IMO to consider phasing in designated ‘in use’ fuel sampling point for verifying MARPOL compliance

Guidelines for taking samples from ships to verify that the fuel in use is compliant with MARPOL sulphur limits have been approved and look set to be adopted, although some reservations remain regarding the safety of personnel involved when collecting a sample from ships’ fuel systems.

The International Maritime Organization guidelines were approved at the 70th meeting of the IMO’s Marine Environment Protection Committee (MEPC 70). Papers and comments were heard at MEPC 70 demonstrating that such samples have been routinely and safely collected for several years.

MEPC 70 also heard a proposal from Norway; MEPC 70/15/3, to gradually phase in a requirement for ships to have designated fuel sampling points. This would require amendments to regulation 14 of MARPOL Annex VI. “We believe this would strengthen and contribute to a harmonized enforcement of the sulphur requirements, facilitate the work of the personnel that would draw the fuel oil samples, ensure that representative fuel oil samples are taken in a cost-effective and safe manner, and will reduce the likelihood of any disputes following a test that shows the use of non-compliant fuel oil,” Norway’s paper said.

There was support for Norway’s proposal from several member states, in particular as it would facilitate compliance checks when the global sulphur cap takes effect.

Several shipping organisations, however, objected to the very principle of formalising a system to take samples from ships to check for sulphur compliance as they believe such sampling should only be done if there is compelling reason for suspecting non-compliance. It was also stressed that any cost arising from sampling and testing fuels for compliance, instigated by port State control officers, should not be charged to shipowners.

Addressing plenary on the proposal from Norway to phase in a designated sampling point for fuel oil, IBIA’s IMO representative Unni Einemo said it made very good sense. “Apart from addressing the safety concerns raised on several occasions, it would standardise the sampling point and bring uniformity. This is really important as we have heard examples of ships being deemed in non-compliance with ECA sulphur limit on the basis of the first sample taken, while a second sample, deemed to be more representative of the fuel in use, tested compliant,” she told MEPC 70.

“There would be a clear benefit for both the ship crew and ports State control officers to have a designated sampling point, providing of course the location is appropriately chosen to give confidence that the sample will be representative of the fuel in use,” she added.

The proposal will be sent to the Sub-Committee on Pollution Prevention and Response (PPR) for development, and to the Sub-Committee on Ship Systems and Equipment (SSE) to consider the safety aspects. However, due to the limited time remaining before PPR 4, which meets in January 2017, MEPC will not instruct PPR until PPR 5.

If you have comments on this item, please contact unni@ibia.net