IBIA raises awareness of sulphur compliance verification challenges at IMO
On January 17 this year, IBIA put on a lunchtime presentation in the main hall at the headquarters of the International Maritime Organization (IMO) for delegations attending the fourth session of the Sub-Committee on Pollution Prevention and Response (PPR 4).
IBIA took this opportunity to again explain some of the challenges we have seen, and which could intensify in 2020, with respect to verifying compliance to applicable MARPOL sulphur limits.
The objective was to raise awareness of the current differences between commercial and statutory approaches to verifying sulphur content in marine fuels and the problems resulting from the difference in procedures. This is causing uncertainty among ship operators who fear falling foul of MARPOL Annex VI sulphur limits, while confusion about the different approaches often results in friction between bunker suppliers and ship charterers and owners.
The 0.50% sulphur limit in MARPOL Annex VI Reg. 14 will no doubt cause much greater scrutiny on ship compliance with sulphur limits than we see today because of its global application. Currently, sulphur inspections are focused on ships and suppliers in countries with emission control areas (ECAs). In addition, European Union (EU) sulphur inspection requirements, which include the testing of fuel samples, apply across the EU, not just in countries bordering ECAs.
IBIA has highlighted several times, in presentations at various fora, that the 0.50% sulphur limit will probably see much more use of blending to meet the sulphur specifications than we see for fuels meeting the current 3.50% and 0.10% sulphur limits. Suppliers will probably blend close to the 0.50% sulphur limit to be able to offer a competitively priced product while also protecting their profit margins. This may increase the risks of potential sulphur ‘off-specs’, in line with what was observed from 2006 until the end of 2014 with the 1.50% and 1.00% ECA sulphur limits, which were largely met by low sulphur fuel oil (LSFO) blends. There is, however, a misalignment between what is considered an ‘off-spec’ fuel in normal commercial practice, and the statutory approach under MARPOL Annex VI as to whether the fuel is considered to meet the regulatory limit.