Drew Marine
Drew Marine

IMO 2020

With IMO 2020 just months away, ship operators who are carrying high sulfur fuel oil (HFSO) and are planning to switch to very low sulfur fuel oil (VLSFO) will need to prepare their fuel tanks. HFSO contains a maximum sulfur content of 0.5%. The fuel tanks will very likely be in need of cleaning due to the deposition of contaminants, such as sulfur, sediment, and cat fines, that may have accumulated over time. The cleaning of the fuel tanks will need to be completed before receiving the first bunker stem of compliant VLSFO.

Without properly cleaning the HSFO tanks, there are two main operating challenges that will arise after the first loading of compliant VLSFO. First, it is anticipated that VLSFO will contain more distillate components than HSFO, which contains mostly residual components. As such, the distillate components, which are known to have good solvency properties, will dissolve the contaminants in the fuel tanks. If the contaminants are not effectively reduced during centrifuging and filtering, they may cause irreparable harm to fuel injection equipment and to the engine. Second, the un-pumpable material, which is expected to have high sulfur content, will mix with VLSFO and significantly increase the risk of having non-compliant fuel. In other words, the vessel will not meet the IMO 2020 allowable maximum fuel sulfur of 0.5 mass % that is needed for compliance.

As most fuel tanks are designed to allow up to 10% fuel remaining on board (ROB), there could be up to 10% of un-pumpable fuel containing the aforementioned contaminants. The exact amount of un-pumpable fuel and contaminants will be dependent on tank design and whether or not the tanks had been regularly cleaned and/or treated with any type of fuel oil conditioner. Again, the said scenario could be present in all HSFO tanks!

Ideally, the fuel ROB and other un-pumpable material should be mucked out of the fuel tanks sometime during a dry docking in 2019. However, unless the ship has already planned a dry docking in 2019, it would be unlikely for any operator to specifically schedule a dry docking just for fuel tank cleaning. Furthermore, the availability for dry docking spaces may be limited as other capex projects, such as SOx scrubber installations and/or ballast water treatment systems (BWTS), may have already been reserved by other vessel operators in 2019.

Short of a planned or available dry docking in 2019, many ship operators will need to prepare their fuel tanks by performing a tank cleaning in situ. This preparation is necessary to mitigate possible operating disruptions and challenges associated with switching to a relatively low viscosity fuel, VLSFO, after many years of using high viscosity, HSFO. In addition to fuel tanks, all associated fuel piping may need to be flushed to eliminate all remnants of HSFO.

To mitigate the first challenge, Drew Marine has assembled a simple 3-step procedure for preparing their HSFO tanks to receive compliant VLSFO. The procedure is called HSFO Tank Cleaning In situ.


Please contact us at IMO2020@drew-marine.com to learn more about Drew Marine’s HSFO Tank Cleaning In situ Program.


The procedure relies on the application of a series of fuel additive treatments dosed during at least two bunkerings in 2019 that are followed by a post-treatment tank inspection.

The application of fuel additive treatments will minimize any manual cleaning of the fuel tanks that may still be required afterwards as well as limit the production of slop water from tank cleaning/flushing done by the crew. As an added benefit, the fuel additive treatments will help to reclaim any usable fuel that was previously left as un-pumpable material and will leave behind only the deposits which are unusable and possess little to no energy content.

Over the course of several bunkerings, the application of successive fuel additive treatments will slowly clean the tanks of any accumulated organic deposits without overloading the centrifuges/purifiers and fuel filters. The tank inspection is required to ascertain the effectiveness of the fuel additive treatments and to determine whether any of the remaining contaminants, which are expected to be mostly inorganic in nature, would have to be manually removed. While organic fuel deposits can be reclaimed and burned in the engine or boiler, inorganic deposits are comprised of incombustible solids. The incombustible solids are best removed from the fuel tanks manually. If the inorganic deposits are not removed manually nor sufficiently reduced during centrifuging and filtration of the fuel, the solid deposits may cause severe damage to fuel injection equipment and to the engine.

During the tank cleaning process, it is expected that centrifuges will be run with shorter sludge cycle times and that additional back-flushing of the auto-filter will occur. As such, the onboard centrifuges and fuel filters will need to be maintained and cleaned more frequently in order to keep up with the increased sediment load coming from the fuel tanks. Please contact Drew Marine for more information on how our cleaning solutions can help with the overall tank cleaning process.

To mitigate the second challenge, the regulatory bodies are recommending to pump distillate fuel or MGO to the fuel tanks in order to blend and to reduce the overall sulfur content of fuel ROB to below 0.5 mass %. Pumping MGO to the fuel tanks will also serve to flush all fuel tanks and piping of any remaining HSFO. Certain operators may choose to proceed with this additional procedure in order to avoid having non-compliant fuel ROB. CLICK HERE TO READ ENTIRE ARTICLE.

CREW CARE Accommodation Cleaning Program

To improve crew welfare by providing cleaner, safer, and healthier living spaces, and to support customer CSR and sustainability goals, Drew Marine recently launched The CREW CARE Accommodation Cleaning Program. CLICK HERE to read recent customer testimonials for our innovative program and to learn more about it.

Span Gases

Today’s ships are more frequently using sophisticated instruments to monitor onboard atmospheres. These instruments are critical in measuring dangerous levels of flammable gases, toxic gases, exhaust emissions, and oxygen levels in atmospheres. And they are required to ensure the safety of the crew, ship, and the quality of the product being transported. In order to make certain these instruments are working correctly, calibration gases are necessary. The Drew Marine Span Gas Program will deliver the consistency, reliability, and compliance our customers demand for all of their calibration requirements.

SOLAS requires ships carrying cargoes that are likely to emit a toxic or flammable gas, or that are likely to cause oxygen depletion in a cargo space, be provided with an appropriate instrument for measuring the concentration of gas or oxygen in the air, together with detailed instructions for its use. The calibration, according to the IMO MSC 1370, should be carried out at a minimum once a month and the system should be designed to permit onboard calibration by the crew. Implicit in the provision is the requirement that the operator provides the correct instrument for each gas testing need. It should be noted that the different gas testing functions may be incorporated into a multi-function gas measuring instrument. The gas measurement instrumentation on board a tanker should form a comprehensive and integrated system that addresses all the necessary applications identified by the operator. The instruments should be fit for the task to which they are applied, and users should be made aware of the particular applications and limitations of each instrument. Users of gas measuring instruments should be trained in the proper use of the equipment, to a level suited to their work duties. A sufficient number of gas measuring instruments should be available on board the ship to meet all the identified requirements. This will allow for instrument failures, servicing requirements, and the capability of the ship’s staff to undertake repair and certified calibration of the instruments. All of the following factors must be considered: The SOLAS regulations found in Chapter II-2, IMO MSC circular 1370, Chapter 16 of the FSS Code, the frequency of equipment usage, and the gas detection equipment OEM requirements. Once these have all been reviewed the procedure for calibration, including the frequency, can be developed for the ship’s Safety Management System (SMS). Drew Marine has authorized equipment calibration experts for both onboard fixed or portable systems that require calibration. Whether if it is a small personnel protective device or a large fixed gas detection system, Drew Marine can perform the calibration on board or at our many service centers.

Drew Marine has a wide range of span/calibration gases available in both refillable and disposable cylinders. The Drew Marine 10-liter (Water Capacity) cylinder (PCN 0726119) is the standard for refillable span gas cylinders. Drew Marine also offers a complete line of disposable cylinders for calibration gases. Disposable cylinders are available in a variety of sizes ranging from 12 Liter (gas) to 103 Liter (gas). To optimize your supply needs, Drew Marine also stands ready to provide the equipment, such as gas regulators, cylinder brackets, and tubing for both refillable and disposable calibration gas cylinders, and with our technical expertise, we can guide you to the correct gas and cylinder based on your usage rate, the gas, and the gas’ expiration date. For details on span/calibration gases, contact your Drew Marine Representative.

Drinking Water Regulatory Update

ILO Maritime Labour Convention (MLC), 2006 entered into force on August 20, 2013.  The MLC requires crews be provided with quality drinking water.  Additionally, MLC requires auditors (e.g., Flag/Class) to verify that there are frequent and documented inspections and monitoring of drinking water.   Port State Control provisions of the MLC also mandate that ships of all countries (irrespective of Flag State ratification) will be subject to inspection by Port State Inspectors when those vessels call at ports of signatory Port States. For our latest enhancement to the Drew Marine solution to drinking water monitoring. CLICK HERE.

Lifeboat Release & Retrieval System Regulatory Update
If Dry-Docking between 01 July 2014 to 01 July 2019 …

In May 2011, the IMO adopted amendments to the Chapter III of SOLAS - Life Saving Appliance (LSA) Code,
and issued the MSC.1/ Circular 1392 “Guideline for the Evaluation and Replacement of Lifeboat Release and
Retrieval Systems (ie. On-load Release and Retrieval Systems, OLRRS) that became effective 01 January 2013.
While this MSC.1/Circular currently contains a provision for the replacement or modification of lifeboat releasing
gear-mechanism hooks at a ship’s first scheduled dry-docking, during the period 01 July 2014 to 01 July 2019, it
also requires that the installed releasing gear/ hooks be evaluated for LSA Code compliance, with regards to
technical aspects, strength, and performance tested as well. This phase was required to be completed by 01
July 2013, with reporting to the IMO, via the USCG, for listing on the Global Integrated Shipping Information
Systems, or GISIS database. The GISIS is a web-based collection of manufacturers’ OLRRS that have been
evaluated and assigned the appropriate, applicable categorization : Compliant, Compliant after Modification, or
Non-Compliant/ replace with new system. Hook release systems not mentioned in the GISIS database are
presumed Non-Compliant, and shall be replaced. For more information on GISIS, CLICK HERE (requires you to log in).

Drew Marine and its marine division, Alexander/ Ryan Marine Services – a recognized expert in lifeboat hook/
OLRRS matters – have been actively involved in this process, through advising our customers on how best to
comply with the regulations, as well as, offering timely, technical solutions to them.

CLICK HERE for a brief summary of “Lifeboat Release & Retrieval Systems/ A Brief Summary - New IMO
Regulations” and applicable IMO MSC.1/ Circular 1392 and Circular 1327 (LB Fall Preventer Devices). Please
contact your local Drew Marine Account Representative for further information, in addition to the entire presentation.

MARPOL Annex V Regulatory Update

MARPOL Annex V has been amended per IMO Resolution MEPC.201(62). Under the amendments, effective 1 January 2013, the discharge of all “garbage” into the sea will be prohibited. Generally, under Annex V, allowable discharge of garbage is restricted to food wastes, animal carcasses, identified cleaning agents and additives, identified cargo residues, and identified cargo residues entrained in wash water.

The amendments apply to those cleaning agents and additives used for cargo hold cleaning, external surface washing, and deck washing. Cleaning agents/additives used in said applications are considered “operational wastes” and thus garbage under MARPOL Annex V. Operational wastes do not include grey water, bilge water, or other similar discharges essential to the operation of a ship, taking into account guidelines developed by the IMO, i.e., 2012 Guidelines for the Implementation of MARPOL Annex V. The guidelines define other similar discharges essential to the operation of the ship, including boiler/economizer blow down, machinery waste water, and gas turbine wash water, to name a few.

While cleaning agents and additives contained in hold wash water and deck and external surface wash water are considered "operational wastes" and thus "garbage" under Annex V, these cleaning agents and additives may be discharged into the sea in so long as they are not harmful to the marine environment. Note: There are discharge limitations, depending on the vessel’s area of operation.

A cleaning agent or additive is considered harmful to the marine environment if it:

  • is classified a "harmful substance" in accordance with the criteria in MARPOL Annex III
    (One that is classified as a marine pollutant under IMDG Code.); or
  • contains any component which is known to be carcinogenic, mutagenic or reprotoxin (CMR).

Drew Marine’s recommended cleaners for cargo hold cleaning and external surface/deck wash are compliant with the MARPOL Annex V Amendments. For additional information on our recommended cargo hold cleaners for bulk carriers, contact your Drew Marine representative.

For a copy of IMO’s simplified overview of the discharge provisions of the revised MARPOL Annex V (resolution MEPC.201(62)), which will entered into force on 1 January 2013. CLICK HERE.

Refrigerant Industry Update

The United States’ original planning called for elimination of R-22 by 2015 by stair-stepping the amount of
R-22 available in the marketplace. The US model established a baseline volume for the year 2000 with reductions in 2004 and 2008 coupled with the elimination of R-22 in some new air conditioning and refrigeration equipment. In 2009 a new model was developed reducing year-to-year production and availability annually in order to create a balanced phase-out by 2015. Under this model, supply and demand have been relatively well matched. Through 2011 there has been sufficient R-22 in the US market for the international marine requirements. CLICK HERE to download Refrigerant Industry Update. For our solution to management of R-22, CLICK HERE to download the Drew Marine Refrigeration Products and Equipment brochure.

Fixed Fire Extinguishing Foam Concentrate Regulatory Update

In June 2009, the IMO issued MSC.1/Circ. 1312 “Revised Guidelines for the Performance and Testing Criteria and Surveys of Foam Concentrates for Fixed Fire-Extinguishing Systems.” This circular supersedes MSC 582 and adds additional fire testing requirements for alcohol resistant foam concentrates.

DMS is aware that many alcohol resistant foam concentrates currently onboard vessels cannot pass the fire tests. Some of these foams are type approved by Classification Societies; however, per the IMO circular, the approvals are only valid until1 July 2012. Shipowners and operators have been searching for a suitable replacement and finding that some “new and improved” formulations still cannot meet the criteria. CLICK HERE for Drew Marine Safety’s solution for MSC.1/Circ. 1312 compliant foam concentrates.

Please contact your local Drew Marine Account Representative for further information.