In the interest of air quality the IMO, MARPOL Annex VI mandated fuel sampling for all vessels over 400GT. “But actually, there are two reasons to sample bunkers, regulatory and commercial,” says YPI’s yacht manager, Capt. Guy Huybrechts, who holds an unrestricted deep sea master’s ticket with lots of cruise ship experience before joining YPI.
Certainly an unhappy class and/or flag state surveyor waving MARPOL is not good news. But on any size yacht, having “CREW NEGLIGENCE” written next to a seven-figure machinery casualty caused by contaminated fuel is not career enhancing either.
So following a few simple fuel sampling steps is important. Remember, it’s not unheard of for yachts to unknowingly receive low flashpoint fuel that, even if low sulphur and clean, can be very dangerous.
Capt. Huybrechts says the first step is straightforward but vitally important, regardless of the size of yacht. When ordering bunkers, state clearly what you need, buy it from a reputable source and document that order i.e. “Please deliver 100,000 litres of Marine Gas Oil as per ISO 8217 DMA quality.”
The next step is to always get a properly completed Bunker Delivery Note (“BDN” in IMO SPEAK) and keep it for three years.
Once the fuel is flowing, the IMO suggests sampling continuously but at the receiving end, even laying out three methods to do it. However, because few yachts have the necessary fittings, they instead tend to take the samples straight from the truck – but remember, take one from each and every truck or barge and hope the hose was clean and above all make sure you have enough liquid to perform an analysis.
The IMO guidelines say that two samples should be obtained and placed in clean 400-ml bottles, 95 percent filled, sealed and properly labelled.
One should be sent out for analysis, although yachts often do this only if there are problems. Ideally of course, fuel should not be used until the results are received, but with yachts having a small number of relatively small bunker tanks, this is often just not possible. (It also probably goes without saying that once lots have been mixed, it’s impossible to prove which lot caused your problem.)
The other bottle, regally called the “statutory sample,” must be retained for at least a year on board, in segregated, secure storage, outside of the accommodation presumably to avoid it’s getting mixed up with the Single-Malt.
Although all this is solid good practice, remember that if you’re over 400GT much of it is required, subject to survey and on occasion Port State control.
In turn, most flag states have delegated the IAPP (“International Air Pollution Prevention”) surveying responsibility to classification societies whose surveyors do all kind of vessels with all types of fuel – high and low sulphur – so they might not be really up on superyachts.
Consequently Capt. Huybrechts suggests that key to a successful IAPP survey is managing surveyor expectations with good first impressions.
He advises first making sure the surveyors understand that they are on board a superyacht in case they just came from a bulker with both high and low sulphur fuel; then proudly show them your three years of delivery notes and twelve months of fuel samples.
Sadly, regularly changing the filters just isn’t good enough anymore.
Lloyds has some really useful info at www.lr.org/NR/rdonlyres/764160D1-6DA3-4D6C-8BD0-73E8E12E7B46/37869/FOBASAnnexVI.pdf .
MARPOL Annex VI: www.imo.org/includes/blastDataOnly.asp/data_id%3D15732/129(53).pdf