On 1 January 2020 the Regulation 14.1.3 of Annex VI of the Marpol Convention (IMO Sulphur Cap) adopted by the IMO in 2016 will come into force. The IMO Sulphur Cap prohibits not just the use, but also carriage of bunkers above 0.5% sulphur unless the ship has been fitted with equivalent means of compliance. The carriage ban is set to kick in on 1 March 2020 so that in the interim period it is anticipated that charterers will have to ensure that any non-compliant fuel is discharged from the vessel’s bunker tanks at the latest by 1 March 2020 and owners then have the obligation to clean such tanks to receive compliant fuel thereafter.
Under mounting pressure to reduce sulphur emissions this might be seen as simply the next step since the adoption of Annex VI of the Marpol Convention on 17 May 2005 to prevent air pollution from ships and the introduction of emissions control areas. In fact, the implications of this change cannot be underestimated, and, for most stakeholders, they remain unknown.
Failure to manage anything from fuel availability, stability and compatibility challenges to scrubber installation, operation and maintenance could result in costly delays, fines, which could be discretionary, and, worse still, loss of power resulting in groundings and collisions. This could have serious implications for P&I clubs, including claims arising from wreck removal, pollution, cargo damage/loss and injury/death of crew.
While members are taking the necessary steps to ensure they are compliant and mitigate against associated risks with the different methods, the club is ensuring it is in a position to advise and assist members as necessary. On this page we will keep members up to date on the latest information, opinion and useful resources to ensure compliance.