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Complying with Emission Control
Confusing USA Environmental Regulations  
Owners’ duties - New low sulphur emissions in ECAs
Using hybrid fuels for ECA-SOx compliance - Operational guidance for shipowners and operators
Managing our bunkers

Complying with Emission Control 

Hongjung Sun
Marine Claims Manager
Team Asia

MARPOL ANNEX VI sets the limits on sulphur oxide (SOX) and nitrogen oxide (NOX) emissions from a ship’s exhausts, and prohibits the deliberate emissions of ozone-depleting substances. It also contains provisions that allow member states to establish special SOX Emission Control Areas (SECAS) where more stringent sulphur emission controls would apply. As of February 2011, a total of 60 countries have ratified Annex VI. 

Local regulation regarding the penalty for non-compliance 

Following Annex VI coming into force, member states have adopted strict measures to control emissions, penalizing crew or shipowners for reckless or negligent violation, or non-compliance. In the Netherlands, the authorities may detain ships in violation of emission controls until compliant sulphur fuel has been supplied. In Italy, the fine for non-compliance of sulphur requirement at berth may be imposed in the ranges from EUR 15,000 to 150,000. In practice the port authority in Italy normally imposes a fine of double the minimum, or a third of the maximum for a first time offender.  

In Shanghai, a new anti-pollution regulation took effect from 1 June 2015. Violators will be fined between 10,000 and 100,000 Yuan according to the new regulation. In Hong Kong, the Air Pollution Control Regulation came into force on 1 July 2015. A person who commits an offence is liable on conviction to a fine of HKD 200,000, and to imprisonment for six months. Similar regulations were also established and published in many other countries.

Risks accompanying the compliance 

In most cases so far reported, loss or damage occurs in the following circumstances: 

  • Engine stoppage or equipment damage due to improper operation of the changeover from fuel oil to low sulphur oil;
  • Laboratory test shown the fuel oil in use at berth or ports or SECAs is non-complainant due to incomplete changeover, which leads to high sulphur fuel residue existing in the system. This also mostly involves an operation problem;
  • Incorrect or incomplete entry in the log books regarding the oil changeover, which leads to a penalty by the port authority. 

Make compliance safely 

For the avoidance of loss or damage arising out of the associated operation for compliance,

Firstly, owners should be well aware of their duty to make their ships technically suitable to run on the low sulphur oil (seaworthiness). Some modification for the burning apparatus might be necessary on some low standard vessels in this regard;

Secondly, owners need to work out a set of specific and applicable operation procedures, i.e. a fuel oil changeover manual for each single ship to safeguard the oil changeover operation. A practicable fuel oil changeover manual should contain detailed changeover procedures. If engine crews follow the procedures closely then the risk of violation can be substantially reduced. Compared to the standard practice of changeover between heavy fuel oil grades, changeover from heavy fuel oil to marine gas oil is completely different. Precautions should be taken and technical skills are required to prevent gassing of gas oil in the system, which can easily cause abnormal airlock in the fuel oil supply system, and leads to engine stoppage. When this happens it can have serious consequences. This Association had a major RDC/FFO claim when an entered ship had contact with a terminal and a ship along the berth due to a stoppage of the main engine causing the vessel to lose control in the process of the fuel oil changeover. The changeover manual could have guided the engine crew to make a smooth changeover operation.

There are some templates of the manual readily available on the website It should be noted that ship managers should tailor the manual to fit each and every respective ship with reference to the actual condition of the ship itself, including, but not limited to, the tank specification and arrangements, pipe lines for fuel oil transfer and supply system, as well as specific bunker consumption under different loads etc. 

Normally, low sulphur oil is required when the ship is along the berth or sailing within SECAs. Obviously the owners would not like to burn more low sulphur oil than necessary due to obvious economic considerations, as low sulphur oil is more expensive. Therefore the changeover should normally take place just before the vessel reaches the berth or comes across the boundary of SECAs. The engine crew should also ensure that the fuel supply system has been completely filled with low sulphur oil as soon as reaching the berth or coming within the boundary of SECAs. This can be achieved by following the manual.  As to how to maximise the saving of low sulphur oil, the engine crew should reference the “Changeover Calculator”, e.g. FOBAS etc., for calculating times. This is also available on the website

Thirdly, provide training for engine room crew members on fuel oil changeovers;

Lastly, maintain a complete record or log entry including any other relevant documents covering the changeover operation.

Deal with non-intentional violation

In case there is a violation, owners and ship managers can rely on the fuel oil change
over manual and proper entries in the ship’s logbook recording the changeover operation in mitigation of penalties or fines. The manual and logbook can be good evidence to show that the owners and managers have tried to exercise due diligence to comply with the convention.


Confusing USA Environmental Regulations 

David J. Farrell, Jr.
Admiralty Attorney
Farrell McAleer & Smith LLP
Cape Cod, Massachusetts, USA       

Because of the USA’s geographic expanse, and its multiple governmental entities’ concurrent or overlapping jurisdiction in maritime and environmental matters, it is impossible to concisely summarize the various laws and regulations that impact a ship in USA waters. But there can be no doubt that due to applicable international treaties, USA federal laws (sometimes inconsistently enforced by different federal agencies), and widely differing laws among the 50 individual states that shipowners and operators face a target filled radar screen in USA waters.

A good example is the Act to Prevent Pollution from Ships (“APPS”), 33 U.S.C. §§ 1901 et seq., which is the USA law that implements MARPOL, the International Convention for the Prevention of Pollution from Ships. Under APPS, the USA has concurrent jurisdiction with the foreign-flag state over any foreign-flag ship operating in USA waters. 

But there are two different USA agencies charged with enforcing APPS, first the US Coast Guard and second the US Environmental Protection Agency. Generally speaking, the US Coast Guard in conjunction with its onboard inspections verifies compliance with MARPOL’s regulations whereas the US Environmental Protection Agency enforces MARPOL violations. 

Those different functions can be significant: While the US Coast Guard is able to recognize the importance of maritime commerce as part of its broad mission, the US Environmental Protection Agency’s narrower focus on the environment alone can result in harsh treatment of commercial violators – including ships.

 Greenhouse Gas Regulations 

Under MARPOL Annex VI and APPS, fuel oil with ultra-low sulfur (“ULS”) content of 0.10% is now required on all ships (unless exempted under Annex VI) operating in the North American and US Caribbean Sea Emission Control Area (“ECA”).  

US Coast Guard – compliance verification 

The starting point for ULS compliance in USA waters is a US Coast Guard March 10, 2015 Marine Safety Bulletin, available at

The Marine Safety Information Bulletin emphasizes that foreign-flag ships are subject to examination under Port State Control by the US Coast Guard while operating in the ECA (200 miles from the USA coast or 50 miles from the USA Caribbean coast).  Ships found in violation of Annex VI will be detained and can have their customs clearance revoked; clearance will then be granted only when the deficiency is resolved and an LOU or approved security is posted for the maximum penalty amount.

The US Coast Guard also cautions it is aware that loss of propulsion can occur during ULS changeover so the Marine Safety Information Bulletin recommends that “advanced planning and preventive maintenance are critical” beforehand.  As well, owners and operators are reminded under SOLAS to obtain “approval prior to operating with 0.10% fuel sulfur that has a flashpoint of less than 60 degrees Celsius.”

US Environmental Protection Agency – enforcement of violations

Despite these mechanical risks, a ship’s full compliance with the ULS requirements in MARPOL Annex VI and APPS is clearly the best practice. A January 15, 2015 penalty policy memo outlines civil fines the US Environmental Protection Agency can assess for violations.  See

Hope that you never have to read it. The penalty policy memo details factors that allow for fines up to USD 25,000 per day, based on the gravity of the violation, with a goal of deterring violations by removing any economic benefit from noncompliance. There is also a discussion of factors that could double or otherwise increase fines (such as poor record keeping or repeated noncompliance) or could reduce fines (such as cooperation). Revealingly, a fill-in-the-blank “Penalty Worksheet” demonstrates the US Environmental Protection Agency is ready to pounce when a violation occurs.

Ballast Water Regulations

USA ballast water regulations include a complicated set of legal standards which are evolving to accommodate emerging ballast water treatment technologies. Rules now in place and vague policy statements by the agencies have laid a confusing mine field. For example, a Panamanian container ship in Seattle, at this writing, has been detained by the US Coast Guard for failing to send required ballast tank information to the National Ballast Information Clearinghouse, among other violations.

US Coast Guard Ballast Water Regulations 

Perhaps the best starting point is the US Coast Guard’s ballast water website, It summarizes the essential point that unless a ship is equipped with a US Coast Guard approved Ballast Water Management System, in USA waters ballast water can neither be taken on unless the water comes from a USA public water system nor discharged except to an approved treatment facility.

US Environmental Protection Agency – unnecessary duplication 

Adding confusion, the US Environmental Protection Agency also regulates ballast water discharges through its Vessel General Permit (“VGP”) program; see, claiming in a December 27, 2013 memo that it recognizes the need for a “coordinated response” with the US Coast Guard: 

As part of the regular coordination between EPA and the Coast Guard as co-regulators of ballast water discharges, the provisions of the 2013 VGP and Coast Guard requirements for ballast water were intended to work in tandem.

But why in the first place was there any need for tandem coregulation by two USA agencies?  As might be expected, the two agencies’ implementation of their overlapping responsibilities resulted in inefficiency, making compliance by ships unnecessarily complicated, confusing, and costly. 

The December 27, 2013 memo on the one hand notes the US Coast Guard “has indicated that, on a case-by-case basis, it may determine ‘that despite all efforts to meet the ballast water discharge standard requirements,’ it is necessary to issue a temporary extension….”  This indicates the US Coast Guard’s willingness to work around practicalities faced by the maritime industry. 

But on the other hand the same December 27, 2013 memo states the US Environmental Protection Agency “reserves the right to act at variance” from its own policy and to even change policy “at any time.” The memo, in other words, provides the maritime industry zero predictability on how the US Environmental Protection Agency will enforce its policies on a case-bycase basis. 

A congressional resolution? 

Aggravating the confusion, 25 individual states – in addition to the US Coast Guard and US Environmental Protection Agency – have issued their own ballast water discharge regulations which can be even stricter. This has created exactly the type of inconsistent, regulatory nightmare that a uniform body of maritime law is supposed to avoid. 

Currently the US domestic shipping industry is urging Congress to impose one uniform national framework for the regulation of ballast water discharges, to replace the patchwork of inconsistent regulations that now exist. We can only hope this sensible approach will appeal to elected officials.


Owners’ duties - New low sulphur emissions in ECAs 

Dimitra Chourdaki
Assistant Claims Executive, FD&D
Team Gothenburg

MARPOL ANNEX VI aims to reduce air pollution from a vessel’s exhaust gasses. In particular, Regulation 14 states that ships trading in Emission Control Areas (ECAs) have to use fuel oil with a sulphur content of no more than 0.1% from 1 January 2015. The established ECAs are the Baltic Sea, North Sea, North American Coastline and US Caribbean. The idea of introducing such a requirement has been known for quite some time, but in the current difficult market, some owners have not prepared their vessels accordingly, thus facing the risk of significant penalties. 

Current situation and position of owners 

The compliance problem for owners is twofold, depending on whether they or their time charterers are providing the fuel. For owners paying for their own bunkers, the question is which type of ULSFO (ECA-compliant fuel) is the most economical solution depending on the circumstances and the required investment. In this case, non-compliance will most probably result in costly fines, with the owners having only limited defences at their disposal.

The issue is however more complicated for owners with vessels in time charter where charterers provide the bunkers. The question is then whether owners have done enough to comply with their charterparty obligations. To what extent owners have to comply with the regulation in cases where there is limited or no capacity for ECA-compliant fuel tanks on the vessel? Does the obligation under the MARPOL extend to retrofitting or making physical modifications to the vessel? 

Obligations under the time charters 

Under the time charters there is a general obligation on charterers to provide fuels that are suitable for the engines fitted. Does this obligation “protect” owners and allow them to keep burning the already existing fuels? Can ULSFO be rejected because extraordinary steps need to be taken in order to burn it? Can it then be argued that this fuel is not suitable as described in the charterparty? The answer is no. 

Owners are obliged to make all necessary modifications 

Owners are invariably obliged to provide “at the date of delivery and throughout the charterparty” a vessel that is “in every way fitted for the service” (see the NYPE and SHELLTIME 4 form for example). Accordingly, a vessel that cannot burn ECA-compliant fuel is not fit for trading on a worldwide scale and cannot follow Charterers’ orders to proceed into any of the ECAs. Owners will then find themselves in breach and liable to pay damages. So, owners are obliged to make all necessary modifications to the ship (re-structuring pipes, extensive cleaning of current HFO tanks, etc) so that she can burn ULSFO, thus rendering her again fit for service. 

There have been theoretical discussions about whether an owner’s duty to provide a vessel fit for service “at the date of delivery and throughout the charter period” is considered absolute and continuing no matter what happens during the charter. It is thought by many that this would involve owners in obligations much higher than those taken on when they signed the charter, or than the normal obligation to “exercise due diligence to maintain or restore the ship”. However this was not the view taken by the English Courts.

Recent case law 

In “The Elli and The Frixos” both vessels were single-hulled, as opposed to the new MARPOL regulation, which required that fuel oil could only be carried in double-hulled vessels. The Court of Appeal held that the wording of the clause 1g) of the Shelltime 4 Form should take precedence, therefore “the ship shall have on board all certificates and documents required from time to time by any applicable law” – and not only at the date of delivery, as it is stated in the headline. Based on this reasoning, there are indications that owners are obliged to alter the vessel and make such modifications as are necessary in order to comply with changing regulations. It remains to be seen whether the case will be followed also in the future.

IMO expects owners to comply 

It is worth noting that some shipping companies have managed to receive funding from the European Union in order to make the necessary changes to their vessels. At the end of the day, IMO expects owners to comply. Although the question of who should bear the costs for such modifications to the vessel does not have a straightforward answer, it is likely that the responsibility will rest with the owners; the vessel has to comply with international regulations and inevitably any fine will be addressed to the ship. 


Using hybrid fuels for ECA-SOx compliance - Operational guidance for shipowners and operators 

With permission from Lloyd’s Register EMEA, we are pleased to provide our readers with an extract from the publication “Using hybrid fuels for ECA-SOx compliance”.  
The publication in full is available at

The revised MARPOL Annex VI regulations limit the sulphur content of bunker fuels used in emission control areas for SOx (ECA-SOx) to 0.10% m/m from 1 January 2015. Although there are alternative methods of compliance, such as alternative fuels (liquefied natural gas, methanol, bio-fuels) and abatement technologies (exhaust gas cleaning systems), their viability is still undermined by logistical, technological, and sustainability factors. Currently, only a few options are mature enough to fully replace residual fuels for main propulsion, so most ships will inevitably opt for distillates – marine gas oil and marine diesel oil – at least for now. 

For ships operating both inside and outside ECA-SOx, this will represent a major change from existing practice, both in terms of the different characteristics of residual and distillate fuel oils and the increased sulphur differential between them.

In an attempt to minimise the operational risks of running ships on distillates, several oil companies have made announcements in recent months regarding new ‘hybrid’ fuels designed to help shipowners navigate the upcoming entry into force of the 0.10% sulphur cap in ECA-SOx. Table that shows the different grades that have been announced publically in the media, see 

Although these new fuel types are designed to minimise the complexities of operation on distillates, their characteristics (particularly the fact that they are blended products of different refinery streams) mean they present specific challenges. This guidance details the available specifications of all such hybrid fuels and details any associated risks in order to assist you in choosing the best option for your vessels.

Storage and handling hybrid fuels on board 

Most of the new hybrid fuels are blended products and have some characteristics of distillate products. This
means they may exert a ‘cleaning’ action, mobilising previously deposited asphaltenic material, potentially leading to increased filter loading and other operational issues. It is therefore recommended that fuel tanks which will carry these new fuel types are cleaned or at least cleared of the ‘unpumpables’ at the tank bottom.

Despite their distillate characteristics, most of these hybrid fuels are particularly waxy in nature, as exhibited by their pour point (the lowest temperature at which a fuel will continue to flow). These fuels therefore need to be stored and handled in systems with heating arrangements should not be stored in tanks which are subject to low external temperatures, such as a ship’s side tanks. Even in tanks with heating coils that maintain the bulk of the fuel as liquid, the formation and then breakaway of material at the cold interface could result in operational problems. 

These fuels will also need to be purified, taking into account their density (gravity disc selection) and viscosity for optimised preheat. Based on the tested viscosity and density of the fuels, the purifier manufacturer’s recommendations should be followed for the correct operational adjustments.

Viscosity and lubricity

Viscosity and lubricity are two of the key challenges that the new hybrid fuels aim to address. When changing over from residual fuel oil to distillates, viscosity has to be carefully controlled (along with the fuel temperature and the risk of thermal shock) in order to maintain sufficient hydrodynamic lubrication film between the moving surfaces of the fuel pump and injectors. 

The new hybrid fuels have good lubricity values and comparatively high viscosities. Therefore, at normal engine room ambient temperatures, they will maintain hydrodynamic film lubrication, eliminating the need for any fuel coolers or chillers. 

Their high viscosity, however, does mean that some heating will still be required (as with residual fuel oil) to bring the viscosities in line with the engine manufacturer’s limit. The manufacturers’ typical viscosity values vary considerably; therefore it is critically important to use the tested viscosity of the fuel for treatment and combustion purposes

Compatibility and stability 

Availability and compatibility with other fuels are critical things to consider when dealing with new hybrid fuel types. The fuel tanks taking on these fuels must be as empty as possible and a compatibility test must be carried out before any attempt is made to mix hybrid fuels with standard fuels. 

Because of their waxy nature, there is a high risk of incompatibility between hybrid fuels and conventional residual fuel oil. Provided that the mixed proportions are at a low ratio, serious issues should not be expected; as always, minimising the quantities involved is a good policy. As standard practice, the fuel should be passed through the ship’s treatment system (purifiers) before use, which means that the fuel will be passed to the settling tank first. Consequently, if a conventional residual fuel has previously been used, the changeover to hybrid fuel must be properly managed and monitored, and should be undertaken in a low-risk location. 

The specification values for sediments and oxidation stability (where applicable) have been found to be low for the new hybrid fuels. However, it should be verified whether there will be any deterioration of the fuel over time or due to extended heating.

During changeover, it is inevitable that the hybrid fuels will be mixed with the fuels already in the system, so the risk of incompatibility still exists. However, because this risk can be fairly accurately predicted (even through onboard tests) and will only occur at the interface between the two fuels, it can be dealt with by closely monitoring the situation.


As hybrid fuels are mainly blended products, the Calculated carbon Aromaticity index (CCAI) value may not reflect the true ignition and combustion characteristics of the fuel. If not provided by the fuel supplier, further information regarding the combustion characteristics of such fuels, for example through a ‘FIA100/FCA’ test data, should be sought for further consideration. Also, the usual relationships used for viscosity index may not be as exact; therefore, the correct injection viscosity should be maintained to achieve efficient combustion.

Changeover procedure 

Changeover procedure Changeover from residual fuels to distillates and continuous operation of engines on low-viscosity distillates are two challenges that the new hybrid fuels aim to address.Hybrid fuels have a high enough viscosity to tolerate the temperature fluctuations within the fuel system during changeover, without going below the minimum viscosity requirement. Care still needs to be taken; if temperatures and corresponding viscosities are not controlled correctly, pump seizure may occur, potentially leading to loss of power – a commonly reported fuel-related problem during changeovers to distillates.

Depending on the hybrid fuel the ship is using, the vessel crew will also need to be cautious about sudden temperature change to avoid any risk of thermal shock, especially when changing over to 0.10% sulphur products. The change of temperature gradient should not be more than 2° C per minute as any sudden changes in temperature can thermally load fuel pumps and/or injectors and cause them to seize.

Because these fuels have solvency and cleaning effects, just like regular distillate fuels, they also tend to carry any sludge and sediments accumulated in the fuel system tanks and pipelines, leading to higher levels of sludge deposition in the early stages of changeover. Attention should be given to the rate of filter blocking during the changeover process.


Availability is an important consideration when using new fuels. It should be ensured that the same product is available in all ports the vessel is calling at, based on the ship’s operating profile. It should also be ensured that the vessel can load and store the right quantity on board to complete its ECA voyage so that no other fuels are needed, thereby avoiding compatibility issues. 


Although the new hybrid fuel types are produced to meet the 0.10% sulphur regulation for use within ECA-SOx, they are complex blends that don’t fit into either the ‘table 1’ or ‘table 2’ grades of the ISO 8217 standard. However, it is strongly recommended that new hybrid fuel types are still ordered against the ISO 8217 specification. This can still be applied, as hybrid fuels are petroleum-derived products. The benefit of using ISO 8217 lies principally in the ‘general requirements’ aspects contained in section 5 of the standard.


Managing our bunkers 

Peter Henney
Marine Consultant, Engineer
Andrew Moore & Associates, Liverpool   

In 2007 the International Maritime Organisation (IMO) completed a study that identified that international shipping emitted 2.7% of the world’s man-made emissions. The majority of these emissions came from ships’ funnels. They elected to take action to reduce emissions through the development and implementation of a program of legislation under MARPOL Annex VI.

Part of the solution is a requirement for reductions in Sulphur Oxides (SOX) and Nitrogen Oxides (NOX) emissions over the coming years. A global reduction in the sulphur content of fuel to 3.5% in 2012 and 0.5% in 2020 (maybe deferred until 2025) together with even tighter limits in Emission Control Areas to 0.1% by 2015, brings about a significant challenge to the shipping industry and the bunker supply chain. 

The industry is also to deliver greater energy efficiency savings with the introduction of more stringent design and manufacturing requirements for vessels, machinery and systems (EEDI) and onboard management of energy usage through a Ships Energy Efficiency Management Plan (SEEMP).  Added to this, although in a current dip, it is expected that the cost of fuel will continue to rise and this is particularly relevant as we increasingly compete for the low sulphur distillates. 

Quantity management 

An issue that can significantly increase running costs and affect the delivery of an accurate and successful SEEMP, is that of poor quantity management.  Apart from the obvious financial loss incurred when there are discrepancies when considering a potential short delivery during loading and/or inflated consumption figures in operation, the measurement of fuel usage and therefore energy consumption can be significantly distorted, whether this is by error or misappropriation of fuel. 

Quality management 

A reported increase in machinery failures, largely attributed to contaminants found in bunkers is also causing concern amongst the maritime and insurance industry. In order to reduce the risk of machinery damage caused by poor quality fuel and/or insufficient onboard fuel management, it is essential that the quality of the fuel is ascertained at the earliest possible stage in the process. 

Therefore the need for a suitable and sufficient bunker fuel management system where quantity and quality management are key components in ensuring plant optimization and machinery protection, cannot be over emphasized. 

Loading bunkers 

The earliest phase in managing bunker quantity and quality once the supplier has been identified and a suitable delivery port arranged, is prior to the arrival of the supplier. It is essential that the vessel has adequately prepared for loading. Where practicable this will include a full inventory of the fuel currently held and where necessary to avoid issues with quality and incompatibility, space provided for the bunkers to be kept separate from those currently held. 

Ideally the intent would be to refrain from using these bunkers until an analysis as to the quality of the fuels loaded is received from the laboratory to prove it is conducive to that required to safely and efficiently operate the machinery onboard the vessel. 

Loading procedures and important check points

BEFORE BUNKERING – Quantity survey 

  •  Conduct the survey in accordance with ISO 13739 / 2009 “Procedures for the transfer of bunkers to vessels”. The vessel should hold a copy of this document for reference. There may also be other guidance/regulation at the port of loading and this should be checked when the bunkers are being arranged.
  •  Ship crew should not sign papers and documents prior to loading apart from that agreed as being part of the safe loading of the bunkers. 
  •  For record and documentation, the Chief Engineer should take a print-out of all quantities in the bunker fuel tanks prior to loading and have this duly acknowledged by any attending third party surveyor/barge representative. 
  •  Insist that the Barge Cargo Officer does not strip the tanks and does not blow the lines until after measurements have been taken. 
  •  The Chief Engineer or a representative (Surveyor) must witness the gauging on board the barge.  It is most advisable that one’s own sounding tape and approved temperature measuring device is used.
  •  In the presence of the Barge Cargo Officer, if possible, all tanks should be measured including all non-nominated tanks, settling, service, overflow and sludge tanks. 
  • The determination of the temperature of the fuel delivered should be verified and recorded. 
  •  Remote gauging and indications are also to be recorded (with print-out/photo), as an additional reference where possible.
  •  Where Radar is used in preference to manual gauging, the  Cargo Officer should be asked to produce the last calibration date of the equipment. 
  •  The Cargo Officer should also be asked to provide calibration tables with a certified stamp from an approved and recognized body. 
  • The initial Fuel ROB must be carried out prior to the bunkering operation and all figures recorded. Where there is deviation from the logbook figures this should be documented.


  •  Closely monitor the loading operation in accordance with procedures within the vessel’s ISM manual and ISO 13739/2009.
  •  Take photographs throughout the evolution at the bunkering manifold, register pressure and temperature recorded at various intervals, sampling arrangements evident. 
  •  Signal and record any abnormality detected; suggest/impose appropriate measures for avoiding quantity/quality problems and document actions taken. 
  •  Observe carefully the bunker hose for any excessive vibrations and “air in liquid” specific sounds.
  • Where possible randomly check the bunkering barge, verify the levels in the tanks declared as empty, verify the bunker supply lines do not have peculiar or “out of place” connections.


  •  Obtain a print-out from automatic ships measurement devices after bunkering, to verify if the expected volume is correct. 
    Temperature of fuel received must be taken immediately after the bunkering (especially in cold waters).
  • When the delivery is complete ensure the lines are not blown through until the final measurements are taken and the final figures ascertained. 
  •  Witness measurement of all barge tanks.
  •  If blowing through is required, this must be done in a nominated tank on the vessel for easy gauging. (Ensure adequate safety precautions are taken to avoid over pressurisation of the receiving tank or an environmental incident.) 
  •  Request a print out of the Barge tank statement which should be signed by all parties attending: Barge Captain – Chief Engineer – Surveyor (where applicable). 
  •  Measure the receiving tanks. An ullage can be taken where there is a good reference to reference height.
  •  Ask the Barge Cargo Officer to open the hatch to visually check the content of each tank when in doubt of the tank’s emptiness. 
  •  The Chief Engineer should not give the vessel’s figures before the Barge Cargo Officer gives his own figures. 
  •  In case of a dispute the company should be notified and a “Letter Of Protest” (LOP) issued. 


  •  Pay special attention to abnormal noises and vibration of bunker hoses, and note where there is the possibility of air mixed in the fuel. 
  •  If in doubt, stop the bunkering operations and wait for a short time – say 20 minutes – for the oil to settle. 
  •  Evidence should be gathered prior to departure and make several soundings at 30 minute intervals to determine the level drop. 
  •  Take photos of the air bubbles on the sounding tape to produce evidence and document your concerns on the BDN. 

QUALITY SURVEY – Sampling and testing during bunkering

  •  MARPOL Annex VI recommends samples to be taken at the closest point on the vessel’s manifold. 
  •  ALWAYS insist on an in-line continuous drip sampler at the vessel’s manifold. 
  •  Prior to the bunkering operations agree upon the number of samples to be drawn for each party and the joint sealing. Avoid agreeing on too many samples as the control may be lost. 
  •  If no agreement is reached, it is strongly advisable that the Chief Engineer uses his own set of samples by continuous drip. Most barges have no correct in-line continuous drip sampler. 
  • Record the seal numbers and document these numbers on a “Sample witnessing report”. 
  •  Take a photograph of the samples. 
  •  Sign and stamp all labels. 
  •  Maintain good oil hygiene throughout and safely stow the samples held onboard in a managed system that allows for easy recall in future. 
  • It is recommended where possible that all samples are submitted for testing to a registered laboratory.

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