MEPC 71 last week saw the adoption of new mandatory text to be included in the bunker delivery note (BDN) in the face of objections from the International Bunker Industry Association.
The new text amends the current supplier’s declaration to allow for supply of high sulphur fuel to ships equipped with abatement technology, and ships undertaking trials of such technology.
The new mandatory BDN text from the International Maritime Organization replaces the current supplier’s declaration and introduces a tick box system.
IBIA has identified problems with the new format that creates previously unforeseen issues with the preparation for, and transition to, the 0.5 per cent sulphur limit in 2020. A document highlighting these concerns was presented to MEPC 71 by IBIA’s IMO representative, Unni Einemo.
IBIA’s primary objection concerns periods when compliant fuel is not available in some ports. Should a ship without abatement technology be in a port where it cannot obtain compliant fuel, but needs fuel to reach its next port, the new BDN text will, in effect, prevent a supplier with available higher sulphur fuel from delivering that fuel to the ship because it requires the supplier to declare they were notified that the ship has a scrubber or a valid exemption while trialling abatement technology.
Another issue with the format is that, to comply with the 0.5 per cent sulphur limit with effect from 1 January 2020, ships will need to start buying compliant fuels in advance. The first tick box as drafted refers only to regulation 14.1 and hence it only guarantees the regulation limit value on the date of delivery, ie 3.5 per cent prior to 1 January 2020. This will render the document without any statutory value for ships preparing to comply with the 0.5 per cent limit prior to the deadline.
In a statement, the IBIA said: “The text approved at MEPC 70 was formally adopted, despite issues pointed out by IBIA. There was, however, some support for IBIA’s views and proposals and we sought clarifications on how the issues raised can be addressed in practice. We will advise our members accordingly.”