A proposal by China to mandate specific ISO test methods for sulphur, building on a proposal made by IBIA to the IMO earlier this year, has won support to be further considered as the IMO works on measures to ensure uniform implementation of the 0.50% sulphur limit.
China submitted its proposal to the 72nd session of the IMO’s Marine Environment Protection Committee (MEPC 72) last week, proposing that the test method of sulphur content of fuel oil should be made mandatory to avoid disputes, and that the methods should be ISO 8754:2003 or ISO 14596:2007.
China’s submission further noted: “ Document PPR 5/13/9 (IBIA) proposes adding the definition of sulphur content in regulation 2 of MARPOL Annex VI to ensure the analysis of sulphur content is done in a uniform way and the test method shall be the latest edition of ISO 8754 as mandatory. China supports the proposal in document PPR 5/13/9 (IBIA) to add a definition of sulphur content in order to unify the test method for sulphur content.”
However, while IBIA had proposed the use of just one test method in the definition, namely ISO 8754, China’s proposal argued that because the test range of ISO 8754 only varies from 0.03% to 5.00%, it does not cover situations where ships receive and use fuel oil with a sulphur content lower than 0.03%. China therefore proposed adding ISO 14596 which covers fuels in the 0.001% to 2.50% sulphur range.
Commenting on China’s paper in plenary at MEPC 72, IBIA said: “We are very grateful to China for their proposal in MEPC 72/5/7 and it is clear to us that we are seeking the same outcome: namely for authorities in all jurisdictions to use the same methods when testing bunker fuel in order to verify compliance with the relevant MARPOL sulphur limits. This would help achieve uniformity in enforcement across the board when verifying the sulphur content of different kinds of fuel oil samples.
As noted by China, the test range of ISO 8754 covers sulphur content ranging from 0.030% to 5.00%. In fact, this test method can record lower values but the test reporting protocol nevertheless stipulates that results must be reported within the defined range. It is indeed the case, as China has noted, that some fuels supplied to ships may have sulphur content below 0.030% and that the ISO 14596 test method, which covers the range 0.001% to 2.50% sulphur would be needed to more accurately report the sulphur content of such fuels.
We do not dispute these observations. In fact, we support the use of all suitable sulphur test methods to obtain indicative test results, whether that is handheld sulphur analyser instruments, using so-called sniffers to detect excessive sulphur emissions, or when checking sulphur content in fuel oils supplied to ships for operational purposes. However, the key phrase here is indicative test results.
We believe the needs are materially different when you consider another key phrase, which is verification of compliance. The outcome we are looking for is to have a uniform approach to verification of compliance with MARPOL Annex VI sulphur limits for all types of fuel oil samples. For this purpose, the test range of ISO 8754 meets all the regulatory requirements as 0.03% is well below 0.10%, which is the lowest sulphur limit covered by MARPOL. For this reason, we believe only ISO 8754 is needed when testing various fuel oil samples for compliance with MARPOL sulphur limits.”
The Chair of MEPC proposed to forward China’s document to an intersessional meeting due to take place in July where work will continue on the development of guidelines and potential regulatory amendments to promote consistent implementation of the 0.50% sulphur limit.
Seven member states voiced support for the ideas in China’s paper and to send the document to the July intersessional meeting for consideration, and there were no objections.
IBIA’s proposal to the 5th session of the Sub-Committee on Pollution Prevention and Response earlier this year, PPR 5/13/9, will also be forwarded to the intersessional meeting in July for consideration.
So will IBIA’s proposal in PPR 5/12/1 to develop appropriate guidelines for verifying the sulphur content in fuel oil samples taken from ships fuel systems (in-use samples). IBIA has proposed that guidelines for in-use samples should specify the use of the ISO 8754 test method and recognize the 95% confidence principle meaning that the in-use sample should be regarded as complaint as long as it does not exceed the limit plus 0.59 x R.
The deadline for such submissions is 25 May and we encourage IBIA members to share their views and ideas for making the guidelines effective and helpful with your IMO representative, Unni Einemo. Her e-mail is email@example.com