Business

Integr8 Fuels: Never underestimate the importance of accurate sampling during supply

Proactively buyers should clarify means of delivery and location of the sampler used to produce the binding contractual samples; Singapore is a notable exception, it said.

Published

6 years ago

September 4, 2020

Admin

Integr8 Fuels, the bunker trading and brokerage arm of Navig8, on Thursday (3 September) published an article highlighting the importance of sampling during a bunker operation to ensure the provenance of the fuel; it was written by Chris Turner, Manager, Bunker Quality & Claims.

In recent times, we have written as to the importance of having an open mind when it comes to claims investigations when assessing the bunker stems against issues experienced onboard but what is equally important, is that we have a solid base for a claim against the fuel in the first place.

Indeed the most basic hurdles to overcome are whether we are basing the claim on a sample representative of the bunker contract and are we confident as the sample’s provenance, in other words, how, where, when it was drawn and is it fully representative of the supply?

At the end of the day, you will not be surprised that as a former laboratory chemist, that for years I have been heard preaching the same mantra in that “any laboratory is only as good as the quality of the sample provided”.

So how do we address one of the biggest variable of them all?

Prior to supply

Proactively buyers should always look to clarify means of delivery and the location of the sampler used to produce the binding contractual samples. Singapore is a notable exception in that SS600 and SS 648 mandate that samples which form the BDN are drawn from the vessels manifold but many areas have no such control with samples being drawn from the barge manifold unless agreed in writing prior to supply.

Truck and ex pipe deliveries require special attention in order to define how and from where samples are drawn which ultimately will be listed on the BDN and are inevitably the binding samples in the case of a dispute.

It is also important to understand access limitations given the continued Covid-19 challenges. Clarification must be sought early as to whether crew members can attend a barge or shore installation to witness samples being drawn and/or can barge crew attend the vessel as given the importance of samples the mobilization of surveyors would always be recommended.

Recently we have identified that some suppliers list these Covid limitations in their calling instructions, so all stakeholders should be sure to read them thoroughly as this document may give you the “heads up” needed to appoint a surveyor in advance to protect your interests.

Time of delivery

At the end of the day, if you don’t raise concerns at the time as to the provenance of samples or any deviation from sampling protocols then you have little recourse in the future.

Indeed it would not be the first time that the representative (and contractually binding sample) does not bear any resemblance to other samples presented which of course could expose you to the full weight of the claim.

Therefore any deviation or issue should be documented in a Statement Of Fact (SOF) or Letter Of Protest (LOP) at the time of supply and should this be refused or not accepted to be signed by the supplier, then urgent communications should be made to the relevant counter-parties in order to document the occurrence.

Common deviations include:

Lack of continuous drip sampler on board the barge resulting in “SPOT ONE SHOT” samples forming the BDN.
Continuous drip sampler not started at commencement of delivery.
Cubitainer seen to be full prior to delivery completion.

Post delivery

Particularly if time is of the essence on completion, it can be a bad habit to ignore the samples and concentrate on the ullaging – which of course would render all previous attention potentially useless. It is essential that the entire sampling process is covered from the moment the cubitainer is connected to the continuous drip sampler until the last sample has been sealed and accurately documented on the BDN and both the BDN and the sample labels have been signed off by all parties.

Conclusion

So to conclude, I would argue that given some of the quality challenges and the issues with barge accessibility for the crew given Covid-19 concerns, it is almost essential to employ a barge based surveyor to protect buyers interests even in a relatively low flat price world as we have at present.

This allows any deviations relating to Quantity and Sampling to be noted, documented and dealt with at the time and gives you peace of mind in the event a claim occurs further down the line.

Remember the adage, the laboratory is only as good as the sample provided – you are wise to always employ a gold standard ISO 17025 accredited laboratory for your testing but if the sample is not representative then it is irrelevant and is a recipe for disaster. 

Photo credit and source: Integr8 Fuels
Published: 4 September, 2020

Legal

Singapore police arrest eight over alleged illegal MGO transaction off Tuas

SPF says preliminary investigations found that crew members of a Singapore-registered tugboat misappropriated MGO worth about SGD 10,570 without their company’s knowledge and sold it illegally.

Published

11 hours ago

August 14, 2026

Admin

Singapore police arrest eight over alleged illegal MGO transaction off Tuas

The Singapore Police Force (SPF) on Thursday (13 August) said it has arrested eight men, aged between 25 and 54, for their suspected involvement in an illegal transaction of Marine Gas Oil (MGO).

On 13 August 2026 at about 1.05am, officers from the Police Coast Guard (PCG) conducted a check on a Singapore-registered tugboat in the waters off Tuas and discovered that eight crew members were possibly involved in the illegal transaction of MGO.

“Preliminary investigations revealed that the crew members of the tugboats misappropriated MGO valued at about SGD 10,570 (USD 8,258), without their company’s knowledge,” SPF said in a statement.

“The MGO was sold illegally for their personal financial gain.”

The eight crew members will be charged in court on 14 August 2026 with the offence of theft by servant of property in possession of master under Section 381 of the Penal Code 1871 If convicted, they shall be punished with an imprisonment term that may extend to seven years and shall also be liable to fine.

“The Police take a serious view of illegal transaction of MGO in Singapore Territorial Waters and will continue to conduct enforcement and security checks to prevent, deter and detect such illicit activities in Singapore waters,” SPF added.

Photo credit: Singapore Police Force
Published: 14 August, 2026

Port & Regulatory

Gard: Sulphur-related bunker claims rise amid tighter China MSA enforcement

Claims involving excessive sulphur content in marine fuels have been rising, while stricter inspections by the China MSA have heightened the focus on sulphur compliance, particularly in the Bohai Sea.

Published

12 hours ago

August 14, 2026

Admin

Maritime protection and indemnity (P&I) club Gard on Wednesday (12 August) highlighted that claims involving excessive sulphur content in marine fuels have been rising, while stricter inspections by the China MSA have heightened the focus on sulphur compliance, particularly in the Bohai Sea:

Rise in off-spec sulphur claims

Recent claims experience indicates that bunker quality continues to pose a significant operational risk for shipowners. In our earlier review of bunker-related claims during the first five months of 2026, we highlighted a rise in off-specification bunker incidents amid increased pressure on global fuel supply chains following the escalation of the conflict in the Middle East.

Specifically for Sulphur compliance, between January and June 2026, the number of sulphur-related cases increased by more than threefold compared with the same period in 2025. Notably, the number of cases recorded in the first six months of this year has already exceeded the total number reported during the whole of last year by approximately 40%.

While each case is fact-specific, the increase is notable because excessive sulphur content constitutes a MARPOL compliance issue. Unlike many other bunker quality problems, sulphur non-compliance identified through port state inspections can result in vessel delays, enforcement action, and substantial costs associated with debunkering and fuel disposal.

The map below illustrates the geographical distribution of sulphur-related claims recorded during the first six months of 2026, based on the location where the bunkers were stemmed.

Distribution of sulphur related claims

China MSA steps up sulphur compliance enforcement

According to our correspondent, Huatai, on 5 June 2026, the maritime authorities of Tianjin, Hebei, Liaoning and Shandong jointly launched a special campaign on ship pollution prevention and control in the Bohai Sea region. The campaign involves coordinated supervision by local MSA branches across the region and is expected to last nearly five months. It covers major ports and surrounding port areas in the Bohai Sea region, including Tianjin, Tangshan, Qinhuangdao, Huanghua, Jinzhou, Yingkou and Longkou.

While the initiative is broader than bunker sulphur compliance alone, its scope includes inspections relating to air pollution prevention, SOx emissions, fuel compliance and other high-pollution-risk operations. Enforcement measures are expected to comprise onboard inspections, cross-regional enforcement activities, unannounced spot checks and remote monitoring. These efforts will be supported by a combination of UAV patrols, maritime patrol vessels, shore-based monitoring systems and rapid on-site fuel testing.

As a result, vessels trading in the Bohai Sea region may experience increased scrutiny of fuel compliance documentation, fuel sampling records, onboard fuel management procedures, and the handling or disposal of suspected non-compliant fuel.

Documents typically requested by China MSA

Based on our recent experience, including the case discussed above, and subject to the specific requirements of the local MSA office, owners and operators may be requested to provide supporting documentation such as:

Bunker documentation – Bunker Delivery Notes (BDNs), MARPOL fuel sample records, fuel test reports, and relevant fuel quality certificates.
Statutory certificates – including the International Air Pollution Prevention (IAPP) Certificate and International Oil Pollution Prevention (IOPP) Certificate.
Operational records – engine logbooks, deck and navigation logbooks, Oil Record Book entries, and records relating to fuel transfers, storage and consumption.
Sampling documentation – the Master’s statement and any records demonstrating how fuel samples were drawn, sealed, labelled, handled and retained.
Correspondence records – communications with the authorities, bunker suppliers, charterers and other relevant stakeholders.
Fuel disposal records – approved disposal plans, debunkering documentation, receipts and evidence of final disposal, where applicable.

The exact documentation required will depend on the nature of the investigation, the findings of the inspection, and the requirements of the local enforcement authority.

Possible regulatory consequences in China

Under the Air Pollution Prevention and Control Law of the People’s Republic of China, ocean-going vessels are required to use fuel oil meeting atmospheric pollutant control requirements after berthing. Vessels operating within designated emission control areas must also comply with applicable emission standards. Article 106 provides that where vessel fuel oil fails to meet applicable standards or requirements, the competent maritime authorities may impose fines ranging from RMB 10,000 to RMB 100,000. Liability may extend to shipowners, ship operators and ship managers depending upon the circumstances of the case.

Recommendation

Sulphur compliance should be treated as both a fuel quality and regulatory risk. Owners and operators are encouraged to take preventive steps before bunkering, act promptly if non-compliant fuel is suspected, and preserve evidence carefully if an inspection or claim arises. Under amended

Resolution A.1206(34), Appendix 18, 2.1.5, if the BDN shows compliant fuel, but the master has independent test results of the fuel oil sample taken by the ship during the bunkering which indicates non-compliance, the master may document this by notifying the ship’s flag Administration, with copies to:

the competent authority of the relevant port of destination,
the Administration under whose jurisdiction the bunker deliverer is located,
and to the bunker deliverer.

Photo credit: shraga kopstein on Unsplash / Gard
Published: 14 August, 2026

LNG Bunkering

Shell expands LNG bunkering footprint in Spain with Valencia

As one of the region’s key maritime hubs, the company said Valencia expands the options available to shipowners seeking LNG supply along major shipping routes.

Published

12 hours ago

August 14, 2026

Admin

Shell expands LNG bunkering footprint in Spain with Valencia

British oil giant Shell on Thursday (13 August) said Valencia has joined its growing network of bunkering locations, making LNG available as a marine fuel.

The successful completion of the first LNG bunkering operation in Valencia marked an important milestone for Spain and further strengthened Shell’s LNG supply capabilities across the Mediterranean.

In a video shared by the company, bunkering vessel Alice Consulich was shown supplying an undisclosed volume of LNG to the container ship MSC Sabrina.

“As one of the region’s key maritime hubs, Valencia expands the options available to shipowners seeking LNG supply along major shipping routes,” Shell said in a social media post.

Shell said the achievement reflected the strong collaboration across the maritime value chain, including MSC Mediterranean Shipping Company, the Port of Valencia and Fratelli Cosulich Group.

“We look forward to making more LNG bunker deliveries in Valencia and across the Mediterranean as LNG infrastructure and capabilities continue to expand,” the company said.

Photo credit: Shell
Published: 14 August, 2026