Luckily for the industry, there has been a lot of activity around the topic, as multiple NGOs and working groups have been working on ways to minimise the risk of non-compliance.
At the same time, many analyses have been carried out trying to assess the real exposure and areas where undetected non-compliance situations might occur. There is also the probability; although very rare, of vessels navigating within shipping routes, exclusively between non-signatory flag states to Annex VI, which could be burning HSFO without being at risk of non-compliance.
To demonstrate the level of activity regarding this topic, we will highlight some of the key findings or facts supporting our view:
To help strengthen the level of compliance, various sub-task forces under IMO moreover arrived at two very strong process recommendations:
When we look at the different activities, studies/analyses and actions going on up to this point, Bunker One believes that the suppliers should focus on making sure that they provide the fuels ordered by the customers in accordance with the specifications outlined in their contracts.
Suppliers should not be expected to play a role in the monitoring and enforcing of compliance. Just like ship owners, they should not be responsible for monitoring the specifications coming out of refineries and blending operations. They should expect their suppliers to deliver within the specifications of the bunker fuel being ordered.
ISO Specifications for 2020 will not be ready in time. Instead, there is a possibility that there will be a “publicly available specification” by the time the new sulphur cap comes into effect. However, even this would be a challenge during the first 12 months or so, as no official ISO standards will be available by the time the new sulphur cap comes into effect. The official specifications are not likely to be ready until late 2020 or early 2021, however.
In summary, we believe that the monitoring and enforcement of the IMO specification should be left to the resources or authorities identified within the flag states. Suppliers and ship owners should focus on their core activities and make sure to follow agreed procedures or policies in support of strengthening compliance with the new specifications. There is no question that there is a strong probability for non-compliance to take place. Most of the recent estimates forecast the level of non-compliance to be around 10%.
Working with reliable suppliers and following the agreed policies and procedures will be very important. Bunker One is ready to assist you and be your preferred trusted supplier.
Bunker One continues to take bunkering one step further by providing unparalleled service - offering guidance and advice that exceeds customer expectations.
Some players are scrambling to prepare and implement changes as the new decade approaches. We are not. The reason for our calm is simple. Our 2020 preparations started more than a year ago.
2020-preparations are progressing at full speed. But from now until the carriage ban is enforced 1 March 2020, we will undoubtedly see a need for de-bunkering/offloading of non-compliant volume, when vessels for some reason is captured with high sulphur fuel on board.
Wrecks of ships that contained high amounts of oil when they sank are environmental timebombs, as the stored oil will escape the tanks once the hull have been sufficiently corroded.