IBIA reminds the industry that new regulatory requirements under MARPOL Annex VI, regarding the information to be included in the bunker delivery note (BDN), will enter into force on 1 January 2019. That is why, IBIA provides practical advice and dispel some of the misunderstandings regarding the responsibility of suppliers.
Namely, IBIA provides the text of the new Appendix V, ‘Information to be included in the bunker delivery note’ that consists of Name and IMO Number of receiving ship, Port, Date of commencement of delivery, Name, address and telephone number of marine fuel oil supplier, Product name(s), Quantity in metric tonnes, Density at 15°C (kg/m3) Sulphur content (% m/m).
The announcement signed by the fuel oil supplier’s representative should address that the fuel oil supplied agrees with regulation 18.3 of this Annex and does not surpass
- the limit value given by regulation 14.1 of this Annex;
- the limit value given by regulation 14.4 of this Annex;
- the purchaser’s specified limit value, as completed by the fuel oil supplier’s representative and on the basis of purchaser’s notification that the fuel oil is intended to be used:
This declaration shall be completed by the fuel oil supplier’s representative by marking the applicable box(es) with a cross (x).”
Moreover, IBIA highlighted that as there was no tick box against the two sub-clauses, the third tick box only requires that the sulphur value specified by the purchaser is entered. There is no requirement for validation by the supplier on the BDN as to which method of compliance is used by the ship.
The regulation requires bunker suppliers, if asked to provide fuel exceeding the sulphur limit in Regulation 14.1 to a ship, to do so only on the basis of receiving a notification from the buyer that the fuel is intended to be used compliantly.
Finally, policing of ship compliance is up to port state control officers. If they check the BDN and it shows that the ship has purchased fuel with sulphur above 0.50% after 1 Jan 2020, they should immediately ask for the ship’s IAPP supplement detailing if it has an equivalent arrangement approved in accordance with regulation 4.1 which allows the ship to use fuel with sulphur above 0.50%.
