Recently, refiners, shipowners and global shipping institutions came together to provide a joint guidance for IMO2020 and in these article we are highlighting the responsibilities that need to be taken for using Compliant Fuel.
Responsibilities of fuel suppliers
Suppliers are expected to deliver a fuel which meets the parameters agreed between the supplier and the buyer.
‘Supplier’ in this context may not necessarily be the actual person delivering the fuel; the fuel supplier is the party responsible for the delivered quantity and quality either directly or through subcontractors.
Likewise, ‘meeting the needs of the ship’ means that the fuel supplied should be stable in regular handling, homogeneous across the entire delivery and fit for purpose after appropriate on-board treatment (settling, centrifuging, heating and filtration).
Maintaining Documentation
- The supplier is responsible for maintaining appropriate documentation to help identify product origins, including the manufacturing source and the various links in the supply chain, to enable traceability.
- Monitoring fuel quality at each step of the supply chain will also help to identify points of entry of any extraneous or harmful materials if these are discovered when the fuel is being used; where suppliers get components from other suppliers they should obtain assurance that appropriate supply chain quality control steps have been taken.
- It is important that the supplier delivers accurate information so that the ship operator can characterize the fuel supplied and take the appropriate initial steps in setting up procedures for the handling, treatment and use of that fuel.
- This information (e.g. special heating requirements) would be in addition to the required provision of the representative commercial samples, MARPOL delivered sample, material safety data sheets (MSDS) and bunker delivery notes (BDNs); the additional information would be in the format of a comprehensive certificate of quality (CoQ) or equivalent documentation.
Fuel Quality Control
Quality control during production of bunkers
Marine fuels, or bunkers, are hydrocarbon-based fuels for use on board a ship. They are primarily derived from petroleum sources and may also contain hydrocarbons from synthetic or renewable sources, as defined in ISO 8217:2017, Petroleum products—Fuels (class F)—Specifications of marine fuels.
- The bunker supplier should ensure control of individual blend component quality. This includes knowing the components’ individual properties through accurate data, and the component origins supported by relevant documentation as agreed between the buyer and seller of the components.
- Blend components should be of known suitability for bunker fuel production, with particular attention being given to ensure that the final product is stable.
- The fuel should not contain harmful or damaging materials in concentrations that may cause damage as defined in Clause 5 of ISO 8217:2017 and Regulation 18.3 of MARPOL Annex VI.
- This does not preclude the use of additives intended to improve specific fuel characteristics such as cold flow or combustion properties.
- Any additive used should have a proven track record and should be thoroughly evaluated to ensure that it is fit for use in marine fuel applications. Further details can be found in IMO (2018), Guidance on best practice for fuel oil suppliers for assuring the quality of fuel oil delivered
The supplier should ensure that the final blend, whether produced at a refinery or in a tank terminal, is tested at an accredited (e.g. ISO or equivalent certification) laboratory.
Transport, storage and transfer
- Where actions in the supply chain are performed by other parties, these should be identified. The supplier should ensure control over, and maintain oversight of, the supply chain.
- The quality of a bunker fuel or blend components may change compared to its origin during transportation, transfers and storage.
- The supplier should oversee the transportation of the fuel, blend components and additives to ensure that product contamination does not occur in tanker ships, shore tanks, pipelines, road tankers or barges prior to delivery.
- The supplier is expected to have in place a QMS (ISO 9001 or equivalent) to monitor, manage and assess the quality of the products they are supplying throughout the above processes.
- When arranging delivery, the supplier is expected to ensure that the product is supplied without cross-contamination from any other grade being supplied to the ship, or from any other material previously handled by the delivery facility.
- This is particularly important where delivery facilities are used to supply different grades of fuel and/or different sulphur specifications.
Delivery
- If more than one grade of bunker fuel is to be supplied, the order in which the grades are supplied should be agreed between the supplier’s representative and the ship’s master or officer in charge of the bunker operation.
- To avoid contamination of product during delivery, it is recommended that the lighter/lowest sulphur grade is supplied first, followed by the heavier/higher sulphur grade.
- Where necessary, segregated pipelines/hoses and bunker connections for supply of materially different types of product should be provided, e.g. for residual and distillate grades, and for high and low-sulphur bunkers, to prevent cross-contamination of products.
- The use of multiple bunker barges or other delivery facilities to discharge a single product in ‘series’ adds complexity to the delivery and will require additional management and oversight. In view of this, such operations should be avoided to the greatest extent possible.
Sampling
- Representative samples should be drawn during the bunker delivery for retention by both the receiving ship and the supplier, in addition to the MARPOL delivered sample6 which is a statutory requirement.
- The sampling process should be witnessed by representatives for both the supplier and the receiving ship.
- The sample containers should then be sealed at least once (and counter sealed if requested by the receiving ship) with tamper-evident seals that have a unique means of identification, and should be labelled, signed and countersigned by representatives of both parties.
Sampling in the supply chain
- Sampling should take place at each point of product custody transfer throughout the supply chain.
- The supplier should retain the bunker transfer samples for at least 30 days. If a dispute over the fuel quality should arise, samples should be kept until the dispute has been resolved.
- The above should be documented in the supplier’s QMS. This is a key part of a QMS; it enables transparency and traceability, and assists the supplier in identifying the origin of potential problems and taking steps to remedy and prevent further quality issues.
- It should be recognized that, in many ports, the contractual barge loading sample is often taken from the shore tank and not at a subsequent custody transfer point.
Responsibilities of fuel users
Reference should be made to the IMO guidelines for fuel users and fuel purchasers in MEPC.1/Circ.875.7
Fuel purchasers are expected to order fuel of a quality or grade suitable for the receiving ship, bearing in mind its intended trading area as well as the capabilities of the ship to receive, store, handle and use the fuel, including the ability to segregate different batches of fuel to safeguard against incompatibility issues.
The fuel purchaser and the end user (the ship)
should take note of the following:
- On-board fuel management is an essential element of preventing operational issues.
- Improper handling of fuel on board may lead to non-compliance with MARPOL requirements on fuel quality and safety, even if the fuel received was compliant. In this context, the following should be noted
- Once fuel is delivered on board, ships should have documented procedures for the safe handling and use of the fuel.
- These procedures should form part of the company’s SafetyManagement System (SMS) which should be in place as a measure of good practice and/or as required by the International Safety Management (ISM) Code, as applicable, supported by equipment operating and maintenance manuals.
- Each ship should have in place fuel switching procedures (where applicable). The ship’s crew should be familiar with implementing these procedures.
- Marine fuel which fully meets statutory requirements and purchase specifications such as ISO 8217:2017, will nevertheless still require treatment before it meets most engine manufacturers’ requirements.
- Where a ship is exempted from some of the provisions of MARPOL Annex VI under Regulation 3 of the Annex, or will comply with the requirements of the Convention using an equivalent means of compliance under Regulation 4 of the Annex, fuel oil purchasers should consider any conditions attached to the exemption or equivalent means which may affect fuel purchasing.
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Source: CIMAC
