Testing for LSMGO compliance is becoming increasingly prevalent in Emission Control Areas in both the United States and European Union. The Republic of the Marshall Islands has issued Marine Safety Advisory in order to advise of Low Sulphur Marine Gas Oil (LSMGO) fuel oil testing by port States to ensure ships are using fuel with no more than 0.10% sulphur content, in accordance with the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI requirements.
Following on from the US Coast Guard’s (USCG) pilot scheme for a voluntary vessel fuel oil sampling program during 2016, USCG port State control officers (PSCOs) have begun the strict enforcement of LSMGO testing in line with CG-543 Policy Letter 09-01.
EU Member States are pursuing the strict enforcement of the use of marine fuel with no more than 0.10% sulphur content. For example, the United Kingdom (UK) requires flag States to verify that immediate corrective action has been taken by the vessel’s management to bring the vessel into compliance, even for marginally non-compliant LSMGO.
These policies are in accordance with the EU requirement that:
1. Member States, including the UK, must inspect the bunker delivery notes and log books of at least 10% of arriving ships; and
2. Of that 10%, the following percentage of ships should have the sulphur content of marine fuel sampled:
- 40% in Member States fully bordering SOx ECAs
- 30% in Member States partly bordering SOx ECAs
- 20% in Member States not bordering SOx ECAs.
The RMI further mentions that perators need to understand the importance of both receiving sealed bunker delivery samples as well as having accepted procedures in place to obtain on-board spot sampling. To this end, the International Maritime Organization (IMO) has recently published “Guidelines For Onboard Sampling For The Verification Of The Sulphur Content Of The Fuel Oil Used On Board Ships”
Operators are further recommended to have fuel oil sampling plans in place should a PSCO request an on-board sample. The plans should ensure that fuel oil be sampled or taken from a point that is carefully considered by the Master and crew; where the risk of contamination from other fuels and sediments is extremely unlikely in order to provide an accurate sample for LSMGO testing.
They should also address the ship’s representative (i.e., Master) retaining and securing the one spot sampling container that must be given to him or her.
Further details may be found in the report herebelow
Source: RMI
