Maritime shipping has one of the lowest carbon emissions compared to other modes of transport..
Despite this, the International Maritime Organization (IMO), the regulatory authority for international shipping, has been working to reduce the harmful impacts of shipping on the environment since the 1960s..
In April 2018, the IMO adopted an initial strategy on the reduction of greenhouse gas emissions from ships by at least 50% by 2050 compared to 2008 levels, thereby actively contributing to global action to combat climate change..
As part of IMO’s efforts to also reduce air pollution from shipping, on January 1st 2020 IMO’s MARPOL Annex VI (colloquially known as IMO2020) regulated to lower the current global limit for sulphur content of marine fuels from 3.50% to 0.50% was implemented..
We caught up with Roel Hoenders, Acting Head of Air Pollution and Energy Efficiency, Sub-Division for Protective Measures, Marine Environment Division, with the IMO for his views on the implementation of IMO2020, Best practices and guidelines for Port State Controls..
SFR : MARPOL Annex VI (IMO2020) seems to have been implemented successfully as of the 1st of Jan 2020. What sort of engagements and challenges did the IMO have in order to ensure the successful implementation?
RH : There has been a lot of work by IMO, its Member States, the shipping industry, the fuel supply industry and other relevant industries to ensure such a major rule change is being implemented successfully without significant disruption to maritime transport and those that depend on it.
An immense amount of preparatory work was undertaken by IMO and industry stakeholders to ensure the changeover went smoothly.
IMO issued a series of guidelines to help the shipping sector and its Member States to prepare, including ship implementation planning guidance (addressing issues such as risk assessment for new fuels and tank cleaning) and port State control guidelines.
SFR : Will the implementation of IMO2020 alone help the industry achieve the 50% reduction in GHG by 2050 or are there other actions the industry needs to take to achieve this?
RH : The limit on sulphur in fuel oil is aimed at preventing air pollution from ships and specifically addressing sulphur oxides – sulphur oxides (SOx) are known to be harmful to human health, causing respiratory symptoms and lung disease.
In the atmosphere, SOx can lead to acid rain, which can harm crops, forests and aquatic species, and contributes to the acidification of the oceans.
Limiting SOx emissions from ships will improve air quality and protects the environment.
IMO is also addressing greenhouse gas emissions from ships, to contribute to the global fight against climate change, in support of the UN Sustainable Development Goal 13, to take urgent action to combat climate change and its impacts.
Greenhouse gases (GHGs) are defined as the six gases initially considered under the UNFCCC process: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF6).
IMO has adopted mandatory measures to reduce emissions of greenhouse gases from international shipping, under IMO’s pollution prevention treaty (MARPOL) – the Energy Efficiency Design Index (EEDI) mandatory for new ships, and the Ship Energy Efficiency Management Plan (SEEMP).
In 2018, IMO adopted an initial IMO strategy on reduction of GHG emissions from ships, setting out a vision which confirms IMO’s commitment to reducing GHG emissions from international shipping and to phasing them out as soon as possible.
IMO is also executing global technical cooperation projects to support the capacity of States, particularly developing States to implement and support energy efficiency in the shipping sector.
SFR : What contingencies does the IMO have in place for companies who may default against this ruling? Are there any guidelines for Port State Controls for the monitoring of IMO2020..??
RH : Monitoring, compliance and enforcement of the new limit falls to Governments and national authorities of Member States that are Parties to MARPOL Annex VI.
Flag States (the State of registry of a ship) and port States have rights and responsibilities to enforce compliance. IMO has adopted 2019 Guidelines for port State control under MARPOL Annex VI Chapter 3 (download the guidelines here).
IMO does not have any right or remit to issue any fines or sanctions – this is the remit and responsibility of national authorities.
IMO has worked with Member States as well as industry (including the shipping industry and the bunker supply and refining industry) to identify and mitigate transitional issues so that ships may meet the new requirement.
For example, developing guidance and standardised formats for reporting fuel oil non availability if a ship cannot obtain compliant fuel oil and considering verification and control issues.
The MEPC has issued guidance on ship implementation planning, part of a set of guidelines developed by IMO for consistent implementation of the MARPOL regulation that came into effect on 1 January 2020.
Guidance on best practice for fuel oil suppliers has also been issued. The Guidance is intended to assist fuel oil purchasers and users in assuring the quality of fuel oil delivered to and used on board ships, with respect to both compliance with the MARPOL requirements and the safe and efficient operation of the ship. The guidance pertains to aspects of the fuel oil purchase up to the loading of the purchased fuel oil on board.
A full list of guidance and guidelines can be found on the infographic.
In October 2018, IMO’s Marine Environment Protection Committee (MEPC) adopted a MARPOL amendment to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship – unless the ship has an exhaust gas cleaning system (“scrubber”) fitted, which will come into force on 1 March 2020
SFR : Does IMO have any strategy or plan to assist the industry with the availability of VLSFO?
RH : The supply of fuel oil is a matter for refineries and the bunker suppliers. They need to respond to the demand from shipping for compliant fuel oil.
SFR : It has been recently reported that two vessels were caught in China for IMO2020 violations. In such cases, does the PSC of the relevant country decide on the punitive measures to be taken or are there any IMO guidelines for the same?
RH : Yes, the PSC of the country decides what action to take. There are IMO guidelines. IMO has adopted 2019 Guidelines for port State control under MARPOL Annex VI Chapter 3 (download here).
SFR : Which is a better option for emission control – VLSFO, Scrubbers or LNG?
RH : MARPOL allows for the use of equivalent methods other than compliant fuels. However, the choice of how to comply is a matter for the individual ship owner/operator. The important thing is that they comply with the regulations.