Bunkering operations are governed in general terms internationally
by the IMO’s MARPOL Annexes I & VI. SOLAS Chapter VI Regulation
5.1 also requires that a Material Safety Data Sheet be provided for
oil products carried on board ships. In addition to the IMO regulations, many states, and even individual ports, have their own regulatory regimes covering bunkering operations. It is of paramount
importance that prior to commencement of any bunkering operation, a check is made with the local agent and/or bulk supplier for
information and guidance pertaining to the local regulations.
The MARPOL Annex VI sulphur limits and application dates are as
• 1 July 2010 – Sulphur cap in Emission Control Area’s (ECA’s)
reduced from 1.50% to 1.00%
• 1 January 2012 – Global sulphur cap to be reduced from 4.50%
• 1 January 2015 – Sulphur cap within ECA’s to be reduced to
• 1 January 2020 – Global sulphur cap to be reduced to 0.50
There are two types of bunker fuel oil: • Residual fuel – available in varying viscosities and high and low sulphur variants • Distillate fuel - marine diesel & gas oil Residual fuels are a mix of refinery residual fuel and distillates blended to meet specification requirements. Distillate Fuel (which is product obtained by condensing the vapours distilled from petroleum crude oil or its products) comes in two variants and again, both are available with varying levels of sulphur content: • Marine Gasoil – (MGO) clear and not containing any residual component • Marine Diesel Oil – (MDO) essentially a distillate fuel which may contain a small amount of residual component.
Health, Safety, environmental protection SOLAS Chapter VI Regulation 5-1 requires that a Material Safety Data Sheet (MSDS) for MARPOL Annex I type Cargoes and Marine Fuel Oils shall be provided to the ship by the supplier prior to loading or bunkering; this is to assist shipboard personnel in carrying out their duties under safe conditions. MSDSs might include the following warnings and guidance: Fuel oil and vapours may: • Ignite • Cause dizziness and headaches • Contain hydrogen sulphide which is highly poisonous • Harm or cause irritation to skin • Irritate the mouth and lungs Precautions: • Never enter an enclosed space not approved as safe for entry • Stand to windward when opening tank lids or sampling points • Use goggles • Wear suitable gloves • Wear suitable working protective clothing • Change out of any oil-soaked clothing as soon as possible
Fire Precautions: • Keep all bunker fuel away from naked flames, sparks or other sources of ignition • Keep all bunker fuel away from heated surfaces
• Do not smoke on deck during bunkering operations • Do not smoke near fuel tanks, or other locations where fuel vapours may be given off Safety and Environmental Protection: • Know and use the appropriate Safety Management System checklists and procedures for bunkering, and if applicable, for Ship to Ship operations • Know the ship’s Shipboard Oil Pollution Emergency Plan (SOPEP) or Shipboard Marine Pollution Emergency Plan (SMPEP) • Ship’s oil spill equipment is to be ready and available in accordance with the SOPEP/SMPEP • Ensure that proper lines and means of communication internally and externally are established prior to commencing operations, including particularly agreement on how ship stop or supplier stop instructions will be given, acknowledged and implemented • Any spill in connection with a bunkering operation must immediately and in accordance with the SOPEP/SMPEP be reported to the appropriate bodies, including but not limited to: o Port Authorities o Port State Authorities o Owners/Operators/Managers o Ship’s P&I Club o Oil Spill Contractors/Qualified Individual, if applicable o Ship’s Flag State
Planning for a bunkering operation The following points should be covered in the on board procedures of the vessel however and are restated here for the sake of clarity.
Prior to bunkering the staff and crew involved must be aware of: • The quantity and grades of fuel to be received. • The method of delivery (pipeline, barge or road tanker). • The tanks and pipeline systems on board that will be used during the operation, • The order in which the tanks will be filled. • The anticipated pumping rate and duration of the operation. • Who will be responsible for each aspect of the bunkering. • All involved should review the appropriate requirements of the vessel SMS and SOPEP or SMPEP.
Monitoring and watch-keeping As with all shipboard operations, monitoring of the operation and watch-keeping is to be carried out in accordance with the Safety Management System, Ship Security Plan and good seamanship taking into account the prevailing conditions on board and in the vicinity of the ship. There should be a minimum of one deck watch and one engine-room watch on duty at all times overseeing the: • Safe access between shore or ship to ship • Bunker transfer connection • Bunker transfer progress (transfer rate, in order to avoid overfills, bunkers received versus capacity and agreed quantity to be received on board, estimated time of completion, etc.) • Sampling
Record keeping All events and operations are to be carefully entered in both the Deck and Engine log books respectively and checks made that the appropriate entries in the Engine Room Oil Record Book are also made
• Bunker system maintenance and testing • Pre-arrival checklist • Bunker loading plan • Bunker start-up and completion times • Sounding/ullage records • Bunker measurement calculations • Bunker tank gas readings • Compliance with SMS, SSP, inclusive procedures and best practices • Completed bunker checklists • Record book entries (deck, engine and scrap log books) • Oil record books • All bunker-related communications and exchange of documents including: o Bunker Delivery Note (BDN) o Letters of Protest o Fact Sheets o Sounding reports and measurement calculations sheets o Bunker Quality certificates o Bunker receipts o Sample distribution and records should be carefully completed, checked, forwarded and filed as appropriate.
• Procedures In ports which are not in a state which is party to MARPOL Annex VI the suppliers sampling procedure may not be in accordance with that detailed below. The suppliers may chose to follow good practice as detailed below but this will be a matter controlled by the regulations in that port and the commercial agreement between the seller of the fuel and the buyer of the fuel. A continuous drip sample is to be taken throughout bunkering at the closest available sampling point to the receiving ship’s bunkering connection/manifold agreed between the supplier’s and receiver’s representatives. • The sampling equipment, including a sampling container, is to be checked for proper cleanliness and operation. • Prior to commencement of bunkering, proper sealing of sampling container and needle valve are to be agreed upon and properly recorded. • Sampling is to start simultaneously with the bunkering; if necessary, the needle valve must be adjusted to produce appropriate sample flow. • If the sampling container is changed during bunkering, the new sampling container and needle valve must be re-sealed; all sample seal numbers must be recorded. • Continuous checks of the sampling container and needle valve seals are to be carried out. • After completion of bunkering, both the supplier’s and receiver’s representatives are to verify and witness the condition of the seals before breaking the seals. • The sampling container is to be shaken in order to promote homogeneity of the sample. • The sample is to be poured into 4 or 5 sample containers. • Sample containers are to be sealed with uniquely-numbered seals. • Sample labels are to be checked against the uniquely-numbered seals. • Both the supplier’s and receiver’s representatives are to sign the sample labels.
• Sample labels are to be pasted on the sample containers in the presence of the supplier’s and receiver’s representatives. • All seal numbers are to be recorded on the sample labels and in the Bunker Delivery Note (BDN). • The BDN is to be signed and countersigned by the supplier’s and receiver’s representatives respectively. If the vessel is enrolled in a fuel testing programme additional samples will be required over and above the statutory samples; these additional seal numbers should also be included on the BDN. It is important to remember that in the event of a dispute the samples may be required as evidence in a court of law
Minimum information for a Sample label: • Name and IMO number of the receiving ship • Place or port of bunkering • Name of bunker supplier • Name of bunker carrier (barge, tanker, truck or installation) • Grade of bunker fuel • Date and time delivery commenced • Sample method used to obtain representative sample • Location at which sample was drawn • Name and signature of the supplier's representative • Name and signature of the receiver's representative • Seal number (and also cross-checked with BDN)
Caution • Do not sign any sample seals or labels prior to completion of the bunkering
• Do not sign extra seals or sample labels • Do not sign as having received any samples without witnessing the origin of them • Always re-check the condition of seals and recorded seal numbers prior to signing the BDN • If the receiving ship is only provided with samples of unknown origin and/or samples which have not been witnessed, such samples and associated documents should be stamped and/or marked and/or signed “sample [or samples if more than one] origin unknown, signed without prejudice to acknowledge receipt only” and a letter of protest issued to that effect. • The samples given to the vessel should be stored in a safe place and retained for a period (usually at least 3 months) before safe disposal. Individual vessel operators may require the samples to be retained for a longer period • The requirements for the MARPOL sample are more stringent, these must be retained for a period of 1 year, either on board the vessel or at a location which is “under the ships control”
Testing It is common to have the supplied bunkers tested by an appropriate laboratory before use on board in order to be confident that the bunkers are within the agreed specifications and do not contain any substances that might diminish performance, increase wear and tear of the ship’s engines or otherwise cause harm.
Laboratory testing is also used to ensure compliance in MARPOL Annex VI’s Emission Control Areas and with local regulations requiring the use of low sulphur fuels. It is recommended that any indication of sulphur levels above 4.5 % or 1.0 % respectivelyshould initiate a notification to the flag administration, bunker port administration and supplier according to the requirements of the IMO Port State Control Guidelines for MARPOL Annex VI as set out below: The Port State Control Officer (PSCO) should check whether the quality of fuel oil used on board the ship conforms to the provisions of MARPOL Annex VI regulations 14 and 18*, taking into account appendix IV to the Annex. Furthermore, the PSCO should pay attention to the record required in regulation 14(6) in order to identify the sulphur content of fuel oil used while the ship is within SOx emission control areas, or that other equivalent approved means have been applied as required. *It should be noted that in the case where the bunker delivery note or representative sample as required by regulation VI/18 is not in compliance with the relevant requirements, the master or crew should have documented that fact. Where fuel oil supply was undertaken in a port under the jurisdiction of a Party to MARPOL Annex VI, the PSCO should report that non-compliance to the appropriate authority responsible for the registration of fuel oil suppliers in accordance with regulation VI/18(8)(a).
Measurements and quantity If possible, both the supplying ship’s and receiving ship’s designated fuel tanks for the bunkering operation should be measured and surveyed before commencement in order for supplier’s and receiver’s representative to agree upon the content and condition of the these tanks. If there is any disagreement related to the quantity, this should form a basis for issuing a letter of protest but it should be noted that suppliers’ terms and conditions generally specifically disallow shipboard measurement in connection with any dispute as to quantity delivered. The tank or tanks should be checked for water by water finding paste dipping or by using a tank bottom sampling device. The water paste if used in HFO, might indicate traces of water and should form the basis of a letter of protest.
Be aware Receiving ship's crew should be alert to the following malpractices: • Shortening or lengthening of measuring tapes used by the supplier • Falsified tank tables for the supplying tank or tanks • Deliberately declaring incorrect densities and temperatures of the delivered fuel or fuels
• Adding water; for example by using the supplying barge’s firepumps or other service-pumps • By adding air to the fuel, the so-called “cappuccino effect” Other less sophisticated methods of reducing the quantity of bunker fuel delivered include unauthorised or concealed piping between the storage tanks and other un-nominated tanks, such as coffer dams or void spaces.