IBIA asks clarifications on IMO guidelines for onboard samples

The guidelines were one of several items up for approval at the 75th session of the IMO’s Marine Environment Protection Committee and 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.

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 onboard a ship, to enable authorities to check for compliance with the carriage ban. According to the 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, such as scrubbers.

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”.

…IBIA’s Director and IMO representative, Unni Einemo, said in an intervention when the guidelines came up for approval.

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 onboard fuel oil sample, as this is not clear.

In response, 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 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 onboard 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 onboard 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,

…explained IBIA.

IBIA provided a statement to MEPC 75 urging Member States to implement the amendments to appendix VI of MARPOL Annex VI without delay, in line with Circular MEPC.1/Circ.882 issued by MEPC 74 in 2019.

The newly approved Guidelines for onboard sampling of fuel oil intended to be used or carried for use onboard a ship will be issued as MEPC.1/Circ.889.

In November, ahead the MEPC 75 meeting, BIMCO expressed concerns over the procedure for ‘Onboard sample’ to be used for determining if the ship is in compliance with the sulphur regulation, warning that this could cause confusion and uncertainty between the ship, bunker supplier, time charter and other stakeholders.

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