DNV GL has published an advice sheet for shipowners and managers regarding the carriage of non-compliant fuel due to delays in scrubber installation as a result of the Coronavirus.
From 1 March 2020, high sulphur fuel oil (HSFO) cannot be carried in ships’ fuel oil tanks unless the vessel is fitted with scrubber to reduce sulphur oxides (SOx), unless another approved arrangement has been made.
However, DNV GL states that due to the COVID-19 crisis, there are some vessels where the installation of the scrubber was not completed before the March deadline as planned, and therefore these vessels still have HSFO in their bunker tanks.
There is currently no general procedure in place that covers how to deal with ships that are in dry-dock for scrubber installations and still have HSFO onboard. According to DNV GL, the IMO does not consider COVID-19 to fall under force majeure, meaning that vessels carrying fuel above the permitted 0.5 per cent sulphur content are in breach of the MARPOL Annex VI requirement.
DNV GL recommends shipowners and managers act in a proactive, transparent and cooperative matter towards the authorities as enforcement falls to the port state.
DNV GL’s advice to meet the requirements set by MARPOL include sealing off the inlet and outlet valves of the tank containing the non-compliant fuel, noting the seal numbers and tank sounding in the oil record book (ORB) under “Additional operational procedures and general remarks”, all witnessed and endorsed by a DNV GL surveyor.
DNV GL states that, ‘if your vessel has HSFO onboard due to a delay in EGCS installation, it is vitally important to proactively contact PSC and inform them of the situation. Be transparent and cooperative to implement any required contingency measures with the acceptance of PSC and the flag.’
Read DNV GL’s advice on Sulphur Cap 2020 – carriage of non-compliant fuel due to delays in scrubber installation here.