CM Technologies (CMT) advised shipowners and operators to urgently review their fuel and lubricating oil sampling practices following the entry into force of revised IMO guidelines.
Recent amendments to MARPOL Annex VI and SOLAS Chapter II-2 include a 50% increase in the required sample volume and stricter expectations around equipment, handling and record-keeping. The International Maritime Organization’s updated protocol, MSC-MEPC.2/Circ.18, mandates that fuel samples collected for MARPOL compliance now be a minimum of 600ml, up from the previous 400ml.
This change ensures there is sufficient material to perform both sulphur content testing under MARPOL and flash point testing under SOLAS requirements. It also reinforces proper sampling procedures, including the use of tamper-evident containers, accurate labelling and secure onboard storage.
Sampling is often regarded as a technicality, but it is the foundation for effective compliance and dispute resolution. Too often, we see crew improvising with makeshift containers due to a lack of proper gear onboard. Samples are often sent to labs in recycled beverage bottles – which can invalidate test results.
…said David Fuhlbrügge, Managing Director, CM Technologies.
According to CMT, soft drink bottles frequently contain plasticizers, chemical additives designed to make plastic bottles flexible. These and other contaminants such as residual sweeteners, flavourings, or cleaning agents can alter the properties of the sample. This not only undermines test accuracy but can also lead to delays, re-sampling, or even the rejection of results by the laboratory.
In addition, contaminated or poorly documented samples cannot be presented in bunker disputes or during Port State Control (PSC) inspections and any results labelled ‘indicative only’ would not be used to support compliance claims.
With new IMO regulations, any issues with tampering, contamination, or inadequate documentation could result in fines, detention, or liability. The revised guidelines also transfer responsibility for tracking and storing MARPOL Delivered Samples from the ship’s master to the ship owner or management company.
This shift underscores the importance of fleet-wide procedures and oversight. Crews must be trained in how to operate sampling equipment, seal and label containers, and store samples correctly –typically for up to 12 months or until the fuel is consumed.
…said David Fuhlbrügge,
