Regulation 18.8.1 of MARPOL Annex VI requires the sampling of the fuel oil “delivered” to ships. However, this sampling requirement does not guarantee that ships will use the appropriate compliant fuel when visiting a SOx emission control area.
In order to facilitate the need for taking fuel samples “in-use”, the IMO has published MEPC.1/Circ.864: ‘Guidelines for onboard sampling for the verification of the sulphur content of the fuel oil used on board ships’. The guidelines describe requirements for sampling locations and sample handling.
The relevant Lloyd’s Register (LR) rules on fuel piping systems have been updated to take into account the technical contents of the guidelines.
The IMO will also consider mandatory design arrangements for the sampling point as a possible future amendment to the MARPOL Convention.
Particular attention may be paid to the following parts of the guidelines:
- The main objective of onboard sampling guidelines is to facilitate a consistent, safe and uniform approach to sampling on board for the verification of compliance with the requirements in regulation 14 of MARPOL Annex VI. The issue of clear grounds or justification is a separate issue and does not need to be addressed in these guidelines.
- The location and installation of a sampling point in the fuel system piping arrangement of the ship should be taken into account to ensure that onboard sampling does not cause any interruption to the normal operation of the ship.
- Due to the risk of fire and explosion in a high-temperature environment and the high pressure of fuel oil passing through the fuel conditioning units, the sampling location has to be carefully considered to prevent any leakage.