The Worldwide Maritime Group (IMO) might be discussing adjustments to the MARPOL Annex VI rules on how Port State Management (PSC) can draw gas oil samples on board, when assembly on the 75 session of the Marine Atmosphere Safety Committee (MEPC 75) on 16 to twenty November 2020. A few of the new recommendations are a trigger for concern, BIMCO believes.
Whereas shipowners have been centered on the 2020 sulphur regulation which entered into drive on 1 January 2020 as a consequence of security considerations, IMO members states have had their eyes on the procedures that management whether or not ships are carrying low-sulphur gas oil in accordance with the brand new rules.
In reference to the amendments to MARPOL Annex VI a number of definitions will turn out to be useful:
- In-use pattern, outlined because the pattern of gas oil in use on a ship. It might probably for instance be drawn from the gas oil line between the service tank and an auxiliary engine.
- On board pattern, outlined because the pattern of gas oil supposed for use or carried to be used on board a ship. It’s drawn immediately or not directly from gas oil tanks.
In line with the brand new regulation, authorities together with Port State Management are thus given specific authority to attract oil samples from the ship’s gas oil tanks.
BIMCO is anxious with the advised process for ‘On board sampling’ for use for figuring out if the ship is in compliance with the sulphur regulation, for the reason that solely really homogenous and consultant gas oil pattern is the MARPOL pattern (MARPOL delivered pattern). The brand new suggestion might trigger confusion and uncertainty between the ship, bunker provider, time constitution and different stakeholders, particularly if the testing outcomes change into completely different, BIMCO believes.
Direct samples drawn by means of the sounding pipe or the manhole can not in BIMCO’s view be thought-about homogenous and consultant for the sulphur content material within the gas oil tank. That is recognised (but in addition disregarded) within the round on early utility of the verification procedures for a MARPOL Annex VI gas oil pattern (MEPC.1/Circ.882 ):
“The in-use or on board gas oil pattern, as acceptable, shall be used to confirm the sulphur content material of the gas oil as represented by that pattern of gas oil on the level of sampling.”
Which means a gas oil pattern drawn by PSC is simply consultant of the gas oil on the degree or level of suction, however not consultant of the gas oil within the tank.
Oblique samples drawn through the use of the gas oil switch pump, can’t be used both, for the reason that pattern will not be homogenous and consultant of the sulphur content material within the tank. For the reason that switch pump’s suction is positioned within the backside of the gas tank, BIMCO fears that such samples would present unsuitable outcomes even when the sulphur content material of the gas oil is definitely compliant.
This results in the truth that the one gas pattern really homogenous and consultant of the sulphur content material that’s accessible right this moment, is the MARPOL pattern as a result of it’s drawn over your complete bunker operation.
Security considerations in case of direct sampling from gas oil tanks
A traditional gas oil tank solely has two openings, the manhole, for inspection when the tank is empty, and the sounding pipe. Gas oil tanks on present ships aren’t constructed with designated sampling factors.
The manhole ought to by no means be opened whereas there’s gas oil contained in the tank. Gas oils are saved at excessive temperatures and it’s consequently unsafe for the individuals taking the pattern.
The MARPOL (delivered) pattern continues to be important
The statutory gas verification process for MARPOL Annex VI gas oil samples is being up to date to incorporate the brand new gas oil samples and making the textual content of the round on early utility of the verification procedures for a MARPOL Annex VI gas oil pattern obligatory.
Extra data might be discovered right here interpretation of the discord between MARPOL and commercial fuel samples.
In comparison with the present verification process, MARPOL (delivered) samples will sooner or later be examined with out taking the Reproducibility (R) of the take a look at technique into consideration. This implies there might be no take a look at margin and thus, the take a look at results of a MARPOL pattern (common of two assessments by the identical laboratory) should not exceed 0.50% m/m sulphur.
For ‘In-use’ and ‘On board’ samples, the Reproducibility (R) of the take a look at technique, in accordance with ISO 4259-2:2017, ought to be considered when assessing whether or not the take a look at result’s acceptable or not. Which means the take a look at consequence, from the gas oil samples drawn by PSC, shall be thought-about acceptable if the sulphur content material doesn’t exceed 0.53%.
This small however important distinction between the verification process for MARPOL samples and samples drawn by PSC was agreed by IMO intentionally. The distinction is meant to make sure that ships aren’t unfairly penalised for marginal exceedances as a consequence of components exterior the ship’s management. Time will present if that is adequate to keep away from that completely different conclusions are drawn from the various kinds of samples.
Ultimately we must always not overlook that it’s nonetheless the accountability of the provider to ship gas oil which is compliant with the statutory sulphur content material limits i.e. 0.50% or 0.10% m/m.
Supply: BIMCO