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Early warning on global 2020 sulphur cap compliance

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The Maritime Authorities of the Paris and the Tokyo Memoranda of Understanding (MoU) on Port State Control will start issuing a letter of warning from 1 January 2019 on the sulphur content of marine fuels during inspections in order to increase awareness of and to encourage timely compliance with the new requirements.


The requirement of maximum sulphur content of 0,50% m/m for marine fuel oil will enter into force on 1 January 2020, which is known as the global 2020 sulphur cap. The implementation of the global 2020 sulphur cap will have considerable implications on ship operators, the fuel oil supply chain and the industry as a whole.
For the purpose of facilitating smooth and consistent implementation of the global 2020 sulphur cap, the Paris and the Tokyo Memoranda will carry out a joint information campaign by issuing a letter of warning to ships during inspections from 1 January to 31 December 2019. The aim is to increase awareness of the ships’ crew and company on the matter and to remind and encourage compliance with Regulations 14 (*1,*2) and 18 of MARPOL Annex VI from 1 January 2020.
The letter of warning will be issued to ships found not yet ready for compliance with the relevant requirements that will enter into force on 1 January 2020.

The letter of warning which may be issued is attached
PARIS MOU ON PORT STATE CONTROL
To the Master of Flag State
IMO No
Date
LETTER OF WARNING
MARPOL Annex VI
Sulphur Oxides (SOx) and Particulate Matter (Regulation 14)1
Dear Captain,
This letter is to bring to your attention the new regulations on sulphur content of fuel oils used on board from 1 January 2020. From that date all ships subject to MARPOL Annex VI are, in principle, required to use on board fuel oils with a sulphur content of maximum 0,50% m/m in accordance with MARPOL Annex VI regulation 142, or use alternative emission reduction and control technologies to comply with the emission standard.
From 1 January 2020 Port State Control Officers of the Paris MoU will check compliance with these regulations through the bunker delivery notes and related ships’ log books and records and by means of sampling from the fuel lines.
The following check boxes indicate the areas investigated:
1 SOx records □
2 Sulphur oxides □
3 Sulphur content of fuel used □
4 Alternative arrangements (SOx) □
Deficiencies in the areas listed above may be recorded by the Paris MoU if the regulations were in place now.
From 1 January 2020 Port State Control Officers will put further emphasis on the following items:
1 That the ship carries on board fuel oil with a sulphur content depending on the area of operation
2 There are records of the bunker delivery notes (BDNs) and associated samples or records thereof are kept on board
3 There are written procedures on board covering fuel oil change over operations where appropriate
4 That the Master and ship’s personnel are familiar with essential fuel oil management procedures
5 That the ship has an appropriate approval for any installed exhaust gas cleaning systems, or equivalent means, if required
This list is to help you prepare for compliance by 1 January 2020. If deficiencies are recorded against any of these items from 1 January 2020 action may be taken by the Port State Control Officer which may include a detention of the ship or other enforcements or administrative or corrective measures.
You are requested to inform the company of the above. Further details are given in MARPOL Annex VI Regulations 14 and 18.
On behalf of the Maritime Authority of
PSCO Port Date

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