IBIA asks for review of IMO sulphur verification procedure
The International Bunker Industry Association (IBIA) has
proposed that the sulphur verification procedure described in
appendix VI to MARPOL Annex VI should be reviewed.
The argument was put to the second meeting of the International
Maritime Organization (IMO) sub-committee on Pollution
Prevention and Response (PPR 2), which is meeting at IMO
headquarters in London this week.
“Sulphur testing is not an exact science. In commercial transactions,
buyers and sellers rely on ISO 4259 for the interpretation of sulphur
test results. This provides a statistically sound approach to the fact
that there are inherent variations in fuel test results,” IBIA’s representative at the IMO, John De
Rose, told PPR on Monday.
“At present, there is a conflict between the commercial application of ISO 4259 for the interpretation
of sulphur test results, and the verification procedure described in appendix VI to MARPOL Annex
VI. This has the unfortunate consequence that ship operators risk receiving fuel that is regarded as
within the sulphur specification in a commercial situation, but could fail the IMO’s verification
IBIA’s proposal was put to PPR 2 as a comment paper in connection with a separate proposal by
IMarEST to change the text of the supplier’s declaration on the bunker delivery note. The IMarEST
paper and IBIA’s proposal are both based on recommendations made by the International Council
on Combustion Engines (CIMAC) in a review of MARPOL Annex VI.
The IMO’s sulphur verification procedure is to be used in connection with testing of the ship’s
MARPOL sample. IBIA told PPR 2 that it “places an unnecessary cost and administrative burden on
port state control (PSC) by requiring multiple test results, whereas under the ISO verification
application, one single test result would suffice to determine whether the fuel oil sample is compliant
with the relevant sulphur limits.”
The proposal calls for the MARPOL Annex VI sulphur verification process to be aligned with ISO
4259 and recognise the result of a single test as compliant as long as it falls within 95% confidence
limits. This would mean that a fuel supplied to meet a 0.10% sulphur limit would only be considered
‘off-spec’ if the single test result exceeded 0.11% sulphur.
A Bunkerworld analysis of ‘notes of protest’ (NOPs) concerning the sulphur content of bunker fuel
for the first half of 2014 showed that only around 20% of the NOPs would be considered clear
off-specs against the relevant sulphur limits if taking 95% confidence limits into account.
Revising the IMO sulphur verification procedure “would
protect ship operators from unfair bias caused by
statistically normal variations in sulphur test results, and
cut cost and administrative burden for hard-pressed port
state control authorities,” De Rose told PPR 2 as he
presented IBIA’s submission.
Norway, which played a big part in the formulation of the
current IMO sulphur verification procedure, was quick to
The uncertainty of test results covered by the 95%
confidence limit swings both ways, Norway pointed out. It
was Norway’s view, therefore, that bunker suppliers
should take these variations into consideration when
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caused by statistically
normal variations in
sulphur test results.
In other words, Norway thinks suppliers should strive to
blend fuels to slightly below the sulphur target to ensure
the product supplied would not fall foul of variations in
Two further countries aligned with Norway’s position, but
INTERTANKO voiced support for IBIA’s proposal, saying it would be “a good way forward”.
At present, practice varies with PSC in some member states following the IMO guidelines while
others apply ISO 4259 in line with what IBIA’s paper proposes. It would be good to have uniform
standards, INTERTANKO said.
IBIA’s proposal could not, however, be considered at this session, PPR chairman Sveinung Oftedal
of Norway said.
It constituted an “unplanned output” and can only go forward if a member state sees merit for it and
supports a submission going to the IMO’s Marine Environment Protection Committee (MEPC),
It remains to be seen if IBIA can find any member state co-sponsors to take the proposal any
Unni Einemo, Courtesy of Bunkerworld.London News Desk, 20th January 2015 11:30 GMT