The International Maritime Organization (IMO) issued a new joint circular, MSC-MEPC.2/Circ.18, on 11 July 2024. The circular updates the fuel oil sampling guidelines used for compliance verification under MARPOL Annex VI and SOLAS Chapter II-2.
With this update, the IMO extends the use of the MARPOL Delivered Sample to verify compliance with the flashpoint requirement under SOLAS Regulation II-2/4.2.1. Previously, this requirement followed MEPC Resolution 182(59). Now, the new circular introduces a harmonised approach that covers both environmental and safety compliance.
Key Changes in the Updated Guidelines
Minimum Sample Size
The updated guidelines increase the minimum sample size from 400 ml to 600 ml.
However, the basic requirements for sampling location, arrangements, and procedures remain unchanged.
Likewise, the rules for sample labelling and storage continue to apply without modification.
Fuel Oil Definition
For the purpose of these guidelines, the circular defines oil fuel in accordance with Regulation 2.1.14 of MARPOL Annex VI.
In addition, it also includes oil fuel as defined under Regulation 1 of MARPOL Annex I.
Therefore, the definition aligns safety and environmental requirements under a single framework.
Sampling and Sample Preparation
Personnel involved in sampling must be familiar with the equipment and applicable procedures.
Moreover, they must follow the guidelines consistently to ensure reliability of the sample.
During the sampling operation, representatives from both the ship and the supplier should witness the process.
As a result, the procedure ensures transparency and traceability.
New Section 10 – Flashpoint Verification
The circular introduces a new Section 10.
This section defines the procedures and documentation requirements for verifying the fuel oil flashpoint.
Importantly, it does not change the existing MARPOL Annex VI Appendix VI procedures for sulphur verification.
Instead, it focuses exclusively on flashpoint compliance under SOLAS.
Tracking of MARPOL Delivered Samples
Under the updated guidelines, the company assumes responsibility for tracking MARPOL Delivered Samples.
Previously, this responsibility rested with the ship’s master.
This change is particularly relevant when laboratories remove samples from the vessel for testing.
In such cases, the remaining material may not return on board.
Therefore, clear tracking procedures are essential to maintain compliance.
Use of MARPOL Delivered Samples
The guidelines clearly state that only parties to MARPOL Annex VI or SOLAS may use the MARPOL Delivered Sample for compliance testing.
Furthermore, operators must not use these samples to resolve commercial fuel quality disputes.
Conclusion
Keeping vessels aligned with the updated fuel oil sampling guidelines is essential.
As a result, operators can ensure continued compliance with both environmental and safety regulations.
Proper understanding and correct implementation on board reduce compliance risks.
Ultimately, this approach also limits exposure during inspections and vetting.
For further clarification or operational support, Marine Surveyor Consultant SAGL remains available to assist.
