IACS Annual Review 2019

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established and implemented a Data Collection System as a key tool for collecting per-ship GHG emission data to underpin further regulatory efforts and as a basis for future revision of the GHG strategy. MEPC 73 agreed, in principle, that a method for conducting future data analysis of the IMO Ship Fuel Oil Consumption Database needs to be developed as a priority. At MEPC 74, IACS and OCIMF submitted a document (deferred to MEPC 75) providing information on possible analysis of data from the IMO Ship Fuel Oil Consumption Database including the identification of performance indicators and possible further analyses that could be undertaken. IACS will continue to support the proper and timely implementation of the three step approach of data collection, analysis and development of measure, for example in consideration of EEDI, in terms of tightening the provisions for Phase 3 and/or introduction of further phases.

Sulphur 2020 Since 1 January 2020,the global upper limit on the sulphur content of ship’s fuel oil has entered into force. The next important target set by IMO is that carrying non-compliant fuel oil on board ships becomes prohibited from 1 March 2020. At present, most residual fuel oils supplied to ships are blended products and incidents related to fuel oil quality problems occur only occasionally. However, when they do happen, incidents related to fuel oil quality problems can be severe. Considering that more blended products are expected to enter the fuel market in the near future, it is important to increase awareness among all involved parties of the identified potential risks and relevant mitigation measures, including alerting the fuel oil supply network to the consequences of a failure to supply a product that is not to specification.

IACS | International Association of Classification Societies

Some of the problems related to the quality of fuel oil may be addressed by operational measures involving fuel storage, fuel transfer systems, fuel cleaning, combustion equipment, fuel changeover, documentation and training. However, operational measures may not address all problems that are related to the chemistry of the fuel. Appropriate operational measures can be identified by undertaking the ‘Risk assessment and mitigation plan on the impact of new fuels’ recommended by MEPC.1/Circ.878 as part of the ship implementation plan for the consistent implementation of 0.50% sulphur limit under MARPOL Annex VI. However, IACS is of the view that consideration should be given to more concrete action such as mandatory application of operational precautions intended to identify and, when possible, to mitigate fuel-related risks. In support of this, at the 101st session of the Maritime Safety Committee (MSC 101), IACS proposed a method of work and items to be taken into account when developing measures to enhance the safety of ships relating to the use of fuel oil, in particular that a structured approach is proposed in order to justify the need to take regulatory action. Following the consideration of the relevant proposal, MSC 101 endorsed an action plan to further consider measures relating to the flashpoint of fuel oil, with a view to finalising such measures by MSC 104 (2021). IACS will continue to use its knowledge and expertise and engage closely with the IMO and industry in the development and technical implementation of regulations, striving to ensure that all use of fuels satisfies IMO requirements regarding safety, including operational safety matters related to storage, fuel systems, filters, centrifuges and purifiers, or potential damage to engines.

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