P&I Club Gard has issued guidance of compliance following the early 0.50% sulphur cap implementation that entered into force in Hong Kong, Taiwan and mainland China on 1 January 2019.
Shipowners and operators should:
- Emphasise that a ship’s fuel changeover operations must be completed prior to the entry into or commenced after exit from a designated area.
- To avoid contamination, ensure that the written changeover procedure allow sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable sulphur content prior to entry into the designated area.
- Highlight the importance of correctly completing ships’ log books, by including items such as the time when fuel changeover operations are performed, the volume of low sulphur fuel oils in each tank, as well as the date, time, and position of the ship when any fuel oil changeover operation is completed prior to the entry into the designated area or commenced after exit from such an area.
- Ensure that the quality of fuel purchased can be documented, eg by obtaining and retaining onboard bunker delivery notes and representative samples of the low sulphur fuel oil delivered.
- Verify the applicable sulphur emission requirements, as well as scrubber wash water discharge requirements, at any given time with the local agent or port authorities well before arrival as local cities and relevant authorities continue to evaluate the implementation of the new regulation and the control measures to be taken.
Hong Kong’s new regulation extends to all ships not fitted with scrubbers to burn fuel with a sulphur content not exceeding 0.50% within Hong Kong waters, irrespective of whether they are sailing or at berth.
Taiwan’s Ministry of Transport and Communication has also implemented a 0.50% sulphur cap one year ahead of the IMO.
The original notice was that ships not fitted with scrubbers are required to burn fuel with a sulphur content not exceeding 0.50% when entering Taiwan’s international commercial port areas, but this has been de facto extended to most ports in Taiwan.
Mainland China has extended its compliant fuel requirement to all sea areas and ports within China’s territorial sea and announced a prohibition on the discharge of wash water from ships’ open loop scrubbers from 1 January 2019 to ships operating in parts of the Yangtze River and the Xi Jiang River as well as in Bohai Bay.
In addition, China has ratified the Ballast Water Management Treatment convention and foreign ships may be inspected by China Maritime Safety Administration when entering Chinese waters.
Has the implementation of these regulations in Asia caught the tanker industry by surprise, and how is it coping with the challenges? Discuss this topic at the Asian Tanker Conference in Singapore. Book your place now.