Elements of New IMO BDN Amendments "Problematic," Says IBIA

IBIA has called certain elements of the tick box system and text of the new BDN "problematic."

The International Bunker Industry Association (IBIA), following last week's approval of amendments to the bunker delivery note (BDN) by the International Maritime Organization (IMO) at the 70th session of the Marine Environment Protection Committee (MEPC 70), has called certain elements of the tick box system and text of the new BDN "problematic."

IBIA says it understands and supports the purpose of the BDN amendments, which are intended to allow for situations when a ship is entitled to use fuel that exceeds the set sulfur limits for marine fuel because it can achieve compliance by equivalent means by using approved abatement technology, or has an exemption.

IBIA presented a paper offering a number of changes to the proposed amendments that it said would make the new tick box system "simple, clear and unambiguous," as well as changes to the text from the third tick box, which it calls "overly complex and potentially misleading."

However, despite IBIA's concern over some aspects of the amendments, proposals for changes are said to have been disregarded.

"It appeared as though the decision was a 'done deal' with nobody wanting to take time to understand or accept our proposed improvements to elements in the new BDN document," said Unni Einemo, IBIA's IMO representative, adding: "as a result, we are now stuck with a rather unsatisfying format of the supplier's declaration that lends itself to mistakes and misunderstandings. I'm disappointed all our hard work failed to have the desired impact."

IBIA notes that, upon the MEPC chair opening the floor for comment, three major shipping organisations spoke against IBIA's proposal, stating they could not support the alternative text as it would put responsibility to the ship instead of the supplier and increase the administrative burden on the ship.

Three member states also said they could not support IBIA's proposal, explaining that they believed amendments developed by PPR 3 to be adequate, and that the subject had already been discussed for too long, requiring conclusion without further debate.

"Clearly, the shipping organisations did not listen to the introduction of the paper where Einemo specified that text that they were concerned about may in fact be superfluous," said IBIA, adding that it "was not given the chance to respond after their statements to clarify this point, and the chair concluded that the format sent to MEPC 70 from PPR 3 was approved."

Last month, U.S. and Canada-based Vortex Development Group (Vortex) said it was ready to formally launch its Digital Bunker framework, a suite of tools aimed at digitising delivery paperwork in the bunkering industry.