Do not be caught off guard by introduction of new sulphur limit
2nd November 2011 06:32 GMT

By now it is common knowledge that in less than two months, on the 1st of January 2012, the global sulphur cap will fall from 4.50% to 3.50% in accordance with MARPOL Annex VI regulations. It is important for ship operators to note that in order to comply with the new regulations, action needs to be taken now.

In order to prevent being caught off guard, it would be wise for shipowners and operators to begin the transition as soon as possible. As this limit applies to the fuel oil as it is actually used, it will be necessary to ensure that any fuel oil on board with sulphur content that exceeds 3.50% m/m has been fully consumed.

Most importantly, the maximum sulphur limit given in charter party bunker clauses or bunker nominations will need to be duly amended sufficiently in advance of the deadline in order to avoid ships being supplied with quantities of fuel oil about the 3.50% m/m limit which they will not be able to consume fully before the implementation date.

Since the 3.50% limit is not restricted to those delivering sulphur controlled fuel oil to be used in Emission Control Areas, all suppliers need to be mindful that they are prepared to supply fuel that is compliant with the new limits.

Even as suppliers work to ensure adequate supply of fuel that meets requirements, according to FOBAS data, 10-15% of bunkerings worldwide will be affected by this change. Due to the international nature of the petroleum industry, affected fuel will not be isolated to oil producing areas that are known for their high sulphur fuels.

It is worth noting that in accordance with MARPOL Annex VI requirements, it is the responsibility of receivers of fuel oils to ensure that all bunker delivery notes provided by suppliers correctly document the actual sulphur content and that the value does not exceed the maximum specified.

Leaving these necessary steps to the last minute could have costly consequences for ship operators who find that there is excess fuel in their tanks that does not meet requirements and needs to be blended or, in a worst-case scenario, de-bunkered. This is not to mention the potential penalties should they find themselves on the wrong side of regulations come the New Year.

Douglas Raitt,
2nd November 2011 06:32 GMT