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IMO-2020 sulphur cap - issues to consider prior to the implementation of the carriage ban on 1 March 2020

IMO-2020 sulphur cap - issues to consider prior to the implementation of the carriage ban on 1 March 2020
With the IMO 2020 global sulphur cap now in force, members should bear in mind another significant date in relation to the ‘carriage ban’ - coming into force on 1 March 2020. The ban mandates that fuel oil used and carried on board ships must not exceed the 0.50% sulphur limit, unless the ship is provided with ‘equivalent’ compliance mechanism like exhaust gas cleaning system (EGCS), or 'scrubbers'.

The carriage ban may prompt increased enforcement action in the coming months, as the breach will be clearly evident to authorities, and it will be relatively straightforward for port state control officers (PSCOs) to pursue action against ships (without scrubbers) that are found to have fuel oil above the 0.50% limit in any of its tanks.

There could also be potential disputes and/or claims arising due to complaints about bunker quality, or when the MARPOL bunker sample tests generate results which exceed the prescribed 0.50% limit.

In order to comply with the carriage ban, members with ships without scrubbers will, therefore, need to ensure that any supplied fuel is in compliance with the sulphur limits set out in MARPOL Annex VI, and that any residual high sulphur fuel in the tanks does not push the limit above 0.50%.

Members are recommended to refer to the following news alerts published on the club's website in order to prepare themselves for the carriage ban in advance of 1 March 2020 –

De-bunkering of HSFO
Blending of fuel on ship for achieving compliance with IMO 2020 regulation
IMO 2020 - Bunker tank cleaning and preparation to receive compliant fuel

Alternatively, members may consider complying with the carriage ban by installing scrubbers before 1 March 2020. However, given the impact of the coronavirus outbreak in China, there have been reports of delays, and it is highly unlikely that installations will be completed in time.
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Posted: Feb 12, 2020,
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Author: Jon
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