World Bunkering > News > Spring 2011 > Pre-testing

The following is a considerably edited and abbreviated summary version of a paper submitted jointly by IBIA and BIMCO to the 15th session of IMO’s subcommittee on Bulk Liquids and Gases (BLG), which took place in early February, just after World Bunkering had gone to press.

Norway and Intertanko, in a paper to IMO’s Marine Environment Protection Committee (MEPC), argue that the lack of mandated minimum quality requirements on the fuel supplied to vessels causes preventable risk to the safety of shipping, the environment and the health of seafarers. Their paper puts the case for adopting the quality provisions detailed in ISO 8217 as part of the requirements of MARPOL Annex VI. The issue has been sent to BLG for consideration.

At present the quality of the fuel supplied is regulated on a national basis. In practice, almost all marine fuel ordered and supplied worldwide is contracted to meet the requirements of one of the grades detailed in ISO 8217:2005 and increasingly by its recent replacement, ISO 8217:2010.

IBIA and BIMCO welcome the Norwegian/Intertanko initiative but are concerned that the application of legislation to what has previously been a commercial contractual issue may cause genuine problems in the logistical supply chain by imposing a disproportionate increase in the regulatory and operational burden on ports and ships relative to the anticipated benefits of the proposed legislation.

The ambition of bringing all 23 parameters in the ISO standard together with the additional content of the eight main clauses and 12 annexes may be beyond the scope of a simple addition to MARPOL, especially as some of the provisions of ISO 8217 are incompatible with some of the provisions of the current Annex VI. In other words, to achieve the objective outlined in MEPC 61/4/7 it will be necessary to revise either Annex VI or ISO 8217 2010 or possibly both, and possibly substantially.

An additional potential restriction is that the adoption of ISO 8217 as the overarching control would prevent the use of alternative fuels for ships, which although safe, effective and desirable, do not fall into Clause 1 or Clause 5 of the standard.

IBIA and BIMCO propose setting up a correspondence group to select those parameters and elements of fuel quality which have the greatest impact on safety, environmental pollution and health and which can be readily quantified and assayed at the delivery location. These should be assessed on the basis of delivering a genuine improvement in the control of the identified risk and at a cost which does not discriminate against any suppliers.

We believe, ideally, that pre-testing is a valid addition to delivery routines as it will provide increasing transparency in the supply chain. Consideration must also be given to the potential for contamination of the product subsequent to pre-testing during transportation and storage on board the receiving vessel.

IBIA and BIMCO propose that the correspondence group should make recommendations on the establishment of a pre-testing regime for marine fuel prior to delivery to a vessel after considering the following:

• An acceptable routine for pre-testing fuel quality as delivered and assessing the potential for contamination of the product post-testing during transportation and storage on board the receiving vessel.
• The impact of the pre-testing routine on current supply chain logistics in terms of efficiency, cost and effectiveness.
• Stricter enforcement of Regulation 18 of MARPOL Annex VI: in particular the requirement for specific criteria for bunker suppliers’ operational procedures for the delivery of fuel to vessels; registration of bunker suppliers and the availability of such registers.
• Port authorities’ response note of protest the supply of noncompliant fuel and the practical consequences of a ban on blending bunker fuel on board supply barges.
• Establishing a definitive list of parameters which have a direct and measurable impact on the safety of shipping, the environment and the health of seafarers.
• Any possible positive effects of harmonising shore-side and marine specifications for gas oil in respect of parameters such as flash point, with the aim of enhancing and simplifying compliance.