CIMAC Guideline on Marine Fuel Oil Analysis Test Results

CIMAC, The International Council on Combustion Engines, has published guideline to give an overview regarding the interpretation of marine fuel oil analysis test results with particular reference to sulphur content.

With the introduction of MARPOL Annex VI, the sulphur content of a particular fuel oil is now often the primary factor in assessing whether or not that fuel oil is acceptable for intended use. However, at present, this issue is complicated by the fact that the Annex’s approach to assessing compliance
differs fundamentally from the commercial process under which the fuel oil is ordered and supplied.

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Since all fuel oil testing is subject to inherent variations, the commercial assessment of fuel oils as supplied is governed by the provisions of ISO 4259. This requires that the supplier must not obtain a test result over the required specification limit value. In contrast, the recipient cannot consider a product out of specification unless the recipient’s test result exceeds the specification limit value by more than the 95% confidence limit which, for a single test result, is given by the reproducibility of the test method multiplied by 0.59.

This statistically based process defines how results shall be interpreted allowing for these inherent test variations. However, within the Annex, the assessment of sulphur compliance is undertaken by testing the mandatory MARPOL Sample, using the given verification procedure, to determine a value which is then compared to the relevant limit. This verification procedure does not take into consideration inherent variations in results obtained in one laboratory and normal bias between laboratories.

Furthermore, this can result in a fuel oil being established as non-compliant, in accordance with the Annex, despite both the supplier’s and recipient’s test results meeting the recipient’s specification limit, where that limit is the regulation 14 value.

To date, the members of the CIMAC Fuels Working Group, which spans oil suppliers, fuel testing services, ship owners and others, are aware that the Annex verification procedure is not being widely applied in practice. From discussions with some authorities, this is, at least in part, due to the conflict with the standard commercial practice. Furthermore, the Annex’s verification procedure lacks the necessary robustness and certainty required for an authority to take action, as specified under regulation 18, against the supplier, in the case of the supply of non-compliant fuel oil.

This review concludes that IMO should be invited to re-consider the Annex verification procedure, taking into account the technical facts and the established commercial practice. If there is to be a robust and reliable enforcement of the sulphur limits, there needs to be a single universal unambiguous approach. The international standard for marine fuels (ISO 8217) applies the well established, statistically based, ISO 4259 for the interpretation of test results and it is recommended that IMO should adopt the same approach for the enforcement of the Annex sulphur limits, since this would then provide uniformity and an unambiguous approach across the marine industry. Adoption by IMO would also align the marine industry with automotive and land based industries which are legislated to use the ISO 4259 approach.

Recommendations to IMO

This review has highlighted a number of significant points which CIMAC WG7 Fuels recommends that the Parties to the Annex should bring to the attention to IMO. These need to be addressed in order to bring consistency and uniformity across the industry.

1. MARPOL Sample testing for compliance. The existing Appendix VI procedure should be replaced by the ISO 4259 approach
2. Guidelines covering in-use fuel sampling need to be developed to cover where and how representative ‘in-use’ samples should be drawn, together with their handling, distribution and analysis
3. The ISO 4259 approach should be adopted when comparing the sulphur result obtained from fuel samples drawn from ‘in-use‘ with the relevant regulation 14 limits
4. Whilst not covered in detail in this report, consideration should be given to amending the fuel oil supplier’s bunker declaration as outlined in Appendix V of this review

Conclusions

The MARPOL Annex VI fuel oil sulphur limits represent real reductions, and in the case of the 0.50% and 0.10% limits substantial reductions, in sulphur and particulate emissions from shipping, compared to what otherwise would have been the case.

It is important to recognise that adopting the ISO 4259 approach to assess compliance will not represent any lessening of the reduction in the emissions of SOx and associated particulate matter achieved by IMO. ISO 4259 is the established normal practice within the global marine fuel oil
supply chain and other regulatory systems providing a proven means of dealing with the question of test variability.

Furthermore, putting in place robust and reliable assessment criteria will reduce uncertainty and promote a higher level of oversight and workable enforcement – to the advantage of Administrations, shipowners, fuel oil suppliers and the industry as a whole.

Further information may be found by reading CIMAC Guideline on The Interpretation of Marine Fuel Oil Analysis Test Results with Particular Reference to Sulphur Content

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