Introduction
On October 23, 2024, Lloyd’s Register Group Limited announced significant updates to the International Maritime Organization (IMO) fuel oil sampling guidelines. These changes, outlined in MSC-MEPC.2/Circ.18 issued on July 11, 2024, are crucial for shipowners, operators, managers, masters, and fuel oil suppliers to ensure compliance with MARPOL Annex VI and SOLAS Chapter II-2 regulations.
Key Changes in the Updated Guidelines
- Increased Minimum Sample Size
The new guidelines raise the minimum sample size from 400ml to 600ml. This adjustment ensures a more representative sample for accurate compliance verification. While the sample size has increased, the requirements for sampling location, arrangements, labeling, and storage remain consistent with the 2009 Guidelines. - Refined Fuel Oil Definition
For the purposes of these guidelines and SOLAS Regulation II-2/4.2.1, oil fuel is now defined according to Regulation 2.1.14 of MARPOL Annex VI and Regulation 1 of MARPOL Annex I. This clarification aligns fuel oil definitions across different regulations, ensuring consistency and reducing confusion during compliance checks. - Enhanced Sampling and Preparation Procedures
The updated circular emphasizes the need for personnel involved in sampling and preparing MARPOL Delivered Samples to be well-versed in using specific equipment and the guidelines themselves. Additionally, it mandates that sampling operations be witnessed by representatives from both the ship and the fuel supplier, enhancing transparency and accuracy in the sampling process. - Introduction of Section 10: Flashpoint Verification
A new Section 10 has been added to cover procedures and documentation requirements for checking fuel oil’s flashpoint. This section does not alter the existing MARPOL Annex VI Appendix VI requirements related to sulfur verification but provides additional protocols for flashpoint assessments under SOLAS regulations. - Shift in Responsibility for Tracking Delivered Samples
Responsibility for tracking MARPOL Delivered Samples has shifted from the ship’s master to the company. This change is particularly important when samples are taken off the ship for testing, but the remaining material is not returned. Ensuring proper tracking helps maintain sample integrity and compliance with regulatory standards. - Restricted Use of MARPOL Delivered Samples
The guidelines now clearly state that MARPOL Delivered Samples should only be used by parties to MARPOL Annex VI or SOLAS for compliance testing. They must not be used to resolve commercial quality disputes, ensuring that samples are solely utilized for their intended regulatory purposes.
Implications for the Maritime Industry
These updates reinforce the importance of accurate fuel oil sampling in maintaining vessel compliance and operational integrity. By increasing the sample size and refining definitions, the IMO aims to enhance the reliability of compliance verification processes. The introduction of flashpoint verification procedures adds an extra layer of safety, ensuring that fuel oils meet critical safety standards during voyages.
To effectively implement the updated guidelines, shipowners and operators should consider the following best practices:
- Training and Familiarization: Ensure that all personnel involved in fuel oil sampling and preparation are thoroughly trained on the new guidelines and proficient in using the required equipment.
- Collaborative Sampling Operations: Facilitate the presence of both ship and supplier representatives during sampling to ensure transparency and accuracy.
- Robust Tracking Systems: Implement comprehensive tracking systems to monitor MARPOL Delivered Samples, shifting the responsibility to the company level as mandated.
- Adherence to Flashpoint Procedures: To effectively meet SOLAS requirements, incorporate the new flashpoint verification procedures into regular maintenance and compliance checks.
Conclusion
The updated IMO fuel oil sampling guidelines mark a significant advancement in maritime compliance standards. Addressing key areas such as sample size, fuel oil definitions, and the introduction of flashpoint verification enhances the accuracy and reliability of fuel oil compliance verification. Shipowners, operators, and other stakeholders must adapt to these updates to ensure their vessels remain compliant, safe, and efficient in their operations.