The fuel oil sample rules for confirming conformity with SOLAS Chapter II-2 and MARPOL Annex VI have been updated by the IMO in a joint circular.
The previous MEPC Resolution 182(59) titled “2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI” is revoked by MSC-MEPC.2/Circ.18, which was issued on July 11, 2024, and expands the use of the MARPOL Delivered Sample to include checking the flashpoint requirement under SOLAS Regulation II-2/4.2.1.
Noteworthy modifications to the revised guidelines:
The smallest possible sample size: With the exception of raising the minimum sample size from 400 to 600 milliliters, the 2009 Guidelines’ fundamental requirements for the sampling site, plans, and protocols for what the joint circular refers to as the “Representative Sample” remain the same. The issues of sample storage and labeling have not altered either.
Definition of fuel oil: Oil fuel is specified in Regulation 2.1.14 of MARPOL Annex VI, including Regulation 1 of MARPOL Annex I, for the purposes of these Guidelines and the implementation of SOLAS Regulation II-2/4.2.
sample and preparation: The circular now specifically mentions that staff members conducting this sample and the ensuing MARPOL Delivered Sample processing must be conversant with the Guidelines and how to utilize the equipment. Additionally, officials from the ship and supplier should observe the actual sampling procedure.
New Section 10: The new Section 10 is the only noteworthy addition. This addresses the protocols and documentation needs in situations where the flashpoint of the fuel oil needs to be determined. This has no bearing whatsoever on the standards of MARPOL Annex VI Appendix VI concerning the sulfur verification processes, which remain unchanged.
Monitoring of Delivered Samples: As previously mentioned in the 2009 Guidelines, the firm is now responsible for monitoring these MARPOL Delivered Samples, rather than the ship’s master. When samples are removed from the ship for testing and the remaining material is not later returned, this will be crucial.
Only Parties to SOLAS or MARPOL Annex VI may use the MARPOL Delivered Sample to verify that the convention’s obligations are being met. It is not permitted to use the MARPOL Delivered Sample for any other reason, including settling disputes over commercial quality.
