FONAR IMO 2020

IMO Sulphur 2020 has been the keyword for the year 2019.

Rightly so. After all, the deadline for switching over to the low sulphur fuel was fast approaching.

In layman’s terms, after 01st Jan 2020, all vessels need to use fuel with sulphur content less than 0.50% m/m.

By this time, most shipowners already have a strategy in place to comply with this regulation that came in effect from 01st Jan 2020.

The strategy would most likely be among one of the following

  • Supply low sulphur fuel
  • Install the exhaust gas cleaning system (Called Scrubbers)
  • Change over to alternate fuels like LNG

imo 2020 alternatives for compliance

Each option has its own merits and demerits which I have discussed in another blog on IMO Sulphur 2020.

But the shipowner’s and ship manager’s challenges do not end with the choice of the above options.

There are more challenges ahead, beyond 01st Jan 2020.

Challenges beyond 01st Jan 2020

The biggest challenge that all stakeholders may face is the availability of low sulphur fuel.

I am not talking about a few ports which would not have the infrastructure in place to supply low sulphur fuel.

Shipowners and managers can take care of that.

When the shipowners know about these ports they would make arrangements for bunkering at a different port in advance where low sulphur fuel will be available.

I am talking about last-minute changes.

Let us say a ship is scheduled to receive low sulphur fuel at a port.

And when the vessel arrives or is about to arrive at the bunkering port, the bunker supplier informs that the low sulphur fuel is not available.

The ship does not have a sufficient quantity of fuel onboard to reach a port where low sulphur fuel is available.

Or the diversion is way too much for the alternative port of fuel supply.

Shipowners would be in a fix.

It is not that I am the inventor of the above situation.

IMO has assessed this situation and put the measures in place to address this situation.

The measure to address this situation is Fuel Oil non Availability Report (FONAR).

FONAR comes to the rescue

FONAR stands for Fuel oil Non Availability Report.

Fuel Oil Non Availability Report

In case the compliant fuel is not available, the vessel is not required to unduly delay or deviate from the intended voyage.

The vessel can arrive at the port with non-compliant fuel provided that the vessel and vessel managers have made all the efforts to receive the compliant fuel.

FONAR is a report that lists all the details of the voyage and efforts made by the ship operator to get the compliant fuel.

Each port state may have its own format for the FONAR but all would more or less contain the same information.

Here is one of the FONAR format.

FONAR is not an easy way out

We might think that life would be easy with FONAR.

We try to get compliant fuel, we do not get it and we receive high sulphur fuel and send the FONAR to the port state of the next port and that is it.

No, it isn’t that easy.

Sending the FONAR does not mean that we are allowed to use the high sulphur fuel.

It is completely up to the discretion of the port state

  • if the vessel can be allowed to use non-compliant fuel
  • If the vessel will be fined for use of non-compliant fuel

FONAR simply helps the port state to make that decision.

If the port state is completely satisfied with the efforts made by ship operators as described in the FONAR, the ship may be allowed to use non-compliant fuel without any penalty to the vessel.

If not, the port state may allow use with the penalty to the vessel which would depend upon the seriousness of the non-compliance.

It is entirely up to the port state to decide about the extent of the penalty.

That makes the FONAR so much important.

FONAR is an expensive tool

FONAR is considered to be an expensive tool shipowner should avoid.

There is a reason for that.

It is not about the penalty alone.

Some port states may accept the FONAR and impose no penalty at all.

But if the compliant fuel is available at the port of arrival, they may want the vessel to debunker the non-compliant fuel and bunker the required fuel.

This may require not only de-bunkering but also cleaning of the tank before compliant fuel can be bunkered.

Singapore is one such port where even when FONAR is accepted, it would be required to offload the non-compliant bunker and take compliant bunker.

This process could involve thousands of dollars and days of off-hire for the vessel.

So the best possible way is to avoid being in a situation where the use of FONAR would be required.

To be able to do that each stakeholder needs to take some kind of responsibility to achieve that.

Responsibilities of Master, chief engineer, and the ship

Master, chief engineer, and ship staff play an important role under FONAR.

Their role is that of proactive planning.

This includes

  • Do not wait for the commercial operator to ask you about bunkers. Remind them instead well in time.
  • Maximizing the bunkers in such a way that the vessel is not short of low sulphur bunkers for the entire voyage
  • Proactively calculating the quantity of bunkers to receive at each bunkering port so that the vessel is not short of low sulphur bunkers at any time.

Let us cover this in detail.

Constant reminders about the bunkering activity

Even though bunkering is primarily the responsibility of the vessel’s commercial operator, it does not stop us from timely remind them.

Time is an important factor for the successful consideration of FONAR.

For example, if the communication between vessel and vessel operator regarding bunkering started just a couple of days before arrival the bunkering port, there could be no valid excuse for the non-availability of the fuel at the bunkering port.

And in this case, we can expect the port state to reject the reason for submitting the FONAR.

So the first responsibility of the vessel is to remind the vessel’s commercial operator regarding the bunkering at the next bunkering port.

Maximizing the bunkers

If a vessel is to load maximum bunkers, plan to receive maximum bunkers as per the company’s allowed limit.

If the company permits loading 95% of the bunker tank capacity, do not unnecessarily reduce the quantity to receive say up to 85% just because you do not want to trouble yourself to load 95% of the capacity.

For example, if the vessel has to submit FONAR because the vessel is short of 10-20 MT of low sulphur bunkers, FONAR could be rejected because of vessel short-loaded bunkers at last bunkering port.

Proactive bunker calculation

Loading maximum bunkers is not always a great idea.

We also need to consider to have at least one tank empty before arrival bunkering port with other bunker tanks close to full.

Let us understand this with an example.

A Vessel has 3 bunker tanks with capacities 500 MT, 450 MT, and 400 MT.

Vessel to receive bunkers at Fujairah with another bunkering option enroute in Singapore.

Vessel departs Fujairah with all bunker tanks full. Bunker consumption from Fujairah to Singapore will be about 300 MT.

On Arrival Singapore the vessel will have 500MT, 450 MT and 100 MT in the bunker tanks with no option to receive bunkers in Singapore.

Departure Singapore bunker onboard would be 1050 MT.

If the vessel had received 100 MT less bunkers at Fujairah, we would have one tank empty on arrival Singapore.

In this case, the vessel could have received 400 MT of bunkers in Singapore.

Bunkers onboard on departure Singapore would be 1350 MT instead of 1050 MT.

If after all the efforts, the ship has to receive non-compliant fuel, then it is the master’s responsibility to send the FONAR to its flag state and port state of their next port of call.

If this is sent by the company on the master’s behalf, the mast must ask the company to keep his email in copy or should ask for the email and FONAR report sent.

Responsibilities of Commercial Operator

With IMO 2020 the responsibilities of the commercial operators are going to increase.

Earlier the responsibility of the commercial operator was to get the fuel for the vessel.

Now apart from this, the commercial operator needs to make sure that not just the fuel but compliant fuel is received by the vessel.

This is because earlier fuel with more than 3.5% sulphur (non-compliant fuel) was not available globally.

But now even though the global sulphur limit is reduced to less than 1%, fuel with up to 3.5% sulphur content would still be available for supply to the ships using scrubber technology.

With respect to FONAR, having a contract with one fuel supplier is not considered to be a valid reason for the non-availability of the fuel.

For example, let us say the commercial operator of the vessel has a contract with one fuel supplier in Singapore.

This supplier was unable to provide the compliant fuel to the vessel for some reason.

In this case, it is the responsibility of the commercial operator to enquire with other suppliers in the port for the supply of compliant fuel.

This may be a little expensive option but if this is not done and vessel arrives at a port with non-compliant fuel and submits FONAR, it is most likely that the reason mentioned in FONAR for non-availability will not be accepted by the port state.

Responsibilities of Port state

There are two major responsibilities of port states with respect to FONAR.

First, they have to decide on the validity of the evidence presented in the FONAR by the vessel.

According to their judgment, they have to decide on the action required to deal with non-compliance.

Even though Marpol annex VI, regulation 18.2.3 urges the port states to not take any control measures if actions in FONAR are found to be appropriate.

REG 18 Annex VI MARPOL FONAR

However, it is absolutely the port state’s discretion on what action they take.

The second responsibility of the port states is to notify IMO when any vessel has submitted FONAR.

IMO assesses the situation of fuel availability based on the FONARs that it receives.

Conclusion

The best way to use FONAR to our advantage is to never arrive in a situation that warrants the use of FONAR.

Everyone from the ship’s staff to the voyage manager and commercial operator plays an important part in achieving that.

And it is by being proactive to the extent that the vessel never is short of compliant fuel.

But sometimes situations are not our favor and we must bunker non-compliant fuel.

In this case, the master must fill the FONAR in a discussion with the company and commercial operator.

Master then must send the FONAR to the port state of next port and to the flag state of the vessel.

The important factor in the acceptance of the FONAR is if the vessel had made all the efforts to get the compliant fuel.

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Capt Rajeev Jassal

About Capt Rajeev Jassal

Capt. Rajeev Jassal has sailed for over 20 years mainly on crude oil, product and chemical tankers. He holds MBA in shipping & Logistics degree from London. He has done extensive research on quantitatively measuring Safety culture onboard and safety climate ashore which he believes is the most important element for safer shipping.

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42 Comments

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Ilyas
Feb 25, 2020

It is always a pleasure to read your articles Cpt. We wait for a new topic for along time .Thank you for your efforts sir ...

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I am very happy to see you back . You still having so many things to learn from you . Thanks captain

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????ARE YOU ABSOLUTELY IN NEED OF THE SERVICES OF A PROFESSIONAL HACKER?(CATCHING A CHEATING SPOUSE[Phone Hack], RECOVERY OF LOST FUNDS, CREDIT SCORE UPGRADE, WEBSITE HACK...) High prolific information and Priviledges comes rare as i would be sharing with you magnificent insight you wish you heard years before now. As it's been understood that what people don't see, they will never know. When you wonder “which hacking company should I hire, the first aspect that should concern you is quality. Clearly, you want to embark for services that povides swift response, Thanks to our talented and Astonish Hackers , you are rest assured that your expectations will always be met. You’ll be glad to find out that our services Implies precisions and actions. This post is definitely for those who are willing to turn their lives around for the better, either financial-wise, relationship-wise or businesses. Welcome to the Global KOS hacking agency where every request on hacking related issues are met within a short period of time. If your shoe fits in any of the required services below, you will be assigned to a designated professional hacker who is systematically known for operating on a dark web V-link protocol. The manual Operation of this hackers is to potentially deploy a distinguished hacking techniques to penetrating computers and various type of database system to meet your request. Penetration of computing systems are achieved using core software tools like Ransomeware, SQL/Keylogger injection. botnet, trojan and DDOS attacks. Providing value added services to clients as a hacker has been our sustaining goal. Are you faced with cyber challenges like ????Recovery of lost funds:✅It saddens our mind when client expresses annoyance or dissatisfaction of unethical behaviours of scammers. We have striven to make tenacious efforts to help those who are victims of this flees get off their traumatic feeling of loss. The cyber security technique used to retrieving back the victims stolen funds is the application of a diverse intercall XX breacher software enables you track the data location of a scammer. Extracting every informations on the con database, every requested information required by the Global KOS would be used to tracking every transaction, time and location of the scammer using this systematic courier tracking base method. ???? Hacking into the mobile phone of a cheating spouse.✅ This type of hack helps you track every movement of your cheater as we are bent on helping you gain full remote access into the cheater's mobile phone using a Trojan breach cracking system to penetrate their social media platforms like Facebook, whatsapp, snapchat etc. This spy processing is used via an HDSI folder which synchronizes the target mobile operating system into a clone S-Drive unit. ????Credit Score Upgrade:✅Due to our transformed changes on Equifax tracking , upgrading of credit score are backed by our cyber tech breaching licence, This hacking process drastically generates you an undestructive higher credit score which correlates to a higher level of creditworthiness. The time frame for upgrading a credit score requires eighteen(18) hours ????️ BITCOIN GENERATOR:✅ (Higher job profile). This involves using the ANTPOOL Sysytem drifting a specialized hardware and software implementing tool in slot even-algorithms to incentivize more coins into your wallet which in turn generates more coins exponentially like a dream at specified intervals. The company is large enough to provide comprehensive range of services such as. • Email hacks???? • Hacking of websites.???? • Uber free payment hacks.???? • website hack.???? Our strength is based on the ability to help you fix cyber problems by bringing together active cyber hacking professionals in the GlobalkOS to work with. Contact: ✉️Email: clarksoncoleman(at)gmail • com. Theglobalkos(at)gmail •com. ©Global KOS™ 2030.•√

Deby Johnson
Deby Johnson
Sep 6, 2020

Do you need a personal loan? Or even expand your business? Do you need money for inventory, cash flow, expansion or advertising? Do you want to start a business and have no or low capital? Do you need refinancing? Want to avoid a lengthy loan process with hidden fees and no guarantee of approval? C.E.O. Deby Johnson. debyfinancingloans@gmail.com Whatsapp Number: +447459797459 Whatsapp Number: +918375004762 DEBY FINANCING LOANS COMPANY

Joseph Eric
Joseph Eric
Sep 10, 2020

Welcome. DO NOT BE TROUBLED ANYMORE. you’re at the right place. Nothing like having trustworthy Hackers. have you lost money before or bitcoins and you are looking for a hacker to get your money back? You should contact us right away. It's very affordable and we give guarantees to our clients. Our hacking services are as follows: -Hack into any kind of phone _Increase Credit Scores _Western union, bitcoin and money gram hacking _Criminal records deletion_BLANK ATM/CREDIT CARDS _Hacking of phones(that of your spouse, boss, friends, and see whatever is being discussed behind your back) _Security system hacking... and so much more. Contact THEM now and get whatever you want at Email: atmgeniuslinks@gmail.com   Whatsapp: +1-(781)-656-7138.   WHY WOULD YOU NEED TO HIRE A HACKER: There are so many Reasons why people need to hire a hacker, It might be to Hack a Websites to deface informations, retrieve information, edit information or give you admin access. • Some people might need us To Hack Their Target Smartphone so that they could get access to all activities on the phone like , text messages , call logs , Social media Apps and other informations • Some might need to Hack a Facebook , gmail, Instagram , twitter and other social media Accounts, • Also Some Individuals might want to Track someone else's Location probably for investigation cases • Some might need Us to Hack into the Court's Database to Clear criminal records. • However, Some People Might Have Lost So Much Funds With BINARY OPTIONS BROKERS or BTC MINING and wish to Recover Their Funds • All these Are what we can get Done Asap With The Help Of Our Root HackTools, Special HackTools and Our Technical Hacking Strategies Which Surpasses All Other Hackers. ★ OUR SPECIAL SERVICES WE OFFER ARE: * RECOVERY OF LOST FUNDS ON SCAM INVESTMENTS, BINARY OPTIONS TRADING & ALL TYPES OF INVESTMENT SCAMS. * Credit Cards Loading ( USA Only ) * BANK Account Loading (USA Banks Only) ★ You can also contact us for other Cyber Attacks And Hijackings, we do All★   Whatsapp: +1-(781)-656-7138.    ★ CONTACTS: * For Binary Options Recovery, Feel free to contact us via Email: atmgeniuslinks@gmail.com for a wonderful job well done, Stay Safe. IT HAS BEEN TESTED AND TRUSTED.

Monika Love
Monika Love
Sep 10, 2020

I will always advice, that when you want to trade, you should seek the assistance of a well trained personnel. I've been trading with Robert Seaman and it would be selfish of me, if i don't recommend them. With their well guarded signals and forever active strategies i have been able to make over 11,200usd weekly Email: Robertseaman939@gmail.com

ALEXANDRA MCDONALD
ALEXANDRA MCDONALD
Sep 13, 2020

I got my already programmed and blanked ATM card to withdraw the maximum of $1,000 daily for a maximum of 20 days. I am so happy about this because i got mine last week and I have used it to get $20,000. Mike Fisher Hackers is giving out the card just to help the poor and needy though it is illegal but it is something nice and he is not like other scam pretending to have the blank ATM cards. And no one gets caught when using the card. get yours from Mike *email: int.hackers002@gmail.com you can also call or whatsapp us Contact us today for more enlightenment +1(765) 705-0044

Robert Christopher
Robert Christopher
Sep 15, 2020

Good day everyone My name is Robert Christopher and I am from Austria. I want to use this time to write to the internet that anyone if you need a true loan Piper Sandler is the right company to apply from few days i was in need of money and i looked for a loan online i saw a company and i applied that company cheated me 2 times of my money i was so sad cause i needed money so i decided to look for another company and i applied from another company that same company also told me to deposit money and i did and never got my loan i was like what is happening to me cause i needed money urgently to buy a house cause if i do not get a house soon my landlord will drive i and my family away from his house so i needed to get my own house. When i was searching again i saw this company Piper Sandler i saw a lot of people testified about this company that the company is truly great so at first, i was afraid to apply cause i was cheated 2 times so i said to myself let me try and see if this company was real so i applied. When i applied they told me all i was needed to do i was still afraid but i trusted them and they assured me that in 8 hours time i was going to be with the loan i wanted for my loan and on my eyes i received an alert from my bank that there were a sum of 200,000.00 Euros into my bank account and i was very happy in a while ago the company called me and asked if i have received my loan and i told them yes and o thank them and as i am writing this message on the internet now this company have also helped my 2 brothers so anyone if you need a true loan Piper Sandler is the right company to apply from. In case you are in need of money you can only contact them via mail customerservice@pipersandlerinquire.com or WhatsApp +1 909 343-4860

Amanda Smith
Amanda Smith
9 hours ago

I am so grateful to Mr.Carlos Oscar.. You have made my dreams come true, after i try to invest with so many expert forex and binary traders who scammed me, I finally met carlos oscarthrough someone he helped, I took a bold step invested $500 which was all I got at the moment and unbelievably I got my profit worth $5000 within 7 days I am happy right now so f you are interested in starting up an investment with him kindly Contact Him now on WhatsApp +1(502)2064419 or Email: tradewithcarlos2156@gmail.com

GABRIEL RYAN
GABRIEL RYAN
2 hours ago

Hello everyone, I want to testify about Luis Carlos who help me invest my bitcoin and made me who i am today, i never believe in bitcoin investment till i met Luis Carlos, I saw so many testimony about Luis Carlos helping people to invest their bitcoin, So i decide to contact him and invested $500 and after 7 days i receive my profit of $5,000 on my bitcoin wallet, Ever since i have been investing with them and i always receive my profit without any delay, so if you want to invest your bitcoin, Luis Carlos is the best trader you can invest with and getting your profit is guarantee, So if you want to invest just contact them and they will guide you on how start your investment . Email: tradewithluiscarlos@gmail.com or WhatsApp : +16234044993

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