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Will the implementation of the Sulphur Cap 2020 be delayed?​

By Mr. Kim Yeon-tae, Executive Director, Korean Register ​

Two of the most discussed issues in the international maritime industry in recent years have been the implementation of Ballast Water Management Convention (BWMC) and the approaching Sulphur Cap 2020.


The prolonged maritime downturn of the last decade combined with the substantial capital expenses required to meet the requirements of both conventions have raised serious concerns among maritime stakeholders and have led to heated debates at IMO meetings, with many calling for the postponement of their implementation.

The first convention to allow postponement was the BWMC. The two-year postponement of the installation of the Ballast Water Management System (BWMS) was agreed at the 71st Marine Environment Protection Committee (MEPC 71) which took place in London in July 2017. As a result of the many obstacles to the effective implementation of the BWMC, such as the lack of facilities to install BWMS onboard, the application of NEW G8 and USCG Type Approval, the decision was made to postpone its implementation.

However, this decision means that the early movers – i.e., those shipping companies which had already installed BWMS on board their ships in accordance with the convention – are having to face many more hurdles such as non-compliance with the requirements of USCG type-approval, etc., whereas those who decided to wait and see – can now benefit from installing a more reliable system with a proven track record.


Now the eyes of the maritime industry are turning to the global Sulphur Cap which will come into effect in 2020. But, there is a significant doubt across the industry that the convention will actually come into effect in 2020, as currently scheduled.

With less than two years left before the sulphur convention comes into force, it is evident that the relevant parties are far from being fully prepared. For example, the IMO regulations, which are relevant to the convention, in terms of how to apply and implement the convention, have still not been finalized.

The majority of shipping companies have still not made up their minds on what measures they will be taking, to comply with the convention. The refineries, on the other hand, are not expected to be able to produce a sufficient amount of low sulphur fuel oil (LSFO) for ships, in time. These factors are similar to those faced by the industry when it came to complying with the BWMC, and so many in the industry have voiced a need to postpone the implementation of Sulphur Cap 2020.

However, I think there is very little chance that the implementation of the global Sulphur Cap 2020 will be postponed, for the following reasons.

It is anticipated that there will be a regional shortage of LSFO after 2020. However, if LSFO is not available at the place of bunkering, under MARPOL Annex IV/18.2, the ship is simply allowed to be exempt from compliance with the Sulphur Cap 2020 regulation. Therefore, a shortage of LSFO will not be a legitimate excuse for postponement.

Some ships will be fitted with Exhaust Gas Cleaning System (EGCS) to comply with the Sulphur Cap 2020. The availability of EGCS may not fully meet the demand before the year 2020. In such cases, a ship will be allowed to use LSFO until it is equipped with an EGCS.

In the last two IMO meetings, the 4th Pollution Prevention Response (PPR) held in February 2017 and the 71st MEPC, several member states highlighted their concerns regarding the difficulty of implementing the global Sulphur Cap, but they were excluded from discussions. It’s likely to be difficult for IMO member states to re-submit the same proposal in future committee meetings.

Furthermore, to amend the conventions, the proposal must not attract objections from more than one-third of the contracting Governments. At the moment the number of member States that have ratified MARPOL Annex IV is eighty-nine (89), and the number of states objecting the postponement of implementation is likely to be more than thirty (30). With the EU member states objecting, the likelihood of postponing the implementation of the Sulphur Cap 2020 convention seems very low.

Above all, if the implementation of Sulphur Cap 2020 is postponed once again after the BWMC, IMO will lose public confidence and face a significant obstacle to the smooth implementation of any future conventions. In reality, the chances of postponing the Sulphur Cap 2020, are very, very small.


The Korean Register is an IACS member classification society established in 1960 with the purpose of promoting safety of life, property and the protection of the marine environment.

KR currently classes an international fleet of 3,032 vessels totalling 69 million GT. It is headquartered in Busan, South Korea and operates a network of 66 offices around the world. It is authorized to perform statutory and certification services in 78 countries.


Trade Suggests Options to Erase Congestion Out of Chennai Port

By N Gajendran,  Customs Broker


For the past 15 years, the Chennai Port is suffering from continuous congestion in terms of inefficient container handling. Due to that sluggishness, nearby ports are getting more volume and growing rapidly. The current volumes handled by nearby ports are actually the one that moved away from Chennai port due to the heavy congestion.

The Big USA buyers such as ‘Gap Inc’, Walmart and Decathlon do not prefer Chennai Port for their movement mainly due to the port congestion, uncertainty of planned vessel connection, and also inefficiency of operational handling.

With reference to improve productivity in container terminals in the port and to move out congestion from Chennai Port permanently, we, as one of the leading players in the logistics supply chain system, would like to give our suggestions to change the present situation.

The real problems:

According to the trade, total volume of each container terminal in the port is 70,000 TEUs that is 50,000 Units of 20ft and 40ft. There are two operations normally handled at ports. LO/LO  at Port Yard —From and To the Ship and LO/LO  at Port Yard —From and To the Trucks. (CFS/ ICD).

When calculated, that is 50,000 units  X 2 Moves = 1,00, 000 moves by RTG at each terminal. The time taken for handling of each or per box of  20 / 40ft container by RTG at port yard is 15 Minutes which leads to 4 units per hour.

The handling of containers by Per RTG per Day work outs to only 88 Units, that is 4 Units per hour multiplied by 22 hours.  50,000 Units or 1,00,000 moves divided by 30 days = 3333 Moves and 1666 Units per Shift.

Per Shift 10 hrs = 1666 Units divided by 88 Units per Day per RTG= Per Shift requirement is 19 RTGs. Do these terminals deploy adequate RTGs per Shift?

The shortage of required RTGs in the port yard has caused slow handling of containers and ultimately creates congestion. It is the major hindrance to the trade.


Below is the flow chart of the current operation at the Chennai Port.

The containers are unloaded from the Ship by Quay Cranes and loading onto the local Trucks (as inter-carting movement) –unloading in the yard by RTG –Within the 24 to 36 hrs after the unloading operation completed at the Container Yard (CY), the Delivery of containers starts by the CFS Trucks or CFS nominated Trucks.

Normally, the trucks come inside the port either with Export Laden or Empty Containers or as an empty truck to pick up the PNR import Box.

Considering this current practice as unnecessary, we suggest remedial solutions, which all the other ports in our country follow. In other ports, Containers are delivered at Vessel Hook Point. That is, delivery and receipt of containers to / from directly from Ships Hook.


PNR processing has to be completed in advance that is 24 Hours before the birth of vessel / ship at Dock. Form-13 to be released to respective CFS 24 hrs before vessel berth.

Six hours (6 hrs) before the vessel’s actual berthing, the necessary arrangements and planning should be made to make the trucks to be on the queue near the marked area to pick up the container directly from Vessel Hook Point. To attain such readiness, all the trucks should be provided with Form-13 in hand. Furthermore, with a view to streamline, the truck queue should be arranged in such a way to accommodate more trucks in the following manner in three rows or lanes. It should be like — one row for heavy weight container that is 1 x40 ft or 2x 20ft TEU, another one is for light weight  only 40 ft or 20ft TEU, and the third one should be for inter-carting the non-CFS nominated containers to move to the yard.

When container comes out from the ships released by quay crane, driver of the waiting truck should accept the first available container and move out without any delay. For example, if the container belonged to Triway CFS but the truck standing on the queue to pick up the container is bound for another CFS having Form 13 to Sanco CFS, the driver must hand over Triway Form 13 and carry Sanco CFS container without any objection.

Likewise, all CFS truck or CFS nominated truck should move the container out.

When the Port Out Gate generates the Gate Pass, it should be clearly mentioned the name of the CFS and inform to the Driver to carry to particular CFS. The concerned CFS also should get mail with the full details of Import Container, Truck number.


With this type of movement, the operation cost of Wharf to Yard movement of Rs. 1000/- per TEU could be saved. And more importantly, huge operational cost of equipment and its fuel will also be saved considerably. As such, 50,000 boxes will be moved directly out from vessel point without any hindrance and congestion of trucks.

And, yard operation will be totally 60% free and it will always get large empty space to accept and accommodate more Export-Laden containers. The Port will get an additional capacity to handle three times of current volume. Within the 24 Hrs, all import containers will be moved out directly from the Ship

If the system is followed properly, congestion on road and port will not arise, and it will be over once for all.

The export containers will be moved fast from the yard to the concerned vessel as planned.

If the congestion goes, all export volume from other ports will definitely come back to Chennai Port. Import volume, which we have lost to other ports due to congestion, will also return back for handling here. We can easily say that the Chennai Port will register threefold growth in cargo handling.

Since containers are moved out of the port in shortest time, the port will be able to maintain better and planned connectivity with international route mother vessels.

And, it will give Chennai Port the much-needed grading in trade as committed port. Any incident and accident in the case of containerized cargo, the concerned CFS operators will take care of everything.

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