Bunker Delivery Note (BDN) has evolved from Bunker Delivery Receipt (BDR). Originally the BDR was used as a means to document the quantity delivered from a supplier to a customer and provide evidence of receipt of the product. MARPOL Annex VI, International Convention for the Prevention of Air Pollution from Ships, now requires certain information in a BDN. As well as being required for the above purposes, a BDN (as dictated in MEPC.176(58)) must also include the sulphur levels in the product, as well as delivered quantities.
Details in the BDN
The following information must be included in the BDN to comply with global standards:
- Name and IMO number of receiving vessel
- Port of bunkering
- Date of commencement of delivery
- Name, address and telephone number of fuel oil supplier
- Product name(s)
- Quantity in metric tons
- Density at 15 degrees Celsius (kg/m3
- Sulphur content (%m/m)
- A declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with regulation 18.3 of this Annex VI and that the sulphur content of the fuel oil supplied does not exceed the limit.
- The declaration shall be completed by the fuel oil supplier’s representative by marking the applicable box(es) with a cross (x).
The limit is indicated as follows:
- the limit value is given by regulation 14.1 of this Annex VI of MARPOL;
- the limit value given by regulation 14.4 of this Annex; or the purchaser’s specified limit value of _____ (% m/m), as completed by the fuel oil supplier’s representative and on the basis of the purchaser’s notification that the fuel oil is intended to be used (in combination with an equivalent means of compliance in accordance with regulation 4 of this Annex; or is subject to a relevant exemption for a ship to conduct trials for sulfur oxides emission reduction and control technology research in accordance with regulation 3.2 of this Annex).
The BDN is also used in conjunction with bunker samples to provide proof of regulatory compliance. Bunker sample seal numbers are documented on the BDN to provide a record of the sample for that particular delivery. Each sample (commercial and MARPOL) must be sealed with the seal identification number clearly listed on the BDN. Note that BDNs may also require additional information to comply with local laws/regulations at the port of delivery.
The BDN must be maintained onboard the vessel for three (3) years. Port State Control has the authority to board the vessel to inspect and make copies of the BDN to verify that the fuel complies with global and local regulations.
Bunkering and considered as a hazardous activity and in case something goes wrong, there are numerous repercussions. These repercussions are mainly pollution, fire, machinery failure, loss of life, etc. There are numerous recommendations that are to be taken care of during the bunkering process:
- There should be clear communication between the receiving ship and the bunker supplier (bunker barge, truck or terminal), and emergency stop, and response actions should be arranged before bunkering starts.
- It’s best to avoid co-mingling of fuel oils onboard to minimize cross-contamination.
- While bunkering, a representative fuel oil sample should be taken. There are guidelines for collecting the MARPOL sample in MEPC.182(59) on 2009 Guidelines for the sampling of fuel oil to determine compliance with MARPOL Annex VI.
- In order to observe and record bunkering and sampling processes, cameras could be used.
- Fuel oil purchasers should have a sample of fuel oil collected during bunkering tested to make sure it meets the contract specifications. Independent labs should analyze samples according to ISO/IEC 17025 General requirements for competence of testing and calibration laboratories or equivalent national standards. A list of accredited laboratories in a country should be on the national accreditation body’s website. Labs should also have an ISO 9001 Quality management system – Requirements, or equivalent. Fuel oil should not be used until this analysis is complete, if possible.
- The buyer should confirm the lab’s accreditation or certification, especially if any accreditation is general (overall lab practices) or specific (analytical methods).
- In case of disputes, the contract should specify how the lab analysis will be done.
- It’s not always necessary to analyze fuel oil before using it (like when fuel oil is frequently delivered on contract with the same supplier).
- Where an analysis is required by the the analysis should be carried out in accordance with
- While a fuel oil purchaser/user may choose to use ISO 13739, ISO 4259, or other testing protocols, it should be mindful that MARPOL Annex VI sets out the procedures for compliance and enforcement, including Appendix VI fuel verification procedure for MARPOL Annex VI fuel oil samples. Guidance is also in resolution MEPC.182(59) Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI, and the Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864). If a different test is desired, it can be specified in the fuel oil purchase contract itself. However, that contract will not respect to determining compliance with the mandatory in a compliance or enforcement action brought by a flag, port, or coastal State.
Recent development for BDN
PPR 10 agreed on two UIs for approval by MEPC 80. The UI enables having the Bunker Delivery Note (BDN) in an electronic format provided it contains all the required information and is protected from edits, modifications, or revisions. Authentication should be possible by a verification method, for example, tracking number, watermark, date and time stamp, QR code or GPS coordinates. The 10th session of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 10) was held in London from 24 to 28 April 2023.