The IMO has published a joint circular updating the fuel oil sampling guidelines for compliance verification with MARPOL Annex VI and SOLAS Chapter II-2.
MSC-MEPC.2/Circ.18, issued on 11 July 2024, extends the use of the MARPOL Delivered Sample to also be available for checking the flashpoint requirement under SOLAS Regulation II-2/4.2.1.
This joint circular 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”.
Changes to note in updated Guidelines:
- Minimum sample size: The basic requirements (as given by the 2009 Guidelines regarding the sampling location, arrangements and procedures for what the joint circular refers to as the “Representative
Sample”) are unchanged apart from the minimum sample size being increased from 400ml to 600ml. Also unchanged are the sample labelling and sample storage aspects. - Fuel oil definition: For the purpose of these Guidelines, and for the application of SOLAS Regulation II2/4.2, oil fuel is as defined in Regulation 2.1.14 of MARPOL Annex VI, including oil fuel as defined in
Regulation 1 of MARPOL Annex I. - Sampling and preparation: There are now explicit references in the circular to the need for personnel undertaking this sampling and the subsequent MARPOL Delivered Sample preparation to be familiar with the use of the equipment and the Guidelines. Also, that the sampling operation itself should be witnessed by representatives of both the ship and supplier.
- New Section 10: The one notable addition is the new Section 10. This covers the procedures and documentation requirements in those instances where the fuel oil’s flashpoint 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.
- Tracking of Delivered Samples: 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 responsibility of the ship’s master, as previously stated in the 2009 Guidelines. This will be important where samples are taken off the
ship for testing, but the remaining material is not subsequently returned.
The MARPOL Delivered Sample should only be used by a Party to either MARPOL Annex VI or SOLAS, to test for compliance with the convention requirements. The MARPOL Delivered Sample should not be used for any other purposes such as the resolution of commercial quality disputes.
