Ship owners, ship operators and ship managers who are busy preparing for the upcoming high sulphur fuel oil (“HSFO”) ban which enters into force on 1 January 2020 will be familiar with the option to install Exhaust Gas Cleaning Systems (EGCSs) otherwise known as “scrubbers” as one route to compliance. There appears to be some confusion within certain parts of industry as to whether it is sufficient to merely commission and not necessarily install or use a scrubber by 31 December 2019 in order...