Despite the fact that IMO 2020 is less than 8 months away, industry stakeholders are still facing a number of major uncertainties. Fuel prices of new compliant fuel are generally unknown and ship operators are afraid of an increase in fuel costs which might hit their already low profitability. Availability is also not known, while a big issue exists with the quality of the new fuel blends and their compatibility with ship engines. In the meantime, PSC inspections will be increased significantly in order to ensure vessels’ compliance with the revised maximum sulfur content and shipowners may face unwanted penalties either in cases they do not fully comply with regulations or in case of mistakes from port authorities which appear to happen from time to time.
Under these circumstances, the role of ships’ crew is becoming more important. A well trained and attentive crew which is aware of the new regulations and follows the procedures properly can save shipowners from operating expenses or even unwanted PSC fines.
The importance of crew is highlighted by Gard, one of the largest P&I Clubs worldwide, in a recent article where it calls its members to sufficiently prepare their crews for the new IMO regulation and the PSC inspections starting from 1st January 2020.
According to Gard, in previous two cases which took place in European ports with ships entered with its P&I, the ship’s crew made the difference in the final result. Specifically, in both cases the port authorities levied a penalty on the ships since the sulfur content was found to exceed the 0.10% limit. Although in both cases was subsequently found that mistakes had occurred and the port officers had taken wrong samples, only in one of the two the owner avoided the penalty thanks to his crew.
In the first case, the crew of the ship had signed the inspector’s report without any notice of protest, despite the fact that the report was incomplete and the sample was taken from a wrong system. In the second case, the owner succeeded to defend the penalty since its crew was not only attending the sampling operation but was also taking pictures and could easily identify the duplicate sample bottle, retest and find out that it also included hydraulic oil.
Gard recommends its members to take the following steps well in advance:
– Revise ship’s procedures for fuel sampling so as to comply with MARPOL Annex VI which describes samples taken from ship’s pipeline system (in-use sample) and ship’s tanks (on-board sample).
– Ensure that the procedures describe acceptable sampling methods in regards with the location of sampling points, handling of the samples (original and duplicate bottles) and keeping of proper records on-board.
– Train the crew and especially the engine crew properly and make sure that the procedures are followed and that the inspector is accompanied at all times.
– Follow the forthcoming IMO recommendations and consider whether they will be implemented in ship’s procedures or not.
“Without proper evidence, the chances of the shipowner losing the claim in a disputed case are high,” Gard concludes.