PACIFIC MARINE SERVICES
For further information, please refer to PMS Circulars on Website of (www.pmsclass.org/circulars)
Ajman Free Zone F.Z.E – P.O.BOX 8474 Ajman – Tel Fax 0097167411070-Mobil No 00971504500338 – Mail ([email protected]) ( [email protected])بريد الكتروني – 00047508500004موبايل رقم – 0004744877040فاكس –( 4848)ب .ص –عجمان المنطقة الحرة
Date :14-03-2020
No .P.M.S/C052/20
CIRCULAR Page No ( 1 )
2020 Sulphur Cap Compliance
Notice to :
Ship Owners / Manager / operators / Surveyors
Dear Sirs,
The global 0.50% m/m limit for sulphur in fuel oil used on board ships established by Regulation 14.1.3 of MARPOL
Annex VI entered into force on 1 January 2020, as confirmed through IMO Resolution MEPC.280(70).
The Marine Environment Protection Committee at its 70th Session, confirmed through MEPC.280(70), the effective date of
implementation of the Fuel Oil Standard in Regulation 14.1.3 of MARPOL Annex VI that shall be 01 January 2020. The 0.50%
sulphur limit is a significant reduction from the current global limit of 3.50% m/m which has been in place since 2012.
Ship Implementation Plan
The Marine Environment Protection Committee at its seventy-third session (MEPC 73), approved Resolution MEPC.1/Circ.878
that provides guidelines on the development of Ship Implementation Plan for the consistent implementation of the 0.50%
Sulphur Limit under MARPOL Annex IV, containing also an indicative template for such Implementation Plan.
The development and adherence to the ship specific Implementation Plan is highly recommended in order to ensure that the
change to compliant fuel is achieved as smoothly as possible, helping the crew to better deal with the associated challenges.
Items recommended to be addressed through such a plan include :
1- Risk assessment and mitigation plan on the impact of new fuels (compatibility and stability issues).
2- Modifications of the fuel oil system and tank cleaning (if needed).
3- Fuel oil capacity and segregation capability.
4- Procurement of compliant fuel.
5- Fuel oil changeover and documentation and reporting.
A ship having on board a suitably developed Implementation Plan with corresponding records being maintained, could be in a
better position during port State control. Attention is also brought to the Guidance on best practice for fuel oil purchasers/users
for assuring the quality of fuel oil used on board ships, as per MEPC.1/Circ.875.
Paris & Tokyo MoUs Information Campaigns
The Maritime Authorities of the Paris and the Tokyo MoUs on Port State Control will start inspection and checking on the
sulphur content of marine fuels during inspections in order to increase awareness of and to encourage timely compliance with the
new requirements.
PACIFIC MARINE SERVICES
For further information, please refer to PMS Circulars on Website of (www.pmsclass.org/circulars)
Ajman Free Zone F.Z.E – P.O.BOX 8474 Ajman – Tel Fax 0097167411070-Mobil No 00971504500338 – Mail ([email protected]) ( [email protected])بريد الكتروني – 00047508500004موبايل رقم – 0004744877040فاكس –( 4848)ب .ص –عجمان المنطقة الحرة
From 1 January 2020 Port State Control Officers of the Paris MoU will check compliance with these regulations through the
bunker delivery notes and related ships’ log books and records and by means of sampling from the fuel lines. The following
check boxes indicate the areas investigated :
1- SOx records
2- Sulphur oxides
3- Sulphur content of fuel used
4- Alternative arrangements (SOx)
From 1 January 2020 Port State Control Officers will put further emphasis on the following items:
1- That the ship carries on board fuel oil with a sulphur content depending on the area of operation
2- There are records of the bunker delivery notes (BDNs) and associated samples or records thereof are kept on board
3- There are written procedures on board covering fuel oil change over operations where appropriate
4- That the Master and ship’s personnel are familiar with essential fuel oil management procedures
5- That the ship has an appropriate approval for any installed exhaust gas cleaning systems, or equivalent means, if required.
Note that the Togo ship registry & Togo Maritime Authority they recommend all ship Managers by implement and shall take
these requirements into consideration and on be implementing on all vessels under (Togo Flag), According to the circular issued
by Flag Ref No. (0032CTECH/TG/TG/19) Issued on Date 25.1 0.2019 as the attached.
ACT NOW
Ship owners / Managers / Operators are urged to develop implementation plans, outlining how the ship may prepare in order to
comply with the required sulphur content limit of 0.50% by 1 January 2020. The plan could be complemented with a record of actions taken by the ship in order to be compliant by the applicable date.
P.M.S Surveyors shall act during the forthcoming annual/intermediate/renewal surveys, ensure that all vessels shall implemented these requirements according to the Regulation 14.1.3 of MARPOL Annex VI entered into force on 1 January 2020, as
confirmed through IMO Resolution MEPC.280(70).
find attached supporting documents as the following :-
( MEPC.280(70) & MEPC.1/Circ.878 & MEPC.1/Circ.875 )
----------------------------------------------------------------------------------------------------------------------------
Kind Regards,
CONTACT US
REPUBLIQUE TOGOLAISE TOGOLESE MARITIME AUTHORITY TRA VAIL - LIBERTE - PATRJE INTERNATIONAL SHlP REGISTRY
Date: 25.1 0.2019
Circular no.: 0032CTECHrrO/ lO/19
To: All Owners I Managers I Operators I Agents I Deputy Registrars IRecognized organizations certifYing vessels on behalf of the Togolese Administration
SUBJECT: IMPLEMENTATION OF THE 0.50% SULPHUR LIMIT UNDER MARPOL ANNEX VI.
(Annex to this circular the resolutions MEPC.320(74) and MEPC.321 (74) and Circulars MEPC.1ICirc.881 MEPC.1ICirc.878 - Appendix 1) (the two Resolutions and the two circulars can also be down loaded from the official site of Togo International Ship Registry : http://www.toqoreqistrar.com/circulars )
i. General
From January 1. 2020. the limit for Sulphur in fuel oil used on board ships operating outside designated emission control areas has been reduced to 0,50% mlm (mass by mass), from 3,50 % mlm. The limit is set in Annex VI (Prevention of Air Pollution from Ships) to the IMO Convention for the Prevention of Pollution from Ships (MAR POL Convention).
In order to ensure consistent implementation of the 0.50% Sulphur limit under MARPOL Annex VI from 1 st January 2020, MEPC 74 adopted one set of guidelines by resolutions MEPC.320(74) and MEPC.321 (74) and also approved various guidel ines.
The scope of this circular, is for the Togo Maritime Administration to inform all interested parties for the implementation of mandatory IMO instruments related to 0.50% sulfur limit and strongly recommends the implementation of the relevant guidelines .
In this respect the Togo Maritime Administration, hereby provides the below notices, applicable for all interested parties:
ii. Notices for implementation of the IMO 2020 Global Sulphur Limit
1. All parties concerned are advised to take into account the above IMO Resolutions MEPC.320(74) and MEPC.321 (74) (annexed to this circular)' for ensuring cons istent implementation of the 0.50% Sulphur limit under MARPOL Annex VI which has already entered into force since 1s1 January 2020.
2. The Shipowners, Ships' Operators and Managers are guided to plan for transition to compliant fuel oil on board their ships well in advance before the indicated deadline of 1 st January 2020, unless the ship : • is fitted with an approved equiva lent (e.g. an Exhaust Gas Cleaning System - "Scrubber") • use alternative fuel (e.g. LNG methanol) • use onshore power supply when at berth
3. A supplementary MARPOL Annex VI amendment ( the carriage ban), enters into force on 1st day of March 2020, and prohibits the carriage of non-compliant fuel oil for combustion purposes, for propulsion or operation on board a ship, unless the ship is equipped with alternative means (e.g. Exhaust Gas Cleaning System - "Scrubber'), approved by the Flag State as an alternative mean. 1(;(.. '.
•
1
REPUBLIQUE TOGOLAISE TOGOLESE MARITIME AUTHORITY TRAVAIL - LlBERTE - PATRIE INTERNATIONAL SHIP REGISTRY
4. Ships not fitted with approved equivalent systems under Regulation 4 may be allowed to carry unconsumed fuel with Sulphur content exceeding 0.50% until 01 March 2020. Consumption of such fuel as of 1st January 2020 is not permitted. Ships having such fuel on board after 1st January2020 must make plans to debunker the non-compliant fuel oil prior to 1 st March 2020.
5. Owners / managers decided for their ships to limit the air pollutants by installing Exhaust Gas Cleaning System need to have the acceptance / approval from the Flag State for that system.
6. IMO Member States have the right to adopt their own laws and measures to reduce the pollution from ships into their ports and territorial waters (limit or restrict discharge of wash water in their areas).
Therefore, it is strongly recommended, when approaching a port or territorial waters of a country, the communication with the local port authorities for relevant guidelines in respect to the use of any equivalent system.
7. It is underlined that the 0,50% Sulphur limit, applies to all ships, irrespectively of their size and the nature of voyages (International voyages, voyages between two or more countries or domestic voyages within waters of a Party to the MARPOL Annex VI).
8. The new 0,50 % Sulfur limit, does not affect the already 0,10 % limit in the ECAs (BaltiC Sea, North Sea, North America Sea, covering designated coastal areas off the US and Canada - and the US Caribbean Sea area, around Puerto Rico and US Virgin Islands.) and ECAs and ports of European Union.
9. In accordance with the IMO decisions, no phase-in period has been allowed as of 01 January 2020 for transition to shipboard consumption of compliant fuel oil.
iii. Making use olthe Ship Implementation Plan (SIP) for enhancing compliance with the 0,50% sulphur limit under MARPOL Annex VI
1. Administrations should have encouraged ships flying their flag to develop implementation plans, outlining how the ship may prepare in order to comply with the required Sulphur content limit of 0.50% by 1 January 2020. .
2. Although A Ship Implementation Plan is not a mandatory requirement, Togo Maritime Administration strongly recommends the use of same.
3. 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 Company to address and mitigate the concerns identified.
The ship implementation plan for 2020 is ship specific and covers various items including, as appropriate , but 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) ; and • documentation and reporting. ~
2
•
REPUBLIQUE TOGOLAISE TOGOLESE MARITIME AUTHORITY TRA VAIL - LIBERTE - PATRIE INTERNATIONAL SIllP REGISTRY
4. It is noted that a lack of a ship implementation plan or an incomplete ship implementation plan should not be considered as "clear grounds" for a more detailed inspection. However, ships voluntary enforcing the Ship Implementation Plan, may be faced by the Port State Control Authorities as more prudent to demonstrate compliance.
5. Guidance on the development of a Ship Implementation Plan for the consistent implementation of the 0.50% Sulphur limit under MARPOL Annex VI can be found enclosed to this Circular (IMO MEPC.1/Circ.878 - Appendix 1)
IV. Fuel oil non-availability Report (FONAR)
1. Regulation 18.2.1 of MARPOL Annex VI mandated that in case compliant fuel oil cannot be obtained , a Party to MARPOL Annex VI can request evidence describing the attempts made to obtain the compliant fuel oil, including attempts made to local alternative sources.
2. Regulations 18.2.4 and 18.2.5 then require that the ship informs its Administration and the competent authority of the port of destination on the inability to obtain compliant fuel oil , with the Party to notify IMO of the non-availability. This notification is commonly referred to as a "Fuel Oil Non-Availability Report" (FONAR).
3. If a ship, in spite of its best efforts to obtain compliant fuel oil, is unable to do so, the master/company must present a record of actions taken and provide evidence. Moreover, the master/Company must immediately notify the port State Administration in the port of arrival and the flag Administration (regulation 18.2.4 of MARPOL Annex VI) .
4. It is noted that the ship should have a procedure for Fuel Oil Non-Availability Reporting (FONAR). The master and chief engineer should be conversant about when and how FONAR should be used and who it should be reported to.
5. Togo Maritime Administration underlines that this particular reporting procedure (FONAR), should be solely used in situations of absolute necessity and provided that vessel and management company can prove with facts and documents the unavailability to have compliant fuel. Moreover, if a ship cannot obtain compliant fuel oil , the FONAR can be completed and presented to Port State Control Authorities, which at their discretion may take it in to account.
It is stressed that the FONAR is NOT a waiver nor an exemption.
v. Port State control and measures against ships that fail to comply
1. It is once again stressed that the implementation of the MARPOL Annex VI , and the guidelines of resolutions MEPC.320(74) and MEPC.321 (74) are mandatory to all ships irrespectively of their size and the nature of voyages (International voyages, voyages between two or more countries or domestic voyages within waters of a Party to the MAR POL Annex VI).
2. It is also underlined that the Port.State,Control Authorities have responsibility for the enforcement of the guidelines and the verification of the vessels ' compliance of same. {(.
3
•
REPUBLIQUE TOGOLAISE TOGOLESE MARITIME AUTHORITY TRAVAIL - LIBERTE - PATRIE INTERNATIONAL SlllP REGISTRY
The Togo Maritime Administration draws the attention to all interested parties to this critical point and encourage owners I managers to make the necessary actions on time as appropriate in order to avoid detentions and other measures imposed by the Port State Control Authorities.
3. Guidance for Port State Control on how to address non-compliant fuel oil has been provided by IMO in Circular MEPC.1/Circ.881 and MARPOL Annex VI Chapter 3 (2019 PSC Guidelines - MEPG.321 (74)) .
4. A ship should not be required to deviate from its intended voyage or unduly delay the voyage in order to achieve compliance.
5. Ships that for any reason be found by any Port State Control to deviate from the above described requirements, may be subject to a detention.
6. The Maritime Administration keeps the right to proceed to measures or penalize ships not complying with the above described requirements.
Your kind compliance with the above requirements is strongly recommended and will be highly appreciated.
Sincerely,
For the ~temational Shi
Director
Inq uiries concerning the subject of this ;::ircvlar, or atly requests shou Id be d·"ected to: INTERNATIONAL REGISTRATIONS BUREAU (LB) ... Phone Number: +961-1-883794 E-Mail: [email protected]
4
Recommended
