Issued as MSC-MEPC.2/Circ.18 on 11 July 2024, the IMO has revised the fuel oil sampling guidelines for verifying compliance with MARPOL Annex VI and SOLAS Chapter II-2.
In particular, the updated guidelines expand the use of the MARPOL Delivered Sample to include verification of the flashpoint requirement under SOLAS Regulation II-2/4.2.1. The new circular supersedes the previous MEPC Resolution 182(59), known as the ‘2009 Guidelines for the sampling of fuel oil for determining compliance with the revised MARPOL Annex VI’.
Lloyd’s Register has issued an article, higlighting the following key changes of the IMO updated guidelines:
#1 Minimum sample size
The basic requirements are unchanged apart from the minimum sample size being increased from 400ml to 600ml. Also unchanged are the sample labelling and sample storage aspects.
#2 Fuel oil definition
For the purpose of these Guidelines, and for the application of SOLAS Regulation II2/4.2, oil fuel is as defined in Regulation 2.1.14 of MARPOL Annex VI, including oil fuel as defined in Regulation 1 of MARPOL Annex I.
#3 Sampling and preparation
There are now explicit references in the circular to the need for personnel undertaking this sampling and the subsequent MARPOL Delivered Sample preparation to be familiar with the use of the equipment and the Guidelines. Also, that the sampling operation itself should be witnessed by representatives of both the ship and supplier.
#4 New Section 10
The one notable addition is the new Section 10. This covers the procedures and documentation requirements in those instances where the fuel oil’s flashpoint is to be checked. This in no way impacts on the MARPOL Annex VI Appendix VI requirements in respect of the sulphur verification procedures, which are unaltered.
According to the IMO circular, if the retained sample has been sent for testing, the laboratory should take a subsample enabling the tests to be carried out and immediately reseal the remaining retained sample container with a new tamper-proof security seal with a unique means of identification in the presence of a representative for the authority that has ordered the test.
A label containing the following information should be secured to the retained sample container:
- name and address of laboratory:
- date when the sample was resealed;
- volume remaining in the retained sample container when resealed;
- names and signatures of the person resealing the sample and the authority’s representative witnessing the process;
- details of the new unique seal identification;
- a declaration that no other material has been added to the sample; and
- relevant information from previous label, including details of original seal identification; name and IMO number of the receiving ship and bunker grade.
#5 Tracking of Delivered Samples
With regard to the key point of keeping track of these MARPOL Delivered Samples, this is now given as being the company’s responsibility rather than the responsibility of the ship’s master, as previously stated in the 2009 Guidelines. This will be important where samples are taken off the ship for testing, but the remaining material is not subsequently returned.
The MARPOL Delivered Sample should only be used by a Party to either MARPOL Annex VI or SOLAS, to test for
compliance with the convention requirements. The MARPOL Delivered Sample should not be used for any other
purposes such as the resolution of commercial quality disputes.
…Lloyd’s Register highlighted.
