MARPOL Annex VI Amendments – Fuel Oil Sampling Points

The 75th session of the IMO’s Marine Environment Protection Committee (MEPC 75) approved amendments to MARPOL Annex VI on procedures for sampling and verification of the sulphur content of fuel oil including definitions of MARPOL delivered sample, in-use sample and on-board sample. The MARPOL amendments published under Resolution MEPC.324(75) and shall enter into force on 1 April 2022.

MARPOL delivered sample means the sample of fuel oil delivered in accordance with regulation 18.8.1 of Annex VI. The amendments within Appendix VI of Annex VI introduce a revised verification procedure for determining whether the fuel oil delivered on board a ship has met the applicable sulphur limit of regulation 14. Operators are reminded that Resolution MEPC.182(59) provides an agreed method to obtain a representative sample of the fuel oil for combustion purposes delivered for use on board ships. The results of the test method shall be equal or below the applicable limit % m/m 0.1 or 0.50.

On board sample means a sample of fuel oil intended to be used or carried for use on board that ship. An agreed method for the purpose of taking representative samples from tanks is provided by MEPC.1/Circ.889 the “2020 guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship”.
In order to take a fuel oil sample direct from a tank, consideration should be given to the use of a specialist service provider having the appropriate sampling equipment, such as that given in ISO 3170:2004, and the expertise necessary to obtain the required sample in a safe and competent manner.
Sampling may alternatively be undertaken from the sounding pipe of a tank by means of a suitable sampling arrangement. When sampling from a sounding pipe, the design of that sounding pipe and the recent filling history of that tank should be considered to assess the relationship of the fuel oil in the sounding pipe to that in the associated tank.

In-use sample means a sample of fuel oil in use on a ship. Sampling point(s) shall be fitted or designated for the purpose of taking representative samples of the fuel oil being used on board the ship taking into account MEPC.1/Circ.864/Rev.1
“2019 Guidelines for onboard Sampling for the Verification of the Sulphur Content of the Fuel Oil Used onboard Ships”

• New ships: For ships with a keel laying date after 1 April 2022, the sampling point(s) shall be confirmed at the initial IAPP survey.
• Existing Ships: For ships with keel laying date before 1 April 2022, the sampling point(s) shall be fitted or designated not later than the first IAPP renewal survey on or after 1 April 2023.

Note: For in-use and onboard samples, the results of the test method shall be equal or below the applicable limit % m/m 0.1 or 0.50 plus 0.59R (where R is the reproducibility of the test method). Therefore, the test margin value is 1.11 and 0.53 respectively.

A plan identifying the fuel oil sampling points is required to be submitted for approval for vessels constructed before 01 April 2022, where modifications of the fuel oil piping system are intended to be carried out. The proposed modifications of the fuel oil piping system are to be submitted to the ABS plan approval office for review. The location and arrangement of the fuel oil sampling points are to be in accordance with paragraph 2 of MEPC.1/Circ.864/Rev.1:

1. be easily and safely accessible
2. take into account different fuel oil grades being used for the fuel oil combustion machinery item
3. be downstream of the in-use fuel oil service tank
4. be as close to the fuel oil combustion machinery as safely feasible taking into account the type of fuel oil, flowrate, temperature, and pressure behind the selected sampling point
5. be clearly marked for easy identification and described in either the piping diagram or other relevant documents
6. each sampling point should be located in a position shielded from any heated surface or electrical equipment and the shielding device or construction should be sturdy enough to endure leaks, splashes or spray under design pressure of the fuel oil supply line so as to preclude impingement of fuel oil onto such surface or equipment
7. 7. the sampling arrangement should be provided with suitable drainage to the drain tank or other safe location.

The number and location of the fuel oil sampling points is to be confirmed by the attending ABS surveyor and will be reflected on the Supplement of the new IAPP Certificate issued on completion of the Survey.
Note: The requirements above are not applicable to a fuel oil service system for a low-flashpoint fuel.