IBIA sought clarification on the link between sample handling and inclusion of bunker delivery note details of the fuel oil sampled as the IMO approved a circular on “Guidelines for onboard sampling of fuel oil intended to be used or carried for use on board a ship”.
The guidelines were one of several items up for approval at the 75th session of the IMO’s Marine Environment Protection Committee. The guidelines were developed to establish an agreed method for the sampling, from tanks, of liquid fuel oil intended to be used or carried for use on board a ship, to enable authorities to check for compliance with the carriage ban. Since 1 March 2020, ships are not allowed to carry any fuel exceeding 0.50% sulphur unless they have an approved alternative compliance method, e.g. a certified exhaust gas cleaning system.
The guidelines set out sampling procedures, either by use of the ship’s fuel oil transfer system or direct sampling from a tank. They also set out sample handling.
As the guidelines came up for approval, IBIA’s Director and IMO representative, Unni Einemo, made the following intervention:
IBIA has a comment and question regarding paragraph 3 of the draft Guidelines for onboard sampling of fuel oil found in Annex 8 of PPR 7/22/Add.1, regarding sample handling. After obtaining an on board sample, the list of information to be included on the labels includes – in point 3.1.2 – “bunker delivery note details of the fuel oil sampled, as per information required by appendix V of MARPOL Annex VI”.
It is important to note that the content of a fuel tank on the ship may be a mix of more than one fuel oil delivery as a result of comingling onboard the ship, or fuel left in the tank when bunkering new fuel. Unless you have confidence that the content of the tank was less than 5% at the start of bunkering, the information on the BDN will not be completely relevant to what is now in that fuel tank.
We just wonder, therefore, if point 3.2.1 refers to a specific BDN, or multiple BDNs to reflect the content of an on board fuel oil sample, as this is not clear.
In response to the point raised by IBIA, IMarEST told the meeting that because the sub-point refers to BDN details, it implies that details from more than one BDN could be included on the label of the sample. IBIA subsequently asked for our intervention, and the clarification provided by IMarEST, to be included in the report from MEPC 75 so that there is an official record of it.
The on board sampling guidelines are also referenced in the amendments to MARPOL Annex VI that were adopted at MEPC 75. The amended regulation states that If the competent authority of a Party requires the in-use or on board sample to be analysed, it shall be done in accordance with the verification procedure in appendix VI.
The amendments of appendix VI make it clear that a MARPOL delivered sample, if tested, must meet the relevant limit to be “considered to have met the requirement”. In-use and on board samples, meanwhile, “shall be considered to have met the requirement” provided the test result is not higher than the applicable limit + 0.59R (where R is the reproducibility of the test method). In other words, the 95% confidence principle is applied to in-use and on board samples.
Source: Hellenic Shipping