Air pollution due to sulphur

Air pollution due to sulphur

Overview

BIMCO's position on "air pollution due to sulphur" has been approved by the BIMCO Board of Directors.

Background

MARPOL Annex VI on Prevention of Air Pollution from ships entered into force in 2006. It covers sulphur and particulate matter, nitrogen oxides, ozone depleting substances and the energy efficiency of ships.

MARPOL Annex VI reduced the limit for sulphur in marine fuel oil used on board ships operating in areas outside designated emission control areas to 0.50% from 1 January 2020.

Compliance with the sulphur emission limits and effective uniform enforcement is of critical importance to ensure a level playing field as it will not be possible for compliant ships to compete with non-compliant ships.

The quality of 0.50% sulphur fuel and its fitness for use on board ships may have a negative effect on safety. Increased blending may also reduce the compatibility and stability of low sulphur content residual-like fuel oils.

BIMCO’s position

  • Only a truly homogenous and representative fuel oil sample such as the MARPOL sample required by Regulation 18 of MARPOL Annex VI can be used to determine sulphur content.    Only bunker storage tanks fitted with dedicated means for drawing representative samples should be subject to PSC on-board sampling.
  • A robust and uniform enforcement of applicable sulphur limits is critical to ensure a level playing field for owners. A clear distinction should be made between cases where the shipowner has bought compliant fuel which leads to minor non-compliance (just above 0.50 % sulphur), and deliberate non-compliance by using HFO with a high sulphur content.
  • BIMCO does not support name and shame initiatives by authorities for cases of minor non-compliance.
  • BIMCO supports implementation by states of a compulsory licensing scheme for fuel oil suppliers and maintaining a register of licensed approved suppliers to help ensure a certain level of quality.
  • BIMCO supports the requirements for Emission Control Areas (ECAs) as the authoritative framework for implementing regional or national air emission control measures for sulphur, particulate matter and nitrogen oxides. 
  • Regional or national regulations for emission control must be aligned with Annex VI.
  • If IMO determines there is a negative impact on the marine environment due to the discharge of wash water from ships equipped with open loop scrubbers, BIMCO would support actions to regulate their use in ports and near coastal areas.
  • Wash water from scrubbers used to produce inert gas to prevent explosions in cargo tanks is safety related and a requirement under SOLAS.  It should not be discussed in the context of MARPOL Annex VI.
  • BIMCO recommends shipowners to use the BIMCO 2020 Marine Fuel Sulphur Content Clause for Time Charter Parties.

 

Rasmus Nord Jorgensen
in Copenhagen, DK

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