Most merchant ships primarily burn fuel oil to produce power for
propulsion purposes, electrical power generation, boilers, or all of these. Nevertheless, any misuse of fuel oil can lead to significant claims and jeopardize the ship's safety. There have been many claims involving bunker fuel that failed to meet the required minimum specifications and caused a significant breakdown of ships' machinery. Fuel oil sampling forms the basis of compliance verification and dispute resolution relating to merchant ships bunkering.
Onboard Chief Engineer should extract the proper volume of samples representing the qualities of the fuel oil delivered in the following items. The sampling method should be continuously dripping at the shore connection on board the vessel, in general. Regarding each sample bottle, the sample label should be filled with necessary items and signed by the Chief Engineer and the suppliers representative and the samples to be sealed. If the FO supplier refuses to sign the samples extracted, the Chief Engineer needs to immediately inform the ship management company of the fact.
Fuel oil sample bottles
The samples should be kept in a safe storage location outside the ship's accommodation.
- Sample bottle required by MARPOL :
One bottle of the Sample (Approx. 1 liter/bottle) shall be extracted from the FO collected by the above mentioned continuous dripping and shall be retained with the seal intact under the ship's control until the fuel oil is substantially consumed. But in any case for not less than 12 months from the time of delivery. MARPOL sample and Bunker Delivery Note shall be kept onboard properly for Port State Control etc.
- Retained SAMPLE :
Two bottles of Sample (Approx. 1 liter/bottle) should be extracted from the FO collected by the above mentioned continuous dripping and one bottle to be delivered to the supplier, and the other should be kept on board.
The Sample for the vessel shall be kept on board for six months with the seal intact. It shall be taken ashore on the Company's instruction, if necessary.
Note: It is a commercially accepted practice to understand that the newly loaded oil is affected by the remained oil in the ship's tank to be different in qualities when it is put into the ship's tank.
(Even if the new oil is put in an empty tank, it is assumed that the new oil may be affected by dead oil or remained oily components in piping.)
Therefore, in the case of engine trouble caused by fuel oil, the only evidential object that represents the qualities of the loaded fuel oil is such retained samples extracted by the above method.
- Sample for Analysis (DNV, VISWALAB, etc) :
In case, FO sample is being analyzed by a third party, C/E should collect Sample in line with the Sampling Procedure instructed from the third party then send it to the designated address. The technical superintendent in charge should inform the vessel of the result of analysis, putting necessary comment on it.
- One sample for the bunker surveyor, if engaged
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Retained Sample (by supplier):
Chief Engineer should receive one bottle of retained Sample from the FO supplier and keep it on board in the following manner:
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If the FO supplier refuses to submit the retained Sample, the Chief Engineer shall inform the Chief Technical Superintendent of the fact immediately through the Captain.
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If retained Sample from the supplier is collected other than continuous dripping, for example, dipping up from the barge tank or collection from a sample cock during a short period, this fact shall be noted on the samples with signature by both the parties. The chief engineer shall report the matter without delay in this case as well.
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The retained sample submitted by Bunker supplier shall be kept intact with the seal onboard for a period of 6 months from the time of delivery.
Fuel oil sampling procedure
When bunkering starts, place a container under the sampler, open the sampler valve fully
and flush the sampler with fuel. It is good practice to check this Sample from fuel initially
pumped on board as it may be high in water content from the bunker barge's tanks.
After flushing, the sampler, close the valve and attach a suitable clean container to the valve.
Adjust the needle valve to give a slow and steady drip. Time the fill rate so that it will provide
for sufficient estimated Sample over the expected delivery period.
If the sample container fills during the bunkering period, remove it and place an empty
sample container (Cubitainer) on the sampler and continue to draw a sample.
On completion of bunkering, mix the samples from both containers to ensure a good, representative sample from the bunkering operation.
- always ensure that the sampler valve is fully open to allow the sampler to drain
- always close the sampler valve before blowing through the fuel lines on completion
of bunkering
- close the sampler valve if pumping stops, to prevent the Sample being drawn back,
under vacuum, into the fuel line
Select three or four clean sample bottles. The exact number depends on the final destination of the various samples. It is recommended that four representative samples are obtained from the delivery. The distribution of the samples being:
- suppliers sample (from their MARPOL connection)
- ships sample for retention on board
- onboard analysis sample
- sample for independent analysis
The full Cubitainer should be placed in the pourer box and thoroughly shaken to ensure
that the contents are mixed. Attach the pourer spout and gradually transfer the
contents into the sample bottles, filling each a little at a time. If more than one Cubitainer
was used during bunkering, then transfer a portion into each of the bottles. Complete
the document labels and attach one to each sample bottle.
Always have the barge operator to witness the removal and sealing of the sample bottle(s)
(shown below). If this request is refused, or if no witness is provided, note this in the
delivery log.
Bunker collection, sampling, and storage guidelines are provided in Annex VI of MARPOL
73/78 and have been defined by MEPC 96(47), which states that:
"A retained sample of all fuel oils as supplied is drawn at the ships receiving manifold,
sealed, signed on behalf of the supplier and the Master or ships officer in charge of the
bunkering operation. Retained Sample is to be kept under ships control until the
subject fuel has been substantially consumed, but in any case for at least 12 months from
the date of delivery."
It is important to remember that this Sample is to be used solely to determine compliance
with Annex VI of MARPOL 73/78 and cannot be used for commercial purposes. However,
samples can be drawn at the same time for other purposes.
Summary-
a representative sample is fundamental for all later testing
- a continuous drip manual sampler is the proven method for effective sampling
- the sample must be witnessed by all parties: the supplier’s representative as well as the
recipient/ship
- the point for custody transfer is usually the ships bunker manifold
- careful measurements during delivery will produce savings
- samples should be handled and stored carefully- they may be the only evidence in the
event of a claim
- IMO MARPOL Annex VI requires ship staff to store the sample for at least 12 months and the
Bunker Delivery Receipt for three years.
IMO website provided more guidelines on global sulfur limit requirements and fuel oil sampling procedures to ensure that samples can be drawn safely from the ships fuel service system when such sampling is requested by a PSC inspector. It is imperative that the ship's crew are aware of the abovementioned requirements and familiarised with the ship-specific system.
Regulation 18 of MARPOL Annex VI covers issues relating to fuel quality, sampling, and delivery requirements. However, this sampling requirement does not guarantee that ships will use the appropriate compliant fuel to comply with the 0.50% global sulfur cap requirement. While the responsibility to comply with this regulation lies with the fuel oil suppliers, the reality is that the enforcement agencies generally look to ships to verify compliance. Port State Control (PSC) inspectors frequently scrutinize ships documentation and records such as fuel sampling and change-over procedures, bunker delivery notes (BDNs), logbook and oil record book entries.
Following initial checks, and based on their clear grounds for suspected non-compliance, PSC inspectors may decide to obtain and verify the fuel oil samples. It could either be a representative sample provided with the BDN (Sample obtained during bunkering), a spot sample drawn from the ship's fuel oil system, or the ship's bunker tanks. The ship's crew must be familiar with the MARPOL requirements and location of the sampling points on board their vessel.
Under MARPOL Annex VI requirements, a BDN is to be retained on board for three years. Every BDN is to be accompanied by a representative sample of the fuel supplied. The Sample is to be retained on board for a minimum of twelve months. The Sample is to be a minimum of 400 ml and provided with a label with information stating the location where the Sample was taken, sampling method, bunker date, name of bunker barge/pier, receiving ship name, and IMO. No, sample seal number and bunker grade.
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