Delivery
If over one grade of bunker fuel is to be supplied, the order in which the grades are supplied should be agreed between the supplier’s representative and the ship’s master or officer in charge of the bunker operation. To prevent contamination of product during delivery, the report suggests that the lighter/lowest sulphur grade is supplied first, followed by the heavier/higher sulphur grade. Where necessary, segregated pipelines/hoses and bunker connections for supply of materially different types of product should be provided, and for high and low- sulphur bunkers, to avoid cross- contamination of products. The use of multiple bunker barges or other delivery facilities to discharge a single product in ‘series’ adds complexity to the delivery and will require additional management and oversight. For this reason, such operations should be avoided to the greatest extent possible.
Sampling
Representative samples should be drawn during the bunker delivery for retention by both the receiving ship and the supplier, in addition to the MARPOL delivered sample which is a statutory requirement. The sampling process should be witnessed by representatives for both the supplier and the receiving ship. The sample containers should then be sealed at least once (and countersealed if requested by the receiving ship) with tamper-evident seals that have a unique means of identification. They should also be labelled, signed and countersigned by representatives of both parties.
Sampling should take place at each point of product custody transfer throughout the supply chain. The supplier should retain the bunker transfer samples for at least 30 days. If a dispute regarding the fuel quality occurs, samples should be kept until the dispute has been resolved. The above should be documented in the supplier’s QMS. This is a key part of a QMS, as it enables transparency and traceability, and helps the supplier identify the origin of potential problems and taking steps to remedy and prevent further quality issues.
It should be recognized that, in many ports, the contractual barge loading sample is often taken from the shore tank and not at a subsequent custody transfer point.
Responsibilities of fuel users
Fuel purchasers are expected to order fuel of a quality or grade suitable for the receiving ship, taking into consideration its intended trading area as well as the capabilities of the ship to receive, store, handle and use the fuel, including the ability to segregate different batches of fuel to safeguard against incompatibility issues. The fuel purchaser and the end user (the ship) should take note of the following:
- On-board fuel management is an essential element of preventing operational issues. Improper handling of fuel on board may lead to non- compliance with MARPOL requirements on fuel quality and safety, even if the fuel received was compliant;
- Once fuel is delivered on board, ships should have documented procedures for the safe handling and use of the fuel. These procedures should form part of the company’s Safety Management System (SMS) which should be in place as a measure of good practice and/or as required by the International Safety Management (ISM) Code, as applicable, supported by equipment operating and maintenance manuals;
- Each ship should have in place fuel switching procedures (where applicable). The ship’s crew should be familiar with implementing these procedures;
- Marine fuel which fully meets statutory requirements and purchase specifications such as ISO 8217:2017, will nevertheless still require treatment before it meets most engine manufacturers’ requirements;
- Where a ship is exempted from some of the provisions of MARPOL Annex VI under Regulation 3 of the Annex, or will comply with the requirements of the Convention using an equivalent means of compliance under Regulation 4 of the Annex, fuel oil purchasers should consider any conditions attached to the exemption or equivalent means which may affect fuel purchasing.
Download the 64 page pdf document at
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60 | The Report • September 2019 • Issue 89
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