- Tested VLSFO manifold samples have recorded a sulphur content of between 0.51 to 0.53%m/m, exceeding the mandatory allowable 0.50%m/m.
- Since the implementation of IMO 2020, there is confusion as to whether the ISO 4259 upper limit of 0.53%mm still applies or not.
- Maritec emphasizes that in-use and onboard samples cannot exceed the maximum limit of 0.53% m/m.
- Routine full analysis on new bunker samples is also recommended.
Maritec recommends onboard bunker samples for compliance amid high sulphur warnings, says an article published in Manifold Times.
Reports of excessive sulphur
Singapore-based marine fuel testing and marine surveying business Maritec Pte Ltd (Maritec), published some advice for shipowners on how best to meet IMO 2020 fuel testing requirements following reports of excessive sulphur in some very low sulphur fuel oils.
Sulphur content exceeding limits
In a Technical Bulletin issued to customers in December, Maritec reported several cases where tested VLSFO manifold samples have recorded a sulphur content of between 0.51 to 0.53%m/m, exceeding the mandatory allowable 0.50%m/m.
Maritec noted this accounts for about 1.23% of VLSFO tested to date.
ISO 4259 upper limit still in place?
The company added, since the implementation of IMO 2020, there is “confusion and frustration” as to whether the ISO 4259 upper limit of 0.53%mm still applies or not.
“Given that there will be variability between test results, even from identical samples tested in the same lab, it raises the question: when does an individual test result indicate that the tested VLSFO fuel is compliant?” Said Maritec VP Business Development John Ren Di.
The 95% confidence testing boundary
“IMO has adopted a 95% confidence testing boundary which is given by ISO 4259 as 0.59 times the reproducibility value R (expressed as 0.59R). However, this applies only to in-use and onboard samples and not the sample taken at the manifold.”
Challenges and inconsistencies
In-use sampling points
In highlighting the challenges and inconsistencies in determining the sampling location of onboard and in-use samples, Maritec reminds ship operators that in-use sampling points need to be fitted to existing ships built before 01 April 2022 no later than the first IAPP renewal survey after 01 April 2023.
For new ships they need to be designated on delivery.
Samples cannot exceed max limit
Maritec emphasizes that in-use and onboard samples cannot exceed the maximum limit of 0.53% m/m. If sulphur content is found to exceed 0.53%m/m, then the source of contamination must be detailed, and evidence provided indicating that all possible steps were taken to ensure compliance.
Witness and document sampling
“It would be prudent for vessel staff to witness and document sampling and sealing by Port State Control Inspectors,” added Ren Di. “Ideally, they should take representative samples of their own and countersealed by the sampling inspector for independent verification in case of dispute.”
Routine full analysis recommended
Maritec recommends that, in addition to routine full analysis on new bunker samples, crew also take onboard and in-use samples. Maritec provides the sulphur verification kit to all vessels in their testing programme.
“There is always a possibility of loading non-compliant fuel onboard. Mitigating this risk begins with sourcing and purchasing compliant fuel oil and reducing the risk of poor-quality fuel oil being delivered to the vessel,” said Ren Di.
“Knowing the appropriate limits at each stage of the process will help keep vessels compliant and operating in line with IMO’s objective to reduce air pollution and protect the environment.”
Marpol Annex VI amendments for fuel oil sampling are expected to enter into force on 1 April 2022.
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Source: ManifoldTimes
