The IMO's MEPC 75, underway virtually this week, is discussing changes to MARPOL Annex VI regulations on how PSC can draw fuel oil samples onboard. In connection with the amendments, a few definitions will come in handy:

  • In-use sample, defined as the sample of fuel oil in use on a ship. It can for example be drawn from the fuel oil line between the service tank and an auxiliary engine.
  • Onboard sample, defined as the sample of fuel oil intended to be used or carried for use onboard a ship. It is drawn directly or indirectly from fuel oil tanks.

The new regulation gives PSC authorities explicit authority to draw oil samples from the ship’s fuel oil tanks, BIMCO explained. Thus, it expressed concerns on the suggested procedure for ‘On board sampling’ to be used for determining if the ship is in compliance with the sulphur regulation, since the only truly homogenous and representative fuel oil sample is the MARPOL sample (MARPOL delivered sample).

The new suggestion could cause confusion and uncertainty between the ship, bunker supplier, time charter and other stakeholders, especially if the testing results turn out to be different,

...BIMCO stressed.

Direct samples drawn through the sounding pipe or the manhole cannot in BIMCO’s view be considered homogenous and representative for the sulphur content in the fuel oil tank. This is recognised in the circular on early application of the verification procedures for a MARPOL Annex VI fuel oil sample (MEPC.1/Circ.882):

“The in-use or on board fuel oil sample, as appropriate, shall be used to verify the sulphur content of the fuel oil as represented by that sample of fuel oil at the point of sampling.”

This means that a fuel oil sample drawn by PSC is only representative of the fuel oil at the level or point of suction, but not representative of the fuel oil in the tank.

Indirect samples drawn by using the fuel oil transfer pump, cannot be used either, since the sample is not homogenous and representative of the sulphur content in the tank. Since the transfer pump’s suction is placed in the bottom of the fuel tank, BIMCO fears that such samples would show wrong results even if the sulphur content of the fuel oil is actually compliant.

This leads to the fact that the only fuel sample truly homogenous and representative of the sulphur content that is available today, is the MARPOL sample because it is drawn over the entire bunker operation.