IMO 2020 - Burn Baby Burn - USCG to Require Removal of All Non-Compliant Fuel

Change is Coming... 

Effective Jan. 1, 2020, the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI will put into effect their revisions, including a reduction of the global sulfur cap from the current 3.5 % to 0.5 %. The new reduction will be regulated and enforced in United States waters by the United States Coast Guard (USCG).

Why The Reduction? ​

The decision to implement a global sulfur limit of 0.5%, significantly reducing sulfur oxide emissions, was made during the Marine Environment Protection Committee's (MEPC) 70^th session in London. Sulfur oxide is a common shipping pollutant that has an impact on greenhouse gasses and can, in large concentrations, harm trees and plants by damaging their foliage and decreasing growth.

International Maritime Organization (IMO) Secretary-General Kitack Lim is in full support of this decision, standing behind the organization's mission to keep shipping the most environmentally friendly mode of transport. Lim believes that we will see a significant beneficial impact on the environment and human health following this reduction, most notably in port cities and coastal communities. 

How Do I Stay Compliant? 

As of Jan. 1, 2020, all commercial ships operating in the U.S. exclusive economic zone must meet the 0.5% sulfur content for fuel, and all commercial ships in the North American Environmental Corporation of America (ECA) and the U.S. Caribbean ECA must meet the 0.1% limit.

According to information obtained from Bloomberg News, to comply with the new fuel requirements, a regulated ship operator has four options:

1. Use IMO-compliant, low-sulfur fuel oil with a maximum sulfur content of 0.5 percent; or 0.1 percent for operations in the Emissions Control Areas (ECAs)
2. Where IMO-compliant fuel is not available, ships can obtain a Fuel Oil Non-Availability Report, documenting unavailability. That report must be filed with the USCG Captain of the Port (not the EPA).
3. Continue to burn high-sulfur fuel with a maximum sulfur content of 3.5 percent by installing a scrubber. Scrubbers, however, do present further issues with having to dispose of the removed sulfur.
4. Use an acceptable alternative marine fuel, such as those identified by the IMO: battery power, biofuels, hydrogen fuel cells, and wind-assisted propulsion.

Further, apart from ships that are operating scrubbers, all others carrying "residual" fuel with a Sulphur content greater than 0.5% on board will be required to remove it. A total ban on the carriage of residual fuel (excluding ships with scrubbers) will come into force on March 1, 2020. After this date, USCG Port State Control will be checking ships' bunker tanks for non-compliant fuel.

Need Help With De-Slopping? 

​If you or your business will be affected by this new reduction, Gulf Marine Contractors will provide De-slopping services to help you collect, transport and dispose of any non-compliant fuel to ensure vessel compliance. For more information, please Contact Us.

What Do I Do To Prove I'm Compliant With the New Regulations? ​

Bloomberg News advises that in addition to fuel requirements, regulations require that ship operators maintain onboard records that verify compliance. For example, bunker delivery notes and representative samples of fuel oil provided by fuel suppliers must be maintained on board for a minimum of three years and 12 months, respectively. The records must also include a written fuel oil changeover procedure and a log recording changeover details. These records may be inspected, and samples may be taken to verify whether or not the fuel oil used onboard meets the MARPOL sulfur standard.

Due to the increasing demand for compliant fuels, bunker providers are expected to have a shortage of compliant fuel. As a result, GMC urges vessels and their operators to plan ahead for bunker operations. GMC can assist as required.

If a vessel is unable to comply with International Maritime Organization (IMO) 2020 fuel standards, GMC can provide a Fuel Non-availability Report Form and assist with submitting to your local USCG Port Captain to request a one-time waiver. It is unclear at this time whether any penalties or fees will be issued as a result of non-compliance. We will continue to update as more information becomes available.

Contact Us with any additional questions or for more information on the services GMC provides.