Beware bunkering at Singapore OPL

Bunkering outside port limits (OPL) was once common practice. Though it may be less prevalent in recent times, bunkering operations continue to occur in these waters, and parties considering engaging in such operations should be aware of the issues that could arise.

Bunker standards and protection

To protect all parties engaged in bunkering within its jurisdiction, the Maritime Port Authority of Singapore (MPA) enforces a set of standards for bunkering. While bunkering OPL can save time and costs, shipowners can lose the protection automatically offered by the MPA’s codes. Bunker suppliers operating at OPL may not operate to the MPA’s high standards or participate in the accreditation scheme.

Higher risk locations

Bunkering in open waters at OPL can expose the vessel to additional risks, typically:

• Maritime security – the risk of piracy and robbery remains present in the Malacca Straits and the Singapore Strait. In 2021, there were 49 reported incidents in the Singapore Strait alone.
• Weather and sea conditions – this can increase the risk of damage to both the receiving vessel and the bunker barge as well as threat of a bunker spill.
• Collisions – bunkering in busy waters introduces an increased risk of contact with another vessel.

Disputed jurisdictions

Some sea areas outside Singapore port limits are the subject of territorial disputes.  In the event of an incident or casualty while bunkering at Singapore OPL, costs and responsiveness can be impacted by uncertainties and conflicts over which country has jurisdiction in the matter.

Illegal anchoring

Malaysia and Indonesia enforce restrictions on unauthorised or illegal anchoring and bunkering in the waters they claim.

Both countries have detained ships alleged to have been engaged in such activities in their waters. Shipowners have been fined or forced to pay significant amounts to obtain the release of their vessels, potentially after significant delays, and in circumstances where the legitimacy of the demand/payment is sometimes unclear – which can create difficulties for the Club when asked to reimburse them.

Take precautions

When considering bunkering at Singapore OPL or ordered to do so by a charterer, consider the risks involved in doing so outside the scope of the MPA’s codes of practice.

Where a charterer orders, or a bunker supplier proposes, bunkering at a specific position at Singapore OPL, the Owner should, provided it is able to do so under the terms of the relevant charterparty, resist doing so unless provided with proof in the form of an official circular or notice issued by the Malaysian or Indonesian maritime authorities confirming that the nominated position is in an area that is authorised for bunkering operations.

Find out more

North Members requiring further information should approach their usual P&I or FD&D contact.

Singapore bunkering standards: https://www.mpa.gov.sg/web/portal/home/port-of-singapore/services/bunkering/bunkering-standards

North news article: Indonesia – Vessel detentions https://www.nepia.com/industry-news/indonesia-%C2%96-vessel-detentions/

North news article: Malaysia Targets Anchoring Vessels with ‘Operation Jangkar Haram’ https://www.nepia.com/industry-news/malaysia-targets-anchoring-vessels-with-operation-jangkar-haram/