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Tuesday, November 26, 2019 

IMO is reminding the industry that its 2020 requirements for ships to cut sulphur oxide emissions - significantly reduce air pollution from ships with positive benefits for human health and the environment - will enter into effect in just over one month's time.

With this in mind, IMO recently hosted a second round table meeting at which interested stakeholders reported increasing confidence towards consistent implementation resulting from their significant efforts to date, while emphasising the continued need for awareness-raising efforts as the deadline looms.

Views were exchanged on the general availability of fuel to meet the 0.50% sulphur limit. It was felt supply would generally be available, with some exceptions. There was some indication that heavy fuel oils continued to be loaded. However, due to the proximity to the deadline, more ship operators and owners are beginning to gain experience of compliant fuels as bunker suppliers move their storage infrastructure and bunker barges to be 0.50% compliant fuel oil ready. The IMO Secretariat encouraged the sharing of information on any testing of fuel oils meeting the 0.50% limit.

Consistent enforcement by port State control was once again recognised as essential to ensure a level playing field and to ensure that ships would not be disproportionately impacted. MARPOL Annex VI, which contains the sulphur limit regulation, has 95 Parties, who between them register 96.71% of world merchant shipping by tonnage. Flag States have jurisdiction over the ship and issue the International Air Pollution Prevention Certificate (IAPP) to ships of 400gt and above.  However, port States need to be a Party to Annex VI to exercise port State control in relation to the sulphur 2020 limit. The number of Parties to the Annex varies in different port State control regions.

Concerns were raised by some attendees on the preparedness of  the PSC regimes to enforce the 2020 sulphur limit, however the IMO Secretariat confirmed the Organization's readiness to support PSC regimes, in particular, with capacity building and training. As well as an offer of training, an IMO Workshop for PSC MoU/Agreement Secretaries and Database Managers will be convened in 2020, which would provide a further opportunity to promote the harmonisation of enforcement measures.

Roundtable participants raised concern about possible inconsistent approaches in relation to the fuel oil non-availability report (FONAR). The report is not intended as an exemption but is a standardised template to report non-availability of compliant fuel oil.  The IMO Secretariat reminded participants that IMO has Guidelines which include a standardised FONAR.

Participants agreed on the need to continue to raise awareness about the sulphur 2020 limit and the need for further preparation by all stakeholders, including the IMO Secretariat, PSC regimes, Member States,  shipowners/operators, charterers, fuel suppliers and others, in order to ensure consistent implementation of the sulphur 2020 limit by 1 January 2020.

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