Update On Unified Interpretations To MARPOL Annex VI

The IMO has formally confirmed the use of Bunker Delivery Notes (BDNs) in electronic format as an acceptable alternative to the conventional hard copy, as long as they conform to the regulations of MARPOL Annex VI, says an article published on lr website.

Summary

• The update is relevant for shipowners and ship managers.
• The International Maritime Organization (IMO) has confirmed that Bunker Delivery Notes (BDNs) in electronic format are an acceptable alternative to traditional hard copies, provided they adhere to the regulations outlined in MARPOL Annex VI.
• The decision comes from the 80th session of the Marine Environment Protection Committee (MEPC), which approved an additional unified interpretation related to regulations 18.5 and 18.6 of MARPOL Annex VI concerning BDNs.
• Regardless of format (hard copy or electronic), the minimum information to be included in the BDN remains the same as outlined in Appendix V of MARPOL Annex VI.

Applicability

This update is relevant for shipowners and ship managers.

IMO Confirmation

The International Maritime Organization (IMO) has formally confirmed that Bunker Delivery Notes (BDNs) in electronic format are considered an acceptable alternative to traditional hard copies. However, electronic BDNs must adhere to the regulations outlined in MARPOL Annex VI.

Outcome Of The 80th MEPC Session

The decision stems from the 80th session of the Marine Environment Protection Committee (MEPC), which approved an additional unified interpretation related to regulations 18.5 and 18.6 of MARPOL Annex VI concerning BDNs. This interpretation is now part of the updated consolidation circular MEPC.1/Circ.795/Rev.8.

Minimum Information Requirements

Regardless of format (hard copy or electronic), the minimum information to be included in the BDN remains the same. The specific details are outlined in Appendix V of MARPOL Annex VI.

Protection And Verification Of Electronic BDNs

Electronic BDNs should be safeguarded against edits, modifications, or revisions, and a verification method must be employed to ensure authentication. Refer to the interpretation for Regulation 18 in MEPC.1/Circ.795/Rev.8 for detailed guidelines.

Retention And Accessibility

An electronic BDN must be retained onboard for a minimum of three years from the delivery date. It should also be easily accessible for inspection when required.

Port Implementations

Some ports are moving towards digitalization, including the adoption of electronic BDNs. Ship officers should be aware of changes in procedures, such as the method for digitally transferring an electronic BDN from the bunker barge to the receiving ship, and ensuring secure retention of the electronic record onboard for the stipulated time period.

This update reflects the industry’s shift toward digital practices and emphasizes compliance with MARPOL Annex VI regulations in the electronic documentation of bunkering operations.

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Source: lr.org

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