Recent amendments to SOLAS
7 require new ships using gases such as LNG or
other low flashpoint fuels to comply with the IGF Code. In the Code, there are
provisions relating to the arrangement, installation, control and monitoring of
machinery, equipment and systems which are mandatory for ships using LNG or
other low flashpoint fuels. All matters needing particular consideration in relation to
the use of low flashpoint fuels are addressed through a goal-based approach to the
issues. The relevant goals and functional requirements are set out in each section of
the Code which contain specific provisions relating to the design, construction and
operation of ships using such fuels.
8
The IMO Sulphur 2020 initiative prescribes the limit of sulphur content in ship’s
fuel as 0.50%. This limit will become mandatorily effective as of 1 January 2020
pursuant to amendments made to MARPOL. Needless to say, this new lower limit
will be of major benefit both in terms of the marine environment as well as human
health.
9 Notably, given the anticipated major health benefits in respect of personnel
onboard ships and people residing in the hinterland near ports and shipping routes, it
is expected that eventually the limit will be even lower than 0.10%. The new limits
provide certainty in terms of standard to refineries and bunkering stations.
To ensure cleaner exhaust emissions, the first option for ship owners is to install
exhaust gas cleaning systems otherwise referred to as scrubbers. Flag states have
accepted this methodology as a viable alternative for meeting the requirements of
sulphur limitations. This is a complementary amendment to MARPOL which will
become effective on 1 March 2020. It is complementary to the 1 January 2020
implementation date to provide flag and port states the means to comply with the
new requirements and carry out effective enforcement. Secondly, there is the option
of using fuels that are compliant with the new standards but from the ship owners’
point of view, that will entail higher costs. The third alternative, which is probably
the best and most viable from a technical perspective is the use of LNG as a clean
gas fuel.
The European Union (EU) policy appears to be the most advanced in terms of
recognising the usefulness of LNG usage as fuel and promoting its use. It is evident
that the EU has in fact adopted certain measures that are more advanced than IMO
requirements. The use of LNG as a marine fuel is thus relatively high on the EU
agenda categorising it as the most promising option for ships’ fuel.
10
7 International Convention for the Safety of Life at Sea, 1974 (SOLAS), 1184 UNTS 3. Chapter II-1
(Construction—Structure, subdivision and stability, machinery and electrical installations).
8 IMO Document (2019).
9 Ibid.
10 European Commission (2013), “SWD (2013) 4 final: Action towards a comprehensive EU
framework on LNG for shipping”. In Sect. 1 it is remarked that “LNG is the most promising
alternative shipping fuel technology in the short to medium term, at least for short sea (and possibly
inland waterway transport), but also for maritime activities outside transport. . .” cited in Xu et al.
(2015), p. 230.
694
J. Xu and P. K. Mukherjee
7 require new ships using gases such as LNG or
other low flashpoint fuels to comply with the IGF Code. In the Code, there are
provisions relating to the arrangement, installation, control and monitoring of
machinery, equipment and systems which are mandatory for ships using LNG or
other low flashpoint fuels. All matters needing particular consideration in relation to
the use of low flashpoint fuels are addressed through a goal-based approach to the
issues. The relevant goals and functional requirements are set out in each section of
the Code which contain specific provisions relating to the design, construction and
operation of ships using such fuels.
8
The IMO Sulphur 2020 initiative prescribes the limit of sulphur content in ship’s
fuel as 0.50%. This limit will become mandatorily effective as of 1 January 2020
pursuant to amendments made to MARPOL. Needless to say, this new lower limit
will be of major benefit both in terms of the marine environment as well as human
health.
9 Notably, given the anticipated major health benefits in respect of personnel
onboard ships and people residing in the hinterland near ports and shipping routes, it
is expected that eventually the limit will be even lower than 0.10%. The new limits
provide certainty in terms of standard to refineries and bunkering stations.
To ensure cleaner exhaust emissions, the first option for ship owners is to install
exhaust gas cleaning systems otherwise referred to as scrubbers. Flag states have
accepted this methodology as a viable alternative for meeting the requirements of
sulphur limitations. This is a complementary amendment to MARPOL which will
become effective on 1 March 2020. It is complementary to the 1 January 2020
implementation date to provide flag and port states the means to comply with the
new requirements and carry out effective enforcement. Secondly, there is the option
of using fuels that are compliant with the new standards but from the ship owners’
point of view, that will entail higher costs. The third alternative, which is probably
the best and most viable from a technical perspective is the use of LNG as a clean
gas fuel.
The European Union (EU) policy appears to be the most advanced in terms of
recognising the usefulness of LNG usage as fuel and promoting its use. It is evident
that the EU has in fact adopted certain measures that are more advanced than IMO
requirements. The use of LNG as a marine fuel is thus relatively high on the EU
agenda categorising it as the most promising option for ships’ fuel.
10
7 International Convention for the Safety of Life at Sea, 1974 (SOLAS), 1184 UNTS 3. Chapter II-1
(Construction—Structure, subdivision and stability, machinery and electrical installations).
8 IMO Document (2019).
9 Ibid.
10 European Commission (2013), “SWD (2013) 4 final: Action towards a comprehensive EU
framework on LNG for shipping”. In Sect. 1 it is remarked that “LNG is the most promising
alternative shipping fuel technology in the short to medium term, at least for short sea (and possibly
inland waterway transport), but also for maritime activities outside transport. . .” cited in Xu et al.
(2015), p. 230.
694
J. Xu and P. K. Mukherjee