Professional Documents
Culture Documents
INSTRUCTION MANUAL
MANAGING RISK
CONTENTS
Appendices
Example -- MARPOL ANNEX VI Bunker Sample Record
MARPOL ANNEX VI Bunker Sample Record Guidelines (Proposed By DNVPS)
DNVPS Guidelines For Issuing Note Of Protest
Example -- MARPOL ANNEX VI Note Of Protest
Introduction
Thank you for choosing DNV Petroleum Services (DNVPS) as your fuel
management partner. We are committed to providing you with the best
possible marine fuel management programme.
DNVPS fulfils the need for an independent international testing service which is credible both to shipowners and
suppliers alike. Unlike some testing services which may only operate a single laboratory or none at all and therefore have
to subcontract the fuel analysis, DNVPS operates five wholly-owned, specialised and accredited laboratories, dedicated to
fuel analysis. These laboratories are strategically located in Oslo, Rotterdam, Singapore, Fujairah and Houston to ensure
that samples from the ships will reach the nearest DNVPS laboratory in the shortest possible time, thereby ensuring fast
turnaround of test results and prompt technical advice. The laboratories, located in different time zones, are linked by a
Wide Area Network and provide 24 hour service access and technical assistance. This special feature of our FQT
programme is unequalled by other testing services.00000000000000000000000000000000000000000000000000000000
Further, by working with the world's top courier companies, such as DHL, TNT and FedEx, your samples will be reliably
handled throughout the delivery.0000000000000000000000000000000000000000000000000000000000000000000000
DNVPS laboratories and offices are manned by highly qualified technical advisers working across all time zones to
provide you with round the clock assistance. Our online service, DataAccess, also lets you download your test reports
directly from the Internet as soon as the results are available.0000000000000000000000000000000000000000000000000
Using state of the art laboratory equipment and leveraging the cumulative in-depth knowledge and experience from
extensive R&D as well as more than 800,000 samples tested to date, our marine fuel experts will ensure that you receive
the best qualified advice available from our detailed fuel analysis reports and personal technical assistance.
With over 70 per cent market share in the bunker analysis business, DNVPS boasts an extensive monitoring network that
can spot fuel quality problems in ports around the world. You will be immediately notified of these problems through our
Bunker Alert and Bulletin service, exclusively available to members of the DNV FQT programme.
Combining DNVPS' timely Bunker Alerts and Bulletins, comprehensive test results and readily available technical advice,
you can avoid or limit fuel-related engine damage and achieve substantial cost savings.0000000000000000000000000000
The procedures and documentation of DNVPS' fuel testing programme complies fully with Annex VI of MARPOL, and
participation in this programme ensures that ships have access to compliant sampling equipment (sample bottles, seals,
line samplers and cubitainers). Further, ship operators will have access to our bunker alerts and bulletins as well as
comprehensive fuel oil quality statistics, all of which will provide ship operators with valuable assistance in their bunker
management.00000000000000000000000000000000000000000000000000000000000000000000000000000000000000
In addition to FQT, DNVPS also provides a whole range of other products and services, such as sampling kits, line
samplers, portable laboratory kits, training videos, technical seminars, fuel system checks (FSC), blend optimisation
programmes (BOP), Bunker Quantity Surveys (BQS), quarterly statistical publications of worldwide fuel quality and
FuelWise, an online service offering real-time updates of bunker quality from virtually any supplier in the world.
DNVPS is also in the forefront of developing extended testing services such as fuel ignition analysis and advanced
investigative analysis for detection of added substances and chemical wastes in marine fuels. These services are all
conducted in-house, meaning that DNVPS is not dependent on sub-contractors' availability. Combined with extensive
fuel knowledge and existing data, this has enabled us to develop unequalled experience in marine fuel analysis and
interpretation of results. Additionally, DNVPS has access to the DNV network and range of advanced testing facilities,
including the advanced materials laboratories in Oslo and Singapore.00000000000000000000000000000000000000000
Finally, DNVPS is also able to provide our customers with relevant information and assistance from DNV Maritime
Industries (classification & maritime consultants), DNV Research, DNV Consulting and other business units within the
DNV organisation.0000000000000000000000000000000000000000000000000000000000000000000000000000000000
As you embark on the DNV Fuel Quality Testing programme, please go through this Instruction Manual to ensure that
your vessels take full advantage of the benefits offered by our programme. 00000000000000000000000000000000000000
1
Annex VI of MARPOL 73/78
Annex VI of MARPOL 73/78 “Regulations for the prevention of Air Pollution from ships” will enter into force on 19 May 2005,
and will apply to all ships, fixed and floating drilling rigs and other platforms. Ships of 400 gross tons and above engaged
in international voyages involving countries that have ratified the conventions are required to hold an International Air
Pollution Prevention Certificate (IAPP Certificate) and will be subject to associated periodical surveys and port state
controls.000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
This certificate must be provided onboard newbuildings keel-laid after 19 May 2005 upon delivery. For ships keel-laid
before this date, the IAPP certificate must be on board at the first scheduled drydocking after 19 May 2005, but not later
than 19 May 2008.00000000000000000000000000000000000000000000000000000000000000000000000000000000000
The implementation of Annex VI implies, among other things, that fuel quality and bunkering procedures will become
a statutory requirement and be subject to surveys, both by flag states (normally delegated to classification societies) as
well as port state control.000000000000000000000000000000000000000000000000000000000000000000000000000000
Details and explanations relating to documentary and procedural requirements are found in Resolution MEPC. 96(47)
“Guidelines for the sampling of fuel for determination of compliance with Annex VI of MARPOL 73/78”. It should be
noted that Intertanko has also issued a thorough and useful guide on MARPOL Annex VI.
Reg.18 requires that fuel oil supplied to ships is to be free from inorganic acids, or chemical wastes that could jeopardise
the safety of the ship, cause harm to ship personnel, or which would contribute overall to additional air pollution.
Further, Resolution MEPC.96(47) recommends that the seal number of the associated MARPOL Annex VI fuel sample is
included in the BDN for cross-reference purposes.000000000000000000000000000000000000000000000000000000000
The BDN is to be kept on board and readily available for inspection at all times. Both the ship and the supplier are
required to retain the BDN for a period of three years after the fuel oil has been delivered on board.
On completion of the bunkering operation, the sample is to be sealed and signed by the supplier's representative and the
receiving ship's master or officer in charge. This sample must be retained under the ship's control until the fuel oil has
been substantially consumed, but in any case for a period of not less than 12 months from the time of delivery. Although
MEPC.96(47) specifies that the volume of the sample bottle should be no less than 400 ml, Intertanko has recommended
that the sample volume is not to be less than 750 ml due to the potential need for repetitive testing. The volume of the
DNVPS sample bottle is in accordance with the Intertanko recommendation.
2
As Annex VI specifies that the Annex VI sample is not to be used for commercial purposes, DNVPS recommends that for
ships already participating in a fuel oil quality testing scheme, the Annex VI sample should be the fourth sample (in
addition to the sample sent for lab testing, the sample given to the supplier, and the sample to be retained on board). The
reason is that it is considered an advantage to always have a dedicated Annex VI sample onboard in case of port state
controls. This is especially so in the event that the ship's retained sample has been sent ashore to settle a fuel quality
dispute or for some other purposes.000000000000000000000000000000000000000000000000000000000000000000000
Sampling procedures:0000000000000000000000000000000000000000000000000000000000000000000000000000000
Resolution MEPC.96(47) specifies in detail that the fuel sample is to be obtained at the receiving ship's inlet bunker
manifold and is to be drawn continuously throughout the bunker delivery period. The term “continuously drawn” means
a continuous collection of drip sample throughout the delivery of bunker fuel. Permitted sampling devices are further
clarified as either manual valve-setting continuous-drip sampler (equivalent to the DNVPS line sampler), time-
proportional automatic sampler, or flow-proportional automatic sampler.00000000000000000000000000000000000000
The guidelines further specify that sample bottle labels are to contain the following information:
Location at which, and the method by which, the sample was drawn
Bunkering date
Name of bunker tanker/bunker installation
Name and IMO number of the receiving ship
Signatures and names of the supplier's representative and the ship's representative
Details of seal identification
Bunker grade
On board bunkering procedures have to be amended to reflect the Annex VI requirements and this can be achieved by
referring to the guidelines in this instruction manual.000000000000000000000000000000000000000000000000000000
DNVPS' line sampler, sample bottle labels and recommended procedures for sampling and sample preparation are in
accordance with the above requirements. 0000000000000000000000000000000000000000000000000000000000000000
Sample inventory:00000000000000000000000000000000000000000000000000000000000000000000000000000000000
Resolution MEPC.96(47) also covers sample storage location. The samples are to be kept in a safe storage location,
outside the ship's accommodation and where personnel would not be exposed to vapours which may be released from
the samples. Further, the retained sample should be stored in a sheltered location preferably at a cool/ambient
temperature, where it will not be subject to elevated temperatures or exposed to direct sunlight. On tankers, the cargo
sample locker would be considered a suitable storage space. Alternatively, a locker with openings for adequate air flow
may be considered, if it is located in a well-ventilated area of the engine room and at a safe distance from ignition sources
and hot surfaces. 000000000000000000000000000000000000000000000000000000000000000000000000000000000000
An inventory system (eg. record book) should also be developed to keep track of the retained samples. For your
reference, DNVPS has enclosed a sample inventory record book guideline in this Instruction Manual.
Supplier's responsibility:00000000000000000000000000000000000000000000000000000000000000000000000000000
While most IMO conventions place full responsibility on ships and the shipowners, Regulation 18 imposes a certain
responsibility on the suppliers. 000000000000000000000000000000000000000000000000000000000000000000000000
Annex VI of MARPOL also contains instruments to encourage port states to ensure that suppliers fulfil their obligations.
Port states are required to:0000000000000000000000000000000000000000000000000000000000000000000000000000
Notwithstanding the suppliers' responsibilities and the instruments available, previous experience from port state
controls indicates that it is advisable for owners/managers themselves to ensure compliance. In order to safeguard the
ship from the non-compliance it is recommended that a Letter of Protest is issued in case the suppliers fail to meet the
requirements of Annex VI. A standard Annex VI Letter of Protest form is included in this Instruction Manual.
3
Regulation 14 - Sulphur Oxide (SOx) emissions from ships
When Annex VI of MARPOL enters into force on 19 May 2005, sulphur oxide (SOx) emissions from ships will be
controlled by a 4.5% limit on sulphur content in marine fuel oils. The average sulphur content in fuels today is
approximately 2.7 %.00000000000000000000000000000000000000000000000000000000000000000000000000000000
Further, a 1.5% limit on the sulphur content of marine fuel oil will apply in designated SOx Emission Control Areas
(SECAs). IMO has currently agreed on the designation of two SECAs:
The Baltic Sea Area, which will come into force on 19 May 2006.
The North Sea Area and the English Channel, which will not take effect until 19 November 2007.
It is expected that additional SECAs will be designated in the future and IMO has set forth certain criteria for designating
such SECAs. It should however be noted that the amendment process within IMO may take considerable time.
Ship operators should also be aware that the limitations in sulphur content applies to all marine fuel oils (heavy fuel oils,
marine diesel oils and gas oils) and regardless of use on board (i.e. in combustion engines, boilers, gas turbines etc.).
Bunker specifications and contracts need to reflect required sulphur levels worldwide and in the SECAs if relevant to the
ship's trading patterns. It is also imperative that the crew verifies that the sulphur content specified in the BDN is in
accordance with the these specifications and contracts. 00000000000000000000000000000000000000000000000000000
Change-over procedures:00000000000000000000000000000000000000000000000000000000000000000000000000000
When approaching a SECA, the fuel must be changed over to fuel with sulphur content fuel not exceeding 1.5 % and this
must be completed upon entry into the SECA.000000000000000000000000000000000000000000000000000000000000
For ships with standard fuel oil system configurations (one service tank and one settling tank), this will involve filling the
settling tank with low sulphur fuel oil, adequate treatment and subsequent channelling of this fuel to the service tank, as
well as flushing the fuel service piping systems to remove all fuel oil with sulphur level above 1.5 %.
Change-over procedures need to be developed and should specify the necessary precautions to be taken and the time
needed for such change-over. 0000000000000000000000000000000000000000000000000000000000000000000000000
Additionally, the time and ship's positions at the start and completion of the change-over must be recorded in a logbook,
together with details of the tanks involved and fuel used. 0000000000000000000000000000000000000000000000000000
Although it is acknowledged that the engine room log books or the deck log books are most suitable for recording
change-over, a record form guideline has been included in this Instruction Manual. 000000000000000000000000000000
Charts:00000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Due to the introduction of SECAs and associated change-over procedures, ship operators must ensure that onboard
charts are upgraded to reflect the borders of the SECAs in force. 0000000000000000000000000000000000000000000000
4
Overview of DNVPS samples
The diagram below describes the purpose of the different fuel oil samples to be taken under the DNV Fuel Quality
Testing and Fuel System Check programmes, as well as the associated labels accompanying these samples.
Please note that each sample must be duly-filled and attached with security seals and the respective service labels.
Sample to Lab Ship's retained Supplier's sample MARPOL Annex FSC sample
sample VI sample
This sample is to This sample is to Affix the FSC
be provided with This sample is to be provided with This sample is to sample bottle
the FQT sample be provided with the FQT sample be provided with label and security
bottle label and the FQT sample bottle label and the MARPOL seal to this sample,
security seal and bottle label and security seal and Annex VI sample which is to be sent
is to be sent to security seal and is to be given to bottle label and to the DNVPS
DNVPS laboratory is to be retained the supplier. security seal and is laboratory for
for fuel quality onboard. to be retained testing.
testing. If the supplier onboard for a
In the event of a declines or minimum of 12 Place the bottle in
The bottle is to be quality dispute, discards the months or until a Ziploc bag
placed in zip loc the sample may sample, make the fuel has been before putting it
bag and carton be required sent sure that this is substantially in the FSC carton
together with to a laboratory recorded in the consumed. box provided.
Chief Engineers for testing in the ship's log. Dispatch the
form and copy of presence of the Details pertaining sample to the
Bunker Delivery parties involved to the MARPOL appropriate
Note and sent to in the dispute. Annex VI sample DNVPS laboratory
the appropriate and subsequent in accordance with
DNVPS laboratory destruction or given instructions.
in accordance shipment need be
with these recorded in a
instructions. sample inventory
log.
5
PROCEDURES FOR SAMPLING
SAMPLING0000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
The importance of proper sampling cannot be over-emphasised, as the analysis results will be only as good as the sample
that you have submitted. 00000000000000000000000000000000000000000000000000000000000000000000000000000
Please ensure that your staff is fully conversant with both the sampling procedure recommended in this instruction
manual and your company's fuel management practices.0000000000000000000000000000000000000000000000000000
DNVPS advocates Custody Transfer Sampling, which is also a requirement under the Singapore Code of Practice CP60. If
your fuel has been purchased on FOB terms and delivered by barge or at the tank terminal, the DNVPS recommended
location for Custody Transfer Sampling is on the ship's bunker manifold. Note that Resolution MEPC 96(47) referred to
in Annex VI of MARPOL 73/78, also specifies that the representative sample is to be taken at the ship manifold. If there
are technical reasons as to why you do not have a choice but to take a sample at the barge manifold or any other locations,
such reasons should be recorded. 0000000000000000000000000000000000000000000000000000000000000000000000
In order to obtain a representative sample of the fuel delivered to the ship, the sample has to be drawn continuously
throughout the entire bunkering process. To achieve this, DNVPS strongly recommends that you use a DNVPS
continuous drip line sampler, together with clean DNVPS cubitainers. The DNVPS line sampler can be sealed to prevent
tampering during the sampling operation. Please note that the use of a continuous drip or auto-sampler is specified in
Resolution MEPC 96(47).000000000000000000000000000000000000000000000000000000000000000000000000
Sampling Kit
The sampling kit contains :-
Sampling bottles with caps
IATA approved FQT shipping cartons
IATA approved Fuel System Check carton
Security seals
Ziploc bags
Labels for FQT Sample Bottles
Labels for FSC sample bottles
Labels for MARPOL sample bottles
One Instruction Manual, containing
- FQT sampling instructions (incl. MARPOL Annex VI)
- FSC sampling instructions
- Line sampler brochure
- Custody transfer brochure
- MARPOL Annex VI sample inventory log guideline
- MARPOL Annex VI letter of protest guideline
- Air Courier Directory
- Request to Witness Sampling Form
- Chief Engineer's Report Form
- Standard Pro Forma Invoice
- Return Address Labels
for sending fuel samples to the nearest DNVPS
Laboratory
6
MARPOL Annex VI sample:0000000000000000000000000000000000000000000000000000000000
MARPOL Annex VI requires each BDN to be accompanied by a fuel sample which is representative of the fuel bunkered.
It is the supplier's responsibility to provide the MARPOL sample(s) to the ship. However, this sample is required to be
taken at the receiving ship's manifold by a continuous drip or an auto-sampler. The bottle is to be sealed while the bottle
label must contain specific information and is to be signed by representatives from both the supplier and the receiving
ship.0000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
During the sampling operation, it is not considered practical to take the MARPOL Annex VI sample separately from
those samples required by the fuel quality testing programme. The ship's crew should therefore prepare for the
MARPOL Annex VI sample to be taken as the fourth sample in conjunction with the three FQT samples.
This will require a sufficient amount of fuel sample to be collected in the cubitainer during the bunkering process.
In case the supplier is not in the position to comply with the procedural or documentary requirements of MARPOL
Annex VI, the following actions should be taken by the ship's crew:00000000000000000000000000000000000000000000
As previously indicated, if there are technical reasons as to why a sample cannot be taken at the receiving ship's manifold
(e.g. vacuum problems), such reasons should be recorded in the ship's log book and the sample taken at the barge
manifold or other locations.
SAMPLING PROCEDURES
Request To Witness Sampling Form000000000000000000000
It is the supplier's responsibility to provide a representative
MARPOL sample, continuously drawn throughout the entire
bunkering process. However, it is not considered feasible to
take representative samples for fuel quality testing purposes
and the MARPOL sample in parallel. Hence, the supplier
should be encouraged to accept the practice of taking the
MARPOL sample in conjunction with the sample for fuel
quality testing. 0000000000000000000000000000000000000
Invite the supplier's representative to witness the sampling procedures. Complete a 'Request to Witness Sampling'
form and give the top copy to the supplier's representative. Retain the blue copy for your file.
If the supplier declines to attend the witnessing of sampling, you must note this in the ship's log-book there and
then. Such a record can serve as contemporaneous evidence should a fuel quality dispute later arise. Please ensure that
full information about the barge, cargo officer, supplier, time, date and circumstances etc, are recorded.
7
Dividing The Sample Evenly000000000000000000000000000
Cap the 5-litre cubitainer and shake the content vigorously
for about 10 minutes to mix the sample thoroughly.
Fill four sample bottles 1/3 at a time. Make several passes
to fill up the bottles equally. This is to ensure that the sample is
evenly distributed and the contents in each bottle is
representative. In some cases both the owner and the
charterer may be on the testing program and will require
separate samples to be sent. Four samples will be needed for
fuel quality testing in such cases.000000000000000000000000
Fill the bottles up to the mark “FILL TO THIS LINE.” Stop
at the line as shown in the diagram on the left.0000000000000
8
Ship's Retained Sample000000000000000000000000000000
It is very important to retain one bottle of sample onboard
in a secure location as in most cases this may be the only
sample left which represents the fuel delivered to your
ship.0000000000000000000000000000000000000000000000
IMPORTANT00000000000000000000000000000000000000
If this sample is eventually sent for testing, all parties
involved or their representatives must be present to witness
the breaking of the seals and the testing process.
9
If the supplier provides a MARPOL Annex VI sample, but it is found not to have been taken in accordance with the
procedures, the suppliers' sample should be countersigned with the appropriate reservations e.g. “For receipt only-
source unknown” (using the rubber stamp supplied in the sampling kit). The ship crew should propose their own
representative MARPOL Annex VI sample, taken in accordance with the procedures in this instruction manual, as the
official MARPOL Annex VI sample. The crew should request counter-signing and sealing by the supplier. If this is
accepted by the supplier, a Letter of Protest is not deemed necessary.000000000000000000000000000000000000000000
If there are technical reasons as to why a sample cannot be taken at the receiving ship's manifold (e.g. vacuum problems
and/or extreme weather conditions), then such reasons should be recorded in the ship's log book and the sample taken
at e.g. barge manifold. 0000000000000000000000000000000000000000000000000000000000000000000000000000000
IMPORTANT00000000000000000000000000000000000000000000000000000000000000000000000000000000000000
This MARPOL Annex VI sample should be kept onboard in a safe location for minimum 12 months or until the fuel
bunkered has been substantially consumed. The sample is only to be handed over to a port or flag state authority.
In such an event, a receipt should be requested and the action should be recorded in a sample inventory log.
In case the supplier has also provided a MARPOL sample but which is not taken in accordance with the requirements of
MARPOL Annex VI, it is recommended that both samples are handed over to the port or flag state authority together
with documentation highlighting any discrepancy. 00000000000000000000000000000000000000000000000000000000
10
Chief Engineer's Instructions to Ship's Agent0000000000000
Complete the courier despatch instructions on the side of
the forwarding box, as indicated in the Air Courier Directory.
Fill in the DNVPS Universal Account Number to prevent
rejection from DHL. This account number may be found in
the Air Courier Directory.00000000000000000000000000000
Complete the Pro Forma Invoice Form and tape it to the
outer side of the forwarding box.00000000000000000000000
The sooner the sample reaches a DNVPS laboratory, the
sooner you will receive the test results.0000000000000000000
11
GENERAL GUIDELINES WHEN BUNKERING
Sometimes these documents are prepared before the delivery and may not reflect the 'facts' of the delivery. We strongly
recommend that you do not sign the BDN or any sample labels from the supplier before the bunkering is completed.
Volume deliveries00000000000000000000000000000000000000000000000000000000000000000000000000000000000
Normally, the terms and conditions of sale state that the quantity of fuel delivered will be determined by shore meters or
measurement of barge outturn.000000000000000000000000000000000000000000000000000000000000000000000000
Please be aware that after the entry into force of the SECAs as defined in Annex VI of MARPOL 73/78, verifying
bunkered quantity of low sulphur fuel will become increasingly important. The is because Port State Control Inspectors
may scrutinise fuel inventory records in order to verify that the ship has used low sulphur fuel within SECAs i.e. bunkered
quantity, recorded consumption within SECA and ROB should balance.000000000000000000000000000000000000000
In either case the chief engineer or ship representative should attend to witness opening meter readings or barge
soundings and temperature. On completion of the delivery the ship representative should also attend to determine the
'actual' volume delivered. The volume recorded on the BDN should be at standard temperature - calculated by referring
to ASTM Petroleum Table 54B.000000000000000000000000000000000000000000000000000000000000000000000000
To convert from volume to weight it is necessary to determine the density of the fuel and, by reference to ASTM Table 56,
multiply the volume at standard temperature by the weight factor. DNVPS finds that the density on the BDN is often
overstated, resulting in an overstatement of weight delivered.000000000000000000000000000000000000000000000000
Receivers of fuel are advised to indicate on the BDN “For Volume at Observed Temperature Only”.
The rubber stamp is provided for your use.000000000000000000000000000000000000000000000000000000000000000
Please ensure that a copy of the BDN is enclosed with your sample in order for us to evaluate the DNVPS density
determination against the supplier's statement.00000000000000000000000000000000000000000000000000000000000
12
General guidelines
Disputes arising from poor quality fuel deliveries can be complex and what may seem to be a simple case can become very
convoluted with respect to documentation, samples and alleged damages.00000000000000000000000000000000000000
A fuel quality dispute can develop at any time, and investigators will need to compile an accurate report if the claim is to
be successful. We stress the need for good routine record-keeping onboard the vessel as 'after the fact' accounting is
difficult and confusing. The DNVPS system will provide support in such cases but the chief engineer, by following the
guidelines listed here, will improve the chances of success :00000000000000000000000000000000000000000000000000
1. Keep a daily record of fuel quantities held onboard in each tank. Record transfers of fuel by date and amount
transferred from tank to tank.
2. Keep careful records of oil bunker deliveries, recording quantity in all tanks before and after delivery.
3. Whenever possible, do not mix fuel from different deliveries and always load into empty tanks.
5. Retain suppliers' samples and samples taken by ship staff for a minimum period of six months. Ensure that they
are correctly labelled, sealed and stored in a safe location.
6. Retain the MARPOL Annex VI sample for a minimum of 12 months or until the fuel has been substantially
consumed. Ensure that the sample is correctly labelled as per MARPOL Annex VI requirements, sealed and stored
in a safe location.
7. Ensure that BDNs are in accordance with MARPOL Annex VI requirements . Keep copies of all BDNs readily
available onboard for a minimum of 3 years.
8. Keep good records on main engine and auxiliary inspections and repairs.
9. Ensure that engine room or machinery log books record temperatures and pressures, so that abnormal conditions
can be recognised and related to a particular period.
10. In case of damages, compile a statement or record of events which should include date, times, damages and costs
(including manhours and spare parts). Also retain broken or damaged parts for future inspection. Photographs of
damages may also prove useful.
11. If problems are encountered, samples of the fuel in use should be are drawn from the fuel system as detailed below.
13
Fuel tank and system sampling:
From time to time, it will be necessary to draw fuel samples from the ship's tanks or fuel system. This may be required to
confirm a poor fuel quality delivery, to resolve a fuel handling problem, or check the performance of fuel treatment plant
components. Again, we must stress that analysis of such samples can only be useful if they have been taken properly.
Tank sampling00000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Ideally, to evaluate the quality of fuel stored in a tank, the following samples should be obtained :
a) Top sample - taken at approximately 6 inches below the surface of the oil.
b) Upper sample - taken from the middle of the upper one-third of the tank's contents.
c) Middle sample - taken from the middle of the tank's contents.
d) Lower sample - taken from the middle of the lower one-third of the tank's contents.
e) Bottom sample - taken from the bottom surface of the tank.
The above samples should not be mixed together but submitted for analysis as individual samples. The label on each
bottle must record the date, the sample type and tank location.00000000000000000000000000000000000000000000000
Sampling devices designed for such sampling should be used. It is therefore recommended that 'liquid' surveyors be
instructed to take such samples. If sampling equipment is available on board, ensure that it is thoroughly cleaned before
use. In some cases, due to limited access to tanks, it is not possible to obtain tank samples as described above. Under these
circumstances, a sample may be taken at the fuel transfer pump as described below.0000000000000000000000000000000
If the suction or discharge lines of the pump contain oil from previous transfers, start the pump and run it for a sufficient
period to empty the lines. After this, start sampling by taking a continuous-drip or stream of oil into a clean cubtainer.
Continue to collect the sample until the tank is empty, during which time you should have adjusted the sample flow to
collect some five litres of oil. If an empty tank is not available, take a continuous-drip sample from the transfer pump
discharge during circulation of the oil back to the same tank.
Thoroughly mix the 5-litre sample and pour one litre into a DNVPS bottle.
Mark the sample as 'Continuous-drip - Fuel tank contents during discharge' together with the tank number.
DO NOT
a. take the sample from tank bottom drain valves. These will probably contain high levels of water and sediment
which will not be representative.
b. take sample from sounding pipes - again these will not be representative.
Sampling from a fuel system when a problematic fuel is loaded will also help indicate the efficiency of the treatment plant
and thus assist the crew in taking preventive action, if needed. 000000000000000000000000000000000000000000000000
Sampling before and after separators is also considered the only feasible condition and performance monitoring of the
fuel.0000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Periodic sampling from the fuel treatment system will also identify such problems as water ingress from ballast systems,
leaking heating coils and cargo contamination. A good fuel management system would include such sampling and
analysis at least once a year.0000000000000000000000000000000000000000000000000000000000000000000000000000
The DNVPS Fuel System Check (FSC) can assist your ship in this regard. Further information and detailed instructions
for fuel system check sampling is provided in this manual.000000000000000000000000000000000000000000000000000
14
FUEL SYSTEM CHECK (FSC)
With the instructions provided herein, you will have all the information needed to take full advantage of this programme.
Fuel standards such as ISO 8217 specify quality at the ship's manifold. It is presumed that quality will not deteriorate in
storage on board and that there will be adequate treatment before use.
Experience gained by DNVPS and its customers since the introduction of the DNV Fuel Quality Testing programme,
coupled with studies and research, confirms that fuel treatment systems are not always operated at optimum efficiency.
Fuel contamination may also occur in the vessel's fuel system and tanks due to defective steam heating coils or
seawater/cargo ingress resulting from badly located or damaged vent pipes.
Efficient and proper centrifuge operation is also essential for the removal of contaminants in the bunkers. With the Fuel
System Check program, malfunction and defects in the centrifuges can be identified; while post-separator sampling
helps uncover possible filtering problems such as filter mesh rupture.
For example, ISO 8217, the most commonly referred to marine fuel specification in the market, indicates 80 mg/kg
Aluminium + Silicon (Al+Si) as the maximum amount of catalyst particles permitted in the fuel as delivered. However,
major marine engine manufacturers recommend not more than 15 mg/kg Al+Si at the engine inlet. Hence, assuming a
delivered fuel contains 75mg/kg Al+Si, your purification system has to operate at an efficiency level capable of removing
80 per cent of these highly abrasive materials, in order to meet the engine manufacturers' requirement.
The purpose of Fuel System Check is to monitor the shipboard fuel system, i.e. the 'gap' between the ship's manifold
and the engine, in a systematic manner. This is done by analysing samples drawn from key locations to assess the total
fuel system.
Figure 1 (Sampling Positions & Sample Identification Letters) shows the locations from which Fuel System Check
samples are to be drawn.
15
A standard set of Fuel System Check samples consists of one sample taken from each of the following locations (see
Figure 1):
Note - Additional samples can be drawn after the individual fuel cleaning components. For a detailed breakdown of
Sampling Positions and Codes, please refer to Figure 2.
16
For ease of sampling, we strongly recommend that these connections be fitted with sampling cocks or valves. A
connecting pipe may extend to a convenient position for sample collection. Ideally, a facility might be provided to allow
for the flushing of the connection back to the system or to a waste tank. The sample should not be drawn from Tank
Drains as DNVPS' experience shows that such a sample is in general not representative of the fuel.
Sampling Procedure
For the assessment of the analysis results to be as meaningful as possible, the samples must be drawn at around the same
time. Routine and requested sample sets should be taken when the fuel from the last bunkering has worked well through
the system, even if two or more bunkerings have had to be mixed together.00000000000000000000000000000000000000
All sampling equipment should be clean and in good order. Oil, sludge, water, cleaning solvents etc, from previous
samplings can cause erroneous analysis results.000000000000000000000000000000000000000000000000000000000000
Bearing in mind the hazards of hot oil under pressure, samples should not be taken from the high pressure booster part
of the fuel system.00000000000000000000000000000000000000000000000000000000000000000000000000000000000
3. Ensure the lines are flushed through before drawing the sample.
4. The sample may be filled directly into the plastic sample bottles. Fill the sample bottle. Make sure each
bottle is clearly marked to prevent mix-up.
5. The plastic bottle cap should be firmly fastened after sample has
cooled to avoid leakage.
6. Ensure each sample is clearly labelled with the RED Fuel System
Check sticker.
8. Pack the three Fuel System Check samples in the FSC cardboard
transportation box. Attach the laboratory address labels according
To instructions given in the FQT Air Courier Directory (ACD).
17
Sludge samples000000000000000000000000000000000000000000000000000000000
Sludge samples taken from tanks, purifiers and pipelines can provide useful information, but without fuel samples taken
at the same time, the analysis results cannot be put into context. Thus, it is important to submit both sludge and fuel
samples. It must be accepted that sludge samples may contain high amounts of water and sediment accumulated over a
period of time from several bunker deliveries.0000000000000000000000000000000000000000000000000000000000000
Safety0000000000000000000000000000000000000000000000000000000000000000
The usual safety precautions should be followed and the guidelines provided below should be read in conjunction with
the appropriate standards and codes of practice.
1. Regulations regarding the entry into hazardous areas should be strictly observed.
2. Smoking and naked lights should be prohibited in the vicinity of oil vapours.
3. Sampling equipment and lights should not pose an electrical risk.
4. When handling fuels, or cleaning fuel treatment components, ensure oil-resistant gloves are worn and eyes are
protected.
The Fuel System Check samples should be sent to the nearest DNVPS laboratory for analysis. The address labels are
provided in this manual.000000000000000000000000000000000000000000000000000000000000000000000000000000
Please instruct your agent to fill out the required customs declarations and contact the nearest courier service listed in
our Air Courier Directory.0000000000000000000000000000000000000000000000000000000000000000000000000000
By agreement with DNVPS, the sample boxes will be forwarded by our international network of courier agencies. The
ship agent should be instructed to request pick-up and dispatch according to Chapter 2 of our FQT Instruction Manual.
Standard pro forma invoices, as enclosed in this manual should be filled out and attached to the sample box.
Samples submitted for analysis under the Fuel System Check programme will be analysed for a number of key parameters
in order to identify the fuel and assess the onboard fuel treatment plant.0000000000000000000000000000000000000000
The test parameters Density and Vanadium are used to “fingerprint” the fuel in order to confirm that the fuel samples
correspond with the bunkered fuel.000000000000000000000000000000000000000000000000000000000000000000000
In order to assess the onboard treatment, the following parameters will be measured:00000000000000000000000000000
Water - Used to monitor if any settling of water has taken place and/or if there is any water contamination; for
example, from steam heating coils or leaking solenoid valves on the separators.0000000000000000000000000000000
Sodium - High Sodium can cause increased corrosion of the high pressure parts of the fuel system and to exhaust
valves as well as increased deposits in the post-combustion spaces.000000000000000000000000000000000000000000
Aluminium + Silicon - These abrasive particles, otherwise known as “cat fines” can cause significant damage to an
engine. Areas such as fuel pumps and injectors and the liners and piston rings can be subject to high wear rates if the
“cat fines” content is not reduced down to a satisfactory level as recommended by your engine manufacturer(s).
Iron - If present, this would most likely be in the form of Iron Oxide (Rust) and as such would be removed by the
separator(s).000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Total Sediment Potential (TSP) - This parameter is used to assess and indicate the Stability and Cleanliness of a fuel.
Fuels with high Sediment content can cause increased sludge problems in the separators.
The analysis report for the Fuel System Check samples will be sent to designated recipients in the same manner as the test
results from the fuel analysis samples.0000000000000000000000000000000000000000000000000000000000000000000
18
GUIDELINES ON INTERPRETING TEST PARAMETERS
Density
Density is expressed in kilograms per cubic metre (kg/m ) at 15 ºC.00000000000000000000000000000000000000000000
Density must be known to determine the weight of a fuel and in order that the ship staff can correctly set the centrifuge
plant for fuel cleaning. On many vessels fitted with conventional centrifuges the maximum density for
effective fuel cleaning is 991 kg/m .000000000000000000000000000000000000000000000000000000000000000000000
Viscosity
Viscosity is expressed in mm2/s (centistokes, or cSt) at a stated temperature. This is a measure of a fluid's resistance to
flow. The kinematic viscosity is measured by the time for a fixed volume of oil to flow through a capillary tube.
Viscosity is not actually a measurement of heavy fuel oil quality. The user of the fuel will need to be aware of the viscosity in
order to set heaters correctly, prior to pumping and cleaning or treating the fuel, and before injection into the main
engine. This is because heavy fuel oil must be heated to reach the correct injection viscosity to ensure optimized
combustion and engine performance. 000000000000000000000000000000000000000000000000000000000000000000
If the viscosity of the fuel is too high, the heating plant may not be capable of raising the fuel to the correct temperature.
In extreme cases, transfer of the fuel onboard may be very difficult and the engine could suffer poor performance and
possibly damages if insufficient heating is applied prior to injection.0000000000000000000000000000000000000000000
Heavy fuel oils are also generally priced and ordered according to viscosity.0000000000000000000000000000000000000
Water
Water content is expressed as per cent by volume. Water reduces the specific energy of fuel oil, thereby increasing
consumption and reducing fuel economy. Water may cause corrosion in the fuel system. The sodium chloride (salt) in
sea-water can also promote corrosion by giving rise to the formation of sodium-vanadium compounds during
combustion (high temperature corrosion). The water content in heavy fuel oils is low during production; thus the
presence of water in bunker oil is usually due to external contamination.000000000000000000000000000000000000000
Separation of water from fuel oil can be a slow process, particularly if the difference in density is small or if the water is
present as minute drops. Separation of water drops is also inhibited by various small-particle impurities, such as dust,
sand and rust. The resulting emulsion clogs filters and affects efficient centrifuging.000000000000000000000000000000
Carbon Residue
The carbon residue level indicates the coke-forming tendencies of a fuel and is expressed as per cent by weight. Fuel oil
with a high carbon residue may cause combustion deposits, particularly when the engines are running at low load.
Sulphur
The sulphur level in fuel contributes to sulphur oxide emissions and thus air pollution. Annex VI of MARPOL 73/78
includes a worldwide 4.5% maximum sulphur content in fuel. In the Sulphur Emission Control Areas (SECAs), the
maximum sulphur content is 1.5%. 000000000000000000000000000000000000000000000000000000000000000000000
Sulphur compounds may corrode cylinder liners and piston rings. The sulphur dioxide generated by combustion may
cause corrosion in exhaust passages at low temperatures.0000000000000000000000000000000000000000000000000000
Engines designed for operation on high sulphur fuels use special lubricants and operate at higher temperatures to
minimise the effects of sulphur. The sulphur content of a fuel affects the energy available.
19
Sediment
All fuels contain sediment consisting of hydrocarbon sludges and extraneous materials. The Total Sediment Test is
designed to determine the quantity of non-fluid material in the fuel by a hot filtration method.000000000000000000000
Ash
Ash represents the incombustible components of fuel oil. These components may have their origin in the fuel or may
have been introduced by poor house keeping. High ash levels can cause wear in the fuel injection system, deposits on
cylinder components and resultant wear. In addition, some ashes are corrosive and may stick on to exhaust valves. High
ash levels may also reduce the efficiency and cause damage to turbochargers.000000000000000000000000000000000000
Small particles of the catalyst (aluminium and silica oxides) used in the refinery process are sometimes carried over into
the residual fuel. They range in size from about 5 microns to 120 microns and are of irregular shape, porous and
extremely hard. Some degree of removal may be achieved by settling and centrifuging onboard ship. Due to
their abrasive nature, catalyst fines can lead to wear of fuel injection system components and cylinder rings/liners.
Some fuel standards prescribe a maximum limit of 30 mg/kg aluminium, or 80 mg/kg aluminium + silicon in fuels as
delivered to vessels. A good cleaning plant should reduce this by some 60-70%. However, fuel deliveries with combined
aluminium and silicon levels of over 200 mg/kg have been recorded and severe engine damages attributed to the
catalytic fines.00000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Catalytic Fines
Elements
Fuel oils contain many metals, of which the most common are vanadium, nickel, iron and sodium. Vanadium and sodium
are perhaps the most dangerous as they may lead to high temperature corrosion. The worst situation is when
the ratio of vanadium to sodium is approximately 3:1. Sodium salts are water-soluble and can be removed with water
during treatment. Vanadium, however, is oil soluble and cannot be removed by onboard fuel treatment equipment.
Flash Point
The flash point is expressed in degrees centrigrade. Safe transport and storage requires that the flash point of the
fuel oil is known. A flash point minimum of 60oC is prescribed for use onboard ships in the machinery spaces. This
minimum temperature is stated in the rules of classification societies and legislated by most governments.
20
MARPOL Annex VI Services
Based on clients' requests, DNVPS has further developed a service where owners can submit fuel oil samples for
verification of compliance with the sulphur content requirements of Annex VI to MARPOL 73/78. The service is
available for marine fuel oils, diesel oils and gas oils. 0000000000000000000000000000000000000000000000000000000
- Low sulphur fuel is anticipated to come at a premium compared to normal sulphur fuel, i.e. there is a commercial
interest in verifying that the fuel quality is in accordance with the specification.
- It is considered preferable to verify the actual sulphur content in advance as opposed to testing on the order of the port
state control. Verification in advance represents an opportunity to be pro-active, i.e. notify flag states and port states on
any failure on the part of the supplier in delivering MARPOL Annex VI compliant fuels.
- Prior verification could limit potential problems in case the vessel is using lubrication oils with a TBN adapted to low
sulphur fuel oils only.00000000000000000000000000000000000000000000000000000000000000000000000000000000
- It serves as a means to limit the emission of sulphur oxides within SECAs, i.e. fulfil the ship's obligation towards
safeguarding the environment 000000000000000000000000000000000000000000000000000000000000000000000000
Besides sulphur, the scope of testing also includes density in order for owners to verify that the actual density is in
accordance with that specified in the supplier's BDN. This is considered increasingly important as one can anticipate that
bunkered quantity together with recorded consumption and ROB will be scrutinized so as to determine that only low
sulphur fuel has been consumed within SECAs.00000000000000000000000000000000000000000000000000000000000
The MARPOL Annex VI low sulphur service is however identical to the complete DNV Fuel Quality Testing programme
in terms of the sampling kits, sampling procedures and sample shipment instructions contained in this instruction
manual. 0000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Subscription to the low sulphur service therefore ensures the availability of MARPOL Annex VI compliant sampling kits
(bottles, labels, instructions etc) as well as access to DNVPS' bunker alerts, fuel quality statistics, line samplers and other
DNVPS services. 000000000000000000000000000000000000000000000000000000000000000000000000000000000000
The time required for this change-over will deviate depending on the tank and piping system configuration onboard.
Although change-over from one fuel quality to another is nothing new onboard ships, MARPOL Annex VI has specific
requirements for the completion of such change-over. It is therefore recommended that additional focus should be put
on the development of proper procedures as MARPOL Annex VI is a statutory requirement subject to statutory surveys
and controls. 000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
In order to verify whether the change-over procedures developed comply with the requirements of MARPOL Annex VI,
DNVPS has developed a service where owners can take in-system samples before and upon completion of change-over
and submit them to DNVPS for testing. 000000000000000000000000000000000000000000000000000000000000000000
Such verification can be carried out without low sulphur fuel being onboard, as long as fuel oils of different grades are
used.000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
DNVPS will test submitted samples for density, viscosity and sulphur in order to determine whether complete change-
over between fuel grades has been achieved. The results of the tests will enable owners to adjust the change-over
procedures to ensure future compliance.0000000000000000000000000000000000000000000000000000000000000000
21
Sampling points:000000000000000000000000000000000000000000000000000000000000000000000000000000000000
The sampling points depend on the fuel tank and piping system configuration onboard. The following sampling points
are however recommended: 00000000000000000000000000000000000000000000000000000000000000000000000000
3. Fuel supply piping immediately before each engine and boiler burner arrangement: 000000000000000000000000000
-In order to confirm that complete change-over of fuel oil supplied to engines and boilers has been achieved.
-Alternatively one could consider taking similar samples in return oil piping from engines and boiler burner
arrangement.00000000000000000000000000000000000000000000000000000000000000000000000000000000000000
In order to limit the number of samples taken, one could limit the scope to the service tank outlet or from the common
supply piping to main engine(s), auxiliary engines and boiler(s). However one needs to bear in mind that this will not
necessarily reflect the quality of the fuel being consumed in the respective engine/boiler.
Please ensure that at the time of sampling safety precautions are taken due to potential hazards if sampling is carried out
from the pressurised fuel oil booster system(s).000000000000000000000000000000000000000000000000000000000000
Sampling equipment:00000000000000000000000000000000000000000000000000000000000000000000000000000000
For ease of sampling, we strongly recommend that the sampling points are provided with sampling cocks or valves. A
connecting pipe may extend to a convenient position for sample collection. Ideally, a facility might be provided to allow
for the flushing of the connection back to the system or to a waste tank. 0000000000000000000000000000000000000000
All sampling equipment should be clean and in good order. Oil, sludge, water, cleaning solvents etc, from previous
samplings can cause erroneous analysis results.000000000000000000000000000000000000000000000000000000000000
Sampling Procedures:
One sample should be taken at each specified sampling point:
- Before commencement of change-over.
- Immediately upon completion of change-over, which is considered the official time to be recorded in the ship's
logs as per MARPOL Annex VI requirements
2. Ensure that each sample bottle is provided with a red FSC label and
mark each label clearly before sampling to prevent mix-up as follows:
“FUEL CHANGE-OVER”
-Whether sample is taken before or upon completion of change over. Fill the sample bottle. Make sure each
bottle is clearly marked to prevent mix-up.
-Sampling point location.
3. Ensure the lines are flushed through before drawing the sample.
4. The sample may be filled directly into the plastic sample bottles. 300
to 400 ml is all that is required for the FSC program. As such, the
bottles only need to be half filled.
Fasten the bottle cap
5. The plastic bottle cap should be firmly fastened after sample has securely to prevent leakage
cooled to avoid leakage.
7. Pack the Fuel System Check samples in the Fuel System Check
carton box. Attach the laboratory address labels according to our Air Attach the red Fuel System
Courier Directory. Check label on the sample bottle.
22
Forwarding the samples 0000000000000000000000000000000000000000000000000000000000000000000000000000
The samples should be sent to the appropriate DNVPS laboratory for analysis. The address labels are provided in this
manual.0000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
Please instruct your agent to fill out the required customs declarations and contact the nearest courier service listed in
our Air Courier Directory.00000000000000000000000000000000000000000000000000000000000000000000000000
By agreement with DNVPS, the sample boxes will be forwarded by our international network of courier agencies. The
ship agent should be instructed to request pick-up and dispatch according to Chapter 2 of our Instruction Manual.
Standard Pro Forma invoices, as enclosed in this manual, should be filled out and attached to the sample box.
Verification frequency:0000000000000000000000000000000000000000000000000000000000000000000000000000
The above comprehensive sampling is considered necessary in connection with development of change-over
procedures. It is however recommended that periodic verification of procedures are carried out, but with a reduced
scope incorporating sampling from settling and service tank(s) outlets only.0000000000000000000000000000000000
Due to uncertainty with respect to availability of low sulphur fuel oil, certain owners have indicated that they intend
to blend fuel onboard to meet the low sulphur requirements.
- Are the different grades of fuel oils and distillates (diesel and gas oil) compatible ?
- What is the minimum amount of the more expensive low sulphur fuel oil, marine diesel oil or gas oil that can be
used, while ensuring that the sulphur specification and engine specification is met ?
- How can the ship verify and document the resultant sulphur content in the blend to a third party.
To limit the above uncertainties, DNVPS offers its Blend Optimisation Programme (BOP). This programme will enable
owners engaging in onboard blending to optimise the composition of blended marine fuels to ensure that the most
economic blends are used; that the blends meet the engine manufacturers' requirements to fuel oil quality; and that the
risk of blend incompatibility, which can lead to severe sludging and potential operating problems, is reduced. 00000000
The Blend Optimisation Programme will consider the critical specifications of the blend components and the non-linear
viscosity blending characteristics. The programme will provide the technical expertise and experience to determine
optimum blend composition and will also verify whether the blend components are compatible. 00000000000000000000
By submitting a representative sample of each blend component, the Blend Optimisation Programme will undertake the
following:00000000000000000000000000000000000000000000000000000000000000000000000000000000000000000
23
EXAMPLE -- MARPOL ANNEX VI BUNKER SAMPLE RECORD
Ship Name:
IMO No:
Date of bunkering:
Bunker port:
Bunker Grade(s):
Quantity (MT)
Name of supplier
Comments
MARPOL ANNEX VI BUNKER SAMPLE RECORD - GUIDELINES (Proposed By DNVPS)
Bunkering Operation ID No : Hints
Date of bunkering Indicate date bunkering was performed (start and completion).
Indicate Product's name/Grade as per Bunker Delivery Note or specification. ISO grades preferably to
Bunker Grade(s)
be used.
Quantity (MT) Indicate quantity received in Metric Tons. Low sulphur fuel consumption within SECA's becomes a
statutory requirement and may therefore be subject to third party verification/control. Accordingly,
it is reccommended that increased focus is put on bunker quantity measurements and testing of density
to acertain that the quantity received is in accordance with BDN value.
Port of Bunkering Indicate the Port where the bunkering operation was performed
Supplier Registration with Answer with Yes, No or Unknown with respect to whether the Supplier is Registered with Port State
Port State Authorities Authorities or not. Note that MARPOL Annex VI does require Port States to maintain such a register.
Although not a requirement, it is reccommended that only registered suppliers are used.
BDN in compliance with Answer with Yes, No. It is a requirement that for every barge and grade delivered to the ship is
MARPOL Annex VI accompanied by a Bunker Delivery Note (BDN). The BDN is to contain Name and IMO no. of
receiving ship, Port, Bunkering date, Suppliers Name/Adress/Telephone no., Product name,
Quantity (MT), Density at 15oC (kg/m3), Sulphur content (% m/m), A declaration signed by the
supplier's rep. stating that the fuel is in conformity with Reg.14(1) or 4(a) and Reg.18(1) of Annex
VI to MARPOL. If the BDN does not contain the required information and declaration, a letter of
protest should be issued. The BDN is to be retained onboard for min. 3 years.
MARPOL sample received Answer with Yes or No. Note that every BDN is to be accompanied by a MARPOL sample representative
from supplier for the fuel supplied. The sample is to retained onboard for min. 12 months. The sample is to be min.
400 ml and provided with a lable with information regarding; Location where sample was taken (ship
manifold), Sampling method, Bunker date, Name of bunker barge/pier, Receiving ship name and
IMO no., Sample seal number and Bunker grade. Every sample is to be sealed by supplier and label is
to be signed by the Officer in charge of the bunkering and the suppliers' rep. It is the suppliers
responsibility to provide such a a sample. See however below requirements. If the supplier does not
provide a MARPOL sample, a letter of protest should be issued and the separate MARPOL sample
taken by the ship's crew in accordance with the DNVPS instruction manual should be maintained
onboard together with the supplier's sample.
MARPOL sample taken Answer with Yes or No. The guideline to Annex VI (MEPC. 96(47)) specifies that the MARPOL
at ship manifold sample is to be continously drawn at the receiving ship's manifold. In case the supplier does not take
the MARPOL sample at the ships' manifold, a letter of protest should be issued and the separate
MARPOL sample taken by the ship's crew in accordance with the DNVPS instruction manual should
be maintained onboard together with the supplier's sample. If there are operational constraints such
as vacuum problems that prohibits samples to be taken at the ship's manifold, this should be recorded
separately and the sample taken e.g. at barge manifold.
Letter of Protes issued Answer with Yes or No. The letter of protest should be referred to in the BDN.
MARPOL sample seal nos. MARPOL Sample bottle seal number(s) are to be specified. Note that it is reccommended that all
seal number(s) related to bunker samples tanken are recorded in the BDN (Requirement in Singapore)
Other sample sent for Answer with Yes or No. Applicable if the vessel sends other fuel samples for fuel quality testing. The
fuel quality testing MARPOL sample is to be retained onboard and not be used for commercial disputes. I.e. the sample
is only be handed over to a Port or Flag state Authority upon request.
Sulphur content (%m/m) Indicate the sulphur content as indicated on the Bunker delivery note (BDN)
Stored in Tank No. Indicate in which tank(s) the received fuel was stored with specified quantity in each tank.
And quantity
Date when fuel was
Indicate the date that the quantity of the fuel bunkered was substantially consumed.
substantially consumed
The disposal date should be indicated. All samples should be stored onboard for a minimum of 12
Sample disposal date
months or until the fuel was substantially consumed - whichever is greater.
Sample given to The date on which the sample was given to an Authority for verification should be indicated with port
Authorities and name of authority, if applicable. A receipt should always be obtained. In case the supplier's sample
is not taken as per Annex VI requirements, both the supplier's sample, the DNVPS MARPOL sample
and a copy of the letter of protest should be handed over.
DNVPS GUIDELINES FOR ISSUING NOTE OF PROTEST REGARDING MARPOL ANNEX VI
The vessel's Master may be required to issue Note of Protest to bunker supplier if the bunker supplier
fails to comply with the MARPOL ANNEX VI requirements.000000000000000000000000000000000
The vessel's Master should note the following possible non-compliance situations and choose the
relevant item/s to be quoted in the Note of Protest:
2 The Bunker Delivery Note did not contain the required information. (In this section further
elaboration is needed to state which information was not given. Refer further explanation under
Regulation 18(3) App.V).
3 A MARPOL Annex VI sample did not accompany each Bunker Delivery Note.
4 The MARPOL Annex VI sample(s) was not taken at receiving ships manifold.
5 The MARPOL Annex VI sample(s) was not taken by continuous drip sampler or auto-sampler.
6 The MARPOL Annex VI sample(s) was not provided with seal and a label containing the required
information. (In this section further elaboration is needed to state which information was not given.
Refer further explanation under Regulation MEPC.96(47) Item 8).
For convenience, an Example of a Note of Protest is shown is shown later in this document.
Further explanation of the possible non-compliance items related to Regulation 18 of Annex VI to MARPOL
73/78 is as follows:
Regulation Description
18(3) A Bunker Delivery Note was not provided for every delivery and grade supplied.
The Bunker Delivery Note did not contain the required information as follows:
- Name and IMO No. of receiving ship.
- Port
- Date of commencement of delivery.
- Name, address and telephone no. of marine fuel oil supplier
- Product name
18(3) App.V - Quantity (metric tons)
o 3
- Density at 15 C (kg/m ) - as per ISO 3675.
- Sulphur content (% m/m) as per ISO 8754.
- Declaration signed and certified by the suppliers rep. that the fuel supplied is in
conformity with Reg.14 (1)* or 4(a)** and Reg.18(1)*** of Annex VI to
MARPOL 73/78.
MEPC.96(47) The MARPOL Annex VI sample(s) was not taken at the receiving ships manifold.
Item 6
MEPC.96(47) The MARPOL Annex VI sample(s) was not provided with a label containing the
Item 8 required information as follows:
- Location at which, and the method by which, the sample was drawn
- date of commencement of delivery;
- name of bunker tanker/bunker installation;
- name and IMO number of the receiving ship;
- signatures and names of the supplier's representative and the ship's
representative;
- details of (tamper proof) seal identification; and
- fuel grade.
Note that MEPC.96(47) is the “Guidelines for the sampling of fuel oil for determination of
compliance with Annex VI of MARPOL 73/78”, which is referred to in Reg.18(6) and which IMO has
invited Governments to apply from the date of entry into force of Annex VI to MARPOL 73/78.
EXAMPLE -- MARPOL ANNEX VI NOTE OF PROTEST
Date :____________________________________
To : ____________________________________
(Name of Supplier)
____________________________________
(Address and telephone number)
Dear Sirs,
This is to record that the stated Supplier failed to comply with the MARPOL Annex VI requirement
as follows:
I hereby lodge a protest to reserve rights for any future consequences on this matter.
Yours faithfully,
_________________________ _____________________________________________
(Name of Master of Vessel) (Signature of Master of Vessel and Vessel Stamp)
ACKNOWLEDGEMENT RECEIPT
__________________________________________________
Name of Master/Cargo Officer of Bunker Tanker/Barge)
______________________________________________________ _____________________
(Signature of Master/Cargo Officer of Bunker Tanker/Barge) (Date)
DNVPS Worldwide HQ DNVPS Regional Office & Laboratory DNVPS Regional Office & Laboratory
Regional Office & Laboratory Singapore Fujairah, UAE Rotterdam, The Netherlands
Port of Fujairah P O Box 1227 Haastrechtstraat 7
27 Changi South Street 1 Singapore 486071 3079 DC Rotterdam P.O. Box 9599
United Arab Emirates 3007 AN Rotterdam The Netherlands
Tel: + 65 6779 2475 Fax: + 65 6779 5636 Tel: + 971 9 2228152 Fax: + 971 9 2228153 Tel: + 31 10 292 2600 Fax: + 31 10 479 7141
Email: singapore@dnvps.com Email: fujairah@dnvps.com Email: rotterdam@dnvps.com
DNVPS Regional Office DNVPS Regional Office & Laboratory DNVPS Regional Office & Laboratory
London, UK Oslo, Norway Houston, Texas, USA
Palace House 3, Cathedral Street 318 North 16th Street
Veritasveien 1 N-1322 Hovik, Norway
London SE1 9DE United Kingdom La Porte, Texas 77571, USA
Tel: + 44 0207 357 6080 Fax: +44 0207 716 6736 Tel: + 47 67 57 9900 Fax: + 47 67 57 9393 Tel: + 1 281 470 1030 Fax: + 1 281 470 1035
Email: london@dnvps.com Email: dnvps.oslo@dnv.com Email: houston@dnvps.com
DNV is a global provider of services for managing risk. Established in 1864, DNV is an
independent foundation with the objective of safeguarding life, property and the environment.
DNV comprises 300 offices in 100 countries, with 6,400 employees.
DNVPS/FQTK_IM/V1R0/0405