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2020 Sulphur update - outcome of the


The 74th session of the Marine Environment Protection Published:

Committee (MEPC 74) was held at IMO in London on 13–17 May 21 May 2019
2019. This was the last MEPC meeting before the 0.50% global
sulphur limit takes effect on 1 January 2020, and the focus was
on the implementation and completion of guidelines to help
stakeholders prepare and ensure consistent implementation. We
strongly recommend stakeholders to prepare in due course and
update plans according to the latest IMO guidance. This
statutory news contains a summary of sulphur-related resolutions
and circulars adopted at MEPC 74.

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Relevant for ship owners and managers, yards, flag states, design
offices as well as suppliers.
Res. MEPC.320(74) – 2019 Guidelines for consistent
implementation of the 0.50% sulphur limit under MARPOL
Annex VI

These guidelines are intended for use by Administrations, port

states, ship owners, ship builders, and fuel oil suppliers to ensure
consistent implementation. The following is addressed:

— Planning for 2020, encouraging the development of ship

implementation plans (SIP)
— Impact on fuel and machinery, covering characteristics and
challenges with different fuel oil types, technical
considerations for ship owners, ISO standard for residual fuels
and cylinder lubrication
— Verification issues and control mechanisms, including survey
and certification by administrations, control measures by port
states, control of fuel oil suppliers, and information sharing
— Fuel oil non-availability, including the FONAR (fuel oil non-
availability report) standard reporting format
— Possible safety implications related to fuel oils

Res. MEPC.321(74) – 2019 Guidelines for port state control

MARPOL Annex VI Chapter 3

These guidelines are meant to provide consistency in conducting

PSC inspections and to provide guidance to PSC officers on
verifying compli¬ance with the various requirements in MARPOL
Annex VI. With regards to sulphur, the guidelines have been
aligned with other IMO sulphur-related decisions and relevant
guidance, including:

— how to follow up a possible discrepancy between the sulphur

content on the bunker delivery note and independent test
results of commercial samples taken by the ship during
— a new appendix, providing guidance to PSC in the case that
non-availability of compliant fuel is claimed (FONAR);
— alternative arrangements in the case of EGCS (exhaust gas
cleaning system) temporary indication of ongoing compliance
in the case of failure of a single monitoring instrument;
— EGCS non-compliance; and
— the carriage ban for non-compliant fuel MEPC.305(73).

MEPC.1/Circ.795/Rev.4 – Unified Interpretations to MARPOL

Annex VI

This UI (interprets MARPOL Annex VI, Reg. 14.1) states that the
requirement that fuel oil used or carried for use on board a ship
not exceed 0.50% should also be applied to the fuel oil of
emergency equipment, e.g. lifeboats and emergency generators.

MEPC.1/Circ.864/Rev.1 2019 – Guidelines for on-board sampling

for the verification of the sulphur content of the fuel oil used on
board ships

Amendment imposing a new retroactive requirement for

designating, or if necessary fitting, sampling points to facilitate
taking the in-use sample was approved (MARPOL Annex VI,

Ships will be required to designate sampling points no later than

the first IAPP renewal survey that occurs 12 months or more after
the entry into force of the regulation, expected to be in 2021. The
2019 guidelines for on-board sampling describes how and where
the designated sampling points are to be fitted.

MEPC.1/Circ.881 – Notification on early application of the

verification procedures for a MARPOL Annex VI fuel oil sample
(Regulation 18.8.2 or 14.8)

Amendments to the verification procedures for MARPOL fuel oil

samples (MARPOL delivered sample, in-use and on-board
samples) were approved (Appendix VI of MARPOL Annex VI). The
purpose of the circular is to facilitate the use of the procedure
ahead of the entry into force of the amendments in 2021.

MEPC.1/Circ.882 – Guidance for port state control on

contingency measures for addressing non-compliant fuel oil

This guidance is meant to address how to deal with all possible

instances of non-compliant fuel oil, not only limited to FONAR
cases. The following contingency measures are to be considered
between ship and port state:

— Actions predetermined in the SIP (if available)

— Discharging non-compliant fuel oil to another ship to be
carried as cargo or to an appropriate ship-board or land-based
facility, if practicable and available
— Managing the non-compliant fuel oil in accordance with a
method acceptable to the port state
— Operational actions, such as modifying sailing or bunkering
schedules and/or retention of non-compliant fuel oil, on board
the ship. The port state and the ship should consider any safety
issues and avoid possible undue delays.

After the non-compliant fuel oil is completely used or discharged,

such actions should include the possibility of cleaning and/or
flushing through or dilution of remaining residues by using
compliant fuel oil with the lowest sulphur content available.

MEPC.1/Circ.883 – Guidance for best practices for member

states / coastal states

These best practices are intended to assist member states in

carrying out their responsibilities under MARPOL Annex VI, to
ensure effective implementation and enforcement without
creating any responsibilities beyond what is required in MARPOL.
The guidance notes that member states or other relevant
authorities desiring to do so may decide to establish or promote a
licensing scheme for bunker suppliers.

MEPC.1/Circ.884 – Guidance on indication of ongoing

compliance in the case of the failure of a single monitoring
instrument, and recommended actions to take if the EGCS fails to
meet the provisions of the 2015 EGCS guidelines

This guidance is meant for ship operators, port states and

Administrations on how to address scrubber malfunction, short-
term exceedances or interim indications of ongoing compliance
in the case of sensor failure.

A system malfunction that cannot be rectified is regarded as an

accidental breakdown. The ship should then changeover to
compliant fuel oil if the EGCS cannot be put back into a compliant
condition within one hour. If the ship does not have compliant
fuel oil or a sufficient amount of compliant fuel oil on board, a
proposed course of action, in order to bunker compliant fuel oil
or carry out repair works, should be communicated to the relevant
authorities, including the ship’s administration, for their

A short-term temporary emission exceedance, typically due to the

EGCS dynamic response when there is a sudden change in the
exhaust gas flow rate to the EGCS, may not necessarily mean
exceedance of emissions and should therefore not be considered
as a breach of the requirements. The typical operating conditions
that may result in a short-term temporary emission exceedance
should be specified by the EGCS manufacturer in the EGCS
Technical Manual that is approved at the time the EGCS is
Interim indication of ongoing compliance in the case of sensor
failure. All parameters monitored (SO2, CO2, pH, PAH and
turbidity) are in a certain interrelation when running on a fuel with
a given sulphur level at a constant wash water / engine load ratio.
If a single sensor signal starts to deviate and where the other
parameters are continuing at normal levels may be an indication
that the there is only an instrumentation malfunction rather than
non-compliance. In such cases, the ship should keep records of
interim indication for demonstrating compliance. This concludes
the IMO delivery to ensure consistent implementation of the
0.50% sulphur limit on fuel oil.

Documents previously issued include:

— MEPC.1/Circ.875 – Guidance on best practices for fuel oil

purchasers/users for assuring the quality of fuel oil used on
board ships
— MEPC.1/Circ.875/Add.1 – Guidance on best practices for fuel
oil suppliers for assuring the quality of fuel oil delivered to
— MEPC.1/Circ.878 – Guidance on the development of a ship
implementation plan for the consistent implementation of the
0.50% sulphur limit under MARPOL Annex VI
— MEPC.1/Circ.880 – Reporting of availability of compliant fuel
oils in accordance with Regulation 18.1 of MARPOL Annex VI

Relevant IMO documents can be found on DNV GL´s Global

Sulphur Cap 2020 web page.

With seven months to go until the global 0.50% sulphur cap is in
force, planning is essential. If not done already, we strongly
recommend to develop a ship implementation plan (SIP) to
ensure compliance on 1 January 2020 and as documentation for
PCS. If you already have a SIP, you may consider updating it to
capture the contingency measures and FONAR procedures as
described above. DNV GL has prepared a web-based application
for the SIP: a user-friendly, step-by-step tool for ship owners and
managers to prepare their ship-specific implementation plans.
The SIP application is free of charge and accessible via the
Veracity data platform.
— Global Sulphur Cap 2020 web page from DNV GL
— Ship Implementation Plan on Veracity marketplace
— WEBINAR 23 May: Global Sulphur Cap 2020 - be prepared for
compliance. Register now

— For customers: DATE – Direct Access to Technical Experts via
My Services on Veracity
— Otherwise: Use our office locator to find the nearest DNV GL

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