||M. Bloor, S. Baker, H. Sampson, K. Dahlgren
||Seafarers International Research Centre
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This document replaces an interim report of January 2012 and concerns the effectiveness of international regulations on ship's sulphur emissions, based on observation of ship inspections in the United Kingdom and Sweden and on interviews with regulators, inspectors and industry stakeholders. A second, related report is planned on issues concerning the enforcement of prospective regulations on vessels' carbon emissions. There is currently a 'culture of compliance' in the industry, but operator compliance depends crucially on the perception that one's competitors are also compliant — the 'level playing field'. Only fragmentary lab-test evidence of compliance levels is available. On the one hand, some commercial laboratories have made available summaries of the test results from large numbers of samples sent to them for commercial purposes. These results are mainly valuable as an indicator of the proportions of off-spec fuel being supplied as bunkers, rather than as an indicator of regulatory avoidance, since ship operators practicing regulatory avoidance are unlikely to send samples for testing. On the other hand, some authorities, such as the Swedish Maritime Administration and the Dutch Human Environment and Transport Inspectorate, are collecting quasi random fuel samples for testing, but the numbers of such samples are small and some of the sampling may be intelligence-led...