Mar. 3 2022

Class and Statutory News

FITTING OR DESIGNATING OF “IN USE” FUEL OIL SAMPLING POINTS - ENTRY INTO FORCE 1 APRIL 2022

MARPOL Annex VI - new requirements related to the procedures for sampling and verification of the sulphur content of fuel oil (Resolution MEPC.324(75)) including mandatory provisions for the fitting or designating of “in use” fuel oil sampling points for new and existing ships

1. Background - Consistent implementation and verification of 2020 Global Sulphur limit

To support consistent implementation and verification of the 0.50% sulphur limit, IMO adopted amendments to MARPOL Annex VI as Resolution MEPC.324(75) for an entry into force on 1 April 2022.

These amendments define 3 different types of fuel oil sampling:

“MARPOL delivered sample” already required and two new samples, namely “In-use sample” and “On board sample”. Refer to MARPOL annex VI/reg.2 for the definition of these type of samples.

The new provisions require that:

  • The “onboard sample” shall be drawn taking into account the guidelines developed by the IMO . Refer to the 2020 Guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship (MEPC.1/Circ.889).

  • The “in-use sample” shall be drawn taking into account the guidelines developed by the IMO . Refer to the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1)

Amendments include mandatory provisions for the fitting or designating of “in use” fuel oil sampling points

2. In-use fuel oil sampling point(s) to be fitted or designated

Regulation 14 (new regulation 14.10) as amended by resolution MEPC.324(75) requires sampling point(s) to be fitted or designated for the purpose of taking representative samples of the fuel oil being used on board the ship taking into account the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1).

Refer to the attached 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships MEPC.1/Circ.864/Rev.1

New provisions in regulation 14.10 (i.e. fitting or designating of “in use” fuel oil sampling points) applies to:

-              New ships constructed (i.e. keel laid) on or after 1 April 2022 upon delivery; and

-              Existing ships, ships constructed (i.e. keel laid) before 1 April 2022, not later than the first IAPP renewal survey on or after 1 April 2023 (regulation 14.11)

NB: The requirements above are not applicable to a fuel oil service system for a low-flashpoint fuel for combustion purposes for propulsion or operation on board the ship. Low-flashpoint fuel means gaseous or liquid fuel oil having a flashpoint lower than otherwise permitted under paragraph 2.1.1 of regulation 4 of chapter II-2 of the International Convention for the Safety of Life at Sea (SOLAS), 1974, as amended.

3. Retroactive application to existing ships (i.e. keel laid before 1 April 2022)

Existing ships are required to fit or designate fuel oil sampling points for the purpose of taking representative samples of the fuel oil being used on board the ship, taking into account MEPC.1/Circ.864/Rev.1 in due time. Thereafter, BV will assess the conformity (plan review and survey onboard) in accordance with MEPC.1/Circ.864/Rev.1. Subsequently the supplement to the ship’s IAPP Certificate is required to be updated not later than the first IAPP renewal survey on or after 1 April 2023, and new provisions have to be recorded as appropriate (i.e. new paragraphs 2.3.4 and 2.3.5 of supplement to IAPP Certificate)