FOBAS: Joint circular from MSC and MEPC on bunker fuel oil sampling guidelines

Lloyd’s Register Fuel Oil Bunkering Analysis and Advisory Service (FOBAS) on Tuesday (10 September) released a bulletin on IMO’s Maritime Safety Committee (MSC) and Marine Environmental Protection Committee (MEPC) jointly approving the fuel oil sampling guidelines during recent sessions (MSC 108 and MEPC 81):

IMO’s Maritime Safety Committee (MSC) and Marine Environmental Protection Committee (MEPC) during recent sessions (MSC 108 and MEPC 81) jointly approved the fuel oil sampling guidelines MSC-MEPC.2/Circ.18 for compliance verification with MARPOL Annex VI and SOLAS chapter II-2. 

This joint circular from MSC and MEPC was issued 11 July 2024 and revokes the previous MEPC resolution 182(59) titled ‘2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI’.

In essence, this Circular simply extends the use of the MARPOL Delivered Sample to also be available for checking of the flash point requirement under SOLAS Chapter II-2/4.2.1 where it is referred to as the Representative Sample. The basic requirements as given by the 2009 Guidelines as regards the sampling location, arrangements and procedures are unchanged apart from the minimum sample size has been increased from 400ml to 600ml. Also unchanged are the sample labelling and sample storage aspects.

The joint circular now provides explicit references in the text to the need that personnel undertaking the sampling and the subsequent MARPOL Delivered Sample preparation, should be familiar with the use of the equipment and the Guidelines. Also, that the sampling operation itself should be witnessed by both the ship’s and supplier’s representatives. 

The one particular addition is the new Section 10 which covers the procedures and documentation requirements in those instances where the fuel oil’s flash point is to be checked. This in no way impacts on the MARPOL Annex VI Appendix VI requirements in respect of the sulphur verification procedures which are unaltered.

Moreover, with regard to the key point of keeping track of these MARPOL Delivered Samples, this is now given as being the company’s responsibility rather than the ship’s master as previously. This will be important where samples are taken off the ship for testing, but the remaining material is not subsequently returned. 

It should be noted that it is the sole prerogative of the representatives of the Parties to either MARPPOL Annex VI or SOLAS, as applicable, to take a MARPOL Delivered Sample for testing. Those sample cannot be opened or tested for any other purposes such as the resolution of commercial quality disputes.

Photo credit: Louis Reed from Unsplash
Published: 11 September, 2024