Sulphur Cap 2020

There is no doubt that the 2020 Global Sulphur Cap is a good thing, environmentally and socially - it certainly ticks those boxes. However, the economic and logistical boxes still remain unticked as we race towards December 31st, 2019. It may still seem like a long way off, but considering that 0.5% LSF is not yet widely in production, the very idea that one could (if it was actually possible or affordable) fit scrubbers to even 10% of the fleet, in the time available - is fanciful. So LSF will become the norm, in time things will settle and we will do our best to continue with trade. That is of course the ideal scenario.

However, there are four current schools of thought on what will happen:

  1. Chaos – not enough LSF.
  2. Organised chaos with winners (fuel suppliers) and losers (users paying high prices).
  3. Deception (catch me if you can/or I just got caught.)
  4. We are experiencing a little turbulence but the seatbelt signs will be turned off shortly. 

Many are in one or even several of these camps, hedging their bets. The fact is that there will be disruption and the overarching question will be: “Fuel quality – is it good, is it to spec, is it stable?". The fact that the bunker industry supports such a large sector of the legal profession with bunker claims today, along with the pre- Sulphur cap, is testimony to the fact that ‘certain practices’ are occurring and that loading bunkers is certainly a practice where vigilance is required.
The bunker purchase, loading and sampling process is well organised and lab reports are robust but they are not always timely.  There are many cases of bunkers loaded, vessels sailing and then a report is produced stating that the fuel is out of spec.

It is unrealistic to think these anomalies will be fewer post December 31st, 2019 – the forecast shows they will increase, some by design and some by default.

How to counter this?

A new product from Parker Kittiwake, a fully hand Portable XRF device (about the size of a bowling ball) that will analyse a 10ml (approximately) sample of fuel and give a lab quality Sulphur level to four decimal places within three minutes.  No reagents or accurate sample sizes required, and the push of one button will give you the answer you need. 

Samples can be taken at multiple intervals and if an anomaly is found, the supplier, broker, purchaser or vessel operator can respond immediately and take action before the vessel sails.  Switching fuel whilst underway can be carried out with confidence and if blending has to take place, a finite Sulphur level can be guaranteed. Bunker delivery notes can be verified by the purchaser and confidence can be restored.

As a Port State authority there has always been concern about how to police the new Sulphur cap, as surveyors would only be presented with historical data of what had been burned, or paper evidence of what is in the tanks*. If a surveyor has a Portable XRF device, samples can be taken immediately and it can be established whether the vessel should be subject to further investigation or ‘passed’ as meeting IMO regulations.
*Particularly important as legislation has been passed to prohibit knowingly carrying out of spec bunker fuel.