The 74th session of the IMO’s Marine Environment Protection Committee (MEPC 74) took place on 13-17 May 2019 at the IMO headquarters in London.
One of the main areas of focus was air pollution and in particular the fast approaching global fuel sulphur cap. We look at some of the key outcomes of MEPC 74 and how it could impact your transition to compliance before 1 January 2020. This article focuses on the new fuel landscape.
New Fuel Definitions
The 2019 Guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI (now adopted and soon to be published as a ResolutionMEPC.320(74)) will provide the following definitions of fuel oils:
- Distillate marine fuels (DM) are as specified in ISO 8217:20171 (e.g. DMA, DMB, DMX, DMZ);
- Residual marine fuels (RM) are as specified in ISO 8217:20171 (e.g. RMD 80, RMG 380);
- Ultra-low sulphur fuel oil (ULSFO) are as specified in ISO 8217:20171 (e.g. maximum 0.10% S ULSFO-DM, maximum 0.10% S ULSFO-RM);
- Very low sulphur fuel oil (VLSFO) (e.g. maximum 0.50% S VLSFO-DM, maximum 0.50% S VLSFO-RM); and
- High sulphur heavy fuel oil (HSHFO) exceeding 0.50% S.
We have previously suggested that terms such as ‘low-sulphur’ or prefixing fuel types with ‘LS’ should be avoided as there are effectively two ‘lower’ sulphur fuels available – 0.10% max and 0.50% max.
These new definitions support our view and should prevent confusion when ordering bunkers or specifying fuel requirements in time charterparties.
We still don’t know much about the new VLSFO products expected to hit the market in coming months. But we can expect a very broad range of products and expect differences from region to region and supplier to supplier.
At MEPC 74, ISO provided an update on the PAS (Publically Available Schedule) 23263 on fuel quality standards which focuses on these new fuels. The PAS is designed to be used in conjunction with ISO8217:2017 but can also be used with earlier editions.
It will not include any new fuel specifications or an updated table. But it will provide general considerations on the expected characteristics of the new fuel products (at least on the ones they know about) as well as providing guidance on stability and compatibility – which is the main concern with the new VLSFO products.
ISO advised that the primary lab test for stability will remain as Total Sediment Potential (TSP). However, they are considering an improved test for compatibility from a non-marine source that can be carried out on board due to concerns on the reliability of the existing “spot” test. But in the meantime, the spot test remains the engineer’s best defence.
Compatibility testing on known new fuels by ISO suggests that fuels with a TSP <0.10% have less risk of compatibility issues. The risk increases with fuels with TSP>0.10% at certain mixing ratios.
The PAS is expected to be released in August or September and this info will also be included in a forthcoming CIMAC guidance document.
Read more about the new fuels in our ‘Preparing for the Big Switch’ guides which are free to download.
An additional laboratory test that can be useful in predicting future stability and possibly compatibility problems is ‘optical scanning’ (Turbiscan ASTM D7061-12). This laboratory test is supplemental to the usual suite of ISO 8217 tests and provides a Reserve Stability Number (RSN), which some fuel experts maintain is a better indication of stability than the regular ‘total sediment’ tests.
Bunker Licensing Schemes
A submission from Intertanko, ICS et al on mandatory bunker licencing schemes caused generated lots of discussion.
Acting on a suggestion from MSC 100 following a review into the safety implications of the sulphur cap, a proposal was made to introduce a worldwide licencing system (similar to what is already in place in Singapore).
After a range of views were expressed, this was sent to the Working Group for their opinion on next steps. Due to a lack of time the group could not fully consider a mandatory scheme but agreed to issue voluntary guidance on implementing licensing schemes.