the FONAR. However, a repeated FONAR may lead to negative reviews against the ship and the owner.

Source:
https://www.marineinsight.com/guidelines/how-ships-can-prepare-for-psc-inspection-for-imo-2020/


The International Maritime Organization (IMO) has sent a recommended framework of protocols to ensure safe ship crew changes and travel during the Covid-19 pandemic to all IMO member states, the UN and other stakeholders.

The protocols outline how crews can join a ship, starting at their residence, and how a crew member can disembark and reach his home – often in a different country.

The framework of protocols was proposed by a broad cross section of global industry associations which has consultative status with IMO, including BIMCO. It includes input from the International Air Transport Association (IATA).

The IMO urges governments and national authorities to designate all professional seafarers and marine personnel as “key workers” and grant them with the necessary exemptions from the local rules that restrict movement, to allow them to join or leave the ships, among other things.

The 61-page document is aimed at all the stakeholders in the process, including shipowners, shipping companies, maritime administrations, customs, health authorities, airport authorities and several other organizations.

“It is an important step that we provide these protocols, to demonstrate that transferring crews can be done safely. It is however down to all the nation states to implement the required measures during a crisis that is still escalating in many locations. It will therefore require continued consultation with governments, to avoid a potential breakdown in supply-chains which will harm everyone,” said Lars Robert Pedersen, BIMCO Deputy Secretary General.

The lack of access to commercial flights is an additional challenge that needs to be solved.

Source:
https://www.motorship.com/news101/regulation-and-classification/imo-backs-protocols-to-facilitate-crew-changes


The sulfur regulation from the International Maritime Organization (IMO) that came into force on 1 January 2020 took the center stage in the shipping industry at outset of the new decade. Four months on, the spotlights have turned to the coronavirus and the OPEC+ oil price war.

The outlook for global economic growth remains bleak as the world is faced with the largest recession since the Great Depression in the 1930s.

Commodity prices have declined across the board and most recently, the West Texas Intermediate (WTI) reference oil future drew headlines as it crashed into negative territory at $-37.63 per barrel on 20 April 2020. The sliding oil prices have driven down bunker fuel prices, which hold mixed implications for the shipping industry.

“From a shipowner’s or charterer’s perspective, the lower bunker prices provide a glimmer of hope in bleak times. Perhaps less hopeful are the bunker suppliers, who must now supply bunker fuels at a fraction of the price seen four months ago,” says BIMCO’s Chief Shipping Analyst, Peter Sand.

The International Energy Agency (IEA) is projecting oil demand to collapse in the second quarter of 2020 with a drop of a staggering 23.1 m/bpd compared to last year, and a drop of 9.3 m/bpd for the full year of 2020. The massive supply-demand imbalance has led to a steep uptick in crude oil stockpiling, which will continue to drag on the oil product prices in the months to come. The OPEC+ cuts amounting to 9.7 million barrels per day (m/bpd), officially in motion since 1 May 2020, have caused prices to tick upward once again. But in the short-term, it will not be enough to balance out the unparalleled demand destruction.

An infected bunker fuel market
In a matter of months, the oil and bunker fuel markets have been turned upside down. Oil market volatility is at an all-time high, as implied by the oil volatility index (OVX), even exceeding the volatility of equity markets. The simultaneous supply and demand shocks have sent bunker prices racing towards previous low levels with very low-sulphur fuel oil (VLSFO) trading at $246 per MT on 5 May 2020 in Singapore.

The current upheaval has collapsed marine gas oil low-sulfur (MGO LS) prices at the fastest pace in recent memory, even exceeding the demise of the Great Financial Crisis and oil crash in 2014. Since the MGO LS price peaked in Singapore at $744 per MT on 8 January 2020, the price has declined 67% in 84 workdays, settling at $243 per MT on 5 May, essentially a market breakdown in a couple of months.

In 2008, the MGO LS price peaked at $1,360 per MT and before starting a prolonged descent, bottoming out at $354 per MT after 174 days, a 74% collapse from the peak. While it took over two years to settle at a new peak at $1,075 per MT on 11 April 2011, the prices never recovered to previous high levels. Past crises and price shocks serve as a reminder that the recovery is nowhere as rap-id as the collapse, and although the nature of the current crisis is different from the previous ones, a price recovery is not likely to follow a sharp v-shaped curve.

“Marine bunker fuel prices in Singapore have collapsed at the fastest rate since the Global Financial Crisis. If the past is anything to go by in this case, the ascent from the doldrums will be nowhere near the same rate as the descent from the peak,” says Sand.

The post-IMO 2020 reality
High-sulfur fuel oil (HSFO) can also be used in some power plants, but the scrubber-fitted fleet still generate the bulk of demand for HSFO. As of May 2020, the scrubber-fitted fleet stands at 2,893 ships, or 2.9% of the combined fleet in terms of ships, but equal to 15.6% of total fleet when looking at deadweight ton (source: Clarksons).

Bunker sales in Singapore illustrate how HSFO is still in demand, constituted by scrubber-fitted ships. Sales for Q1 came in at 12,716 tonnes, 83% of which were low-sulfur fuels, while 17% was HSFO. In total, 8.8 million tonnes of VLSFO were sold, a jump of 83% from the fourth quarter of 2019. This dramatic change in bunker sales is similarly seen in the ports of Rotterdam and Panama. In Rotterdam, the largest bunkering hub in Europe, the low-sulfur to high-sulfur bunker fuel sales ratio came in at 74% to 26%, with VLSFO accounting for 42% of total sales. In Panama, 93% of the 1.3 million tonnes of total bunker sold was VLSFO.

The Panamanian bunker sales highlight the issue of HSFO unavailability. Bunker suppliers have adjust-ed to the IMO 2020 demand, cleaning tanks and storage to accommodate low-sulfur fuels, which is making it increasingly difficult to source HSFO in the spot market. When combining the hassle of sourc-ing HSFO and the VLSFO-HSFO spread at extraordinarily low levels, it is likely that some scrubber-fitted ships could even opt to burn VLSFO.

“Bunker sales in major bunkering hubs underscores the transformation that IMO 2020 sulfur regulation has brought with it. Prior to the implementation, the industry was worried about the availability of low-sulfur bunker fuels. Now in April 2020, the availability of HSFO seems to be the most pressing issue in some places – next to that of quality,” Sand says.

Source: BIMCOLow bunker prices are supporting earnings
Although scrubber owners have seen their investment payback period extended substantially in recent weeks, it is not all cloudy days when looking past the scrubber economics. The lower bunker fuel prices are partly buoying earnings amidst challenging markets conditions.

The VLSFO prices in Singapore averaged $245 per MT in April, a massive cost saving from the January average of $664 per MT. If assuming bunker consumption of 40 MT per day, shipowners are set to save $16,760 per day when going by the averages of January and April. With the lower cost of sailing, some companies have started to sail around the Cape of Good Hope on the Asia-Europe back-haul instead of paying steep toll dues to transit the Suez Canal.

“The depth of the coronavirus crisis and the shape of any potential recovery will ultimately determine how the oil and bunker prices develop in the coming months. With OPEC+ cuts implemented, oil demand must now recover to counteract the massive supply overhang,” says Sand.

(Source: BIMCO)


Shell has carried out trials with 19 shipowners to test its new 0.5pc sulphur content marine fuel in preparation for new International Maritime Organisation (IMO) rules next year.

The shipowners took part in the trials at ports across the world. Shell will be carrying out further tests with customers at New Orleans, Rotterdam and Singapore.

The trials are being conducted in advance of the IMO’s sulphur cap, which will limit ships to burning fuels with 0.5pc sulphur content from 1 January next year, down from the current cap of 3.5pc.

The new fuel performed correctly and the switch did not require extra workload for engine crews, Shell said.

The company has tested its 0.5pc fuel on one of its own vessels — the Silver Carolyn — out of Singapore.

Last month, Shell launched a new lubricant designed to be used in conjunction with 0.5pc marine fuels in two-stroke engines.


The shipping and bunker sectors spent years in preparation for the historic changes imposed by the International Maritime Organization’s global low sulfur mandate, IMO 2020.

But no sooner did the new rules kick in than market participants had to urgently confront a collapse in crude oil prices and obstructed tradeflows, as the world was gripped by the deadly effects of the coronavirus pandemic, and lockdowns and social distancing became the new norm.

“IMO 2020 has got lost somewhere. But that’s how shipping is. There’s always something around the corner,” a shipbroker said.

The IMO 0.5% sulfur limit rule, planned years back and finally implemented from January 1, 2020, forced shipowners to either switch to cleaner marine fuels or continue using high sulfur fuel oil (HSFO) but install scrubber units.

Alternative fuels are also a solution but their reach still remains limited, with very low sulfur fuel oil (VLSFO) emerging as the chief marine fuel choice. Refiners adjusted their crude slate accordingly, and suppliers increasingly invested in storage and barge infrastructure to boost availability of such fuels to quench the shipping sector’s thirst.

VLSFO blends have risen to the forefront despite some initial concerns about a drastic escalation in bunker fuel quality issues worldwide due to their use, particularly related to sediment and sludge formation, cold flow properties and stability.

Rising VLSFO consumption comes even as some environmental groups have said that VLSFO blends with high aromatic content contribute to significant black carbon emissions and should therefore be banned as their consumption is detrimental to the environment.

With some of the challenges of IMO 2020 still not fully resolved, the plunge in crude oil prices has come as a rude shock to many, with demand destruction hitting players in the oil and bunker industry hard.

OPEC expects global oil pandemic demand destruction of 6.8 million b/d year on year in 2020 to 92.82 million b/d, with April seeing the largest downturn at about 20 million b/d, according to the organization’s April monthly oil market report.

Still, oil output from Saudi Arabia is expected to remain elevated, when there is no such real requirement on the consumption side.

“We are heading for a period of massive supply-demand imbalance, where the oil supply is high, but major economies are in lockdown. With land-based oil storage potentially approaching full capacity fast, it is limited how much additional oil can be imported,” BIMCO, the world’s largest international shipping association, said in a statement recently.

Go deeper: Podcast – Q1 earnings give snapshot of pandemic’s impact on oil demand

Risk-loving oil traders have already time chartered VLCCs for floating storage, either because they could not sell and had no option but to store cargoes, or in anticipation of higher returns in coming months.

To cater to IMO 2020 demand, there are companies that have also been stockpiling low sulfur fuel oil (LSFO) material, both on landed tanks and on floaters, reflecting the steepening contango in the LSFO market in major bunkering hubs such as Singapore.

The contango at the front of the Singapore marine fuel 0.5% swaps curve, for example, widened to average $9.56/mt for the month of April, from the March average of $5.11/mt, S&P Global Platts data showed. During April, the outright value of Singapore marine fuel 0.5% cargo dropped 25.96% to average $214.84/mt as compared to the March average of $290.17/mt, Platts data showed. From May 1-11, the average outright value of the product was $221.62/mt.

Singapore marine fuel

But floating storage will also eventually run out if the contango remains supported, sources said.

“It’s like you have a sick man already and you punch him in the stomach,” a shipowner said explaining the predicament of some players in the industry.

Meanwhile, some trading and oil companies with huge exposures to VLSFOs and inappropriate bunker fuel hedging tools are getting hurt, while shipowners who opted for scrubbers as an IMO 2020 compliance solution for their vessels are contending with the prospect of poor payback economics as the price difference between 3.5% and 0.5% bunker fuel has narrowed dramatically.

Last year, some industry sources estimated the VLSFO-HSFO spread would shoot up and remain elevated, well over the $300/mt mark for a sustained period of time in 2020.  But that has certainly not played out.

“I never really expected this kind of VLSFO-HSFO spread,” another shipowner source said.

VLSFO vs HSFO spread

“If you don’t have good processes in place, you will be in trouble,” a credit risk manager said, adding that banking was also putting a “circuit breaker” on lending, particularly after the Hin Leong debacle, amplifying the devastation.

When Singapore’s Hin Leong sneezed 

A case in point is Singapore’s embattled Hin Leong, which recently became the subject of an investigation by the Singapore police force for its conduct, or rather, misconduct.

The investigation came after Hin Leong’s managing director Lim Oon Kuin, or OK Lim, and his son and company director Lim Chee Meng said in two separate court filings for bankruptcy protection dated April 17 that the company suffered about $800 million in futures losses over the years that were not reflected in the financial statements.

OK Lim said in one filing that payments made by Hin Leong Trading or HLT to satisfy margin calls for derivatives losses were reflected as “accounts receivables” and he had given instructions to the finance department to hide the losses and told them that he would be responsible if anything went wrong.

“Further, over the years, HLT had, on my instructions, sold a substantial part of the inventory and used the proceeds as the general funds of HLT, even though the inventory was the subject of inventory financing provided by bank lenders,” Lim said.

Ongoing developments at Hin Leong, which came to the limelight as banks grew impatient to recover their loans from the company amid the coronavirus pandemic, have had huge repercussions.

The situation has driven the Maritime and Port Authority of Singapore, Monetary Authority of Singapore and Enterprise Singapore to issue a joint statement in April saying that the country’s oil trading, bunkering sectors and banking system remained resilient despite the challenges posed by a drop in global demand for energy as well as developments related to HLT.

Hin Leong’s subsidiary, Ocean Bunkering Services, was Singapore’s third-biggest accredited bunker supplier by volume in 2019, and the biggest in 2018, according to MPA. OBS was heard to have cancelled all its bunker spot sales for delivery from April 18 onwards.

As the HLT situation unfolds, two new players – Minerva Bunkering and TFG Marine – have been granted bunker suppliers’ licenses in the Port of Singapore last month and are likely to play a pivotal position in filling the void.

Singapore bunker sales

Still, the industry remains anxious, as conditions in the world’s largest bunkering port are ripe for consolidation, including exits, sources said.

“IMO 2020 was challenging enough and now there are other issues,” a bunker supplier said. “But it’s going to be okay as long as you can sit in the game long enough.”

In the end, the words of Winston Churchill might resonate with many, given the current circumstances.

“Success is not final; failure is not fatal: it is the courage to continue that counts.”

Source:
https://blogs.platts.com/2020/05/12/shipping-bunkers-coronavirus-trade-imo-2020/


The International Maritime Organization has drawn up a roadmap to help countries implement procedures to relieve ship crews. Worldwide, tens of thousands of seafarers are stuck on board because they are unable to disembark or fly home due to strict coronary measures.

The 55-page 12-step plan was drawn up by a broad coalition of international shipowners’ associations and shipping organisations. The book provides governments with a blueprint to facilitate crew changes and ship crew repatriation. The protocols lay down the responsibilities of governments, shipowners, carriers and seafarers.

In two weeks’ time, some 150,000 seafarers worldwide need to be relieved in order to comply with international maritime regulations on working conditions according to the IMO. Tens of thousands of them are currently stuck on board due to travel restrictions.

Safety at stake

Apart from the need for shipping companies to comply with international rules and contractual obligations, employment contracts cannot be extended indefinitely without impacting the health and welfare of ship’s crew and ultimately on the safety of ship operations.

‘The problem is simple, but the solution is complex. So we have taken our responsibility, drawn up protocols and are now working with governments to implement them’, says Guy Platten, Secretary-General of the International Chamber of Shipping (ICS).

Accidents on board

Platten: ‘If we can’t free our seafarers from their covid-19 blockade, this will be a huge disruption to trade and, more importantly, the risk of accidents and psychological problems on board will increase. Postponement is no longer an option.’

Read the 12-step plan here.

This article was first published (in Dutch) on Nieuwsblad Transport, which is also published by SWZ|Maritime’s publishing partner Promedia.


The IMO’s (International Maritime Organization) new Sulphur regulations, IMO 2020, will have far-reaching consequences for the global trade community. During the 17th session of MEPC (Marine Environment Protection Committee) meeting at London on 28th Oct. 2016, International Maritime Organization (IMO) took a landmark decision which will enforce a new regulation from 1st of Jan. 2020.

According to this regulation, the marine sector emissions in international waters will be slashed even outside the emission-controlled area: ECAs (Emission Control Areas; The Baltic Sea Area, The North Sea area, The United States, Canada, and the United States Caribbean Sea area).

The ships now have to reduce their Sulphur emission by over 80% – 85% by switching to Lower Sulphur Fuel.

The current maximum fuel oil limit of 3.5% m/m will fall to mere 0.5% m/m. This regulation will see the largest reduction in the Sulphur content of the transportation fuel under taken at any time in the history.

IMO 2020: The basics, the challenges, and how to lessen its impact on you

What is IMO 2020? (Sulphur cap)

Due to the high level of pollutants in the exhaust of the bunker currently used to power some 60,000+ ships globally, the IMO is going to implement a new regulation regarding these fuels on January 1, 2020. The regulation will require ships to use a fuel that’s better for the environment or undergo physical upgrades to accommodate either of two alternate solutions, effectively reducing Sulphur emissions by more than 80%.

Ships and carriers use heavy fuel oil that contains Sulphur. During the combustion in the ship’s engine, the fuel emits gases that contain Sulphur which harmful to the environment and its ecosystems. To reduce this pollution IMO has passed the regulation that puts a 0.5% cap on Sulphur in marine fuels. This regulation will be implemented from 1st January 2020 and it is a major step towards Sustainability.

Compliance with this new standard will primarily be achieved through the burning of low-Sulphur fuel, although compliance choices include other methods like the use of scrubbers and liquid natural gas (“LNG”) as fuel. Under this regime, the primary responsible party in the freight market will be the vessel owner or operator.

Ships and carriers will gradually limit SO(X) emissions by replacing the current fuel IFO380 with Very low Sulphur fuel oil (VLSFO) or using Liquified Natural Gas (LNG) as fuel or by installing exhausted gas cleaning systems (ECS) for their existing fuel.

The move towards a greener future may cost for surely but it won’t cost our environment!

This has been done to curb pollution and make the industry greener and world more sustainable.

Duration of disruption may last around for 3 years down the line but alternative scenarios range from one to five years, Disruption still underway if HSFO-LSFO spread incentivizes previously uneconomic refinery optimization.

Implications & Possibilities (post IMO implementation)

So the next question is Why this reduction? & Why now?

One of the pillars of IMO is MARPOL (prevention of Marine Pollution in international waters). The ships use the lowest grade of fossil fuel today. Most of the marine fuels which are used on-board ships, use high Sulphur up to 3.5% m/m. The burning of this fuel in ships are main engines, boilers and generator engines and produces exhaust containing Sulphur oxide (SOX) which then reacts with water, oxygen and other chemical to form Sulphuric acid n secondary inorganic aerosols.

Sulphur is also ozone depleting substance which cause harmful rays reaching to earth surface, this done mixed with water and other compounds of atmosphere and turn into the acid rain which is harmful not only to the environment but also to humans – causing diseases lie asthma, lung cancer, stroke and other pulmonary diseases.

Actually, this is not at all recent. If you follow the previous IMO holdings the first reduction came in 2005 by set a limit of 4.5% m/m of Sulphur cap. Later in the year 2012, it was further reduced to 3.5% m/m. The decision to make it 0.5% m/m in 2020 was taken way back in 2008 and it got ratified in 2016 in the 17th session of MEPC meeting.

So, this is not sudden. Ship-owners got ample to prepare for this regulation. Following a typical business mind set-up, most of the shipping companies did not expect regulation to come so early even after the resolution was adopted 28th Oct. 2016. Shipping companies still believed that implementing such a strict regulation will not be possible at least till 2020. However, as the time approached, everyone realized the Doom’s day is near.

Here are the available options for vessel owners:

  1. Switch to a low-Sulphur fuel
  2. Implement on-board scrubbers that process the exhaust created by current fuel
  3. Convert fuel supply to liquid natural gas (LNG)

The IMO will allow each carrier to select the option that works best for its fleet. In development for more than five years, the regulation—referred to as IMO 2020—may cost the industry upwards of $15 billion in 2020. If a carrier opts for scrubber installation or engine conversion to accommodate LNG, these processes will cost approximately $1 million per ship, with each upgrade taking between 30 and 60 days, depending on the size of the vessel.

Landmark set of regulations that will cost carriers $15 billion per year

Now everyone is rushing to the shipyard for fitting different equipment or retrofitting to ensure they comply with IMO 2020 and not get fined or detained by different regulatory authorities.

Hence, we are looking at such a hype for IMO 2020. One of the biggest impacts are operating and preparation cost of the ships.

To understand the impact on the ship-owners, let first understand – how current ship-owners can comply with this regulation:

Reduction in Sulphur content done by – Fitting an exhaust gas cleaning system which will treat the exhaust and reduce the SOX emission to the desirable limit value. Shifting to a cleaner compliant fuel such as low Sulphur oil Shifting to alternate fuel such as Liquefied Natural Gas, Methanol, Ethanol or Bio-fuel using Shore Power in port.

While complying with this new regulation the shipping company will have following impact:

  • Huge cost in fitting an exhaust cleaning system which can go from 6-12 M USD per ship depending upon the size of the ships.
  • Maintenance and operation cost of exhaust cleaning system
  • Higher fuel bill if switching to cleaner and compliant fuel
  • For company having fleet of 200-250 ships, the cost can go up to 1.5 B USD when using liquefied natural gas as a fuel which is costly and the owner needs to modify the engine and boiler for consumption of LNG which will incur additional cost this all can cost up to 20-30 M USD per ship to the owner
  • Apart from these investments, to procure technology or the compliant fuel, the ship-owner will need to invest in training of the seafarers for the technology fitted on board such as exhaust scrubber etc.
  • Clean and dedicated tank for low Sulphur fuel
  • Make arrangement to store liquefied natural gas on board ship
  • Make arrangement to bunker liquefied natural gas on board ship
  • Fuel oil transfer line modification to avoid contamination of fuel – to acquire compatible grade of lube and cylinder oils
  • Modification in engine and boilers to burn LNG fuel
  • Comply with documents and paperwork of the compliant fuel

While complying with this new regulation, the petrochemical refineries will have following impact:

  • Expected to witness price spikes in 2020 as refiners and chemical producers adjust to the new environment
  • Key petchem feedstock naphtha outlook hinges on balance between marine fuels and gasoline
  • Propylene/OlefIns production likely to be affected
  • Rising container freight rates expected to have minimal polymers impact on total cost
  • Aromatics producers hope for wider product margins, but full impact remains hazy
  • Chemical shipping tankers eyeing LSFO to fundamentally improvement
  • For chemical shipping tanker segment supply-demand balance may improve
  • Shipping market will expect more LNG demand after the mandate implementation
  • Methanol will be more expensive due to unfavourable density and energy levels

Reducing sulphur emissions by utilizing low sulphur fuel oils in shipping vessels will help reduce greenhouse gas emissions by at least 50% by 2050 compared to 2008 requirements. That’s 8.5 million metric tons annually

Surcharges passed on to shippers

Once carriers implement their solution, it is expected that they will charge an additional fee per container thought to be between $100 and $300, based on load factor, vessel size, route, and other factors. In trade lanes where surcharges would exceed the actual shipping costs, some carriers may opt to implement a smaller surcharge.

New fuel will likely cost more than current bunker fuels and fuel surcharges will likely be added by carriers & its expected to increase freight rates by at least 15% to 30% in 2020

As carrier begins to adjust their rates, then down hierarchy players such as NVOCCs, LSPs, Trucking, Warehousing etc. will also need to update freight tariffs accordingly.

Near term concern: Capacity issues in Q3 and Q4 will outweigh the surcharge

While the per-container surcharge is a factor that has been discussed, the immediate issue has nothing to do with the added costs that will be passed on to shippers. The real issue is the disruption caused by the new regulation.

If carriers choose to outfit their fleets with scrubbers or convert them for LNG consumption, the ships will need to be dry-docked until work is completed—older ships will be decommissioned and scrapped. It’s simply too cost prohibitive to retrofit older vessels.

All of this could create a capacity shortage that will last into the peak pre-holiday season. Worse, it may last months, certainly into early 2020, and perhaps more than a year.

The cost of IMO 2020 non-compliance on government authorities

Individual countries are responsible for monitoring compliance and enforcing the new regulations. Both the state of registry of a ship and port states have rights and responsibilities to enforce compliance. According to the IMO, ships of all sizes will need to use fuel oil that meets the 2020 regulations.

At this time, the IMO does not allow exemptions to the regulations. That said, if a ship cannot obtain compliant fuel oil, they can complete a fuel oil non-availability report (FONAR). The port state control can take this into account when processing, but this does not qualify as an exemption for that vessel.

Impact of IMO 2020 Non-Compliance on the business trade

Vessels are integral to the energy trade. Refiners, shippers, suppliers, owners and vessel operators cannot afford the penalties of non-compliance. A vessel provides economies of scale to transport feedstock (crude or other feedstocks) or refined products to market. Each party is incented to avoid delays in the supply chain and avoid unnecessary delays, penalties or fines.

Business trade efficiencies would be hurt based on being caught for non-compliance.

  • The first cost is FINANCIAL. As with the case in the U.S. Virgin Islands, the shipowners and operators incurred a penalty. The $3 million was meant as a signal to other potential offenders. Some owners and operators may be able to cover the $3 million without issues. Most cannot and will suffer financially.
  • The second cost is to REPUTATION. The energy supply chain is based on relationships and working with reputable parties to provide for feedstocks or deliver finished products. More and more, energy companies are getting savvy in only dealing with players that have a good reputation. Still recent in the minds of refiners are the issues with fraudulently issued Renewable Identification Numbers under the Renewable Fuels Standard program. There are numerous cases of fraud by the U.S. Department of Justice for those that tried to deceive. These individuals and companies were placed on “blacklists” and circulated amongst the reputable companies.
  • The third cost of non-compliance is TIME. The Ocean Princess was anchored at the port in the U.S. Virgin Islands and detained along with the crew while the investigation was underway. That represents a huge cost to the supply chain where each party tries to run lean, just-in-time inventory. A detained ship means that product was either not delivered or picked up according to schedule. That imposes other delays downstream in the process, affecting overall inventory and increasing costs unnecessarily.

How can you prepare?

With IMO 2020 just around the corner, it is essential that all parties seek to implement robust compliance plans and due diligence of their counter-parties—including charter parties, fellow shippers, vessel owners and operator and bunker fuel sale counter-parties.

  • Shipping early to avoid the capacity shortage, and arrange for domestic storage if required
  • Optimize flexibility in the event your first or second option are blank sailings
  • Diversifying shipments so that no single carrier has all of your product and understanding how using multiple carriers can work for you in periods of limited capacity
  • Considering air freight for certain shipments
  • Reconfirm allocations and forecasts for coming months to help prepare in advance

For all of its good intentions, IMO 2020 is adding new layers of stress to a system that has already endured many months of stress due to the U.S./China tariff war—and will surely endure many more. Like the ones caused by the escalated tariffs, the changes caused by IMO 2020 will require importers and exporters to work with logistics experts to find solutions that preserve the integrity of supply chains and the profitability of their businesses.

Preparing for a New Marine Freight World

With the new regulation soon to go into effect companies must ask themselves what is to be done. Companies must plan and think about managing their supply chain effectively. It’s paramount that shippers, refiners, marketers and traders prepare now so fines don’t mount, and trade flows aren’t further disrupted. Refiners must focus on relationships with suppliers and other logistics companies now to negotiate term deals for fuel.

Final thoughts

The new IMO 2020 regulations reducing sulphur oxide emissions to less than 0.50% will have a significant impact on today’s shipping industry. But it’s important to remember that these regulations are not the first sulphur oxide emissions standards. Previous requirements did not cause a significant fuel shortage or permanently increase prices.

There is no doubt, this new regulation has a significant positive effect on the environment.

However, the increased cost of cleaner ocean freight shipping would get passed along to the shipper and eventually to the consumer.

Credits: Alphaliner, BCG, Google Images, MARPOL & IMO


IMO 2020

Rome – On 1 January 2020, the date of entry into force of the new Global Sulfur Cap regime, it is a milestone of fundamental importance for international shipping. Last October 2016, the IMO MEPC 70, in accordance with Annex VI of the MARPOL Convention, established the application of the limit of 0.50% m / m sulfur content in marine fuels starting from this term in non-SECA areas. This legislation, based on the study published by DNV GL, will involve more than 70,000 ships, entailing considerable costs for shipowners and a large investment for the continuous search for new technologies.

As is known, at the moment, to achieve the result required by the new legislation, ship owners have the possibility to choose different options based on various factors, including the age of the ship. They are:
1. use of fuel with low sulfur content or fuel blends which comply with the limit of 0.50% sulfur content;
2. use of marine gas oil (MGO) or distillates instead of fuel with high sulfur content (HSFO); 3. modification of ships in operation in order to allow the use of alternative and sulfur-free fuels such as Liquefied Natural Gas (LNG); and
4. installation of waste gas scrubbing systems (scrubbers) capable of operating with HSFO.

However, this last option risks having huge additional costs for the owners. While some ports such as those in China, Singapore, Belgium and the UAE have already banned the use of open loop scrubbers, the Singapore Port Authority (MPA) has also established that exhaust gas cleaning residues , including those of scrubbers, must be considered as toxic industrial waste which must therefore be managed by companies with specific licenses and transported in packaged form or in tanks on trucks or on boats with a specific license issued by the MPA. All this leads to a significant increase in costs for shipping companies.

With reference to the use of compliant purification devices, it should also be noted that, based on the MEPC 305 Resolution (73), from 1 March 2020, in the absence of the same, a ban on the transport of non-compliant fuel will be in force. purpose of combustion for propulsion or operation on board a ship, maintaining the possibility of transporting HSFO as a cargo. However, in the event of violation of this prohibition, the ship may be seized by the PSC without the need to determine the purpose of use of the fuel: a measure that leaves ample room for the action of the PSC and that has a strong preventive value. The amendment in question entails, inter alia, also a modification of the IAPP certificate such as to specify that, for a ship without a scrubber, the sulfur content of the fuel oil transported for use on board does not exceed 0.50% m / m, as documented by the delivery note of the bunker.

With regard to the use of distillates, it is instead appropriate to consider that a “safety issue” related to the distillation process is configured, which increases the risk of “catalytic fines” both on machinery and combustion plants. These particles can cause considerable damage resulting from the abrasion of the cylinders during the combustion process. It is therefore important to clean the tanks containing the fuel, the c.d. tank cleaning, or use alternative solutions such as the use of specific conversion procedures to be gradually discharged through the feeding system until obtaining the required sulfur content.

The complications arising from the change of fuel can be avoided through the preparation of guidelines and the training of crews, but above all thanks to the use by the shipping companies of a Ship Implementation Plan (SIP), specific for each ship. This plan, which is not mandatory, nor subject to the approval of the flag State or classification societies, should include, inter alia, risk assessment and a mitigation plan in relation to the fuel change, changes to the fuel system combustion and possible tank cleaning, information on capacity, segregation and supply of fuel oil, as well as the changeover plan decided for the vessel in question. According to Rule 18.2.3 of Annex VI of MARPOL, the PSC will be able to take into consideration the SIP during the inspection activities aimed at verifying the new limits of sulfur content imposed, without, however, being able to use the same as a basis for detecting ship deficiencies.

It is clear that, together with the above-mentioned technologies, there is also the need to have infrastructures able to support them and to plan an efficient bunkering strategy.

In this sense, the potential of Italian ports, in particular those of Augusta and Civitavecchia, in the supply of low sulfur fuel bunkering could significantly increase, thanks to their decisive position for traffic in the Mediterranean and to the investments that are being made to achieve this goal . Bunker Energy S.p.A. has already started a logistics plan to make the port of Augusta, already today the main Italian petrochemical port, adequately equipped with barges, storage facilities and a terminal capable of ensuring well before 1 January 2020 (possibly within the third semester) of the year) the regular availability and delivery of fuels in compliance with the new regime that will come from a refinery in Northern Italy. Pending the finalization of the new pumps that will avoid any risk of contamination deriving from HSFO, the applicable price structure is being defined. In the same way, the Company has launched a plan also in the Port of Civitavecchia where it expects even higher demand based on the large volume of ferry and cruise ship traffic.

The “consistent implementation” of Regulation 14 of Annex VI stands today as the main challenge for the Member States which, through the work of the subsequent MEPC and the PPR Sub Committee, must, inter alia, investigate the mechanisms for the enforcement of the new limits and verification of the conformity of naval units and fuel suppliers, with the consequent need to introduce specific procedures for checking the fuel in use in addition to those relating to the “Marpol sampling”.

The control measures of the PSC, in fact, will be based mainly on the control of the IAPP Certificate and Bunker Delivery Notes on board. However, in the presence of reasonable grounds, there will then be the possibility of conducting more detailed inspections including sampling.

In case of violation of the limit deriving from the use of non-compliant fuel or from not being able to prove the lack of availability of compliant fuel in the port of bunkering – in this sense we recall the presentation to the flag State of the Fuel Oil Non Availability Report (FONAR), pursuant to Rule 18 of Annex VI – Member States will have to put in place an adequate sanctioning system that will include fines, seizure of the ship and de-bunkering of the same, variable port-in-port measures.

Together with the above-explained IMO regime, it is necessary to remember, for completeness of information, that at European level the Directive 2016/802 is also in force, c.d. Sulfur Directive, a further instrument aimed at reducing sulfur dioxide emissions deriving from the combustion of heavy fuel oil, gas oil, marine gas oil and marine diesel oil used in the EU. It is added to the IMO regulation, establishing stricter limits in EU waters. In fact, a maximum limit of 0.50% m / m of sulfur content in marine fuels is foreseen for ships of any flag present in European waters from 1 January 2020. Furthermore, the limit of 0.1% is established for ships moored in EU ports, unless they remain at berth with the engines turned off and are connected to an electrical ground system or their stop does not exceed two hours.

Finally, we point out that Italy, through the Ministry of the Environment and the Protection of the Territory and the Sea, in agreement with the Ministry of Transport, has made itself the proponent of the Barcelona Convention (1978), of a agreement of a political nature aimed at acquiring the consent of all Mediterranean countries for the creation, possibly by 2024, of a Sulfur Emission Control Area (SECA) in the Mediterranean Sea, characterized by a sulfur emissions limit of 0.10% m / m, even at sea. Also thanks to the solid foundations of the SAFEMED project managed by the European Maritime Safety Agency and aimed at harmonizing maritime legislation in the Mare Nostrum, the MATTM, in particular through the efforts of the Marine Environmental Department of the Harbor Corps Corps, is carrying out important negotiations with the countries of the Middle East and North Africa in order to achieve this ambitious goal.

IMO 2020

SOURCE : THE MEDI TELEGRAPH


Autonomous Ships – Rolls-Royce has completed a research project it says demonstrates that the operation of autonomous vessels can meet, if not exceed, current collision avoidance (COLREG) rules.

The MAchine eXecutable Collision regulations for Marine Autonomous Systems (MAXCMAS) project included partners Lloyd’s Register, Warsash Maritime Academy (WMA), Queen’s University Belfast and Atlas Elektronik (AEUK).

The team found that use of newly developed algorithms allowed existing COLREGs to remain relevant in a crewless environment, finding that artificial intelligence-based navigation systems were able to enact the rules to avoid collision effectively, even when approaching manned vessels were interpreting the rules differently.

A key aspect of the research was the use of WMA’s networked bridge simulators. The simulators were used to analyze reactions from the crew when faced with a range of real-world situations and subsequently hone the MAXCMAS algorithms.

Rolls-Royce Future Technologies Group’s Eshan Rajabally, who led the project, said: “Through MAXCMAS, we have demonstrated autonomous collision avoidance that is indistinguishable from good seafarer behavior, and we’ve confirmed this by having WMA instructors assess MAXCMAS exactly as they would assess the human.”

During the development project, Rolls-Royce and its partners adapted a commercial-specification bridge simulator as a testbed for autonomous navigation. This was also used to validate autonomous seafarer-like collision avoidance in likely real-world scenarios. Various simulator-based scenarios were designed, with the algorithms installed in one of WMA’s conventional bridge simulators. This also included Atlas Elektronik’s ARCIMS mission manager Autonomy Engine, Queen’s University Belfast’s Collision Avoidance algorithms and a Rolls-Royce interface.

During sea trials aboard AEUK’s ARCIMS unmanned surface vessel, collision avoidance was successfully demonstrated in a real environment under true platform motion, sensor performance and environmental conditions.

“The trials showed that an unmanned vessel is capable of making a collision avoidance judgment call even when the give-way vessel isn’t taking appropriate action,” said Ralph Dodds, Innovation & Autonomous Systems Programme Manager at AEUK. “What MAXCMAS does is make the collision avoidance regulations applicable to the unmanned ship.”

The MAXCMAS technology and system has been thoroughly tested both at sea and under a multitude of scenarios using desktop and bridge simulators, says Rolls-Royce, proving that autonomous navigation can meet existing COLREG requirements.

 

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The International Maritime Organization answers the questions of Government Europa on how the next generation of autonomous vessels can be regulated to ensure safety for all involved.

With a myriad of emergent new technologies on the horizon of the maritime industry, such as autonomous vessels, it is vital that regulations are established to ensure the safety, security and efficiency of a new generation of ships. In May, the International Maritime Organization (IMO) – responsible for regulating international shipping – initiated its work into analysing the safety, security and environmental aspects of Maritime Autonomous Surface Ships (MASS). Under this, IMO will look towards how such vessels can be addressed under the instruments of the organisation. The International Maritime Organization answers the questions of Government Europa on how the next generation of vessels can be regulated to ensure safety for all involved.

How could autonomous vessels transform Europe’s maritime activities? What kind of issues could it eradicate?

This is not really a question we can answer, as there are many variables in Europe’s maritime activities which are outside IMO’s sphere. IMO, as the global regulatory body, sets the regulations for safe, secure and efficient shipping and for prevention of pollution by ships.

It is important to remember that when we talk about integrating new technologies in shipping, we need to balance the benefits derived from new and advancing technologies against:

  • Safety and security concerns;
  • The impact on the environment;
  • International trade facilitation;
  • The potential costs to the industry; and
  • Their impact on personnel, both on board and ashore.

At 2017’s meeting of the Maritime Safety Committee (MSC), a plan to conduct a series of scoping exercises on MASS was scheduled. As the first stage of that scoping exercise was conducted in May, what safety implications have been identified as a result?

The scoping exercise at the moment is aimed at looking at the current regulations in relation to maritime autonomous surface ships. What we are looking at now is how the rules already adopted could be applied to a ship in various modes of autonomy. So, we are looking at each regulation and seeing whether it would apply to a ship in an autonomous mode, whether it would not apply at all, or do we need to have a new rule specifically for autonomous ships?

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