The International Bunker Industry Association (IBIA) has proposed that the sulphur verification procedure described in appendix VI to MARPOL Annex VI should be reviewed.
The argument was put to the second meeting of the International Maritime Organization (IMO) sub-committee on Pollution Prevention and Response (PPR 2), which met IMO headquarters in London this week.
“Sulphur testing is not an exact science. In commercial transactions, buyers and sellers rely on ISO 4259 for the interpretation of sulphur test results. This provides a statistically sound approach to the fact that there are inherent variations in fuel test results,” IBIA’s representative at the IMO, John De Rose, told PPR on Monday.
“At present, there is a conflict between the commercial application of ISO 4259 for the interpretation of sulphur test results, and the verification procedure described in appendix VI to MARPOL Annex VI. This has the unfortunate consequence that ship operators risk receiving fuel that is regarded as within the sulphur specification in a commercial situation, but could fail the IMO’s verification procedure.”
IBIA’s proposal was put to PPR 2 as a comment paper in connection with a separate proposal by IMarEST to change the text of the supplier’s declaration on the bunker delivery note. The IMarEST paper and IBIA’s proposal are both based on recommendations made by the International Council on Combustion Engines (CIMAC) in a review of MARPOL Annex VI.
The IMO’s sulphur verification procedure is to be used in connection with testing of the ship’s MARPOL sample. IBIA told PPR 2 that it “places an unnecessary cost and administrative burden on port state control (PSC) by requiring multiple test results, whereas under the ISO verification application, one single test result would suffice to determine whether the fuel oil sample is compliant with the relevant sulphur limits.”
The proposal calls for the MARPOL Annex VI sulphur verification process to be aligned with ISO 4259 and recognise the result of a single test as compliant as long as it falls within 95% confidence limits. This would mean that a fuel supplied to meet a 0.10% sulphur limit would only be considered ‘off-spec’ if the single test result exceeded 0.11% sulphur.
Source: IBIA
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