A bureaucratic approach to vessel operation
08 Jan 2019by Craig Jallal
This week’s comment concerns the array of regulations coming into force in 2019 in a year when management time and energy will be spent preparing the IMO 2020 global sulphur cap strategy
Running ships is less about the smell of the sea and more about ticking boxes
My comment this week is that for many owners and operators, 2019 will mark another step toward the tanker business being a bureaucracy with a bit of cargo carrying on the side. For many operators the concentration of management energy in 2019 will be on creating and implementing an IMO 2020 global sulphur cap compliance strategy.
In that respect, team Riviera can provide the information you require though our forthcoming conferences:
But the IMO 2020 global sulphur cap is not the only regulatory issue. In fact, six other major regulations came into force on 1 January 2019 or will do so during the year. Not all apply to tankers, but some will have an impact on how ships are operated from that date forward:
- Early adoption of IMO 2020 global sulphur cap. I doubt few tanker operators saw this one coming, but Taiwan, Hong Kong and China have instituted a version of the sulphur cap in some form in their waters.
- EU ship recycling regulations. I and others have reservations concerning the practical implementation of this new ruling, which subscribes that EU-flag vessels must be scrapped at a shipyard on the EU list. So far, no recycling yards in Asia have been included on the list. Until an India recycling yard is added to the list it is impractical as far as the large tanker sector is concerned.
- 2019 changes to the bunker delivery note. Under Marpol Annex VI (Appendix V) a revised bunker delivery note came into force that includes an amended declaration on the sulphur content of the fuel delivered the “purchaser’s specified limit value” which will be applicable if the vessel is fitted with exhaust gas cleaning systems (scrubbers). According to some, this system could be open to abuse.
- IMO data collection system. From the start of this year, all vessels of 5,000 gt and greater must start collecting data using the methodology described in Part II of the vessel’s SEEMP (Ship Energy Efficiency Management Plan). In the past, this was seen as conflicting with the EU’s attempts to compile the same data.
- The 2019 amendments to the International Maritime Solid Bulk Cargoes (IMSBC) code only pertain to vessels carrying coal and iron ore fines. However, this will impact the operations of a diversified fleet and is yet another regulation that needs careful attention.
- Ships built before 8 September 2017 and not fitted with a ballast water treatment system must comply by the first International Oil Pollution Prevention (IOPP) certificate renewal after 8 September 2019. According to the trade body BEMA, you may be too late to have a system fitted in time.
Sadly, this list is by no means complete. So, while the industry’s focus is on 2020 and the IMO global sulphur cap, the chances are that in 2019 you may already behind schedule on meeting other regulatory requirements.
Have a nice 2019.