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Article: IMO 2020 and beyond: Guidelines for fuel oil sampling and designated sampling points
News & Insights 30 June 2021
The club previously published an article on the ‘sampling of fuel oil used on board (PSC enforcement criteria)’. This article was published based on the outcome of the 74th session of IMO's Marine Environment Protection Committee...
The club previously published an article on the ‘sampling of fuel oil used on board (PSC enforcement criteria)’. This article was published based on the outcome of the 74th session of IMO's Marine Environment Protection Committee (MEPC-74).
During MEPC-75 meeting, that was held in November-2020, new amendments to MARPOL Annex VI were adopted through Resolution MEPC.324(75). These amendments will enter into force on 1 April 2022. It introduces new requirements for fuel oil sampling points and outline methods for sampling fuel oil to validate its sulphur content.
Fuel oil samples
Essentially, there are three types of fuel oil samples as defined in the IMO guidelines:
- sample of the fuel delivered to the ship during the bunker operation, i.e. ‘MARPOL delivered sample’ (MEPC.182(59))
- sample of the fuel oil in use on a ship, i.e. ‘in-use sample’ (MEPC.1/Circ.864/Rev.1)
- sample of the fuel oil intended to be used or carried in tanks for use, i.e. ‘onboard sample’ (MEPC.1/Circ.889)
In addition to the above-mentioned statutory samples, members may wish to collect ‘commercial samples’ during the bunker operation to verify the physical and chemical properties in accordance with ISO 8217. These samples are generally drawn on voluntary basis, by the sampling equipment positioned at the bunker manifold of the receiving ship.
Designating sampling points
In order to facilitate the need for taking ‘in-use samples’, ships constructed before 1 April 2022 are required to designate or, if necessary, fit sampling points no later than the first IAPP renewal survey on or after 1 April 2023. For ships built on or after 1 April 2022, sampling points needs to be in place and designated upon delivery.
These requirements are not applicable to a fuel oil service system for a low-flashpoint fuel, i.e. having a flashpoint less than 60oC.
Members are recommended to review their fuel oil sampling procedures to ensure that samples can be drawn safely from the ship’s fuel service system in compliance with these guidelines. It is imperative that the ship’s crew are aware of the above-mentioned requirements and familiarised with the ship-specific system.
Additionally, members are also reminded that until the amendments come into force, IMO has issued a circular (MEPC.1/Circ.882) requesting its member States to apply the amendments related to the verification procedure for a MARPOL Annex VI fuel oil sample (regulation 18.8.2 or regulation 14.8) in advance of their entry into force. As such, the Port State Control (PSC) inspectors may draw samples during this interim period.
If so, the sample should be collected in a suitable container and should be representative of the fuel oil being used or intended to be used. The sample bottles should be sealed by the inspector with a unique means of identification installed in the presence of the ship's representative. The label should include the following information:
- sampling point location where the sample was drawn;
- bunker delivery note (BDN) details of the fuel oil sampled, as per information required by appendix V of MARPOL Annex VI;
- date and port of sampling;
- name and IMO number of the ship;
- details of seal identification; and
- signatures and names of the inspector and the ship's representative.
It is recommended that the ship should retain a duplicate sample and maintain appropriate record in the sample log.
Members are reminded that club cover for fines arising from breaches of low-sulphur fuel regulations and other MARPOL violations is strictly discretionary. The board is entitled to take into consideration the zero-tolerance attitude towards reimbursement of liabilities and fines for environmental offences, save in the most exceptional circumstances.
Category: Loss Prevention