CONSULTATION: Shipping’s response to 2020 sulphur limit

The Institute of Marine Engineering, Science & Technology is surveying the shipping industry’s response to the 2020 sulphur limit.

As the commercial shipping industry prepares to transition to 0.50% sulphur fuel, the Institute has been invited by IMO to participate in an industry roundtable discussion to share your collective feedback on the practical realities of implementation.

In 2017 IMO confirmed that, under MARPOL Annex VI, ships operating outside Emission Control Areas (ECAs) must limit the sulphur fuel content to 0.50% m/m by 1 January 2020 as compared to the 3.50% m/m currently applicable. That deadline is rapidly approaching. 

We want to build a detailed picture of the practical realities of implementing this regulation, based on individual experiences from the membership. We want to hear what went well and what unexpected challenges arose.

The MARPOL Annex VI provides for alternative means to compliance with the new requirements. Ships can switch to burning a low-sulphur fuel oil, choose another fuel like natural gas or use approved equivalent methods such as an exhaust gas cleaning system (EGCS) which gives the option to stick with a higher sulphur fuel by removing sulphur dioxide before it enters the atmosphere. It is expected that the vast majority of ships will seek to comply by use of sulphur controlled fuel oils which may range from distillates through to residuals. This would represent the greatest change to marine fuel oil that has ever taken place, compounded by the fact that this transition is to occur for all ships over the next few months. However, as the saying goes: the devil is the detail.

For this reason, the IMarEST is gathering feedback related to the implementation of the new regulation, so that it can bring any issues to the attention of industry regulators and others. Input is needed on aspects relating to the marine fuel supply chain (e.g. production, storage, distribution, safety implications, use of the fuel, etc.); operational considerations such as fuel compatibility and testing; availability of fuels; port infrastructure; as well as experience with exhaust gas cleaning systems. All feedback will be treated in full confidence and anonymized before analysis.

The outputs of this exercise will assist the IMarEST in providing a user’s perspective on those issues encountered in ‘real-world’ situations and help shipowners/operators navigate the transition to 0.5% sulphur fuel by highlighting any recurrent problems or traps to avoid. Documented experience will also add weight to discussions at industry forums and at IMO exploring the full implications of the regulation.

Respond to the consultation

To assist the IMarEST in this initiative, simply email [email protected] by Tuesday 18 June 2019, indicating your route to implementation together with your experiences on the challenges faced.

We are looking to compile this information in a staged approach recognising that in the short transition period experiences will become quickly dated. Make your views known and contribute to the industry roundtable discussions by the 18 June. If you went down the EGCS route, you can provide your feedback using the link on the Engine Room Perspectives webpage.