Wilhelmsen insights

Preparation for compliant fuel

To comply with IMO Sulfur Cap 2020, one of the options is changing to compliant fuel.
Bunker change main image

Wilhelmsen insights |
Rajiv Nigam, GM - Technical Services Group

With the deadline of IMO Sulphur Cap 2020 drawing closer, we understand the owner's pressing need to keep vessels operational while simultaneously preparing to comply with this environmental regulation.

A ship specific detailed changeover procedure must be available onboard all ships trading between areas with different Sulphur limitations. A calculation system (e.g. FOBAS) shall be used, if required. Crew involved in the changeover process must be fully immersed in all relevant procedures and tasks. This is crucial to prevent potential technical issues such as engine or boiler malfunction.  


WSM recommends owners, charterers and ship managers to start the discussion regarding switching to compliant fuel as early as eight months in advance to ensure that the plans materialize and are implemented effectively. If you have chosen to comply by using low Sulphur fuel, begin planning today. 

TImeline to compliant fuel

The processes for change must be detailed and precise to minimize complications and non-compliance.

For owners choosing to use compliant fuel, we have enumerated some recommendations below to assist smooth transition. :


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  • Contact bunker suppliers at least six months ahead to ensure compliant fuel availability
  • Any bunker with over 0.5% Sulphur must be consumed before 31 December 2019
  • Any bunker tank previously containing fuel with more than 0.5% Sulphur must be cleaned and records maintained with relevant evidence latest by 29 February 2020


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  • Document your tank cleaning process with photographs and dated evidence.
  • Bunker Delivery Notes (BDN) displaying less than 0.5% Sulphur bunkers to be kept on board
  • BDN must also show less than 0.1% Sulphur compliant bunker for use in Emission Control Areas (ECA)
  • Bunker changeover procedures for engines and boilers are prepared and explained to ship staff
  • Develop detailed plans for prevention of any accidental contamination of fuel meant for ECA
  • Diligent documentation of compliance strategy is highly advisable to declare best efforts to inspecting authorities   


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  • There may be a need for structural modification and one of the initial plans for an owner is determining the configuration of bunker distribution basis number of tanks on the ship
  • Segregation is very important and structural modification of tanks and pipelines require Class approval


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Consulting makers and suppliers

  • Consult the makers of the main and auxiliary engines, boilers and lubricant (lub) oil for guidance on continuous use with compliant fuel
  • Should a change of cylinder lub oil be required, lub oil and main engine makers must be consulted for recommendation to change the cylinder lub oil to one that is compatible with the compliant fuel
  • For vessels with single cylinder lub oil tank, documentation regarding procedures on how to change the cylinder lub oil to low sulfur compatible grade must be in place.


Monitoring and trial

  • As this is an environment-related regulation, we expect stringent Port State Control (PSC) inspection so a clean and detailed line of operations must be in place before the regulation is enforced
  • A sea trial of main engine, aux engine and boilers should be scheduled to confirm smooth operations with compliant fuel once all compliant bunkers are on board.
  • Clear segregation of crew duties is detailed in the Ship Safety Management Manual and all guidance materials regarding compliant fuel also included

Having a good implementation fuel oil / changeover plan is just the begining of the transition phase. A very important aspect of the plan is to address potential risks that may arise. 

WSM is determined to keep our managed vessels in line with new international environmental requirements while maintaining safe operations.

Contact us to understand the options for sailing in compliance.

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Disclaimer : While care has been taken to ensure the information in this publication is accurate, this is a general guide and not intended to be relied on for any specific purpose. Wilhelmsen Ship Management Holding Limited and its subsidiaries cannot be held responsible for any errors or consequences arising therefrom. If you would like to reproduce any part of this publication, please seek our prior approval.