How can a SIP support smooth sailing into 2020?
Last issue, we explored how V.Group is helping owners prepare for 2020 with detailed Ship Implementation Plans. Now that we have just passed 1st of January deadline, V.Group’s Sarwar Hassan, V.Ships UK Fleet Manager explains how we managed to roll out SIPs for our whole fleet, what to do if you haven’t made one yet, and what owners will need to look out for in the post-2020 fuels environment.
How many shipowners are adopting SIPs?
We are proud to report 100% compliance. Since 1st October 2019, all vessels under V.Group management have a SIP on board.
What are the main benefits that SIPs are delivering?
At a time when there is a great deal of uncertainty around complying with the new 2020 sulphur regulations now in effect, SIPs provide ship owners with guidance, clear instructions, and peace of mind.
Recommended by the IMO as a means to determine exactly what needs to be done for each individual vessel and ensure that it is prepared and ready to operate on compliant fuels, port state control and third party inspectors are likely to ask to look at the SIP to ensure compliance due diligence process.
While not mandatory, SIPs demonstrate a proactive approach from ship owners and managers, assisting in effective 2020 arrangements. As vessels are required to comply with sulphur requirements and consume the fuel in a safe and complaint method at all times, on board records and documentation provide evidence to the authorities that the vessel owner and manager are doing their utmost to be transparent and prove their efforts to comply. V.Group is supporting its vessels in adopting industry best practice to mitigate any potential challenges faced during inspections on board our managed fleet.
The SIP provides clear guidance on how to deal with the new compliant fuel, including storage, handling, and use onboard, including the reporting structures for non-compliant fuel. Fuel characteristics, such as compatibility and stability, are also covered within the revised e-learning module which is mandatory for all seafarers and operational shore staff. It seems the old adage of ‘time spent in reconnaissance is seldom wasted’ certainly rings true.
What are the main questions you’re being asked by owners? What are their key areas of concern?
The majority of owners are concerned about the availability of compliant fuel, as well as its price and quality. However the owners and charterers are working together on this plan order and delivery.
The risk of high catalytic fines, or cat fines, also remains a core concern. The fines are particles of spent aluminium and silicon catalyst that arise from the catalytic cracking process in the refinery, and vary in both size and hardness. If not detected and reduced by suitable treatment, the abrasive nature of these fines will damage the engine, particularly fuel pumps, injectors, piston rings and liners, leading to damage, costly repairs, and unplanned downtime.
While the industry is familiar with cat fines, the correct operation of the fuel purifiers will be critical to the operational reliability of the main and auxiliary engines – and it’s likely that the extent of the potential problem will only become fully evident as we see increased adoption of low sulphur fuel.
In addition, it is clear that chemical contaminants and the stability of the fuel will have a direct impact on the main propulsion, auxiliary operations, and overall performance.
Whilst every fuel is manufactured to be stable – in that it does not have the tendency to produce asphaltenic sludge – two stable fuels are not necessarily compatible when blended or mixed together. A blend is regarded as being stable only if it is homogeneous immediately after preparation, remains so in normal storage and at no time produces or tends to produce sludge on a significant scale. If behaving in this way, the fuels forming the blend can be considered as compatible with each other. Incompatibility is the tendency of a residual fuel to produce a deposit on dilution or on blending with other fuel oils and typical incompatibility problems include sludging and blockage of bunker and service tanks, pipe runs, filters and centrifuge bowls. In extreme circumstances the only remedy is manual removal of the sludge build up, which is both time-consuming and extremely costly.
How is V.Group helping?
V.Group has been supporting owners in the preparation of SIPs, as well as through webinars and training modules for all those working on a vessel. We have been working hard to familiarise everyone with the challenges associated with handling compliant fuel, including circulation of industry and manufacturers’ technical bulletins.
What if you don’t have a SIP?
All vessels under V.Group management now have a SIP. Any new vessels which enter into V.Group management will have a SIP created by their regional office, documenting the compliance method and specific configuration for that vessel.
What will happen if compliant fuel is not being burnt?
While some in the industry believed that there may have been an extension, the IMO has repeatedly quashed these claims and reiterated this is a strict deadline; non-compliance is not an option, and no extension or exemption will be given.
Shipowners who are found not to comply risk penalty fines and reputational damage, as well as the significant delays and additional cost associated with being held in port and de-bunkering non-compliant fuel.
While the IMO has stressed on numerous occasions that a FONAR (Fuel Oil Non Availability Report) does not represent a ‘get out of jail free’ card to use or carry non-compliant fuel, it may be taken into consideration by the administration and Port State Control, particularly if safe, compliant fuels are unexpectedly unavailable. The procedure for completion and submission of the FONAR is included within the SIP and also the Company Safety Management System (VMS).
In your view, what are the main hurdles now January 2020 is upon us?
There are many different perspectives on this, yet no one really knows! The biggest challenge the industry faces is the for the vessel itself to store the new grades of fuel whilst maintaining operational performance and complying with legislation. The issue will be the availability of the compliant fuel to meet the demand now the 1st January is upon us, as well as the various grades and structures of the new fuel. It will be a challenge for vessels arriving in a port with the uncertainty of whether the fuel on offer will be compatible with what is already in the tanks and what potential issues the mixtures will cause.