PHOENIX REGISTER OF SHIPPING S.A. will participate to the upcoming East Med Maritime Conference which will take place on June 19-20 2019 at Hilton Beirut Habtoor Grand.
The East Med Maritime Conference - EMMC2019 is organized under the patronage of the President of Council of Ministers of Lebanon and the Lebanese Directorate General of Land and Maritime Transport with a wide list of topics ranging from Maritime Transport and Logistics Sector in the Eastern Mediterranean region to Oil and Gas Wealth in the Eastern Mediterranean and Human Resources Competencies Development in Shipping, Logistics and Offshore Industries.
During the 2-day conference, the participants will discuss the latest developments in the shipping, maritime, and offshore industries, and provide a premier interdisciplinary forum to the maritime training professionals and community to present the most recent innovations, trends, and concerns, present/future challenges and recommended solutions.
In order to register, please click here.
NL 213/19 | Updated Panama Flag Regulations for the use of the Ship Security Alert System (SSAS)
Refers to: Owners and Operators of Panamanian flagged vessels, PHRS Representatives/ Surveyors
Action Date: Immediate
With regards to PHRS NL192/17 (which can be found here) regarding the instructions and procedures on the Ship Security Alert System (SSAS) from Panama Maritime Authority, recently PMA has updated the pertinent instructions and procedures on the Ship Security Alert System (SSAS)
According to MMC-133,
- Company Security Officers (CSOs) of vessels under Panama flag, must apply to PMA for the revalidation of their information through the online application (http://certificates.amp.gob.pa/certificates). Once this is done, the CSOs will receive an email from info@panama-ssas.com with their credentials and the instructions for Annual SSAS testing.
- All the Companies must include the following e-mail addresses as recipient’s address of the SSAS alerts / tests, on board the Panamanian Flagged vessels:
- threat@amp.gob.pa , and / or
- authorizations@segumar.com
- In those cases that the SSAS terminal has not been configured with the main email address threat@amp.gob.pa, PMA has granted a period until August 31th, 2019 to make all the necessary arrangement to configure the SSAS terminal.
- All applicant ships under Panama flag, they must schedule an annual SSAS test with PMA through the use of the SSAS platform https://polestarglobal.force.com/SSAS/login. In order to comply with this requirement, the SSAS terminal has been configured with the main email address threat@amp.gob.pa, the company operator shall request access to the PMA’ SSAS platform by email to the e-mail address: info@panama-ssas.com, and should submit copy of the last Declaration of Company Security Officer (CSO) endorsed by this Administration in order to receive an email from info@panama-ssas.com, with their access credentials and instructions for using the platform and be able to schedule the FIRST annual SSAS TEST.
- Only one annual SSAS TEST is mandatory and must be scheduled through the SSAS platform in the following link: https://polestarglobal.force.com/SSAS/login , in a period no longer than twelve (12) calendar months and can be scheduled 24 hours in advance.
After the SSAS TEST is made, a confirmation message shall be sent from PMA through the SSAS platform. This confirmation message must be retained on board the ship as evidence during the ISPS verification, which must be verified by their RSO during the INITIAL ISSC verification.
PHRS Security Auditors are instructed to verify the compliance with the Flag requirement at the Initial ISSC Audits.
With respect to vessels passing in High Risk Areas (HRS):
- PMA recommends that all Panamanian Flagged vessels with or without armed or unarmed security personnel, and that prior to the entry into the High Risk Area (HRA), the crew should be fully briefed on the preparations and a piracy drill shall be conducted as well.
- The security drill should be reviewed and all personnel briefed on their duties, including familiarization with the alarm using to identify a piracy attack.
- These drills must to schedule through the SSAS platform in following link: https://polestarglobal.force.com/SSAS/login, indicating that it is a “Piracy Drill” or “SSAS Test”, at the same time the Panamanian Flagged vessels are requested to verify that the SSAS equipment have been correctly set-up and is working properly.
- These measures should be taken to ensure that the security procedures are working properly along with the recommendations stated in the Best Management Practices BMP (last version) and the Internationally Recommended Transit Corridor (IRTC) established in the Merchant Marine Circulars No. 208 and No.238.
Please click here for the revised Merchant Marine Circular (MMC -133) regarding the updated regulation for the use of the Ship Security Alert System (SSAS).
For any further information please feel free to contact PHRS Head Office or any other PHRS office near you.
May 27th, 2019 - PHRS Head Office
Refers to: Owners and Operators of vessels greater than 5.000 GT, engaged in commercial voyages in/out or between EU ports
Action Date: 01/01/2018
According to the European Regulation (EU) 2015/757 for Monitoring, Reporting and Verification of Carbon Dioxide emissions for Shipping (EU-MRV), from 01/01/2018 on wards, every ship equal to or larger than 5000 GT which has a commercial operation and calls to a European port, is obliged to monitor and report a series of relevant data on to its CO2 emissions.
The submission of the first emissions reports corresponding to the first reporting period (set to be from January 1 up to 31 December 2018) for ships subject to the EU MRV regulation has now come and their managing companies need to submitted them verification.
PHRS clients/ship-owners/managers of affected ships are urged to undertake the necessary actions as soon as possible and submit the emissions report for each ship for verification by accredited verifier (*) which will be subsequently submitted to the EC and to the ship's flag by the company before 30 April 2019. The regulation requires reports to be submitted directly to the THETIS-MRV system (https://mrv.emsa.europa.eu/#public/eumrv ) operated by the European Maritime Safety Agency (EMSA).
Further guidance on the EU MRV can be obtained from:
- PHRS NL 178/2017 | Further guidance regarding EU MRV compliance (which can be found here)
- PHRS NL 167/2017 | Monitoring, Reporting & Verification (MRV) of the CO2 emissions from Maritime Transport (which can be found here)
- DG-CLIMA’s official webpage (https://ec.europa.eu/clima/policies/transport/shipping_en#tab)
*refer to PHRS NL 167/2017 - Phoenix Register of Shipping has entered into a framework agreement for cooperation with a leading verifier, namely EMICERT, which is fully accredited to the ISO 14065 standard with multinational experience, specialized in the Verification of GHG Emissions.
For any further information you are free to contact PHRS Head Office or any other PHRS office near you.
March 7th, 2019 - PHRS Head Office
Refers to: Ship Owners / Managers/ Operators, PHRS Representatives/ Surveyors
Action Date: N/A
PHRS would like to recall ship-owners, managers and operators of the importance of availability of effective procedures and measures for Crew Familiarization for Enclosed Space Entry to safeguard seafarers on board ships when entering and working in enclosed spaces.
These procedures have to be incorporated into the company's SMS procedures according to the ISM Code.
Since 2016, SOLAS Regulation III / 19.3 as amended requires enclosed space entry and rescue drills to be carried out at least once every two months on board all Cargo & Passenger ships of 500 GT and above.
Enclosed space entry and rescue drills should be planned and conducted in accordance with the recommendations developed by IMO as per Resolution A.1050(27) which can be found here .
Crew members with enclosed space entry or rescue responsibilities shall participate in an enclosed space entry and rescue drill at least once every two months.
Each drill shall address the following important crew' familiarization functions:
- Checking and use of personal protective equipment required by entry
- Checking and use of communication equipment and procedures
- Checking and use of instruments for measuring the atmosphere in enclosed spaces
- Checking and use of rescue equipment and procedures
- Instructions in first aid and resuscitation techniques.
Persons responsible for the implementation of Safety Management Systems, have to ensure that they contain a comprehensive program of familiarization training of the crew with the Procedure for Entry into Enclosed Space on board ships, and also that the procedures are implemented on board each ship for the scope of ensuring crew members are aware of their duties. Especially those on board with enclosed space duties, must be familiar with relevant equipment and trained accordingly in order to carry out their duties and identify and understand the hazards associated with entry into enclosed spaces.
In addition, Phoenix Register of Shipping requires the relevant procedures for entry into enclosed space to be thoroughly implemented on surveys of enclosed spaces to be carried out by PHRS Surveyors.
For any further information you are free to contact PHRS Head Office or any other PHRS office near you.
February 15th, 2019 - PHRS Head Office
Refers to: Ship Owners / Managers/ Operators, PHRS Representatives/ Surveyors
Action Date: N/A
The American Waterways Operators (AWO) is working with the US Coast Guard to prevent and manage fatigue risks in the US tugboat, towboat and barge industry since the ‘90s. Towing vessel’ crew members are regularly exposed to the risk of fatigue, among other risks. Managing and mitigating these risks is important to reduce the likelihood of fatigue-related accidents.
With the goal of taking a proactive approach to fatigue prevention and management and reducing this risk of fatigue-related accidents, AWO’s Fatigue Risk Management Working Group developed and recently published the guide, 'Developing a Fatigue Risk Management Plan: A Guide for Towing Vessel Operators', to help member companies develop a fatigue risk management plan to incorporate into their existing safety management systems (SMS).
Fatigue risk management plans take a comprehensive, customized approach to addressing fatigue within a company, including policies and practices to address a wide range of fatigue risk factors and mitigation measures. This guide is tailored to the unique operational and environmental challenges of the towing industry. However, because towing vessel operations and design vary widely across the industry, the guide is not intended as a “one-size-fits-all” approach.
That means the companies have to carefully study the guide, assess their policies and procedures that are already in place to mitigate the fatigue-related risks of their crew members and identify how it is possible to link and possible improve their existing fatigue mitigation measures into a comprehensive fatigue risk management plan.
Companies can also use the guide to identify and implement additional practices, controls and other tools to close gaps or expand their current efforts.
The Fatigue Risk Management Working Group intends the guide to be a toolbox in which every AWO member company can find useful tools to address their specific fatigue challenges, enhancing safety of our shared waterways.
The Fatigue Risk Management Working Group has identified four core elements that it considers to be most important in a fatigue risk management plan:
- Education: Towing vessel crew members must understand the effects of poor sleep on their alertness, performance and safety, as well as know how fatigue mitigation strategies can improve sleep quality and duration.
- Environment: Various environmental factors may inhibit the ability of towing vessel crew members for quality sleep. Simple engineering solutions and behavior modifications to improve the sleep and vessel environments can improve crew members’ sleep quality.
- Work Readiness and Fatigue Reporting: Towing vessel crew members have a shared responsibility to report ready for duty, and of a company to allow adequate opportunity for crew members to rest and provide a process for reporting when they have not been able to obtain sufficient rest and/or feel fatigued.
- Performance Measurement: Companies should implement a process to regularly monitor and evaluate their fatigue management practices. This will allow them to assess whether and how these practices are being implemented, evaluate whether they are working and determine whether modifications are needed.
The Fatigue Risk Management Working Group has also identified some other elements that may affect the effectiveness of a fatigue risk management plan, such as:
- Wellness Program: companies should use wellness initiatives to educate crew members about the importance of having good sleep and it’s positive impact on health. In addition, companies must encourage healthy behaviors and provide access to physical and mental health care, as practicable.
- Commuting: Daily commuting can both impact sleep and be impacted by sleep. A fatigue risk management plan of Companies operating live-aboard vessels should evaluate the commute times and practices of crew-members, identify risks and implement feasible risk mitigation measures.
- Sustainability: Sustainability involves the integration of fatigue risk management into the safety culture of the company, and buy-in for fatigue mitigation measures from shore-side management, captains and crew members.
The guide 'Developing a Fatigue Risk Management Plan: A Guide for Towing Vessel Operators' can be found here.
Do not hesitate to contact us for any clarifications you may need on the above.
February 14th, 2019 - PHRS Head Office
Refers to: Ship Owners / Managers/ Operators, PHRS Representatives/ Surveyors
Action Date: January 1st, 2019
The Chinese Ministry of Transport and China's Maritime Safety authority (MSA) have recently (30/11/2018) took action on emissions regulations.
Specifically, an implementation plan was established by which three major
Domestic Emission Control Areas for Atmospheric Pollution from Vessels ( “DECAs”) have been designated to control and reduce emissions of atmospheric
pollutants including SOx, NOx, particulate matters (PMs) and volatile organic compounds (VOCs) from vessels and to improve the air quality of coastal areas and inland river port cities.
Among other provisions of the new requirements, from 01-01-2019, all vessels entering or operating within the DECAs should use at all times fuel with 0.5% m/m sulfur content.
The designated Domestic Emission Control Areas for Atmospheric Pollution from vessels ( DECAs) are as follows:
- Coastal control areas: all sea areas and ports within 12 nautical miles of the baseline extension of the territorial waters excluding waters under the jurisdiction of Hong Kong, Macao and Taiwan, the Hainan waters and ports.
- Inland control areas: The navigable waters of the main stream of the Yangtze River (from Shuifu, Yunnan to the mouth of the Liuhe River, Jiangsu) and the main stream of the Xijiang River (from Nanning, Guangxi to Zhaoqing, Guangdong).
More details on the exact geographic coverage of the designated DECAs and the control requirements on the SOx, NOx and PMs are shown in the implementation plan, which can be found here, published by the Chinese Ministry of Transport and China's Maritime Safety authority (MSA).
In addition, the Chinese Authorities are promoting the use of shore power for vessels at berth.
February 14th, 2019 - PHRS Head Office
Refers to: Ship Owners / Managers/ Operators, PHRS Representatives/ Surveyors
Action Date: January 1st, 2020
The Maritime Authorities of Paris MoU and Tokyo MoU on Port State Control announced that their officers will start issuing a Letter of Warning from 1st January 2019 on the sulfur content of marine fuels during inspections on ships in order to increase awareness of and to encourage timely compliance with the new requirements of MARPOL Annex VI (Regulations 14 and 18), known as the global 2020 Sulfur cap, which will enter to force from 1 January 2020.
The requirement of maximum sulfur content of 0,50% m/m for marine fuel oil will enter into force on 1 January 2020, and will have considerable implications on ship operators, the fuel oil supply chain and the industry as a whole.
For the purpose of facilitating smooth and consistent implementation of the global 2020 sulfur cap, the Paris and the Tokyo Memorandum will carry out a joint information campaign by issuing a letter of warning to ships during inspections from 1 January to 31 December 2019.
A similar approach has been already implemented by PHRS towards it's clients, ship-owners and managers by placing a relevant entry into the memoranda section of the surveys status of the applicable vessels.
Click here in order to view the relevant Press Release.
The letter of warning which may be issued by the PSCOs of Paris MoU can be found here.
February 13th, 2019 - PHRS Head Office
Refers to: Ship Owners / Managers/ Operators of Panamanian flagged vessels, PHRS Representatives/Surveyors
Action Date: January 8th, 2019
Kindly note that Merchant Marine Circular 269 issued by the Panama Maritime Authority, regarding the certification process for Maritime Labor Convention has been revised.
This revision includes the modification of paragraph 22 stating that from January 8th 2019, the ROs listed in the Circular MMC 255 may extend the validity of the Maritime Labor Certificate for a period not exceeding five months after the expiry date of the existing certificate, provided that the renewal inspection has been carried out according to standard of the MLC (A5.1.3.4). The format to be followed by the RO´s will be the same as that found in the Appendix A5–II of the Convention and will be added to the maritime labor certificate and be available to the competent authorities.
Also, paragraph 25 has been added to the circular, stating that in case of change of ship-owner or operator address, an additional inspection is not required; the RO shall re-issue administratively the full or interim maritime labor certificate with same expiry date of the previous certificate, considering that this change does not affect the operation of the ship or the Company procedures. Therefore, an authorization shall be requested to mlc@segumar.com , copy of the valid maritime labor certificate and the certificate of registry (patent) updated if applicable.
Click here for the full MMC – 269 Maritime Labor Convention 2006 (MLC 2006), Certification Process.
Do not hesitate to contact us for any clarifications you may need on the above.
February 6th, 2019 - PHRS Head Office
NL 203/18 | Maritime Cyber Risk Management
Ships are increasingly using systems that rely on digitization, digitalization, integration, and automation. Cyber technologies have become essential to the operation and management of numerous systems critical to the safety and security of shipping and protection of the marine environment.
As technology continues to develop, information technology and operational technology on board ships are being networked together and more frequently connected to the internet. Therefore the ships’ systems and networks maybe vulnerable to risks may also occur from personnel accessing systems on board, for example by introducing malware via removable media. The vulnerabilities created by accessing, interconnecting or networking these systems can lead to cyber risks which should be addressed.
Vulnerable systems could include, but are not limited to:
.1 Bridge systems;
.2 Cargo handling and management systems;
.3 Propulsion and machinery management and power control systems;
.4 Access control systems;
.5 Passenger servicing and management systems;
.6 Passenger facing public networks;
.7 Administrative and crew welfare systems; and
.8 Communication systems
To mitigate the potential safety, environmental and commercial consequences of a cyber incident, the IMO and other international shipping organizations have participated in the development of guidelines designed to assist shipping companies in formulating their own approaches to cyber risk management on board ships:
- IMO resolution MSC.1/Circ.1526 [ INTERIM GUIDELINES ON MARITIME CYBER RISK MANAGEMENT ] (which can be found here)
- IMO Resolution MSC.428 (98) [ MARITIME CYBER RISK MANAGEMENT IN SAFETY MANAGEMENT SYSTEMS ] (which can be found here)
- IMO MSC-FAL.1/Circ.3 [ GUIDELINES ON MARITIME CYBER RISK MANAGEMENT ] (which can be found here)
- ISO/IEC 27001:2013 [Information technology -- Security techniques -- Information security management systems – Requirements ]
- The Guidelines on Maritime Cyber Risk Management [Produced by BIMCO, CLIA, ICS, INTERCARGO, INTERMANAGER, INTERTANKO, IUMI, OCIMF and WORLD SHIPPING COUNCIL ] (which can be found here)
According to IMO Resolution MSC. 428 (98) on Maritime Cyber Risk Management, the objectives of the International Safety Management (ISM) Code include the provision of safe practices in ship operation and a safe working environment, the assessment of all identified risks to ships, personnel and the environment. In this scope, the Safety Management System (SMS) of the shipping companies should take into account cyber risk management in accordance with the objectives and functional requirements of the ISM Code aiming to safeguard shipping from current and emerging cyber threats and vulnerabilities. Therefore, cyber risks should be appropriately addressed in the SMS no later than the first annual verification of the company’s Document of Compliance that occurs after 1 January 2021.
For that scope, the Interim Guidelines on Maritime Cyber Risk Management [ IMO resolution MSC.1/Circ.1526 ] provides recommendations that can be incorporated into existing risk management processes. The Guidelines also include functional elements that support effective cyber risk management.
The Guidelines on Cyber Security on board Ships (please click here), reflect a deeper experience with risk assessments of operational technology, such as navigational systems and engine controls, and provides more guidance for dealing with the cyber risks to the ship arising from parties in the supply chain. For detailed guidance on cyber risk management.
Flag Administrations will soon publish their own guidelines & requirements for encouraging ship-owners and operators to take the necessary steps to safeguard shipping from current and emerging threats and vulnerabilities related to digitization, integration and automation of processes and systems in shipping. Shipping companies should carefully develop plans and procedures for cyber risk management which should be seen as complementary to existing security and safety risk management requirements contained in the International Safety Management Code (ISM) Code and the International Ship and Port Facility Security (ISPS) Code.
December 21st , 2018 - PHRS Head Office
Υπογραφή Διαπιστωτικής Πράξης από το ΥΝΑΝΠ
ΔΕΛΤΙΟ ΤΥΠΟΥ
Στις 30/01/2019, υπεγράφη η Διαπιστωτική Πράξη Συμμόρφωσης του Οργανισμού με τα κριτήρια του άρθρου 109 του νόμου 4504/2017, από το Υπουργείο Ναυτιλίας και Νησιωτικής Πολιτικής. Η υπογραφή της Διαπιστωτικής Πράξης στο σύνολο της, πιστοποιεί και την συμμόρφωση του Οργανισμού με τα κριτήρια του Κώδικα περί Αναγνωρισμένων Οργανισμών (Recognized Organizations Code) του Διεθνούς Ναυτιλιακού Οργανισμού (IMO) αναλογικά με το βαθμό εξουσιοδότησης του Οργανισμού από την Ελληνική σημαία.
Η ευτυχής αυτή κατάληξη αποτελεί ένα σημαντικό και απαιτητικό επίτευγμα για τον Οργανισμό, που δεν θα ήταν δυνατόν, χωρίς την δύσκολη και επίπονη δουλειά τόσο των στελεχών του Οργανισμού αλλά και των εντεταλμένων υπηρεσιακών παραγόντων του Κλάδου Επιθεώρησης Πλοίων (ΔΚΕΟ/ΚΕΠ) και της Διεύθυνσης Ασφάλειας Ναυσιπλοΐας (ΔΑΝ/ΥΝΝΠ) που ανέλαβαν το επίπονο έργο της διαχείρισης του διαπιστωτικού ελέγχου. Η Διαπιστωτική Πράξη Ελέγχου αντικατοπτρίζει το υψηλό επίπεδο οργάνωσης και συμμόρφωσης του Οργανισμού με τα αυστηρότερα διεθνή πρότυπα του Διεθνούς Ναυτιλιακού Οργανισμού (Ι.Μ.Ο.) στον έλεγχο της ασφάλειας και της αξιοπλοΐας των πλοίων.
Με βάση τα παραπάνω ο Οργανισμός αποκτά την δυνατότητα να διενεργεί τα παρακάτω:
• Έλεγχο και Πιστοποίηση πλοίων και ναυτιλιακών εταιρειών σύμφωνα με τον Διεθνή Κώδικα Ασφαλούς Διαχείρισης (ISM Code) και με τον ΕΚ/336/2006, καθώς και έκδοση των σχετικών εγγράφων πιστοποίησης με τα παραπάνω.
• Επιθεώρηση και Πιστοποίηση Πλοίων σύμφωνα με την Σύμβαση Ναυτικής Εργασίας – Maritime Labor Convention (MLC, 2006)
• Επιθεώρηση και Πιστοποίηση Υποστηρικτικών Πλοίων Υπεράκτιων Εγκαταστάσεων
• Επιθεώρηση και Πιστοποίηση Αλιευτικών Σκαφών άνω των 24μ. TOREMOLINOS (ΠΔ 405/1998)
Η ενεργοποίηση της διαπιστωμένης πλέον δυνατότητας του Οργανισμού να παρέχει υπηρεσίες στις παραπάνω ενότητες είναι σε εξέλιξη από τις αρμόδιες υπηρεσίες του Υ.Ν.Ν.Π. και επίκειται να ολοκληρωθεί τις επόμενες ημέρες.
At its latest Marine Environment Protection Committee (MEPC 73), IMO approved, among others, the guidance on the development of a ship implementation plan outlining how the ship may prepare in order to comply with the required sulfur content limit of 0.50% by 1 January 2020 (IMO 2020 sulfur cap) under MARPOL Annex VI.
IMO's 2020 Sulfur cap, which will take effect from 1 January 2020, requires that ships must run on fuel containing no more than 0.5% m/m of sulfur, unless having scrubbers installed.
Namely, the options available for ship-operators to achieve compliance are:
- The use of low-sulfur fuel
- Installation of scrubbers
- The use of LNG
- The use of other new developed fuels
In this context, MEPC 73 in October 2018 agreed that Administrations should encourage ships flying their flag to develop implementation plans, outlining how the ship may prepare, in order to comply with the regulation.
The plan could be complemented with a record of actions taken by the ship in order to be compliant by the applicable date.
Administrations and Port State control authorities may take into account the implementation plan when verifying compliance with the 0.50% sulfur limit requirement. A ship implementation plan is not a mandatory requirement. A lack of a ship implementation plan or an incomplete ship implementation plan should not be considered as "clear grounds" for a more detailed PSC inspection.
It is advised that ship operators schedule for each of their managed vessels a compliance plan in order to achieve compliance prior of 31st of December 2019 in respect of % content in emissions.
Under the new guidance, the ship implementation plan for 2020 could cover various items relevant for the specific ship, including, as appropriate, but not limited to:
- Risk assessment and mitigation plan (impact of new fuels)
- Fuel oil system modifications and tank cleaning (if needed)
- Fuel oil capacity and segregation capability
- Procurement of compliant fuel
- Fuel oil changeover plan (conventional residual fuel oils to 0.50% sulfur compliant fuel oil)
- Documentation and Reporting
Issues relating to use of sulfur compliant fuel oil
All fuel oil supplied to a ship shall comply with regulation 18.3 of MARPOL Annex VI and chapter II/2 of SOLAS. Meanwhile, operators could consider ordering fuel oil specified in accordance with the ISO 8217 marine fuel standard.
The following potential fuel-related issues may need to be assessed and addressed by ships in preparation for and implementation of the 0.50% sulfur limit requirement:
- Technical capability of ships to handle different types of fuel (e.g. suitability of fuel pumps to handle both higher and lower viscosity fuels, restrictions on fuels suitable for use in a ship's boilers, particularly the use of distillate fuels in large marine boilers)
- Compatibility of different types of fuels e.g. when paraffin and aromatic fuels containing asphaltenes are commingled in bunkering or fuel oil changeover
- Handling sulfur non-compliant fuels in the event of non-availability of sulfur compliant fuels
- Crew preparedness including possible training with changeover procedures during fuel switching from residual fuel oil to 0.50% compliant fuel oils.
Additionally, the ship implementation plan could be used as the appropriate tool to identify any specific safety risks related to sulfur compliant fuel oil, as may be relevant to the ship, and to develop an appropriate action plan for the organization to address and mitigate the concerns identified.
Examples should include:
- Procedures to segregate different types of fuel and fuels from different sources
- Detailed procedures for compatibility testing and segregating fuels from different sources until compatibility can be confirmed
- Procedures to changeover from one type of fuel to another or a fuel oil that is known to be incompatible with another fuel oil
- Plans to address any mechanical constraints with respect to handling specific fuels, including ensuring that minimum/maximum characteristics of fuel oil as identified in ISO 8217 can be safely handled on board the ship
- Procedures to verify machinery performance on fuel oil with characteristics with which the ship does not have prior experience.
Click here for the relevant IMO guidance MEPC.1/ Circ.878 (Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulfur limit under MARPOL Annex VI).
Do not hesitate to contact us for any clarifications you may need on the above.