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LR: Update on MARPOL Annex VI relating to electronic Bunker Delivery Notes

BDN in electronic format must equally be retained onboard for a period of not less than three years from the date of delivery and made readily available for inspection as required, says LR.
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Classification society Lloyd’s Register (LR) recently issued a Class News on an update on the Unified Interpretations to MARPOL Annex VI relating to electronic Bunker Delivery Notes (e-BDNs):

The IMO has formally confirmed the use of Bunker Delivery Notes (BDNs) in electronic format as an acceptable alternative to the conventional hard copy, as long as they conform to the regulations of MARPOL Annex VI.

This follows the 80th session of the Marine Environment Protection Committee, which agreed an additional unified interpretation to regulations 18.5 and 18.6 of MARPOL Annex VI concerning BDNs. It is now included in the updated consolidation circular MEPC.1/Circ.795/Rev.8.

Bunker Delivery Note (BDN)

The updated interpretation relating to regulation 18.5 and 18.6 can be read in full below. 

The minimum information to be contained in the BDN remains the same in hard copy or electronic format and is given in Appendix V of MARPOL Annex VI.

An electronic BDN as supplied should also be protected against any edits/modifications/revisions and a verification method used to make authentication possible. See interpretation for Regulation 18 MEPC.1/Circ.795/Rev.8, below.

A BDN in electronic format must equally be retained onboard for a period of not less than three years from the date of delivery and made readily available for inspection as required.

Next steps

Certain ports are looking to implement electronic BDNs as part of a wider move towards digitalisation, including documentation related to bunkering operations. Ship officers should be aware of these changes such as the method to digitally transfer an electronic BDN from the bunker barge to the receiving ship and the subsequent means to securely retain that electronic record onboard for not less than the required time period.

Unified Interpretations to MARPOL Annex VI

Regulation 18

Fuel oil availability and quality

Regulation 18.5 reads as follows:

“For each ship subject to regulations 5 and 6 of this Annex, details of fuel oil for combustion purposes delivered to and used on board shall be recorded by means of a bunker delivery note that shall contain at least the information specified in appendix V to this Annex.”

Regulation 18.6 reads as follows:

“The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. It shall be retained for a period of three years after the fuel oil has been delivered on board.”

Interpretation:

  • For the application of these regulations, they should be interpreted as being applicable to all ships of 400 gross tonnage or above and, at the Administration’s discretion, to ships of less than 400 gross tonnage.
  • The Bunker Delivery Note (BDN) required by regulation 18.5 is acceptable in either hard copy or electronic format provided it contains at least the information specified in appendix V to MARPOL Annex VI and is retained and made available on board in accordance with regulation 18.6. In addition, an electronic BDN should be protected from edits, modifications or revisions and authentication be possible by a verification method such as a tracking number, watermark, date and time stamp, QR code, GPS coordinates or other verification methods.

Separately, Lloyd’s Register Fuel Oil Bunkering Analysis and Advisory Service (FOBAS) said it will issue follow up bulletin to keep clients informed about the impact this change may have on their sample dispatch processes to our FOBAS laboratories.

The Maritime and Port Authority of Singapore (MPA) on 1 November launched its digital bunkering platform, becoming the world’s first port to implement e-BDN. 

Related: Singapore set to become first port in the world to debut electronic bunker delivery notes
Related: MPA Chief Executive: Port of Singapore begins digital bunkering initiative today
Related: Singapore: MPA publishes guidelines for bunker suppliers in preparation of e-BDN launch
Related: ZeroNorth enables Golden Island to become Singapore’s first 100% digital bunker supplier
Related: Photo essay: e-BDN trial of “One Truth” at Singapore port
Related: Hong Lam Marine ‘fully supportive’ of e-BDN implementation for Singapore bunkering sector
Related: ONE completes e-BDN adoption trial with Shell in Port of Singapore
Related: Singapore: Golden Island switching to 100% e-BDN operations from 1 December

 

Photo credit: Shaah Shahidh on Unsplash
Published: 22 January, 2024

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Photo credit: Korea Research Institute of Ships & Ocean Engineering
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