Annex 2019 Guidelines Marpol 6 Sulphur Guide

Annex - 2019 Guidelines for Consistent Implementation of the 0.50% Sulphur Limit unde...
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Lloyd's Register Rulefinder 2022 - Version 9.36
Statutory Documents - IMO Publications and Documents - Resolutions - Marine Environment Protection Committee
- Resolution MEPC.320(74) - 2019 Guidelines for Consistent Implementation of the 0.50% Sulphur Limit under
MARPOL Annex VI - (adopted on 17 May 2019) - Annex - 2019 Guidelines for Consistent Implementation of the
0.50% Sulphur Limit under MARPOL Annex VI
Annex - 2019 Guidelines for Consistent Implementation of the

0.50% Sulphur Limit under MARPOL Annex VI
1 Introduction
1.1 Objective
1.1.1 The purpose of these Guidelines is to ensure consistent implementation of the 0.50% sulphur limit
under MARPOL Annex VI. These Guidelines are intended for use by Administrations, port States,
shipowners, shipbuilders and fuel oil suppliers, as appropriate.
1.2 Definitions
1.2.1 For the purpose of these Guidelines, the definitions in MARPOL Annex VI apply.
1.2.2 The following definitions of fuel oils are used, as applicable:
.1 Distillate marine fuels (DM) are as specified in ISO 8217:2017footnote (e.g. DMA, DMB, DMX,
DMZ);
.2 Residual marine fuels (RM) are as specified in ISO 8217:2017footnote (e.g. RMD 80, RMG 380);
.3 Ultra-low sulphur fuel oil (ULSFO) are as specified in ISO 8217:2017footnote (e.g. maximum
0.10% S ULSFO-DM, maximum 0.10% S ULSFO-RM);
.4 Very low sulphur fuel oil (VLSFO) (e.g. maximum 0.50% S VLSFO-DM, maximum 0.50% S
VLSFO-RM); and
.5 High sulphur heavy fuel oil (HSHFO) exceeding 0.50% S.
2 Ship implementation planning for 2020
2.1 MEPC 70 agreed to "1 January 2020" as the effective date of implementation for ships to comply with
the 0.50% m/m fuel oil sulphur content limit requirement and adopted resolution MEPC.280(70) on the
Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VIfootnote.
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2.2 In this context, MEPC 73 agreed that Administrations should encourage ships flying their flag to
develop implementation plans, outlining how the ship may prepare in order to comply with the required
sulphur content limit of 0.50% by 1 January 2020. The plan should be complemented with a record of
actions taken by the ships in order to be compliant by the applicable date.
2.3 MEPC 73, recognizing the need for guidance to support the consistent implementation of the 0.50%
sulphur limit under MARPOL Annex VI, approved MEPC.1/Circ.878 on the Guidance on the development
of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL
Annex VI.
3 Impact on fuel and machinery systems
3.0.1 The experiences and lessons learned from the transition to the 0.10% m/m SOX-ECA limit indicated
that current ship machinery operations should be sufficiently capable of addressing the concerns
regarding combustion of the new 0.50% m/m limit fuel oils.
3.0.2 Currently most of the marine diesel engines and boilers on ships operating outside Emission Control
Areas (ECAs) are optimized to operate on heavy fuel oil. From 2020 ships are required to use fuel oils
with a sulphur content of 0.50% m/m or lower, unless fitted with an approved equivalent means of
compliance.
3.1 Distillate fuels
3.1.1 A major challenge with distillate fuels is low viscosity. Low viscosity may cause internal leakages in
diesel engines, boilers and pumps. Internal leakages in fuel injection system may result in reduced fuel
pressure to the engine, which may have consequences for the engine performance (e.g. starting of the
engine). Equipment makers recommendations should be taken into account, and adequate testing,
maintenance and possible installation of coolers, etc. may be performed.
3.1.2 Cold Filter Plugging Points (CFPP) and Cloud Points (CP) as well as the Pour Point (PP) for distillate
fuels need to be considered in light of the ship's intended operating area and ambient temperatures.
3.1.3 These issues are critical concerns as they can result in the formation and accumulation of wax
sediment, which can cause costly and avoidable maintenance. In the worst-case scenario, sediment can
cause engine fuel starvation and power loss.
3.1.4 ISO 8217:2017footnote limits the cold flow properties of a fuel through setting a limit on the PP.
However, given that wax crystals form at temperatures above the PP, fuels that meet the specification in
terms of PP can still be challenging to operations in colder operating regions, as the wax particles can
rapidly block filters, potentially plugging them completely. For cold weather, additional cold flow properties,
CFPP and CP, should be reported by the supplier when the receiving ship has ordered distillate fuel for
cold weather operations, a requirement that is specified in ISO 8217:2017footnote.
3.1.5 Since the residual fuels are usually heated and distillate fuels are not heated, particular attention
needs to be given to the cold flow properties of distillates. Cold flow property challenges can be managed
by heating the fuel. CIMAC has issued "01 2015 CIMAC Guideline Cold flow properties of marine fuel
oils"footnote.
3.1.6 Fuel temperature should be kept approximately 10°C above the PP in order to avoid any risk of
solidification, however this may not reduce the risk of filter blocking in case of high CFPP and CP.
3.1.7 It is good practice to review the possibilities of heating arrangements for distillate fuels on board.
This is usually very limited, as it is not standard practice to have heating arrangements in distillate
storage, settling or service tanks. Transfer arrangements may be adapted to pass through a residual fuel
oil heat exchanger should the need arise.
3.1.8 Knowing the fuel properties before bunkering will assist in taking the necessary precautions where
and when necessary. If the ship is heading towards colder climates and the cold flow properties are
inferior, the fuel may be:
.1 either used before entering cold regions, or
.2 used with suitable heating arrangement, as mentioned above.
3.1.9 If the approach of applying heat is being followed it should be ensured that the fuel is not overheated
resulting in the viscosity dropping below the minimum recommendation of 2 cSt at any point in the fuel
system, including the engine inlet. In order to reduce this risk, heating should be limited to max 40°C.
3.2 Distillate fuel with FAME content
3.2.1 Increased demand for Distillate fuels may result in more land-based products making their way into
the marine supply pool, some of these fuels (e.g. biodiesel) may contain Fatty Acid Methyl Ester (FAME).
3.2.2 There are various technical challenges associated with use of fuel having FAME content, e.g.
potential oxidation of biodiesel, its biodegradable nature, etc. with adverse implications, limitations in
storage life, etc. It also needs to be tested for stability.
3.2.3 The ISO 8217:2017footnote standard includes a maximum FAME content of 7.0% by volume for
DFA/DFZ/DFB fuel oil grades since some ports may offer automotive diesel fuel as the only fuel available,
which contains FAME and could violate the fuel flashpoint requirements addressed in SOLAS chapter II-2.
The maximum 7.0% (v/v) has been chosen as this aligns with the concentrations allowed in some of the
countries applying environmental regulations.
3.2.4 Manufacturers of engines and equipment like oily water separators, overboard discharge monitors,
filters, coalescers, etc. need to be consulted to confirm the ability of engines and equipment to handle
biodiesel blends of up to B7 (i.e. 7.0% v/v).
3.2.5 It is recommended to avoid using such biodiesel blend fuels for lifeboat engines, emergency
generators, fire pumps, etc. where it is stored in isolated individual unit fuel tanks and subjected to
conditions for accelerated degradation.
3.2.6 CIMAC has provided a Guideline for Shipowners and Operators on Managing Distillate Fuels up to
7.0% v/v Fame (Biodiesel).footnote
3.3 Residual fuels
3.3.1 Stability and compatibility
3.3.1.1 It is essential to distinguish between "Fuel stability" within a single batch of fuel and "Fuel
compatibility" between different fuel batches.
3.3.1.2 Regarding stability: the fuel shall be stable and homogeneous at delivery and it is the responsibility
of the fuel oil blenders and suppliers to ensure this.
3.3.1.3 A wide range of blends of refined products will be used to make the new 0.50% sulphur fuels, and
the stability and compatibility of the blends will be an important concern for shipowners/operators.
Unstable fuels can separate on their own and incompatible ones can do so when mixed in a single bunker
tank, forming sludge that can block filters and ultimately cause engine failures.
3.3.1.4 It is recommended that ships have a commingling procedure. The procedure should primarily aim
to ensure new bunkers are loaded into empty tanks to the extent possible. In the event that a ship finds
itself possibly having to commingle a new bunker with bunkers already on board, then it is important that
the ship determines the compatibility between the two said bunkers before comingling.
3.3.1.5 The reference test method shall be the total potential sediment test in accordance with ISO 10307-
2:2009.
3.3.2 Catalytic fines (cat fines)
3.3.2.1 Cat fines are a by-product of refining and consist of small particles of metal that are deliberately
introduced as catalysts to "crack" the fuel oil. Unless reduced by purification, cat fines will become
embedded in engine parts and cause serious and rapid engine damage. Reference should be made to
engine manufacturer's guidance with respect to managing cat fines.
3.4 Key technical considerations for shipowners and operators
3.4.1 Ship tank configuration and fuel system – the viscosity of most of these blended residual fuels is
such that they cannot be used in distillate fuel-only systems and machinery, as they require heating for
cleaning and combustion. A fully segregated fuel system for both distillate fuels and these new fuels is
recommended.
3.4.2 Tank cleaning is recommended when using a residual fuel tank for storing these new fuels. This is to
prevent sludge that has built up in these tanks from entering the fuel system. Further information on tank
cleaning is set out in appendix 3 of MEPC.1/Circ.878 on Guidance on the development of a ship
implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex
VI.
3.4.3 Heating requirements – due to the cold flow properties of most of these new fuels, permanent
heating of the fuel may be necessary to minimize the risk of wax formation, also in storage. This is
especially important in colder regions.
3.4.4 Fuel treatment system – Some of these new fuels may contain cat fines and/or sediments and
therefore need onboard cleaning. Separator temperature and settings should be adjusted to the fuels'
viscosity and density. Please refer to recommendations from OEM and fuel supplier.
3.4.5 Considering that many of these new fuels have lower viscosities compared to conventional residual
fuels, care should be taken to ensure no overheating occurs.
3.5 ISO Standard for residual fuels
3.5.1 The bunker market uses ISO 8217:2017footnote specifications to ensure that the properties of the
fuels it delivers conform to a standard that mean they comply with MARPOL Annex VI.
3.5.2 The existing ISO 8217:2017footnote specification for marine fuels takes into consideration the diverse
nature of marine fuels and incorporates a number of categories of distillate or residual fuels, even though
not all categories may be available in every supply location it covers all marine petroleum fuel oils used
today as well as the 0.50% Sulphur fuels of 2020. The General requirements, in the ISO 8217:2017footnote
specification for marine fuels and characteristics, included in table 1 and 2 of ISO 8217:2017footnote
identified safety, performance and environmental concerns and further takes into consideration the
onboard handling requirements, including storage, cleaning and combustion aspects of all fuel oils used
today and the anticipated fuel blends of 2020, irrespective of the sulphur content of the fuel oils.
3.5.3 It is important that any new standards address and do not preclude the use of renewable and
alternative non-fossil crude derived products, so long as they comply with the chemical properties
specified for these fuel oils.
3.6 Cylinder lubrication
3.6.1 The choice of cylinder lubricating oils will often follow the fuel type in use. Therefore, when changing
to VLSFO operation from RM operation the choice of appropriate cylinder lubricating oil should be
considered in accordance with the recommendations of the engine manufacturer.
4 Verification issues and control mechanism and actions
4.1 Survey and certification by Administrations
4.1.1 When undertaking a survey in accordance with regulation 5 of MARPOL Annex VI, the
Administration should conduct a survey of a ship to verify that the ship complies with the provisions to
implement the 0.50% sulphur limit. In particular, the Administration should check whether the ship carries
compliant fuel oils for use, based on the Bunker Delivery Note (BDN) on board, any other document or fuel
oil samples as appropriate consistent with the provisions of regulation 18 of MARPOL Annex VI. If carriage
of HSHFO for use is identified, the Administration should check whether regulation 3.2, regulation 4 of
MARPOL Annex VI are applied to the ship, or if the ship encountered a fuel availability problem and is
operating pursuant to regulation 18.2 of MARPOL Annex VI.
4.1.2 When an Administration decides to analyse a fuel oil sample to determine compliance with the
sulphur limits in regulation 14.1 or 14.4, the final analysis should be carried out in accordance with ISO
8754:2003 by a laboratory that is accredited for the purpose of conducting the test in accordance with
ISO/IEC 17025 or an equivalent standard. The test results should be in accordance with ISO 8754
reporting protocol, meaning a tested value at or above 0.10% sulphur should be reported with no more
than two decimal places.
4.1.3 According to regulation 11.4 of MARPOL Annex VI, the Administration shall investigate any report of
an alleged violation and thereafter promptly inform the Party which made the report, as well as the
Organization, of the action taken. When informing the Organization, the MARPOL Annex VI GISIS module
should be used.
4.2 Control measures by port States
4.2.1 Port States should take appropriate measures to ensure compliance with the 0.50% of sulphur limit
under MARPOL Annex VI, in line with the regulation 10 of MARPOL Annex VI and the 2019 Guidelines for
port State control under MARPOL Annex VI (resolution MEPC.[…](74)) (2019 PSC Guidelines).
Specifically, the port State should conduct initial inspections based on documents and other possible
materials, including remote sensing and portable devices. Given "clear grounds" to conduct a more
detailed inspection, the port State may conduct sample analysis and other detailed inspections to verify
compliance to the regulation, as appropriate.
4.2.2 Regulation 18.2.3 of MARPOL Annex VI requires a Party to take into account all relevant
circumstances and the evidence presented to determine the action to take, including not taking control
measures. Administrations and port State control authorities may take into account the implementation
plan when verifying compliance with the 0.50% sulphur limit requirement.
4.2.3 Inspections based on documents and other possible targeting measurements
4.2.3.1 During the port State control and other enforcement activities, the port State should investigate
whether a ship carries either compliant fuel oils or HSHFOs for use, based on the documents listed in
paragraph 2.1.2 of the 2019 PSC Guidelines additionally records required to demonstrate compliance
should also then be viewed. Results from remote sensing could be used to trigger inspections and
portable devices could be used during the initial inspections, as appropriate. Remote sensing and portable
devices are, however, of indicative nature and should not be regarded as the evidence of non-compliance
but may be considered clear grounds for expanding the inspection.
4.2.3.2 Port state should determine if regulations 3.2, 4 or 18.2.3 apply together with retained bunker
delivery notes and IAPP Certificate when considering the status of any HSHFO being carried for use on
board.
4.2.4 Fuel oil sample analysis
4.2.4.1 When the port State identifies clear grounds of suspected non-compliance of a ship based on
initial inspections, the port State may require samples of fuel oils to be analysed. The samples to be
analysed may be either the representative samples provided with BDN in accordance with regulation
18.8.2, MARPOL delivered samples or samples from designated sampling points in accordance with the
2019 Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on
board ships (MEPC.1/Circ.864/Rev.1) (in-use fuel oil samples) or other samples obtained by the port
State.
4.2.4.2 Where the MARPOL delivered sample is taken from the ship a receipt should be provided to the
ship. The outcome of the analysis undertaken with appendix VI of MARPOL Annex VI should be advised
to the ship for its records.
4.2.4.3 In detecting suspected non-compliance, the sample analysis should be conducted in a uniform
and reliable manner as described in paragraph 4.1.2. The verification procedure for MARPOL delivered
samples should be in accordance with appendix VIfootnote of MARPOL Annex VI. For other samples taken
on board the ship, the in-use and onboard sample, the sample should be deemed to meet the
requirements provided the test result from the laboratory does not exceed the specification limit +0.59R
(where R is the reproducibility of the test method) and no further testing is necessary.
4.2.4.4 Notwithstanding the above process, all possible efforts should be made to avoid a ship being
unduly detained or delayed. In particular, sample analysis of fuel oils should not unduly delay the
operation, movement or departure of the ship.
4.2.4.5 If a non-compliance is established, consistent with regulation 18.2.3 the port State may prevent
the ship from sailing until the ship takes any suitable measures to achieve compliance which may include
de-bunkering all non-compliant fuel oil. In addition, the port State should report the information of the ship
using or carrying for use non-compliant fuel oil to the Administration of the ship and inform the Party or
non-Party under whose jurisdiction a bunker delivery note was issued of cases of delivery of non-
compliant fuel oil, giving all relevant information. Upon receiving the information, the Party detecting the
deficiency should report the information to the MARPOL Annex VI GISIS module in accordance with
paragraph 3.4 of these Guidelines.
4.2.4.6 The Parties (the port and flag States); however, may permit, with the agreement of the destination
port authority, a single voyage for bunkering of compliant fuel oil for the ship, in accordance with
regulation 18.2.4 of MARPOL Annex VI. The single voyage should be one way and minimum for
bunkering, and the ship proceeds directly to the nearest bunkering facility appropriate to the ship. In the
case that the parties permit a single voyage of a ship, the port State should confirm that the Administration
of the ship has advised the authority at the destination port of the approval for a single voyage including
information on the ship granted with the approval and the certified record of analysis of the sample as the
evidence. Once confirmation has been provided the port State should permit the ship to sail as agreed.
4.2.4.7 If the port State is made aware that a ship is carrying non-compliant fuel oil, which is not for use
through an equivalent method under regulation 4 or a permit under regulation 3.2 of MARPOL Annex VI,
the port State should take action to confirm the fuel is not being used. Action to confirm should include but
is not limited to the examination of the oil record book and the record of tank soundings. Where necessary
the port State may require tank soundings to be undertaken during the inspection. Where it is determined
that the fuel has been used the control action in paragraph 4.2.4.5 should be applied.
4.2.5 Other open-sea compliance monitoring tools:
.1 fuel oil changeover calculator;
.2 data collection system for fuel oil consumption of ships (resolution MEPC.278(70)); and
.3 continuous SOX monitoring.
4.3 Control on fuel oil suppliers
4.3.1 Designated authorities should, if deemed necessary, take a sample and test fuel oils from bunker
barges or shore bunker terminals. Sampling of fuel oils in bunker barges or shore bunker terminals can be
taken and tested in the same manner that the MARPOL delivered fuel oils are tested by the PSC. All
possible efforts should be made to avoid a ship being unduly detained or delayed. If a sample is analysed,
sample analysis of fuel oils should not unduly delay the operation, movement or departure of the ship.
4.3.2 If non-compliance, such as issuance of an incorrect BDN or a BDN without measurement of sulphur
content, was found, the designated authorities should take appropriate corrective measures against the
non-compliant supplier. In such case, the designated authorities should inform the Organization for
transmission to the Member States of the non-compliant supplier, in accordance with the regulation 18.9.6
of MARPOL Annex VI and paragraph 4.4 of these Guidelines.
4.4 Information sharing related to non-compliances under MARPOL Annex VI
4.4.1 When a Party finds a non-compliance of a ship or a fuel oil supplier, the information of the non-
compliance should be reported to the MARPOL Annex VI GISIS module (regulation 11.4).
4.4.2 Publication of information on non-compliant ships/fuel oil suppliers or a reporting scheme to IMO to
be registered on centralized information platforms are proposed as elements of an effective enforcement
strategy. Various PSC regimes have successfully used the publishing of information related to
substandard ships/fuel suppliers as a deterrent to non-compliance. Port States also need to report
detentions of ships to IMO which may affect the future PSC targeting of the ship. The IMO GISIS
database already makes available certain information related to non-compliances with the MARPOL
Annex VI regulations.
5 Fuel oil non-availability
5.1 Guidance and information sharing on fuel oil non-availability
5.1.1 Regulation 18.2.1 of MARPOL Annex VI provides that in the event compliant fuel oil cannot be
obtained, a Party to MARPOL Annex VI can request evidence outlining the attempts made to obtain the
compliant fuel oil, including attempts made to local alternative sources. Regulations 18.2.4 and 18.2.5
then require that the ship notifies its Administration and the competent authority of the port of destination
on the inability to obtain compliant fuel oil, with the Party to notify IMO of the non-availability. This
notification is commonly referred to as a Fuel Oil Non-Availability Report (FONAR).
5.1.2 Guidance on consistent evidence
5.1.3 Regulation 18.2.1.2 of MARPOL Annex VI requires that evidence be provided to support a claim that
all efforts were made to obtain compliant fuel oil. In this regard, a Party may develop more detailed
guidance for the consistent use and acceptance of these reports, including what evidence is needed to
accompany a report to ensure that port States are applying the provisions under regulation 18.2.3,
consistently.
5.1.4 Should a ship, despite its best effort to obtain compliant fuel oil, be unable to do so, the
master/company must:
.1 present a record of actions taken to attempt to bunker correct fuel oil and provide evidence of an
attempt to purchase compliant fuel oil in accordance with its voyage plan and, if it was not made
available where planned, that attempts were made to locate alternative sources for such fuel oil and
that despite best efforts to obtain compliant fuel oil, no such fuel oil was made available for
purchase; and
.2 best efforts to procure compliant fuel oil include, but are not limited to, investigating alternate
sources of fuel oil prior to commencing the voyage. If, despite best efforts, it was not possible to
procure compliant fuel oil, the master/Company must immediately notify the port State
Administration in the port of arrival and the flag Administration (regulation 18.2.4 of MARPOL
Annex VI).
5.1.5 In order to minimize disruption to commerce and avoid delays, the master/company should submit a
Annex - 2019 Guidelines for Consistent Implementation of the 0.50% Sulphur Limit un... Page 10 of 20
FONAR as soon as it is determined or becomes aware that it will not be able to procure and use
compliant fuel oil.
5.1.6 Investigating non-availability
5.1.7 A Party should investigate the reports of non-availability. This process is important to ensure a
consistent supply of compliant fuel to industry, as well as prevent incentives for ships to use ports where it
is known that compliant fuel is not available on an ongoing basis. Critical to this process will be the
sharing of information between Member States on reported compliant fuel oil supply issues.
5.1.8 Regulation 18.2.5 of MARPOL Annex VI provides that a Party to MARPOL Annex VI notify the
Organization when a ship has presented evidence of the non-availability of compliant fuel oil in a port or at
their terminal. For this purpose, MARPOL Annex VI GISIS module provides the platform for Parties to
upload such notifications.
5.1.9 Regulation 18.1 of MARPOL Annex VI provides that each Party take all reasonable steps to promote
the availability of above compliant fuel oil and inform the Organization through MARPOL Annex VI GISIS
module of the availability of compliant fuel oils in its ports and terminals.
5.1.10 Port State control authority may contact the submitter (and/or shipowner or operator), including in
the event of an incomplete submission, and request additional information, or to pursue an enforcement
action such as a Notice of Violation.
5.2 Standard format for reporting fuel oil non-availability
5.2.1 For ships which are unable to purchase fuel oil meeting the requirements of regulations 14.1 or 14.4
of MARPOL Annex VI, the standard format for reporting fuel oil non-availability is set out in appendix 1 to
this document, pursuant to regulation 18.2.4 of MARPOL Annex VI.
6 Possible safety implications relating to fuel oils meeting the 0.50% m/m sulphur limit
6.1 MEPC 73 (October 2018) approved MEPC.1/Circ.878 on Guidance on the development of a ship
implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex
VI (hereafter the "Ship Implementation Plan Guidance") addresses some safety issues identified with
regard to 0.50% maximum sulphur fuel oil, in particular through the section on risk assessment (section 1
of the Ship Implementation Plan Guidance) and additional guidance provided on impact on machinery
systems and tank cleaning (appendix 2 and appendix 3 of the Ship Implementation Plan Guidance,
respectively).
6.2 Identified potential safety implications include, but are not limited to, the following:
.1 stability of blended fuel oil;
.2 compatibility, including new tests and metrics appropriate for future fuels;
.3 cold flow properties;
.4 acid number;
.5 flash point;
.6 ignition and combustion quality;
.7 cat fines;
.8 low viscosity; and
.9 unusual components.
6.3 Additional technical information and a review, displayed in tabular format, of the possible potential
safety implications is set out in appendix 2.
6.4 Reference should also be made to general industry guidance on potential safety and operational
issues related to the supply and use of 0.50% maximum sulphur fuelsfootnote.
APPENDIX 1
FUEL OIL NON-AVAILABILITY REPORT (FONAR)
Note:
1 This report is to be sent to the flag Administration and to the competent authorities in the relevant port(s)
of destination in accordance with regulation 18.2.4 of MARPOL Annex VI. The report shall be sent as
soon as it is determined that the ship/operator will be unable to procure compliant fuel oil and preferably
before the ship leaves the port/terminal where compliant fuel cannot be obtained. A copy of the FONAR
should be kept on board for inspection for at least 36 months.
2 This report should be used to provide evidence if a ship is unable to obtain fuel oil compliant with the
provisions stipulated in regulations 14.1 or 14.4 of MARPOL Annex VI.
3 Before filing a FONAR, the following should be observed by the ship/operator:
3.1 A fuel oil non-availability report is not an exemption. According to regulation 18.2 of MARPOL Annex
VI, it is the responsibility of the Party of the destination port, through its competent authority, to scrutinize
the information provided and take action, as appropriate.
3.2 In the case of insufficiently supported and/or repeated claims of non-availability, the Party may require
additional documentation and substantiation of fuel oil non-availability claims. The ship/operator may also
be subject to more extensive inspections or examinations while in port.
3.3 Ships/operators are expected to take into account logistical conditions and/or terminal/port policies
when planning bunkering, including but not limited to having to change berth or anchor within a port or
terminal in order to obtain compliant fuel.
3.4 Ships/operators are expected to prepare as far as reasonably practicable to be able to operate on
compliant fuel oils. This could include, but is not limited to, fuel oils with different viscosity and different
sulphur content not exceeding regulatory requirements (requiring different lube oils) as well as requiring
heating and/or other treatment on board.
1 Particulars of ship
1.1 Name of ship: _______________________________________________________
1.2 IMO number: ________________________________________________________
1.3 Flag: ______________________________________________________________
1.4 (if other relevant registration number is available, enter here): __________________
2 Description of ship's voyage plan
2.1 Provide a description of the ship's voyage plan in place at the time of entry into "country X" waters
(and ECA, if applicable) (Attach copy of plan if available):
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
2.2 Details of voyage:
1 – Last port of departure
___________________________________________________________________
2 – First port of arrival in "country X":
___________________________________________________________________
3 – Date of departure from last port (dd-mm-yyyy):
___________________________________________________________________
4 – Date of arrival at first "country X" (dd-mm-yyyy):
___________________________________________________________________
5 – Date ship first received notice that it would be transiting in "country X" waters (and ECA, if
applicable) (dd-mm-yyyy):
___________________________________________________________________
6 – Ship's location at the time of notice:
___________________________________________________________________
7 – Date ship operator expects to enter "country X" waters (and ECA, if applicable) (dd-mm-yyyy):
__________________________________________________________________
8 – Time ship operator expects to enter "country X" waters (and ECA, if applicable) (hh:mm UTC):
__________________________________________________________________
9 – Date ship operator expects to exit "country X" waters (and ECA, if applicable) (dd-mm-yyyy):
__________________________________________________________________
10 – Time ship operator expects to exit "country X" waters (and ECA, if applicable) (hh:mm UTC):
__________________________________________________________________
11 – Projected days ship's main propulsion engines will be in operation within "country X" waters
(and ECA, if applicable):
___________________________________________________________________
12 – Sulphur content of fuel oil in use when entering and operating in "country X" waters (and ECA,
if applicable):
__________________________________________________________________
3 Evidence of attempts to purchase compliant fuel oil
3.1 Provide a description of actions taken to attempt to achieve compliance prior to entering "country X"
waters (and ECA, if applicable), including a description of all attempts that were made to locate alternative
sources of compliant fuel oil, and a description of the reason why compliant fuel oil was not available:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
3.2 Name and email address of suppliers contacted, address and phone number and date of contact (dd-
mm-yyyy):
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
Please attach copies of communication with suppliers (e.g. emails to and from suppliers)
4 In case of fuel oil supply disruption only
4.1 Name of port at which ship was scheduled to receive compliant fuel oil:
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
___________________________________________________________________
4.2 Name, email address, and phone number of the fuel oil supplier that was scheduled to deliver (and
now reporting the non-availability): ___________________________
5 Operation constraints, if applicable
5.1 If non-compliant fuel has been bunkered due to concerns that the quality of the compliant fuel
available would cause operational or safety problems on board the ships, the concerns should be
thoroughly documented.
5.2 Describe any operational constraints that prevented use of compliant fuel oil available at port:
__________________________________________________________________________
5.3 Specify steps taken, or to be taken, to resolve these operational constraints that will enable compliant
fuel use: __________________________________________________________________________
6 Plans to obtain compliant fuel oil
6.1 Describe availability of compliant fuel oil at the first port-of-call in "country X", and plans to obtain it:
__________________________________________________________________________
6.2 If compliant fuel oil is not available at the first port-of-call in "country X", list the lowest sulphur content
of available fuel oil(s) or the lowest sulphur content of available fuel oil at the next port-of-call:
__________________________________________________________________________
7 Previous Fuel Oil Non-Availability Reports
7.1 If shipowner/operator has submitted a Fuel Oil Non-Availability Report to "country X" in the previous
12 months, list the number of Fuel Oil Non-Availability Reports previously submitted and provide details
on the dates and ports visited while using non-compliant fuel oil, as set out below:
Report: ___________________________________________________________________
Date (dd-mm-yyyy): _________________________________________________________
Port: _____________________________________________________________________
Type of fuel: _______________________________________________________________
Comments: ________________________________________________________________
8 Master/Company information
Master name: ______________________________________________________________
Local agent in "country X": ____________________________________________________
Ship operator name: _________________________________________________________
Shipowner name: ___________________________________________________________
Name and position of official: __________________ ________________________________
Email address: _____________________________________________________________
Address (street, city, country, postal/zip code): ____________________________________
Telephone number: _________________________________________________________
Signature of Master: _________________________________________________________
Print name: ________________________________________________________________
Date (DD/MM/YYYY): ________________________________________________________
APPENDIX 2
TECHNICAL REVIEW OF IDENTIFIED POTENTIAL SAFETY IMPLICATIONS ASSOCIATED WITH

THE USE OF 2020 COMPLIANT FUELS
Fuel Property Potential Challenges Remarks
Stability The consequences of a ship receiving an The challenge for the fuel producer is
unstable fuel, or one that becomes unstable to blend a fuel which is not only stable
during storage or handling, can be serious. but also has a degree of reserve
Sludge may build up in the storage tanks, stability such that it will remain stable
piping systems or centrifuges and filters can during periods of storage and
become totally blocked by voluminous treatment at elevated temperatures.
amounts of sludge.
More paraffinic blend components are
expected for Very Low Sulphur Fuel
Oil (VLSFO) compared to existing
fuels. Whereas aromatic components
have a stabilizing effect on
asphaltenes, paraffins do not. Fuel
suppliers are responsible for ensuring
that the supplied fuel is stable.
Compatibility Challenges are the same as with stability An incompatible mix may be harmful to
issues (above). ship's operation.
VLSFOs are expected to be paraffinic

based in some regions and aromatic
based in other regions. There is a risk
of experiencing incompatibility when
mixing an aromatic fuel with a
paraffinic fuel. The same risk exists
today, but with the wide range of

products which may exist post 2020, it
is important to segregate fuels as far
as possible and to be cautious of how
to manage/handle incompatible fuels
on board.
Cold flow ISO 8217:2017 limits the cold flow properties VLSFO products are expected to be
properties of a fuel through setting a limit on the pour more paraffinic compared to existing
and Pour point (PP). However, given that wax crystals fuels. As such, it is important to know
Point form at temperatures above the PP, fuels that the cold flow properties of the
meet the specification in terms of PP can still bunkered fuel in order to ensure
be challenging when operating in colder proper temperature management on
regions. Wax particles can rapidly block filters, board.
potentially plugging them completely. The
paraffin's may crystallize and/or deposit in the It is important to note that for additives
to be effective, they have to be applied
storage tanks leading to blockages at the
filters and reduced fuel flow to the machinery before crystallization has occurred in
the fuel.
plants. If fuels are held at temperatures below
the pour point, wax will begin to precipitate.
Reference 1.
This wax may cause blocking of filters and can
deposit on heat exchangers. In severe cases
the wax will build up in storage tank bottoms
and on heating coils, which can restrict the
coils from heating the fuel (fuel will become
unpumpable from the bunker tanks).
Acid number The fuel shall be free from strong, inorganic There is currently no recognized
acids. correlation between an acid number
test result and the corrosive activity of
Fuels with high acid number test results the fuel.
arising from acidic compounds cause
accelerated damage to marine diesel engines. ISO 8217:2017, appendix E covers the
Such damage is found primarily within the fuel topic.
injection equipment.
Flashpoint Flashpoint is considered to be a useful SOLAS requirement.

indicator of the fire hazard associated with the
storage of marine fuels. Even if fuels are
stored at temperatures below the determined
flash point, flammable vapours may still
develop in the tank headspace.
Ignition and Fuels with poor ignition & combustion High and medium-speed engines are
combustion properties can, in extreme cases, result in more prone to experience operational
quality serious operational problems, engine damage difficulties due to poor ignition and
and even total breakdown. Poor combustion combustion properties than low speed
performance is normally characterized by an two stroke types. With four stroke
extended combustion period and/or poor rates engines, poor ignition can result in
of pressure increase and low "p max" resulting excessive exhaust gas system
in incomplete combustion of the fuel. The deposits, black smoke, engine
resulting effects are increased levels of knocking and difficulties operating at
unburned fuel and soot that may be deposited low load.
in the combustion chamber, on the exhaust
If the ignition process is delayed for
valves and in the turbocharger system,
exhaust after treatment devices, waste heat too long a period by virtue of some
chemical quality of the fuel, too large a
recovery units and other exhaust system
components. Extended combustion periods quantity of fuel will be injected into the
engine cylinders and will ignite at
may also result in exposure of the cylinder
liner to high temperatures which may disrupt once, producing a rapid pressure and
heat rise and causing associated
the lubricating oil film, leading to increased
wear rates and scuffing. Unburnt fuel droplets damage to the piston rings and
cylinder liners of the engine.
may also carry over impinging on the liner
surfaces causing further risk of damage to the
Reference 2.
liner.
Cat fines Cat fines will cause abrasive wear of cylinder Major engine manufacturers
liners, piston rings and fuel injection recommend that the fuel's cat fines
equipment if not reduced sufficiently by the content does not exceed 10 mg/kg
fuel treatment system. High wear in the (ppm) at engine inlet.
combustion chamber can result.
Low viscosity Low-viscosity fuels (less than 2 cSt at engine Low fuel viscosity does not only affect
inlet) challenge the function of the fuel pump the engine fuel pumps. Most pumps in
in the following ways: the external fuel oil system (supply
pumps, circulating pumps, transfer
.1 breakdown of the oil film, which could pumps and feed pumps for the
result in seizures; centrifuge) also need viscosities above
2 cSt to function properly.
.2 insufficient injection pressure, which
results in difficulties during start-up and Viscosity is highly temperature
low-load operation; and dependent and the crew must take
proper care of fuel oil temperature
.3 insufficient fuel index margin, which management to avoid viscosity related
limits acceleration. issues.
Reference 3.
Unusual The below components and group of Only for few components, there
components components can be linked to the risk of exists a clear cause and effect
encountering the following problems: between component and
associated operational
Polymers (e.g. polystyrene, polyethylene,
problems.
polypropylene)
Associated with filter blocking There is no statistical study
performed of which components
Polymethacrylates are typically found in marine
Associated with fuel pump sticking fuels and in which
concentration.
Phenols
Occasionally Associated with filter As per ISO 8217:2017, annex B:
blocking/fuel oil pump sticking The marine industry continues
to build on its understanding of
Tall oils the impact of specific chemical
Associated with filter blocking species and the respective
Chlorinated hydrocarbons critical concentrations at which
Associated with fuel pump seizures detrimental effects are observed
on the operational
Estonian shale oil
characteristics of marine fuels in
Associated in the past with excessive
use.
separator sludging
Only in some of the past cases
Organic acids
the origin of the unusual
Associated with corrosion as well as fuel pump components found in bunkers
sticking
were revealed and were due to
various reasons such as:
.1 Russia/Baltic states 1997,

cross contamination in
storage/piping (polypropylene);
.2 Singapore 2001, 4 bunker

barges received material from
road tankers which, in addition
to transporting fuel, also
collected/transported waste oil
from shipyards and motor shops
(esters);
.3 Ventspils 2007, Estonian
shale oil to convert HSHFOs to

LSFOS; and
.4 Houston 2010/11, bunker

barges that were not cleaned
between cargoes (polyacrylates)
Reference 4.
References
1 CIMAC WG7 Fuels Guideline 01/2015: "Cold flow properties of marine fuel oils"
2 CIMAC WG7 Fuels 2011: "Fuel Quality Guide: Ignition and Combustion"
3 MAN Service Letter SL2014-593/DOJA
4 Bureau Veritas Verifuel, Investigative analysis of marine fuel oils: Pros & Cons
Parent topic: Resolution MEPC.320(74) - 2019 Guidelines for Consistent Implementation of the 0.50%
Sulphur Limit under MARPOL Annex VI - (adopted on 17 May 2019)
Copyright 2021 Lloyd's Register Group Limited, International Maritime Organization, International Labour
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referred to in this clause as 'Lloyd's Register'. Lloyd's Register assumes no responsibility and shall not be
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document or howsoever provided, unless that person has signed a contract with the relevant Lloyd's Register
entity for the provision of this information or advice and in that case any responsibility or liability is exclusively
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Annex - 2019 Guidelines for Consistent Implementation of the 0.50% Sulphur Limit unde...

Lloyd's Register Rulefinder 2022 - Version 9.36

Annex - 2019 Guidelines for Consistent Implementation of the

1.2.2 The following definitions of fuel oils are used, as applicable:

.5 High sulphur heavy fuel oil (HSHFO) exceeding 0.50% S.

2 Ship implementation planning for 2020

3 Impact on fuel and machinery systems

3.1 Distillate fuels

.1 either used before entering cold regions, or

.2 used with suitable heating arrangement, as mentioned above.

3.2 Distillate fuel with FAME content

3.3 Residual fuels

3.3.1 Stability and compatibility

3.3.2 Catalytic fines (cat fines)

3.4 Key technical considerations for shipowners and operators

3.5 ISO Standard for residual fuels

3.6 Cylinder lubrication

4 Verification issues and control mechanism and actions

4.1 Survey and certification by Administrations

4.2 Control measures by port States

4.2.3 Inspections based on documents and other possible targeting measurements

4.2.4 Fuel oil sample analysis

4.2.5 Other open-sea compliance monitoring tools:

.1 fuel oil changeover calculator;

.3 continuous SOX monitoring.

4.3 Control on fuel oil suppliers

4.4 Information sharing related to non-compliances under MARPOL Annex VI

5 Fuel oil non-availability

5.1 Guidance and information sharing on fuel oil non-availability

5.1.2 Guidance on consistent evidence

5.1.6 Investigating non-availability

5.2 Standard format for reporting fuel oil non-availability

.1 stability of blended fuel oil;

.3 cold flow properties;

.6 ignition and combustion quality;

.8 low viscosity; and

FUEL OIL NON-AVAILABILITY REPORT (FONAR)

3 Before filing a FONAR, the following should be observed by the ship/operator:

1.1 Name of ship: _______________________________________________________

1.2 IMO number: ________________________________________________________

1.3 Flag: ______________________________________________________________

2 Description of ship's voyage plan

2.2 Details of voyage:

1 – Last port of departure

2 – First port of arrival in "country X":

3 – Date of departure from last port (dd-mm-yyyy):

4 – Date of arrival at first "country X" (dd-mm-yyyy):

6 – Ship's location at the time of notice:

3 Evidence of attempts to purchase compliant fuel oil

4 In case of fuel oil supply disruption only

5 Operation constraints, if applicable

6 Plans to obtain compliant fuel oil

7 Previous Fuel Oil Non-Availability Reports

Date (dd-mm-yyyy): _________________________________________________________

Type of fuel: _______________________________________________________________

Master name: ______________________________________________________________

Local agent in "country X": ____________________________________________________

Ship operator name: _________________________________________________________

Name and position of official: ______________