The 0.50% global sulphur limit for fuel oil used or carried for use has been in force since 1 January 2020. Three months later the so-called carriage ban took effect which prohibits carriage of fuel exceeding the global sulphur limit in the fuel oil tanks. To follow up on the new requirement and enable PSC to take representative samples of the fuel oil being used onboard, in-use sampling points needs to be designated. This statutory news summarizes the sampling point requirement.
Application of the requirement
The new requirement is introduced through Amendments to MARPOL Annex VI given in Resolution MEPC.324(75) adopted November 2020 and will enter into force (EIF) on 1 April 2022. The deadline for designating the in-use sampling points is dependent on the IAPP renewal survey for each ship:
- Existing ships which are keel laid before 1 April 2022 will be required to designate sampling points no later than the first IAPP renewal survey on or after 1 April 2023.
- Newbuilds keel laid on or after 1 April 2022, sampling points needs to be in place and designated on delivery.
The sulphur requirements in MARPOL applies to all fuel oil intended for combustion purposes for both propulsion and on board operations, meaning that all fuel oil systems serving main engines, auxiliary engines, boilers, incinerators, IG generators, emergency equipment and other consumers shall be fitted with designated sampling points. The only exemption is fuel oil service systems for low-flashpoint fuel having a flashpoint less than 60°C.
Fuel oil samples under MARPOL
Following the new amendments there are now three defined fuel oil samples under MARPOL, each provided with a set of IMO guidelines:
- MARPOL delivered sample1) – this is the traditional sample taken during bunkering, accompanying the Bunker Delivery Note (BDN) and which represents the fuel oil delivered on board.
- In-use sample2) – this is a new sample meant to represent the fuel oil in use at the time and for which sampling points shall be designated.
- On board sample3) – this is a new sample meant to represent the fuel in the fuel oil tanks, i.e. fuel oil intended to be used or carried for use.
Designating sampling points
“Designating” is meant to clearly identify the sampling point to be used for the purpose of taking the “In-Use sample” as per MARPOL Annex VI. This should be done by marking the sampling points and identify it on the relevant piping diagram.
When designating sampling points consideration should be given to possible fuel oil cross-contamination and service tank arrangements. The different fuel oil grades being used to be considered and the location should be as close to the consumer as safely feasible, considering fuel oil temperature, pressure and flowrate. For a common fuel oil supply line serving one or more consumers, a single sampling point may be acceptable.
Verification of compliance will be followed up at the first IAPP renewal survey on or after 1 April 2023, confirming the number and location of designated sampling points. On completion of the IAPP renewal survey the new IAPP Certificate will reflect that the vessel is fitted with designated sampling points.
Fitting of new sampling points
While the preferred solution may be to designate already existing sampling points, fitting and designating new sampling points may in some cases be the only option. For such cases, DNV will not require any formal drawing approval, unless modifications other than fitting sampling points are done to the piping system, e.g. additional drainage. Please see the annex to this newsletter for practical advice on fitting of additional sampling points in addition to the IMO guidelines 2).
As for many new environmental requirements we observe that many ship managers seek to comply ahead of the required deadlines and to document the same towards third parties. This is also the case with this regulation, and Classification Societies will therefore offer early compliance upon request, documented by a Statement of Compliance before EIF of the MARPOL Amendments (1 April 2022) and a new IAPP certificate if confirmation is done on or after EIF. For vessels given a Statement of Compliance this will also automatically be shown on the first IAPP certificate issued after EIF. Confirmation of early compliance may be done as part of an annual survey or ordered as a remote survey.
It is recommended designating existing sampling points as far as practicable and feasible. In case fitting and designating new sampling points, utilizing existing connections (e.g. manometers) and existing drip trays/drainage should be considered.
Fitting of new sampling points.
Existing sampling points should be designated as far as possible. If not, new designated sampling points to be fitted and verified.
Different fuel oil grades to be used shall be taken into account and the sampling point location to be downstream of the in use fuel oil service tank and as close to the consumer as safely feasible, considering FO temperature, pressure and flow-rate.
The sampling points shall be provided with a shut-off valve and preferably also with a self-closing valve.
Sampling valves shall be provided with caps to prevent leakage when not in use.
Sampling valves shall be easily accessible in a well-lit and ventilated location.
Sampling valves shall be so located that any drip or spray cannot reach a hot surface, electrical equipment or other source of ignition.
Sampling valves shall be made of ductile material, such as nodular cast iron or steel (DNV GL Rules Pt.4 Ch.6 Sec.2 1.5).
Pressure ratings of flanges/valves – shall not be lower than the maximum working pressure of the FO system, and not lower than 14 bar (DNV GL Rules Pt.4 Ch.6 Sec.5 4.3.8)
Pipe thickness – shall not be less than as required by DNV GL Rules Pt.4 Ch.6 Sec.9.
Drip trays shall be arranged below the sampling points to ensure suitable drainage to a drain tank.
The installation shall be subjected to a function test.
- The sampling point to be designated and clearly marked both in the ER and on the relevant piping diagram.
1)MEPC.182(59) – 2009 guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI
2)MEPC.1/Circ.864/Rev.1 – 2019 guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships
3)MEPC.1/Circ.889 – 2020 guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship
- MEPC.324(75) – Procedures for sampling and verification of the sulphur content of fuel oil and the Energy Efficiency Design Index (EEDI)
- MEPC.1Circ.864/rev.1 – 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships