It seems inconceivable, certainly unbelievable, that having paid up to millions of dollars for
fuel for a vessel to operate, the owners of the vessel and/or the charterers then should have to check themselves that the fuel is actually of a standard that complies with regulations and what they paid for! says a press release published by the American Club which guides shippers from IMO 2020 Fuel Hazards.
The guidance available on the American Club website highlights how the whole concept seems upside-down but unfortunately, the situation still exists when a vessel takes on fuel, commonly referred to as bunkers. So keeping that in mind here we are putting forward some safety checkpoints to be followed onboard a ship to protect the ship and its crew from potential hazards and liabilities.
Protecting Ship & Crew from Contaminated Bunkers
Until such time as there is a major shift in emphasis of responsibility, we are stuck with a certain regime of sampling and testing of fuel oil bunkers loaded into ships. Below, follows a general guide on how to protect ships, their crew and the environment from the effects of sub-standard and/or contaminated bunkers that, unfortunately, still find their way into ships.
Under any circumstances, all bunkering procedures are to comply with the
company’s and shipboard safety management system (SMS) as part of compliance with the
International Safety Management (ISM) Code.
General Safety Procedures
Bunkering operations, while routine in many parts of the world, do in fact pose different risks to those encountered during normal ship operations. Bunkering operations can be conducted while vessels are at anchor or at a berth and will quite often be conducted concurrently with cargo operations.
This adds some additional risk to bunkering operations and the personnel involved, for
which additional precautions are necessary. General procedures associated with bunkering
operations are as follows below.
Overall Responsibility
The Master of a vessel always has overall responsibility for the safety of the vessel and its
crew. But the Chief Engineer has specific responsibility for the safe reception on board and
handling of the vessel’s fuels.
Responsibility for correct implementation of a detailed bunkering plan is assigned to:
- the designated Person In Charge (PIC) usually the Chief Engineer or the Second
Engineer if the Chief Engineer is otherwise occupied and customarily involving the
Fourth Engineer. In any event, the responsibility falls on the most senior engineer
onboard; - engineers of the watch; and
- senior deck officer.
Liability & Responsibility for Fuel Handling & Treatment
IMO conventions place responsibility on the ship’s crews and shipowners. However, Annex VI, regulation 18 of the MARPOL Convention also directs responsibilities onto the fuel suppliers fuel oil quality declaration, via the bunker delivery note (BDN) and requiring fuel oil sampling at the receiving ship’s manifold.
Annex VI of the MARPOL Convention also contains instruments to encourage port States to
ensure that suppliers fulfill their obligations. Owners should therefore:
- provide the BDN and samples, certified by the fuel oil supplier that the fuel oil meets
the relevant specifications; - retain a copy of the BDN for at least three years for inspection and verification by port
State inspectors as necessary; - take action as appropriate against fuel oil suppliers that have been found to deliver
fuel oil that does not comply with that stated on the BDN; - inform the flag Administration of any ship receiving fuel oil found to be noncompliant
with the requirements of regulations 14 or 18; and - as per regulation 18.7(f) of the Parties to the MARPOL Protocol of 1997, inform IMO
for transmission to of all cases where fuel oil suppliers have failed to meet the
requirements specified in regulations 14 or 18.
However, despite the suppliers’ responsibilities and the mandatory statutory instruments
available, previous experience from port State inspections indicate that it is advisable for
owners/managers to ensure compliance themselves.
In order to assist ships in ensuring that the operational requirements are met, clauses related to compliance with Annex VI of MARPOL Convention should be included in bunker contracts, charter parties and agreements with suppliers, as well as charter parties.
For vessels taking part in a fuel testing scheme, it is advantageous to include a clause
referring to the fourth sample taken at the receiving vessel’s manifold as the retained sample in case the supplier is not in a position to comply with the procedural requirements stated in MARPOL Annex VI.
Implementation
Owners should ensure that there is a vessel-specific 2020 implementation plan on board
as recommended by IMO under MEPC.1/Circ.878, Guidance on the Development of a Ship
Implementation Plan for the Consistent Implementation of the 0,50% Sulphur Limit Under
MARPOL Annex VI. As part of which the Chief Engineer should indicate to the Master the PIC for fuel oil transfer operations.
The Master should appoint the PIC, in writing, either by name or by position on board the ship. The PIC should approve any change or relief of personnel assigned to bunkering operations in progress and should inform the Master accordingly.
Safety
Announcements through the vessel’s public address system should be done before
starting operations to remind to all persons on board that smoking on outside decks,
including balconies will be prohibited for the entire duration of bunkering.
Documentation
When accepting bunkers by barge or shore pipeline, the Chief Engineer should always
check the local supplier’s documents to make certain that the bunkers which the ship
is to load conforms in all respects with the terms of quantities and fuel specification
which has actually been ordered, either by owners or charterers.
Additionally, a BDN should be produced by the supplier to verify details of the fuel
oil for combustion purposes delivered and to be consumed on board. The BDN is to
comply with the requirements as set forth in Appendix V to Annex VI of the MARPOL
Convention. A copy must be maintained on board to be exhibited upon request.
Bunkering schedule
The Chief Engineer should discuss with the Master the best possible bunkering plan so
that trim/stability can be calculated to the ships best advantage. Fuels from different
supply ports should be segregated unless this is impossible due to the fuel tank
arrangement.
Quality and samples
The Chief Engineer should check from documentation that bunkers to be loaded do
not contain any unacceptable amounts of water. The maximum allowable water being
0.05% for gas oil, 0.25% for marine diesel oil (MDO) and 1.0% for intermediate fuel oil
(IFO) 180 and above.
Additionally, the sulfur content of any fuel oil used on board ships should not exceed
values as established by codes and local regulation as applicable, which from January
1, 2020 is 0.5% worldwide unless alternative arrangements such as exhaust gas
systems or “scrubbers” (see Chapter 2) are fitted to the vessel.
Note of Protest When Fuel Supplier Fails To Comply
Should the fuel supplier fail to provide the BDN, the Marine Safety Data Sheet (MSDS)
for each fuel product to be bunkered as per requirements of SOLAS Chapter VI
regulations and Resolution MSC 286(86), Recommendations for Material Safety Data
Sheet (MSDS) for MARPOL Annex I Oil Cargo and Oil Fuel, should be obtained for the
sealed and signed sample of the delivered bunkers.
Should the Chief Engineer realize that the sulfur content stated in the BDN exceed the
values established by codes and applicable regulations, a written statement should
be issued by the Master. One copy of the Note of Protest should also be maintained on
board to be provided to authorities in case of inspections.
Bunkering operations
The Chief Engineer is responsible for the bunkering operations. The Chief Engineer, or
in case of his absence the first or second engineer, must be onboard the vessel during
bunkering and a delegated engineer officer will be in charge while bunkering is in
progress.
The Chief Engineer should also verify the grade of product to be delivered, the pumping
rate and the precise means of communication, including the method of stopping the
barge pumping. It is important when bunkering that each fuel tank should be filled to
no more than 90% capacity or to whatever the company policy may be but always to a
safe level. Furthermore, the operation should be carried out in such a manner and at a
rate to allow the tanks to vent safely.
Verification of quantities
When the bunkering operation has been completed, the engineer in charge should
ensure that the fuel main manifold is dry and not become pressurized. Although
bunkered quantities can be checked on meter readings, it is best practice to take
soundings of tanks and temperature before starting and at the end of bunkering
operations, especially when bunkering from a barge. The Chief Engineer will verify
then that the quantities taken are those indicated in the manifest from the barge and
the one obtained from calculation, and if there is a difference, it must be noted in the
delivery receipt.
Sampling procedures
Bunkers are to be delivered at the point of custody at the ship’s rail or manifold and is to be drawn continuously throughout the bunker delivery period. The term “continuously drawn” is specified to mean a continuous collection of drip sample throughout the delivery
of bunker fuel.
Sampling methods are further clarified as either; (1) manual valvesetting continuous-drip sampler, (2) time-proportional automatic sampler, or (3) flowproportional automatic sampler.
Sample bottle labels are to contain the following information:
- location at which, and the method by which, the sample was drawn;
- date of commencement of delivery;
- name of bunker tanker/bunker installation;
- name and IMO number of the receiving ship;
- signatures and names of the supplier’s representative and the ship’s
representative; - details of seal identification; and
- bunker grade.
The vessel should collect a representative sample of the fuel being bunkered
from the point of custody transfer (ship’s manifold). The vessel should not, under
any circumstance, accept pre-filled samples provided by the supplier as being
representative of the fuel being delivered.
The sample is to be processed using supplies provided by the fuel testing vendor.
Samples are to be delivered, the same day, to the ship’s agent to be sent from the ship
directly to the testing lab.
The testing company should provide kit boxes to transport the fuel oil samples from the
ship directly to the testing company. These kits normally include at least three (3) 400
ml sample bottles, addressed mailers and seals. Prepaid courier airway bills should
be provided to the ships to forward samples.
The vessel should provide all of the information requested by the lab and mail it along with the sample. Each bunker operation will generate, at a minimum, three (3) samples:
• one sample is for retention on board the ship;
• the second sample is for the supplier; and
• the third sample is to be sent to the lab for analysis.
The labels on each of the sample containers is to be countersigned by the supplier’s
representative at the time of the sampling.
Fuel Samples Analysis Criteria
The fuel samples will be thereafter be analyzed according to regulation 18 of Annex VI
to the MARPOL Convention and ISO 8217 and a report will be forwarded to the owners
and/or charterers. The report should also contain guidance on the optimal on-board
processing of the bunkers. For the fuel sample to be properly analyzed, the lab will also
need the following information:
- date of bunkering;
- name of the vendor providing the fuel;
- type of fuel;
- bunkering port; and
- other bunker quantity and quality information required in the bunker supply
receipt.
Bunkered fuel oil, marine gas oil or marine diesel oil, etc., if at all possible, should not
be consumed until the results of analysis arrive on board.
Sample testing & analyses
All sample testing should be to the requirements as set forth by the shipowner’s and
charterer’s (if and as applicable) agreed ISO 8217 standard. Non-standard, additional
tests may include for those contaminants as listed in Section 4.2 and:
• trace metals analysis (nickel, cadmium, mercury, etc.);
• heavy distillates testing and inspection; and
• contamination detection and analysis.
Sample inventory
Samples should be kept in a safe, cool and sheltered storage location, outside the
ship’s accommodation and where personnel would not be exposed to vapors which
may be released from the sample as well as not be exposed to direct sunlight.
A suitable locker (with opening ensuring adequate air flow) in an adequately ventilated
area of the engine room located at a safe distance from ignition sources and hot
surfaces may be considered suitable.
The ship’s Master should develop and maintain a system (e.g. log book) to keep track of the retained samples.
Fuel oil transfers
The Chief Engineer should ensure that all engineers are fully conversant with the
complete fuel oil transfer system, including high/low level alarms and auto-stops.
Engineers should only to transfer fuel oil on direct and clear instructions from the Chief
Engineer.
End of operations
- After bunkering is completed the engineer in charge will stop the pump, drain the fill
line, blanking of the hose before passing the hose back to the barge, shore, or truck
station. - All fuel bunker transfers are to be logged in the Oil Record Book (ORB), including start
and stop timings. - At the end of operations, all used shipboard hose pipes (if any) must be drained,
disconnected and manifolds must be blind flanged. - End of operations must be communicated to the Officer On Watch (OOW) on the bridge,
to the engineer on watch in the engine control room and must be recorded in the
relevant engine room log books accordingly
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Source: The American Club
