Fuel bunkering industry lobby group says port state control (PSC) testing mechanisms must be standardised to be fair
The International Bunker Industry Association (IBIA) has submitted a paper to IMO saying port state control authorities should use a global testing regimen to enforce IMO requirements that vessels carry fuel with no more than 0.5% sulphur content.
"The main problem is a lack of consistency in how authorities decide whether a ship is in compliance with the 0.50% sulphur limit," IBIA said.
The group cited reports where authorities have required vessels to fully debunker after proactively reporting their own test results to authorities indicating a sulphur content "marginally above 0.50%", but with a 95% confidence interval commonly used in fuel testing.
IBIA said similar marginal overages in samples taken by PSC authorities had also resulted in vessels being required to fully debunker.
"Debunkering is not a trivial matter. Apart from causing delays and substantial financial costs, it also carries an environmental cost through extra CO2 emissions, and represents safety and environmental risks. In light of this, debunkering should only be required when it has been established, beyond reasonable doubt, that a ship is carrying fuel oil that exceeds the 0.50% sulphur limit," IBIA said.
"We believe [compliance] should be confirmed by testing a Marpol sample in accordance with the regulation, and not on the basis of commercial samples such as a ship’s own sample."
The group said it is aiming to achieve recognition of the 95% confidence principle given the "inherent uncertainty of the sulphur test method".
IBIA said it wants "recognition that the 95% confidence principle applies to fuel oil used and carried for use by the ship and hence any fuel that has tested within 95% confidence of the 0.50% sulphur limit should not be debunkered. However, if [a] Marpol-delivered sample is above 0.50% sulphur (or 0.10% sulphur for ECA fuel), the fuel oil supplier would be considered as not having met the requirement and could face enforcement action."
IBIA raised the issue first in an IMO plenary session with a statement at Marine Environment Protection Committee’s (MEPC) 75th session in November 2020. The IBIA paper, co-sponsored by member state Jamaica, will be considered during the seventh session of MEPC’s Sub-Committee on Implementation of IMO Instruments in a working group session on measures to harmonise port state control.
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