NL 205/19 | IMO Guidance on preparing Ship Implementation Plan for 2020 Sulfur Cap Compliance
NL 205/19|IMO Guidance on preparing Ship Implementation Plan for 2020 Sulfur Cap Compliance
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).
February 5th, 2019 - PHRS Head Office
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.
NL 204/19|Panama Maritime Administration - Mandatory Annual SSAS Test
Company Security Officers (CSO) of companies operating Panamanian flagged vessels are reminded that PMA, as from January 1st, 2018 requires to carry out a mandatory annual SSAS TEST through the online platform in use from PMA, according to MMC-133 and the new MMC-371.
In case of vessel changes name, it will be necessary to schedule a new SSAS TEST, through the platform, in order to verify that the new name was programmed properly.
The Administration urges Companies, Company Security Officers (CSO), Ship Security Officers (SSO) and the Recognized Security Organization (RSOs) of Panamanian flagged vessels to verify and comply with this Resolution
and the MMC 133.
For ships to enter the Panamanian registry as of January 1st, 2018, they must schedule the first SSAS TEST through the use of the new platform, which must be verified by their RSO during the initial verification and from that date onwards, every 12 months. In those cases, it must also be ensured that the Company Security Officer designated by the Company Operator already has the Declaration of Company Security Officer duly endorsed by Panama Maritime Authority (as per MMC-206) in order to schedule the first SSAS TEST according to MMC 133.
PHRS, since January 2018, requires the verification of evidence of SSAS annual test records during Initial verifications onboard ships for which PHRS is the RSO, in accordance to the requirements set by PMA.
For further information on the actions to be taken by the CSOs, Ship-managers/owners/operators can also refer to PHRS Newsletter NL 192 of 2017 [ NL 192/17 | New Panama Flag Regulation for the use of the Ship Security Alert System (SSAS) ] and the attached MMC-133 and MMC-371.
Do not hesitate to contact us for any clarifications you may need on the above.
January 15th, 2019 - PHRS Head Office
"Επιθεωρήσεις Σκαφών Αναψυχής : Το παρόν και το μέλλον" - Ενημερωτική Εκδήλωση στο Ίδρυμα Ευγενίδου
Στις 20 Νοεμβρίου ο Οργανισμός διοργάνωσε την ενημερωτική εκδήλωση / ανοιχτή συζήτηση "Επιθεωρήσεις σκαφών αναψυχής: το παρόν και το μέλλον" στην αίθουσα εκδηλώσεων του Ιδρύματος Ευγενίδου. Στην εκδήλωση, πάνελ ομιλητών αποτελούμενο από στελέχη του Οργανισμού συνομίλησε με το κοινό για θέματα σχετικά με την προετοιμασία μιας επιθεώρησης, τα απαραίτητα δικαιολογητικά που πρέπει να υποβληθούν, την διενέργεια της επιθεώρησης καθώς και για καίρια ζητήματα που απασχολούν όλους τους εμπλεκόμενους στον χώρο των σκαφών αναψυχής. Ιδιαίτερη αναφορά έγινε και στο νέο θεσμικό πλαίσιο επιθεωρήσεων σκαφών σε συνδυασμό με τις αναβαθμισμένες υπηρεσίες που παρέχει ο Οργανισμός στον τομέα της πιστοποίησης.
Την ημερίδα τίμησαν με την παρουσία τους υφιστάμενοι πελάτες του Οργανισμού, συνεργάτες, εκπρόσωποι φορέων (ΣΙΤΕΣΑΠ, ΕΠΕΣΤ, ΠΕΝΕΤΗΣ κ.α), ναυτικοί πράκτορες, πλοιοκτήτες και επαγγελματίες που δραστηριοπούνται στην εκμετάλλευση τουριστικών σκαφών.
Όλο το ενημερωτικό υλικό της παρουσίασης είναι διαθέσιμο, κατόπιν αιτήματος, στο email jenny.arvanitaki@phrs.gr .
Appreciation Letter from Panama Flag Administration regarding PHRS's performance in Paris MoU
We are pleased to share the appreciation letter we received from Panama Flag Administration regarding PHRS’s outstanding performance in Paris MoU evaluation list for the period 2015-2017.
The fact that Phoenix Register of Shipping is the first Greek Classification Society to enter the High Performance Rank, did not go unnoticed by Panama Flag Administration, the world’s largest Flag Administrations with a total fleet of over 8.000 vessels.
Such recognition keeps us inspired to continue our ever- ending work regarding the safety of human life at sea and the protection of the marine environment.
| PHRS Performance in Paris MoU during the evaluation period 2015-2017 June 15th, 2018 |
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Action Date: July 1st, 2018
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We are very glad to announce the results of the evaluation conducted by Paris MoU regarding the performance of all classification societies operating on ports that are under the jurisdiction of Paris MoU, for the period 2015-2017.
Our Organization attained an excess factor of -0.10, thus placing Phoenix Register of Shipping within the High Performance Rank.
In the history of Paris MoU, it is the first time that a hellenic classification society has entered the high performance rank , thus proving our focus and commitment to the provision of high quality services, to the protection of human life at sea and the marine environment.
Paris MoU's mission is to eliminate the operation of sub-standard ships through a harmonized system of Port State Control. Annually more than 18.000 inspections take place on board foreign vessels in the Paris MoU's Ports, ensuring that these ships meet international safety, security and environmental standards, and that the crew members have adequate living and working conditions.
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NL 196/18 | Additional information regarding IMO fuel oil consumption data collection system (IMO DCS)
| Additional information regarding IMO fuel oil consumption data collection system (IMO DCS) NL 196/18 | April 18th, 2018 |
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Refers to: Ship Managers / Owners, PHRS Surveyors / Representatives
Action Date: March 1st, 2018 |
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As previously advised through PHRS NL 166/17 of 30 January 2017, the IMO fuel oil consumption data collection system (IMO DCS) came into force on 1 March 2018, further to MARPOL Annex VI amendments adopted in October 2016 by virtue of IMO Resolution MEPC.278(70). Summarizing the MARPOL Annex VI amendments (with additional information) :
Ships flying the flag of a non-Party State to MARPOL Annex VI will still be required to demonstrate compliance with these requirements. Phoenix Register of Shipping (PHRS) is undertaking the necessary steps for being nominated by the Administrations for which acts as RO/RSO to provide following services related to the IMO DSC:
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NL 194/18 | Amendments to Annex V of the MARPOL Convention (Garbage) in force by 1 March 2018
Refers to: Ship Owners/ Managers, PHRS Representatives/Surveyors
Action Date: February 21st, 2018
The Marine Environment Protection Committee (MEPC 70), which was held on October 2016, adopted important amendments to MARPOL V (Garbage) and as such the garbage handling procedure, management method, and record keeping method regarding garbage from ships:
• Amended MARPOL V adopted by MEPC.277(70) which will enter into force on 1 March 2018.
• 2017 implementation guideline of MARPOL V was amended by MEPC.295(71).
Therefore, vessels are required to implement the following by 1 March 2018:
• Solid bulk cargoes other than grain shall be classified as declared by the shipper as to whether or not they are harmful to the marine environment (HME). in accordance with appendix I of MEPC.277(70). Please refer to appendix II of MEPC.277(70).
• Garbage is to be handled taking into account amended garbage category. The Form of Garbage Record Book (GRB) was amended in order to distinguish the information on delivery/discharge of cargo residues. The Record of Garbage Discharges is divided into Part I and Part II.
Part I will be for the use of all ships and Part II will be only required for ships that carry solid bulk cargoes other than grain
Part I: A Plastics / B Food wastes / C Domestic wastes / D Cooking oil / E Incinerator ashes / F Operational wastes / G Animal carcasses / H Fishing gear / I E-waste
Part II: J Cargo residues (non-HME) / K Cargo residues (HME)"
New category of garbage “e-waste” is included in form of GRB. E-waste is defined as any electronic equipment, including its components, sub-assemblies and consumables, when disposed of as a waste.
Furthermore, in order for the ship managers to be aligned by 01 March 2018 with the revised MARPOL Annex V Garbage Requirements, they should have an effective updated Garbage Record Book and instruct their crews to mark the new Garbage Types on board regarding the “E-Waste” and “Cargo Residues”.
No change has been made regarding the issuance of Statutory Certificate under the MARPOL V as it remains not mandatory.
Every ship of 100 gross tonnage and above, every ship certified to carry 15 or more people and fixed/ floating platforms are required to carry and implement a Garbage Management Plan that specifies procedures to be followed to ensure proper and efficient handling and storage of garbage.
For your reference please find below :
• MEPC.277(70) - Amendments to MARPOL Annex V
• MEPC.295(71) - 2017 implementation guideline of MARPOL V
For more information regarding the issue please do not hesitate to contact us.
February 21st , 2018 – PHRS Head Office
Holiday Notice
We would like to inform you that our Organization will remain closed on the 25th and 26th of December 2017, as well as on Monday January 1st 2018 due to Public Holidays.
For any urgent matter that might occur during this time, you can always contact our Office via the usual e-mails, as our correspondence is regularly being monitored from our emergency staff.
December 18th, 2017
PHRS - Head Office
NL 192/17 | New Panama Flag Regulation for the use of the Ship Security Alert System (SSAS)
Refers to: Owners / Managers /Operators of Panamanian flagged vessels, PHRS Representatives/Surveyors
Action Date: November 30th, 2017
Panama Maritime Authority has recently revised the instructions and procedures on the Ship Security Alert System (SSAS) according to SOLAS 74, Chapter XI-2 Reg. 6, as amended.
Existing requirements (basic)
According of Section 9 Part A of the ISPS Code, each ship requires implementing a Ship Security Plan (SSP) approved by its Flag State or by a Recognized Security Organization.
All the Panamanian flagged vessels shall be provided with a Ship Security Alert System (SSAS), as instructed in the SOLAS 74’, as amended (Chapter XI-2 Regulation 6, paragraph #1). The SSAS shall be capable of transmit a security alert to a designated, competent authority when activated in an emergency situation.
According to MMC-133, 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 (optional)
The CSO designated by the Company has to obtain an Endorsement from the Panama Maritime Administration in order to comply with the duties and responsibilities on behalf of the Company, as per MMC-206. This has to be done BEFORE the issue of INTERIM ISSC by the RSO.
The SSO must ensure that at least one security drill is conducted once every three months to promote the effective implementation of the Ship Security Plan,
The Company Security Officer shall ensure the effective coordination and implementation of Ship Security Plans by participating in exercises at appropriate intervals.
Exercises should be carried out at least once each calendar year with no more than 18 months between the exercises.
All RSO’s must verify in the initial verification that the SSAS system is working properly, performing a real TEST and sending it to threat@amp.gob.pa in order to confirm receipt.
Amendments
Until 15 December 2017, all CSOs shall verify the CSO information in PMA’ data base, by completing and send the CSO Validation Form (which can be found here) with the information required to the following addresses: isps@amp.gob.pa and info@panama-ssas.com
After 15 December 2017, CSOs shall apply for the endorsement or revalidate the information through the online application ( http://certificates.amp.gob.pa/certificates )
From 30 November 2017 all the CSO that already send the Validation Form described in the above paragraph or apply through the CSO Endorsement online application by the website link: http://certificates.amp.gob.pa/certificates will receive an email from info@panama-ssas.com with their credentials and the instructions for Annual SSAS testing.
As from 01 January 2018, all ships flying Panama Flag which complying and certified according to the ISPS Code shall carry out annual SSAS TEST with PMA which will be send through the use of an electronic platform for the Supply and Operation of the Ship Identification and Monitoring System. Ship Owners/ Managers/ Operators of vessels flying Panama Flag, through the CSOs have the responsibility to schedule, through the platform, the annual tests of SSAS TEST in a period no longer than twelve (12) months and the confirmation message of the annual SSAS TEST must be retained on board.
For ships entering the Panama Flag after 01 January 2018, the first SSAS TEST must be scheduled through the use of the new platform, which must be verified by their RSO during the initial verification and from that date onwards, every twelve (12) months. In those cases, it is required that the CSO designed by the Company Operator already has the Declaration of Company Security Officer duly endorsement by PMA, as per MMC-206, in order to schedule the first SSAS TEST.
Only one annual SSAS TEST is mandatory. In case of vessels that perform more than one test and require a flag confirmation they should not schedule it through the platform, in those cases they also have to use the below SSAS TEST message information and send an email directly to threat@amp.gob.pa
Please click here for the revised Merchant Marine Circular (MMC -113) regarding the new regulation for the use of the Ship Security Alert System (SSAS).
Please click here for the revised Merchant Marine Circular (MMC – 353) regarding the updated information to the Company Security Officer (CSO).
For more information regarding this issue please do not hesitate to contact us.
November 29th, 2017 - PHRS Head Office
NL 174/17 | Paris MOU & Tokyo MOU announce Concentrated Inspection Campaign (CIC) on ECDIS
Refers to: Ship Managers/Owners, Clients, PHRS Representatives
Action Date: September 2017
Dear all,
The purpose of subject newsletter is to inform all interested parties about the conduction of a Concentrated Inspection Campaign (CIC) from the Paris Memorandum of Understanding (MoU) jointly with the Tokyo MoU. The Black Sea MoU will also participate in the same CIC campaign.
Please click here for the relevant Press Release for more details.
The CIC will focus on navigation safety, including Electronic Chart Display Information Systems (ECDIS).
The campaign will be held for three months, beginning on the 1st of September 2017 till the 30th of November 2017.
During this time, Port State Control (PSC) Officers are expected to use a standard questionnaire, which will be published in August 2017.
Once the CIC questionnaire will be published in August, PHRS will launch a similar CIC throughout its classed ships in order to ensure that the ships will be better prepared for the CIC.
Do not hesitate to contact us for any clarifications you may need on the above.
June 12th, 2017 - PHRS Head Office