Checklist for compliance with the 2020 sulphur cap

From 1 January 2020, the limit for sulphur in fuel oil on board ships operating outside designated Emission Control Areas (ECAs) will fall to 0.50% mass by mass (m/m). For this reason, the Shipowners’ Club published a checklist, which may be used as a guide to compliment any operational changes that operators are planning, so as to ensure compliance with the upcoming MARPOL convention changes.

The checklist is divided into three categories. These are:


  • Have you developed a ship specific implementation plan, in accordance with guidance from the IMO?
  • In case that any structural modifications are necessary, have these been added to the ship specific implementation plan and approved by the flag state and/or classification society as applicable?
  • Has a risk assessment for compliance been conducted and is it available on board?
  • Has crew and shore side personnel training been carried out with appropriate records available?
  • If the ship is more than 400GT, is the International Air Pollution Prevention (IAPP) Certificate or related exemption documentation available on board?
  • Are the Oil Record Book and any other required records available and up to date?
  • Do records note the condition of tanks, pipelines and other associated bunkering equipment?
  • Do the Bunker Delivery Notes clearly verify whether the fuel oil sulphur content is above 0.50% m/m?
  • Have you taken precautions to avoid comingling of supplied bunkers with fuel already on board the vessel?
  • If comingling of fuel is unavoidable, have you made sure that clear fuel test documentation is available for each batch of fuel?
  • Have you made preparations for entry into Emission Control Areas (ECAs) in sufficient time to allow for complete flushing of the fuel system or effective operation of the scrubber system?
  • If so, are written changeover procedures available to crew and the necessary associated records available and maintained on board the vessel?

On ships where scrubbers are installed

  • Is the scrubber system type approved, in good working order with planned maintenance tasks up to date and monitoring devices fully operational?
  • Are operational and maintenance records for the scrubber system and its related equipment being maintained on board and are these available for inspection?
  • Do any ports restrict or have additional requirements for the discharge of open loop scrubber system wash water on the upcoming voyage(s)?
  • If so, have you made arrangements for specialist disposal arrangements if necessary?

Switching to a new fuel type

  • Have you completed a suitability assessment, including reference to manufacturer’s instructions, to establish what impacts a change in fuel type may have on existing machinery and equipment?
  • Have the tanks and pipelines been thoroughly flushed and cleaned to avoid cross contamination?
  • Do records note that segregation of fuel system tanks and pipe work has been maintained where necessary?
  • Have you carried out additional tests for bunkers before utilising them?
  • If additional tests are not practicable, are you monitoring the vessel’s filters and fuel consumption when commencing use of fresh bunkers in order to identify any problem at the earliest opportunity?

“In the event that the vessel is not able to comply with sulphur cap requirements, the vessel’s shore management should be notified immediately, and the details of any non-compliance recorded in the vessel’s log books”