With effect from 19th May 2005, IMO MARPOL 73 78 Annex VI – Regulations for the Prevention of Air Pollution from Ships became mandatory for all internationally trading vessels above 400 GT. Subsequently, IMO began a review which was completed and adopted in 2008 enabling a revised Annex VI with associated NOx Technical Code to enter into force in July 2010.

The revised Annex VI contains a schedule of tightening emissions limits for nitrogen oxides – NOx and sulphur oxides – SOx. Regulation 13 deals with NOx and regulation 14 SOx and related particulate matter - PM. Whilst NOx emissions are influenced by engine design and operation, SOx emissions are solely related to the fuel consumed. As such Annex VI places limits on the sulphur contained within fuel that can be used on ships whilst in international waters and Emission Control Areas (ECA). Alternatively regulation 4 allows other compliance methods (for example Exhaust Gas Cleaning Systems - see external website www.EGCSA.com) that are at least as effective in terms of emissions reduction as any of the standards in regulations 13 and 14.

Regulation 18 requires fuel of the correct standard to be available. A Bunker Receipt Note with specific contents must be issued for each delivery together with a sample that is fully representative of the fuel delivered. These must be retained for 3 years and 12 months respectively in case they are required as proof of compliance. Furthermore the regulation gives steps that must be taken in the event of non-compliance.

Details of the Bunker Delivery Note and procedures for sampling and verifying the sulphur content of the “MARPOL” sample are provided in appendices V and VI of Annex VI and IMO Resolution MEPC 182 (59).

The latter states “a sample of the fuel delivered to the ship should be obtained at the receiving ship’s inlet bunker manifold and should be drawn continuously throughout the bunker delivery period”. It is important to remember that this sample is to be used solely for determination of compliance with Annex VI of IMO MARPOL 73 78 and cannot be used for any other commercial purposes. However, samples can be drawn at the same time for other purposes.

Summary:

A representative sample is fundamental for all later testing
Continuous drip manual sampler is the proven method for effective sampling
The sample must be witnessed by all parties, supplier’s representative as well as recipient/ship
The point of custody transfer is usually the ship’s manifold
Careful measurements during delivery will produce savings
Samples should be handled and stored carefully - they may be the only evidence
IMO MARPOL Annex VI requires you to store the sample for at least 12 months and the Bunker Delivery Note for 3 years

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Comment:

The Kittiwake Bunker Sample Storage System is approved by Germanischer Lloyd for secure storage and recording of all bunker samples in compliance with IMO MARPOL Annex VI. The retained sample is to be kept under the ship's control for at least 12 months from the date of delivery.

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