2020: Outcomes of MEPC 74 – Fuel Sampling and Testing

The 74th session of the IMO’s Marine Environment Protection Committee (MEPC 74) took place on 13-17 May 2019 at the IMO headquarters in London.

One of the main areas of focus was air pollution and in particular the fast approaching global fuel sulphur cap. We look at some of the key outcomes of MEPC 74 and how it could impact your transition to compliance before 1 January 2020. This article focuses on fuel sampling and verification of sulphur content.

Fuel Sampling

There will now be three fuel samples to consider:

1. The MARPOL delivered sample taken at time of bunkering (recommended to be drawn from the receiving vessel’s manifold).
2. The in-use sample which is drawn as close as possible to the engine inlet.
3. The not in-use onboard sample which is drawn from a vessel’s tank.

MARPOL Annex VI Regulation 14 (Sulphur oxides (SOx) and particulate matter) will be amended to include these new sampling requirements.

The in-use fuel oil sample will need to be drawn in accordance with the new 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1)).

The in-use fuel oil sampling point will be:

• Designated for the purpose of taking representative samples of the fuel oil being used.
• For a ship constructed before entry into force of the new sampling requirements, the sampling point(s) must be fitted or designated no later than the first renewal survey that occurs 12 months or more after the entry into force.
• Port State Control must use the designated sampling point(s) to verify the fuel complies with the sulphur limit. Sampling must be performed as efficiently as possible without causing the ship to be unduly delayed.

North Comments:

We sometimes see instances during inspections where the in-use sample was drawn from the bottom of a filter pot or a dead leg in the system. How representative these samples are of the fuel in use is very questionable and this practice should be avoided.

Don’t assume that the PSCO always knows best and be prepared to challenge them if the sampling procedure they propose looks unsafe or would provide a sample that isn’t representative of the fuel in use.

Guidelines on drawing the on board fuel oil sample have not yet been developed by IMO. Drawing a sample from a tank that is truly representative of its contents is notoriously difficult and IMO guidance will be welcomed.

Fuel Testing

The fuel verification procedure for the MARPOL delivered sample (taken at time of bunkering) has been simplified. The requirement for the supplier to have the sample tested by a second accredited laboratory is now at the discretion of the State where bunkering takes place.

This raised much concern at MEPC 74, but a compromise was found and the option to test a second time is now at the discretion of the relevant State.

Why does this matter? Well, an unintended consequence of this change relates to reproducibility (i.e. variation in the test result of the same sample with different labs).  If the MARPOL sample is tested by another lab, the reproducibility testing criteria means that a 0.47% test by one lab for the BDN could test just above 0.50% elsewhere.

If a port State control later tests the MARPOL delivered sample at 0.51% they could find that fuel does not meet compliance criteria. It is not unreasonable to think that many suppliers will be blending to as close to 0.50% as possible so this could be a common issue.

This is why a number of interested parties, such as IBIA (International Bunker Industry Association) and fuel testing labs such as Intertek recommend suppliers blend to and purchasers specify bunkers to a 0.47% S limit. This gives 95% confidence that the fuel will not later test above 0.50%.

In-Use Test Parameters Differ

Interestingly, the testing criteria for in-use samples are different. Single test repeatability (0.59R) is considered, meaning that a test result of 0.53% (or 0.11% for ULSFOs) would not be considered non-compliant.