World Bunkering > News > Winter 2010 > Pre-testing issue raised

IBIA sent out an e-mail to its members on 14 October asking for their views on a joint Norwegian government/Intertanko paper presented to IMO’s Marine Environment Protection Committee (MEPC) at its recent meeting, which raised the possibility of the mandatory pre-testing of bunkers.

The Norwegian/Intertanko paper commented on a submission by ISO, which consisted of the revised ISO 8217 and asked MEPC to “address and discuss the need to improve proper control on marine fuels prior to being delivered to ships”. It added: “The question is whether the only retro-active assessment of fuel quality by the shipowners after the fuel is delivered to ships is adequately responding to the Committee’s aims to secure safety of ships and crews and to achieve environmental protection. In this regard, the Committee may wish to consider whether there is a need for mandatory requirements to ensure fuel oil quality prior to it being delivered to the ship.”

At MEPC IBIA made an immediate response, saying: “IBIA and its members are committed to the continuous improvement of the efficient and effective, and safe, performance of marine fuels on board ships. We are also fully supportive of any mechanism which can make a genuine contribution to safety, and to mitigate damage to the environment. However, we feel that routine quality of fuel supplied is a commercial issue between buyer and seller.

Regulation should be targeted at the issues of sulphur emissions, flashpoint, H2S and any deleterious materials as covered by clause 5 of ISO 8217. The matter raised by Norway and Intertanko is not as simple as portrayed, however it may appear to members of this committee. We believe that legislation should not unduly restrict the adoption of non-traditional fuel sources which may help reduce pollution and improve the use of resources. IBIA is keen to cooperate with IMO in moving this issue to a practical solution”.

The issue has now been referred to IMO’s Bulk Liquid and Gases (BLG) subcommittee for further discussion. An IBIA Committee meeting has decided to invite comment from its membership in order to further develop a position on pre-testing prior to the BLG meeting.

A subsequent Intertanko Council meeting in Singapore made clear the tanker owners’ group’s determination to see mandatory pre-testing of bunkers come into force. A statement said: “The Council has empowered Intertanko to renew its campaign for effective mandatory quality control of bunkers prior to delivery to ships, since there is currently no mandatory system to control compliance with statutory requirements.” Intertanko is calling for control of specific criteria defining bunkers. It is seeking to:

• ensure that bunkers meet contractual requirements prior to delivery;
• ensure that bunker suppliers take corrective action in case of an off-spec delivery;
• provide clarification on responsibility to ensure that bunkers delivered meet the criteria.

The Council was also supportive of a suggestion that bunkers should be delivered fully fit for use on board ship. Intertanko says impurities could be removed at the refinery rather than requiring the ship to do that job on board. “This,” Intertanko argues, “could help ships attain a potential zero operational pollution.”

By the time Sibcon took place there was relatively little awareness of the issue among IBIA members. However, a number of suppliers and others involved in the regulatory and testing aspects of bunkering raised doubts about the practicality of the proposals. It did appear that Intertanko’s view was substantially based on the Singapore regulatory approach, which does not allow blending on the barge. World Bunkering asked a spokesperson for a major manufacturer of blending equipment whether the proposal would mean the end of blending on barges. He replied: “Not necessarily.”

He did, however, agree that a lot would depend on the exact wording of any new requirement. DNVPS managing director Tore Morten Wetterhus gave World Bunkering his detailed assessment of the proposal. He said: “Pre-testing can be a part of the bunker supplier’s product quality assurance process, but it does not always guarantee that the fuel quality delivered to the receiving vessel will accord with the pre-testing results. The conditions of delivery pipelines as well as sampling methods and locations are among the factors which can respectively influence fuel quality and the representativeness of the fuel samples used in the pre-testing.

“If we consider the multi-party involvements in a typical bunker supply chain, oil majors may for instance sell their products to independent suppliers whose cargoes are then delivered by contracted barge operators to the receiving vessels. The quality of products pre-tested at the original source may change as they move along the supply chain, possibly because of poor ‘house-keeping’ or wilful adulteration. Should this happen, the fuel quality finally delivered to the receiving vessel will differ from that of the pre-tested products at the original source.

“Whenever cargoes ‘change hands’ in the bunker supply chain, testing the fuel samples taken at the point of custody transfer will help determine the product quality delivered and received. This may create an audit trail and add greater transparency to the supply chain, in turn pre-empting quality disagreements between any parties. Some may argue that this proposal will add to the cost of bunker products, but realistically speaking, the extra expenses are minuscule compared to the overall value of the bunkers.

“Between the final supply party and the receiving vessel, the testing of custody transfer fuel samples is especially crucial as the receiving vessel will be consuming the delivered bunkers and therefore faces the attendant risks of operational challenges, engine breakdowns, environmental pollution and compromises to the safety of crew and cargo on board.

“From this perspective, DNVPS does not support the sole reliance on pre-testing as an effective means of ensuring correct product quality.” “Moreover, the testing of custody transfer samples (taken at the receiving vessel’s manifold) will also manifest the receiving vessel’s accountability for the fuel quality received, especially in the event that new and on-spec bunkers received are stored in tanks containing existing quantities of bunkers of unknown quality.”

Another major figure on the fuel testing scene commented: “Pre-testing is not for the faint-hearted.”