Industry stalwarts, suppliers have recently come together to issue a detailed guidance on IMO 2020 compliance. Of this the 0.5% fuel supply guidance is of primary importance.
Here’s the complete directive regarding this.
What Should Suppliers Do?
A fuel supplier needs to have in place a robust and applied QMS which addresses all of the factors that affect the quality or characteristics/properties of the fuel which is to be supplied, and the ability to meet the ordered specification, by:
- controlling the quality of the individual blend stocks used to produce the fuel;
- avoiding the entry of extraneous, potentially harmful, materials within the supplier’s (or upstream) storage, handling and delivery systems;
- ensuring that the correct blending procedures are applied so that a homogeneous fuel is delivered.
Blending Stocks Guidance
The actual physical supplier of a consignment of fuel may be a refinery operator supplying fuel based on blend stocks received directly from its own refineries.
In other instances, the blend stocks used will have been traded, potentially a number of times, by brokers between the various sources and the final supplier; this may have involved the splitting and mixing of different consignments along the way.
Irrespective of the particular supply chain, it will become increasingly important for these operations to be documented so that both the final supplier and the shipowner/operator understand the characteristics of the fuel.
Extraneous materials
The effective application of a robust QMS by fuel oil suppliers will minimize the risk of undesirable material entering the fuel or its constituent components.
Such material could be extraneous to the fuel product, e.g. water (covered by ISO 8217:2017; includes fresh/brackish/saline—together with the risk that it may encourage proliferation of bacteria in the interphase between fuel and water), dust, maintenance materials or corrosion debris.
Alternatively, such undesirable material
could be other fuel/hydrocarbon products, e.g. line residues, washings, or materials remaining
in shore tanks or barges (including ‘unpumpables’). In some instances, this extraneous material has been found to contain waste chemicals and other such material for which marine fuels are occasionally seen by some as a convenient disposal route.
The addition of used lubricating oil
(ULO) as a fuel blend component from both shipboard and land-based sources can also provide a route for waste materials to enter the fuel pool, and can add undesirable contaminants from anti-wear additives containing zinc, calcium and phosphorous.
Suppliers To Provide Information To Shippers for Fuel Safety
- The fuel supplier should provide the receiving ship with enough information on the fuel to be supplied, so that the ship’s crew are able to safely and effectively deal with that fuel in terms of storage, handling, treatment and use of the fuel on board.
- The supplier also has an obligation to communicate clearly to the receiving ship the quantities and grades that they have arranged to supply.
- This information from the supplier should be provided in enough time to enable the ship’s crew to prepare for the bunker delivery and the appropriate storage of the fuel on board—ideally 2–3 days prior to the ship’s bunkering schedule.
- Typically, the specific information to be supplied should, at a minimum, include:
- confirmation of the ordering specification;
- viscosity;
- density;
- Cold flow properties such as pour point
- CFPP/CP as applicable to the grade of fuel;
- Any other information that the supplier considers operationally useful for the ship to know; and
- A full CoQ relating to the current fuel.
Crew Responsibility While Compliant Fuel Delivery
- Equally, the ship’s crew should understand the information received and be able to prepare the system for the receipt of the bunkers.
- The supplier (or the delivery contractor) should be made aware of any special circumstances that may affect the delivery of fuel to the ship; this would normally be done by the ship’s agent in the delivery port.
- The supplier and the ship’s crew should follow the appropriate guidance on the conduct of the delivery.
- This is especially important with regard to the completion of documentation such as the BDN, as well as the management of the samples and the mandatory MARPOL delivered sample.
- The receiving ship should immediately inform all responsible parties about any samples or documentation (e.g. MSDS, fully compliant BDN, IMO sampling guidelines, etc.) that are either not provided or which they believe do not meet the relevant provisions contained in the SOLAS or MARPOL Conventions.
- Records of such communications should be maintained on the ship for future reference/inspections, alongside the actual MSDS, BDNs and CoQ orequivalent documentation.
- Appropriate record-keeping should be maintained on board the ship in line with MARPOL andFlag State requirements, as per MARPOL Annex I, Regulation 17.
- The receiving ship should have procedures established for bunkering, fuel handling and storage of fuel, including spill, pollution and emergency response.
- Shipboard emergency plans addressing different categories of emergencies are required under the provisions of both the SOLAS and MARPOL Conventions, as well as the ISM Code and supporting guidance.
Bunkering Guidance for Suppliers
Detailed guidance for bunkering procedures, including a sample bunkering checklist, may be found in various available guidance documents, and is also covered by the latest revisions of the international standard ISO 13739, Petroleum Products—Procedures for transfer of Bunkers to Vessels, and national standards such as the Singapore Code of practice for bunkering (SS 600).
Under MARPOL Annex VI, it is a statutory requirement that a BDN includes at least the stipulated information and declaration, and this must be provided by the supplier to the ship.
As well as meeting the minimum MARPOL requirements relating to the supply of information on the fuel’s density and sulphur content, additional information that should be provided in writing includes, but is not limited to, data (i.e. actual values, not a range) on:
- pour point (if higher than -6˚C: actual value);
- viscosity;
- water.
For distillate fuels the information should also include data on:
- cloud point (only applicable to clear and bright distillates);
- cold filter plugging point (CFPP).
Additionally, it should be confirmed that the flashpoint of the fuel is in compliance with the SOLAS limit, i.e. a minimum of 60°C.
Additional information may be provided on the chemical characteristics of the fuel to assist the ship’s crew in assessing the associated compatibility risks of any commingling with other fuels on board (see Avoiding fuel incompatibility issues (shipboard strategy and supplier liaison) on page 36). An MSDS should be provided as per SOLAS requirements.
With regard to the sulphur content, the supplier must state the actual sulphur content in accordance with MARPOL Annex VI BDN requirement rather than advising that the sulphur constitutes <X%.
A specific value will enable the ship’s crew to manage the fuel grade switching when entering an ECA and to monitor the effectiveness of any abatement technology being used onboard.
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Source: CIMAC
