In July 2024, the International Maritime Organization (IMO) released a joint circular—MSC-MEPC.2/Circ.18—introducing new guidelines for the sampling of fuel oil to determine compliance with MARPOL Annex VI and SOLAS Chapter II-2.
These guidelines replace the 2009 MEPC.182(59) resolution and are intended to standardize sampling procedures across the industry. Here’s what shipowners, bunker suppliers, port authorities, and inspectors need to know.
🎯 Purpose of the Guidelines
The primary objective is to establish a uniform method for obtaining a representative fuel oil sample, referred to as the MARPOL-delivered sample. This sample is essential for verifying compliance with:
- Sulphur content limits under MARPOL Annex VI.
- Flashpoint requirements under SOLAS II-2/4.2.1.
⚙️ Key Definitions
- Representative Sample: A specimen reflecting the average characteristics of the entire fuel delivery.
- Primary Sample: Collected at the receiving ship’s bunker manifold throughout the bunkering process.
- Retained Sample: A portion of the primary sample stored for verification and testing.
🛠️ Approved Sampling Methods
Sampling must be carried out using one of the following techniques:
- Manual valve-setting continuous-drip sampler
- Time-proportional automatic sampler
- Flow-proportional automatic sampler
The sample must be drawn continuously during the entire bunker delivery.
🔒 Sample Integrity and Sealing
To maintain reliability, the sampling equipment and containers must:
- Be clean, dry, and free of contaminants (e.g., solvents).
- Be sealed during use and tamper-proofed immediately after collection.
- Include a label with all critical information: seal ID, ship name and IMO number, bunker supplier, date/time, and sampling location.
🧊 Storage and Retention
The retained sample:
- Must be stored away from accommodation areas, protected from heat and sunlight.
- Should be kept for at least 12 months or until the associated fuel is nearly consumed.
- Must be tracked by the company through a dedicated procedure.
🔬 Post-Testing Procedures
If a retained sample is tested for compliance:
- A sub-sample is taken under authority supervision.
- The remaining sample is re-sealed with a new tamper-proof ID and documented.
- Test results are formally shared with the requesting authority, ship operator, and optionally the supplier.
🚢 Why This Matters
The new guidelines clarify sampling roles, ensure global consistency, and reinforce traceability in case of disputes or compliance investigations. For marine surveyors and technical operators, this offers stronger legal and procedural backing during PSC inspections or fuel disputes.
At Marine Surveyor Consultant Sagl, we assist shipowners in implementing compliant sampling protocols and training crew accordingly. Contact us for audit services, bunker sampling oversight, or regulatory advisory.
📩 Get in touch
🔗 www.marine-safety-consultant.ch
