FOBAS Alert: Off-Specification Sulphur Results for ECA Fuels at Antwerp

by FOBAS
Monday July 31, 2017

In the last week FOBAS has tested a number of ISO-F-DMA samples bunkered at Antwerp in which, based on single test result, the sulphur contents determined exceeded the limit of 0.10 % m/m required for Emission Control Area for SOx (ECA – SOx) operations.

Advised bunker details from respective Bunker Delivery Notes (BDN) as well as FOBAS quality analysis indicate these samples originate from a single batch of fuel during this period. The tested sulphur content of these samples ranged from 0.16% m/m to 0.22% m/m. Rechecks have been carried out on all such samples which confirmed the off specification sulphur results.

For ship operators, once the sample collected from ship manifold turns out to be off specification, second step should be to analyse a representative sample provided by supplier. At this point it should be noted that supplier sample should only be considered representative if same was collected as continuous drip sample during the course of bunker transfer.  As per ISO 4259, sample provided by supplier should be classed as off specification if test result is in access of 0.10 % mass. This means that as per ISO 4259, for supplier sample 95% confidence limit do not apply. 

Any ships receiving fuels that are confirmed noncompliant fuels should immediately issue a letter of protest to the relevant fuel supplier, flag administration and port authority for their further advice regarding the usability of such fuels. MARPOL sample and related documentation should be kept in safe custody for any further investigation by relevant authorities.  As per IMO guidelines (MEPC 182(59)) MARPOL sample should be collected at the receiving ship manifold as a representative sample during the bunkering process witnessed by all parties.

In view of the multiple off specification results from Antwerp, if your ships are planning to bunker in that region, we recommend that suppliers are advised of your concerns regarding the sulphur content of the fuel in the area, and that they provide you with additional reassurance that they will adhere to the ISO 8217 and ECA – SOx requirements for the grade ordered.

Additional attention should be given to the collection of bunker samples. It should be ensured that all parties have witnessed the sampling process and have signed witness forms accordingly, and that the supporting documentation includes records of all the samples considered representative of the fuel as loaded.

By Chris Manuel
FOBAS Specialist
e-mail : Chris.Manuel@lr.org