AUTORIDAD MARÍTIMA DE PANAMÁ F-410

(PANAMÁ MARITIME AUTHORITY) (DCCM)

DIRECCIÓN GENERAL DE MARINA MERCANTE V.00
(GENERAL DIRECTORATE OF MERCHANT MARINE)
DEPARTAMENTO DE CONTROL Y CUMPLIMIENTO
(DEPARTMENT OF CONTROL AND COMPLIANCE)

Merchant Marine Notice

Important aspects to take into account for the effective implementation of the upcoming IMO 2020.

No.: MMN-10/2019 December, 2019.

1. The purpose of this Merchant Marine Notice is to communicate guidelines for the compliment of any
operational changes that operators are planning, so as to ensure compliance with the upcoming
MARPOL convention changes. The MARPOL Annex VI contains requirements that apply to fuel oil used on
board ships. Regulation 14 sets limits on the sulphur content of fuel oil used on board ships, both within
designated SOX emission control areas (regulation 14.4) and worldwide (regulation 14.1). Regulation 18.3
contains requirements for fuel oil delivered to and used on board ships that should not jeopardize the
safety of ships or adversely affect machinery performance.

2. Goals.

These best practices are intended to assist Crews and ships operator to ensure the effective implementation of
the upcoming IMO 2020.

3. Fuel Oil Quality.

Fuel oil delivered to and used onboard any ship shall meet the standards of Regulation 18 Marpol Annex VI which
addresses the composition of hydrocarbons to be used for combustion purposes.

Fuel oil for combustion purposes derived from methods other than petroleum refining that must meet the
standards of the abovementioned Regulation 18, regarding their composition; also they must not exceed the
sulphur content requirements set forth in Regulation 14, and must not cause an engine to exceed the NOX
emission limits set forth in Regulation 13. When developing their procedures, fuel oil suppliers should also
consider the guidance provided by existing industry practices and standards, for example those published by the
International Organization for Standardization (ISO). The supplier should provide information on properties that
may affect how the bunkers behave during storage and handling on the receiving ship, if the product supplied
differs in handling characteristics from traditional/mainstream bunkers.

This information should include any special fuel management and handling requirements such as heating, special
attention to pre-treatment in separators and centrifuges, and any known compatibility issues particular to the
product.

For distillate fuels, suppliers should report cloud point (CP), cold filter plugging point (CFPP) and pour point (PP).
ISO 8217 fuel oil specifications require for these fuel oil cold characteristic to be tested. This information helps
the ship's crew determine if the fuel will need heating. The responsibility for ordering a product with appropriate
CP, CFPP and PP for the ship's operational needs falls on the buyer.

Bearing in mind all the time for the effective and safety transition:

 The Oil Record Book and any other required file records should be available and updated.
 The records notate the condition of tanks, pipelines and other associated bunkering equipment that
should be ready.
 Precautions must be taken to prevent the supplied bunker from mixing with another bunker on board
that is not compatible, for which purpose a properly approved tank segregation program must exist.
 Make sure that clear fuel test documentation is available for each batch of fuel, in case of mixed fuel is
unavoidable.

3. Bunker delivery note – BDN.

The bunker delivery note (BDN) is the official receipt stating the grade and quantity of bunkers supplied to the
receiving ship. Regulation 18.5 of MARPOL and appendix V of MARPOL Annex VI stipulates information to be
included in the BDN. Additional details, beyond the MARPOL requirements, may be included on the BDN
according to local requirements and the commercial requirements of the supplier.

The BDN should be signed by both the supplier's representative and the representative of the receiving ship and
retained by the supplier for at least three years as per regulation 18.9.3 of MARPOL Annex VI. Suppliers are
responsible for providing bunker delivery notes (BDNs) to the receiving ship and safety data sheets (SDS) in line
with the requirements of SOLAS regulation VI/5-1. It is the supplier's responsibility to ensure that the bunkers
delivered to ship are in conformity with the details provided on the BDN and SDS.

In addition to the minimum requirements (BDN and SDS), suppliers are recommended to provide other
supportive documentation and quality analysis reports and information on properties that may affect how the
bunkers behave during storage and handling on the receiving ship. This might assist the ship in the process of
storing and handling the fuel in a safe and efficient manner. From 01 January 2019, the Bunker Deliver Note is to
be provided in the format specified under Appendix V of MARPOL Annex VI, as amended by IMO Resolution
MEPC.286 (71).

Bearing in mind all the time for a safe and effective transition:

 The Bunker Delivery Notes should be clearly verified whether the fuel oil Sulphur content is above 0.50%
m/m.

4. Flashpoint.

Although Regulation 18 addresses some aspects relating to fuel oil safety, SOLAS regulation II-2/4.2.1 contains
provisions related specifically to the minimum flashpoint requirement for marine oil fuel. However, there are
currently no mandatory provisions under MARPOL or SOLAS for reporting non-compliance with this fuel oil
 parameter. As an temperately measure to enhance the safety of ships relating to the use of fuel oil, all cases
where oil fuel suppliers delivered fuel oil failing to meet the flashpoint requirements specified in SOLAS
regulation II-2/4.2.1 must be reported (see Marine Notice 05/2019).

Taking into account Regulation 18.9.6 and IMO Resolution MSC.465 (101), recommended temperately measures
to enhance the safety of ships relating to the use of oil fuel, the Administrator will subsequently notify the IMO
of reported cases when confirmed.

Bearing in mind all the time for a safe and effective transition :

 Regulation 4.2.1.1 of SOLAS II-2 stipulates that except as otherwise permitted; no fuel oil with a flashpoint
of less than 60°C shall be used.

5. Changing from a High to a Low Sulphur Fuel Oil.

All ships using separate fuel oils when operating within a SOX ECA shall carry a written fuel oil changeover
procedure, developed specifically for that ship, and maintain a record of the date, time and position of the ship for
any fuel oil changeover operation, along with the volume of low Sulphur fuel oils in each tank.

The record may be included in the MARPOL Annex VI Record Book required by the Administrator, providing such
entries are maintained separately within independent sections of the book. Procedures for changing from a High
Sulphur Fuel Oil (HSFO) to a Low Sulphur Fuel Oil (LSFO) should, in addition to this processes required, address the
issues raised below and include arrangement drawings. Several practical issues relating to the development of
plans have been identified. These include the needs to. Address safety issues, including whether it is appropriate
to change to LSFO with the engine room unmanned (if applicable).

To ensure that adequate quantities of ready-to-use fuel oil for engines and boilers used for propulsion and
generating plant remains continuously available during any changeover procedures from HSFO to LSFO. Confirm
with engine and equipment manufacturers that main and auxiliary engines, and associated fuel treatment
equipment are suitable for use of LSFO and implement any recommendations made.

Implement a procedure on board the ship to check the compatibility of the different fuels to be used for the
changeover dilution process. This may be by using a compatibility spot test kit onboard or, preferably, by sending
samples of the two fuels to an independent testing service. Seek approval from the vessel’s RO for any proposed
changes to pipeline systems or fuel storage arrangements that are planned to accommodate the use of LSFO
onboard.

Several organizations and ROs have developed LSFO changeover calculators, which provide an estimate of the
time required to dilute or flush out HSFO in the fuel oil service system to meet the applicable ECA limit. It should
be noted that these calculations are an estimate for guidance purposes only and that spot samples to check actual
Sulphur content at various stages of the process are recommended to account for any operations not considered.

Bearing in mind all the time for safe and effective transition:

 You completed a suitability assessment, including reference to manufacturer’s instructions, to establish

what impacts a change of fuel type on existing machinery and equipment that may have.
  The tanks and pipelines been thoroughly flushed and cleaned to avoid crossed contamination.
 The records note that segregation of fuel system tanks and pipe work has been maintained where
necessary.
 You have carried out additional tests for bunkers before utilizing them.
 You are monitoring the vessel’s filters and fuel consumption when starting to use fresh bunkers in order
to identify any problem at the earliest opportunity?

6. Crew preparation.

It is crucial and of vital importance the constant training of the crew to allow familiarization with the operational
and safety procedures that allows a proper, effective and correct implementation on board the ships for the
transition to the IMO 2020. In this particular case it is necessary a special training on Exhaust Gas Cleaning
System operation, maintenance and repair on board.

Bearing in mind all the time for safe and effective transition:

 The crew and shore side personnel training must be carried out with appropriate records available.
 The written changeover procedures should be available to crew and the necessary associated records
available and maintained on board the vessel.
 A risk assessment in compliance shall be conducted and available on board.

December, 2019.
Inquiries concerning the subject of this Circular or any other request should be directed to:
Control and Enforcement Department
Directorate General of Merchant Marine
Panama Maritime Authority

Phone: (507) 501-5348/5350

(507) 501-5029/30
E-mail: rberrocal@segumar.com
jmbosquez@amp.gob.pa

PanCanal Building
Albrook, Panama City
Republic of Panama
Tel: (507) 501-5355 mmc@amp.gob.pa