Nafsika Ioli Kontou in ELNAVI: “IMO2020 the new reality”

Nafsika Ioli Kontou, AHHIC’s Claims Executive comments on IMO2020 in ELNAVI’s July edition.
Nafsika Ioli Kontou, AHHIC’s Claims Executive comments on IMO2020 in ELNAVI’s July edition.

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IMO2020 is now a new reality we need to confront. Just like the pandemic, it entered in our lives in January 2020. The only difference is that for the shipping industry this was not a stranger, who appeared suddenly on the doorstep. The maritime community was aware of the implementation time of this MARPOL Annex VI Amendment since 2016[1]. So frankly it was a date. Was it prepared?

In theory, we should respond in the affirmative way; availability of fuel oil was assessed, new fuel products emerged, scrubber technology – widely used on land to monitor air pollution- expanded its clientele for marine use, slow steaming and switching to MGO were evaluated, while for the dauntless other methods were employed like LNG-fueled ships – one is already on order and could possibly use ammonia as fuel also – or dual fuel ships and other alternatives to keep ships sailing and the global economy rolling, which is the main requirement, after all.

The long-awaited IMO2020 Regulation, as a remedy to lower the sulphur content and cope with air pollution generated by ships comes as an effort of the UN Agency in shipping, the IMO, to meet the UN Sustainable Development Goals (SDG) until 2030.  Carbon footprint should be reduced by 40% by 2030 and GHG emissions should be halved, compared to 2008 by 2050. Ambitious goal, isn’t it? The MARPOL 73/78 Annex VI – Prevention of Air Pollution from Ships, Amendment addresses SDG 3, Well-being, and SDG 13 Climate Action, whilst there is research that relates Sulphur Cap also with SDG 7 Affordable and Green Energy and 14 Life Below Water.

The new IMO2020 Regulation demands that ships will start burn fuels with 0.50% m/m (mass-by-mass) sulphur content, from 1st January 2020 onwards. This is a global limit and is supplemented by the already established limit for ECAs zones where maximum content is even lower, at 0.10% m/m (mass-by-mass).
In the analysis that follows the two commonly selected options are discussed, namely the use of VLSFO and EGCS.


The new fuels that were introduced to the market to meet the sulphur content requirements are either distillates or residual process products. As with the blends of high sulphur marine fuel types that are in use for quite some period/time the new fuels have characteristics that will make them fit for purpose. These limits are set by the ISO 8217 Petroleum products – Fuels (class F) – Specifications of marine fuels provided by International Organization for Standardization, in its various editions. The more recent edition has been released in 2017, known as ISO 8217:2017 and contains the edges of the different parameters that marine fuels should have, before onboard treatment. ISO reviews its standards as deemed necessary, therefore a revision to consider the new 0.5% Sulphur content was not possible within timeframe. Despite this restraint, the stakeholders of the maritime community gathered together and in September 2019 issued ISO/PAS 23263 Petroleum products – Fuels (class F) – Considerations for fuel suppliers and users regarding marine fuel quality in view of implementation of maximum 0.50% sulphur in 2020, which gives technical considerations for the quality of new types of marine fuels for the audience and to assist the users for a smooth transition towards the new Regulation. Among others, it sheds some light about compatibility issues and touches other features like ignition characteristics, kinematic viscosity, stability, cold flow properties catalyst fines, as well as the application of the ISO 8217:2017 to the 0.5% Sulphur fuels.

For products that are the result of refinery process, it is expected that the characteristics will largely vary with supplier and geographical location. This means that not all the batches are identical to each other, which stimulates some skepticism over compatibility issues. This very wide variety on the compositions (aromatic, paraffinic, etc) of the new Low Sulphur Fuel Oils results in the incompatibility to become a main issue, sometimes complex. Indeed, compatibility is of the points that has been flagged up since the launching of the IMO2020 and it is often seen in technical reports. Compatibility refers to the mix of two blends. Even two stable fuels might be incompatible the one each other and here the mixing ratio usually plays a role.

What has been observed is the build-up of sludge in tanks even if all operational recommendations are followed.

Sludge develops either from incompatible fuels, or because of instable fuels. Stability is another “pain point” for fuels which refers to a single fuel and its ability to resist collapse and form sludge, which then precipitates to the circuits. Stability is indicated also in the ISO 8217 and specifies that the marine fuels should have a homogeneous blend of hydrocarbons. As such, the stability depends on the hydrocarbons in the fuel and their nature. A stable fuel generally keeps its properties whereas, in an unstable fuel changes in its chemical properties take place – normally in short period of time – and highly viscous sludge is formed. It won’t take long before its making to the fuel system and the catastrophic consequences we can all guess without much difficulty, like clogged filters, blocked separators and in the worst-case scenario a black out situation.  What is more, stability is influenced by storage. Keeping fuels for extended periods without use can result to fuel degradation, which again affects its stability.

In a case that was brought to our attention, failures in the engine were constantly encountered. It became evident that engine makers in their Service Letter recommended that cylinder liners should be coated with cermet, which was not followed.

On another occasion encountered by our Company, the cylinder liners and piston rings were excessively worn out, and even after repairs, the problems persisted. Following investigations, the problem identified was the use of High-BN cylinder oil while burning VLSFO. Here is to mention that engine makers had given some “heads up” before enforcement for the IMO2020 sulphur cap by issuing recommendations about the suitable cylinder oils that should be paired with specific fuel grade and engine type. The wrong coupling created overheating of the liners and their breakdown.

On another occasion, a 2-stroke main engine could not be started due to low fuel pressure; Although MGO might be within specifications the engine runs the risk due to low viscosity of this fuel type and potential leakage in the fuel pumps. Here, the minimum required pressure was 200 bar, but only 170 bar was reached. In this instance, MGO was to blame for nevertheless low sulphur marine fuels behave similarly as those too have lower viscosity than their heavier substitutes. Operational specifications of the marine engines and fuels parameters should be considered ahead of switch-over.

Finally, there was a case where piston rings were broken over a continuous period of time. Inspections revealed that the VLSFO in use had Total Sentiment Potential (TSP) beyond limitations at 0.12 % m/m, in contrast to 0.10 which was the maximum permitted reading. When TSP exceeds the specification limit fuel is prone to become unstable, and sludging is imminent.


Another option that the IMO2020 Regulation can be satisfied is the use of exhaust gas cleaning systems (EGCS), broadly known as scrubbers. With this alternative the ship will continue to burn high sulphur marine fuel and sulphur content from the exhaust gas is washed by the cleaning system. These systems can either be retrofitted or installed on a newbuild and they are available in different types, open-loop, close-loop, dry and hybrid. The measure came with some shortcomings, stemmed from operational aspects of open loop types and hence was not welcomed by all the users of the industry. It is argued that the remnants discharged at sea when open loop EGCS are engaged might accumulate polluting substances to the marine environment and therefore many major ports have banned the use of open loop scrubbers in their coastal waters. Research has shown that the environmental impact is also influenced by the characteristics of receiving waters. Despite the drawbacks, the number of ships fitted with scrubbers arrived at 4,300 for 2020 much more than the 3 ships that were coming with scrubbers back in 2008.

To cope with port regulations, even ships that are equipped with open loop ECGS, prior entering the port they change over fuel to MGO. After exiting the restricted waters, they then switch over again to HFO combined with EGCS. This might trigger unfavorable temperature conditions in the scrubber chamber which might lead to thermal shock and subsequent cracks all over the installation. We were notified for such damage and opened a file to our system.

In another instance, the ship needed to shift to Singapore anchorage due to main engine malfunctions, however due to port restrictions that did not allow the use of open loop scrubbers the ship was compelled to request tug assistance.
Finally, a case came before us involving the malfunction of a hybrid scrubber. Hybrid scrubbers can operate both in open loop and close loop mode. In this case during switch over from open to close loop mode there was a failure of a 3-way-valve so that the hot exhaust gases that, would otherwise flow in the open air, redirected to the chamber of the scrubber. This resulted to overhearing and consequential damages of the installation.

What can we do?

And the question remains, “What can we do?” As a matter of fact, there is nothing much that can be done and apparently Owners were well prepared for this evolution. It is absolutely reasonable to get this feeling of frustration; Owners suffer losses just because they conform to the new mandates.

Machinery related damages is not a novelty in marine insurance and enjoy a sizeable position among others, or alternatively put we will continue to encounter this category of claims, regardless of the prevailing legislative framework. In so far as numbers are concerned, those claims account to 37% with an average cost per claim at USD 238,000 and the most ordinary cause of damage to be Crew negligence, that steadily holds the lion’s share of 51.4% for this particular type of damage.

The main issues that should be carefully monitored for IMO2020 are fuel stability, and compatibility and if we are to summarize fields of attention these would be:

  • Compatibility of blends
  • Stability
  • Viscosity
  • Lubrication
  • TSP of marine fuels
  • On board treatment

From the available literature other topics that have been reviewed and call for our awareness are:

  • Storage procedures
  • Quality of marine fuel
  • Cold flow temperature
  • Transfer temperature


The aftermaths of IMO2020 are yet to be seen however some inferences can be drawn after one year in implementation. From the analysis above, it all boils down that, more often than not marine claims are far from being a model of clarity. In that sense is not exaggeration to recall the cliché that the human element is our most precious asset. The sooner we digest this the easier would be to embrace change. Crew training is of paramount importance and should be encouraged for the benefit of all. To this we should add good seamanship, and efficient shore management, which explains underwriters’ stance on Managers’ profile, prior to taking up the risk. Digitalization, innovation, knowledge sharing, attention to detail, are luckily enough available in abundance and in our hands at no time today. Good fellowship and co-operation are key ingredients, too.

Undeniably these are unmapped waters, which demand our focus and unity at minimum, or else we will end up counting losses. Shipping is a rather complex and regulated industry but, history has shown that its people adopt fast track, and this time will not be an exception. From our side we strive our best to serve our valued clients instantly and provide them with bespoke services through our network and professionalism. Detaching our comfort zones is definitely a challenge but for now suffice is to say there is always light at the end of the tunnel.

We share our views and experiences for the interest of the community as we believe this is the only way that we deal with the new norm and raise awareness on topics of great significance.

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