Apart from the need to start ordering compliant fuels earlier, the shipping firms “are strongly recommended to commence developing implementation plans as soon as possible,” ICS Secretary General, Guy Platten, said.
To assist shipping companies prepare for implementation of the International Maritime Organization’s global sulphur cap for ships’ fuel oil, the ICS has produced comprehensive guidance on implementation planning, to help ensure compliance across the shipping industry with this regulatory game changer.
Besides the significant additional cost of compliant fuel, ICS said that implementation of the global cap will be far more complex than for the previous introduction of Emission Control Areas. The organization explained that this is because of the sheer magnitude of the switchover and the much larger quantities and different types of fuel involved, as well as continuing uncertainties about the availability, safety and compatibility of compliant fuels in every port worldwide.
Additionally, ICS argues that if a ship has a suitably developed implementation plan, then the ship’s crew should be in a better position to demonstrate to Port State Control that they have acted in ‘good faith’ and done everything that could be reasonably expected to achieve full compliance.
“This need to demonstrate good faith could be particularly important in the event that safe and compliant fuels are unavailable in some ports during the initial weeks of implementation,” Platten said, adding that IMO has provisionally agreed that Port State Control authorities may take into account the ship’s implementation plan when verifying compliance with the 0.5% sulphur limit.
The new ICS guidance explains that the implementation process will need to address the possibility that some ships may need to carry and use more than one type of compliant fuel in order to operate globally. This could introduce additional challenges such as compatibility between different available grades of fuel that could have significant implications for the safety of the ship as well as its commercial operation.
The global trade association also stressed that primary responsibility for ensuring that compliant and compatible fuels will be available rests with oil suppliers, as well as those IMO Member States which have collectively agreed to implement this major regulatory change in 2020.