IMO committee resists change to sulphur verification procedure
IBIA proposal faced overwhelming headwinds at MEPC 68
A campaign by the International Bunker Industry Association (IBIA) to amend the sulphur verification procedure described in
appendix VI to MARPOL Annex VI has faced a major setback. IBIA first put a proposal to the International Maritime Organization
(IMO) sub-committee on Pollution Prevention and Response (PPR) in January this year, asking to align the verification procedure for the
interpretation of sulphur test results described in appendix VI to MARPOL Annex VI with the commercial application of ISO 4259.
At that meeting, the proposal could not be considered because it constituted an “unplanned output” which can only go forward if a
member state supports a submission to the IMO’s Marine Environment Protection Committee (MEPC).
IBIA presented its arguments in a paper to the 68th session of MEPC this week, explaining in detail
the problems associated with MARPOL Annex VI fuel testing principles.
The submission was explicitly aimed at presenting a strong case to IMO member states in the hope
that they would see its merit, and thereby encourage a member state to come forward to
co-sponsor a formal proposal for a new output to MEPC 69.
The paper explained that the current conflict between ISO 4259 in commercial contracts, and the
verification procedure described in appendix VI to MARPOL Annex VI, was putting ships at a
There is a 95% confidence limit for bunker deliveries applicable under ISO 4259, but the MARPOL
sulphur verification procedure does not recognise it, and has tried to eliminate the test uncertainty
and make sulphur limits ‘absolute’.
The discrepancy leaves ships vulnerable to have a fuel that meets sulphur limits under ISO 4259
test interpretation, but may fail a ports state control inspection using the MARPOL verification
“Annex VI is a unique standard which provides many problems for everyone which I will not refer to
in order to shorten this introduction. The notes of protest system is impracticable and ineffective and
does not work to anyone’s satisfaction,” IBIA’s representative at the IMO told MEPC.
“We are of the belief that ISO 4259 or its equivalent should be the one standard that should be used
worldwide and that MARPOL Annex VI should be amended. It will provide a more robust and
Norway, however, put in a counter-argument in a submission to MEPC 68. Among Norway’s
arguments was that the large number of notes of protest issued against bunker suppliers for
exceeding MARPOL sulphur limits was evidence that ‘off-spec’ deliveries were potentially a big
“If an error margin is applied to the fuel oil delivered, we believe that would only benefit, or mostly
benefit, the fuel oil suppliers,” Norway told MEPC 68.
For fuel oil in use, however, Norway believes that port states will allow for a small error margin to
take into account the very narrow error margins that ships have when switching from high sulphur
fuel oil (HSFO) to a compliant low sulphur gas oil (LS MGO) before entering an emissions control
Norway said that if the fuel oil supplied to the ship had sulphur content in the upper range of the
confidence limits, it will be quite challenging for ship to meet the MARPOL requirements, even if the
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port state allows for an error margin.
Basically, Norway argued that suppliers may have “used up” the error margin that would otherwise
allow the ship to pass a port state control inspection, even if that was forgiving.
Norway also warned that allowing for the 95% confidence limit will have an impact on other relevant
properties of the fuel, such as flash point. It cited the SOLAS minimum flashpoint of 60oC and said
that applying ISO 4259 and the 95% confidence level would allow a single test result of 56oC to be
regarded as meeting the regulation.
“Our understanding is that these limits are absolute, and the acceptance of a certain error margin
would in our view make these requirements less clear.”
Norway did note that IBIAs paper mentioned that under the ISO 4259 principles, suppliers should
still use the limit minus the confidence margin as their blend target to ensure the product supplied
would test safely within the limit. Norway said it did not believe suppliers adhere to these principles
and were prone to blend fuels right up to the maximum limit.
Bahamas expressed its support for the IBIA paper. The reason for this was the constitution of the
CIMAC working group which wrote the paper IBIA’s submission was built on. It consisted of 35
experts from various backgrounds including shipowners, engine manufacturers and fuel testing
agencies. The IMO should heed the advise of a whole range of expert opinion, Bahamas said.
The Marshall Islands also supported IBIA’s paper.
However, Latvia, US, Belgium, Ireland, Sweden, Poland, Canada and Germany all aligned with
Norway’s comments, while South Korea looked for a middle ground.
That led the MEPC chairman, Arsenio Dominguez, to conclude that the committee considered that
IBIA’s paper was “insufficiently supported and will not be taken forward”.
Other shipping organisations that support IBIA’s proposal did not come forward to say anything at
MEPC 68. That may have been because the proposal was primarily aimed at finding member states
that may be willing to support a formal request to the next MEPC session to add and amendment of
the MARPOL Annex VI sulphur verification procedure to its agenda.
Unni Einemo, London News Desk, 14th May 2015 22:01 GMT