In essence, the Club highlights that continuous drip sampling throughout bunkering operations should be used for both Commercial and MARPOL Samples and should be carried out at a single mutually agreeable and monitored location.
It is reported that the issues are due to the availability of two locations for sampling - one at the receiving vessels manifold and the other at the bunker barge’s manifold. While the MARPOL Convention (and consequently the MARPOL sample) clearly identifies the bunker manifold of the receiving vessel as the appropriate location for sampling, ISO 13739 (which provides guidance on Commercial sampling) states from either end of the bunker hose.
As bunker sampling is a crucial operation, it should be reminded that the Commercial sample is used as evidence in disputes over quality of the fuel and the MARPOL sample provides evidence to the Flag States and Port States regarding adherence to the MARPOL requirements.
In the majority of bunkering ports, the Chief Engineer is provided with the samples drawn onboard the bunker barge. The Club notes that this is the routine in most cases, as the agreed sampling procedure under the bunker supply contract and these samples are considered as representative and also the binding sample for any potential commercial disputes. If this is the case, it is important that a senior representative from the ship’s crew attends on the barge to ensure that proper sampling procedures are taking place at all times.
Sampling equipment should be checked for cleanliness and should be tamper proof. All samples collected must be sealed and retained in the presence of both the supplier and ship’s representative.
When the bunkering operation is completed, the supplier provides the bunker delivery note; It is important to note that only representative and witnessed sample seal numbers are referenced in the BDN and that the bunker samples themselves are properly labelled and the numbers match up with the BDN.
In addition, the BDN is signed by the supplier and the receiving vessels representative and this becomes an important document in any dispute resolution.
However, if a dispute arises concerning the quality of the fuel an analysis of the sample retained by the supplier is carried out (in most cases jointly at a mutually agreed laboratory). During this analysis it is important to carry out testing of all ISO 8217 fuel parameters so that the supplier’s sample can be finger-printed / traced back to the actual fuel received on board.