DNV GL Industry update on global sulfur cap 2020 and ballast water management


The results of the Marine Environmental Protection Committee 71st session significantly impact ship owners and managers.

To support the maritime industry, and raise awareness of the available methods to address impending regulatory challenges, DNV GL hosted maritime leaders, operators, and regulators at its Houston headquarters.

Global Sulfur Cap 2020
The Marine Environmental Protection Committee 71st session (known as the MEPC 71) confirmed the implementation of the 0.50% limit of the sulfur content of fuel oil from January 1, 2020.

Owners and operators are now exploring options to better understand the best path for compliance. The many methods to evaluate, including:
-    Switching from heavy fuel oil (HFO) to marine gas oil,
-    Burning ultra-low sulfur HFO/hybrid fuel,
-    Retrofitting vessels to use alternative fuels, such as LNG,
-    Installing scrubber systems which allow vessels to continue operating on regular HFO

“There is a lot that must be looked in preparation for the 2020 sulfur cap. Considering a ‘total compliance strategy’ for SOx-NOx (sulfur oxide- nitric oxide) is recommended,” commented Jan Hagen Andersen, Business Development Director. Andersen added, “Given the number of compliance options available, to have the best competitive edge, we recommend that operators start preparing now to take steps to pursue compliance in the most cost-effective way.”

Ballast Water Management
The Ballast Water Management (BWM) Convention entered into force on September 8, 2017, requiring all ships to have an approved BWM plan and certificate onboard. The amendment approved by MEPC 71 reached a compromise on compliance dates for installation of ballast water treatment systems (BWTS).

“The first milestone of the BWM Convention has passed,” said Anthony Teo, Technology and LNG Business Development Director, DNV GL. He continued, “If they have not done so already, it is critical that international operators implement BWM solutions to ensure their vessels have a BWM Certificate onboard.”

All vessels, for which the convention is applicable, are expected to conduct ballast water exchange (D-1 standard) according to the ship’s approved plan; until compliance with the D-2 discharge standard and related enforcement dates become mandatory.

Special Requirements for US Operations
While the BWM convention applies to international waters, the United States is not a signatory to the convention. Vessels discharging ballast into U.S. waters must comply with the requirements of Title 33 Code of Federal Regulations Part 151, Subparts C and D.

Mr. Jamie Wilson, United States Coast Guard Sector (USCG) Houston-Galveston's Senior Port State Control Officer, stressed the need for operators to pay special attention to what constitutes compliance in "U.S. waters, which by law extends to 12nm from the baseline" (jurisdiction of National Invasive Species Act)." 

For vessels past their ship specific compliance date, when operating in U.S. waters, they must not discharge UNTREATED ballast. This is primarily accomplished by having installed and using a BWTS onboard. 

Wilson emphasized that, "BWTSs must either have formal Coast Guard type approval (5 systems have received official USCG type approval to date), or have IMO type-approval and be accepted by the Coast Guard as an Alternate Management System (only authorized for use temporarily for 5 years from compliance date; the USCG has accepted 105 such systems to date). Under the U.S. ballast water regulations, sequential exchange meeting the BWM Convention requirements is NOT an acceptable BWM method for vessels beyond their compliance date specified in 33 CFR 151.2035 without a valid USCG extension letter. For vessels experiencing operational failures of their BWTSs, communication with the USCG Captain of the Port where ballast discharge operations may need to be conducted is required and highly encouraged to be initiated early."