1. How will vessels flagged in countries that have ratified Annex VI to Marpol be serviced in countries that have not ratified the regulations?

If the country of fuel supply has not ratified Marpol Annex VI, the BDN will in any case provide the information that the supplied fuel oil is complying with the Marpol Annex VI regulations.  The Annex VI representative sample however may not be available and   samples will be taken according to local and contract guidelines

If the country of fuel supply has ratified Marpol Annex VI, vessels will be provided with the required BDN and representative Marpol sample. The manner in which the representative Marpol sample is provided may vary from port to port and for that reason local operations personnel need to be consulted prior to delivery.

2. How will paperwork supplied in support of deliveries conform to Marpol Annex VI ?

CGMP BDN’s have been reformatted and will include the information (such as IMO number of the vessel, density (@15 °C kg/m3), sulphur content,…) defined in Appendix V of Annex VI.  In addition, the BDN will state that the fuel as supplied is meeting the Marpol Annex VI max. sulphur and  general fuel quality regulation.

3. How will the Marpol representative sample be obtained ?

In countries that have ratified the Marpol Annex VI regulations, CGMP will endeavor to take the Marpol representative sample according to the sampling guidelines as set forth by the signatory countries.   It should be pointed out that sampling at the receiving ship’s manifold, as laid out in the IMO guidelines, may at some locations prove practically impossible and unsafe for the supplier’s representative.

Where provided as required in those countries that are signatories to the Annex and in order to prove compliance with Annex VI, the representative fuel oil will be sealed and the sample container will be secured with a label containing information such as location at which, and method by which, the sample was drawn, bunker grade,    details of seal identification, signatures and names of the supplier’s and ship’s representative.  

In countries that have not ratified the regulations, samples will continue to be taken according local sampling guidelines.

4. Will CGMP accept a sample taken by the ship as an official Marpol sample and sign for it ?

As noted in #3 above, it may be impractical or unsafe for CGMP’s representative to take a Marpol compliant sample. However, if practical, CGMP will consider a sample drawn by a mutually agreed Inspector as representative if this arrangement is agreed prior to delivery and at the expense of the vessel and/or owner.

If unable to take a sample, CGMP will, subject to appropriate disclosures, accept a sample drawn by the ship as the Marpol compliant sample.

5. Will CGMP, in those countries that have not ratified Annex VI to Marpol, on explicit request from the customer, provide a Marpol representative sample?

This is to be checked with the operations group at supply location. Customer may be charged for this service.

6. Can the Marpol representative sample be used for general quality control ?

No. This sample should be kept onboard the ship until the fuel oil is substantially consumed, but in any case for a period not less than 12 months from the time of delivery. The Marpol sample is solely for inspections by Port State Control.

7. How will representative delivery retain samples be obtained ?

The delivery retained samples of record used for ISO 8217 quality testing in case of dispute,  will be obtained as outlined in the Terms of Sale, contract and/or in line with local sampling codes.

8. Can a fuel oil ordered as ISO 8217:1996 grade x be assumed to be compliant with Marpol Annex VI?

No. Upon nomination it should be stipulated that the fuel also has to meet the Marpol Annex VI requirements.  Some residual fuel oil grades in ISO 8217:1996 have a max. sulphur limit of 5 m/m %, which exceeds the max. sulphur content specified in regulation 14 (1) of Annex VI.

A customer nomination accepted by CGMP stipulating Marpol Annex VI requirements accepted will be compliant with Marpol Annex VI

9. Will the fuel oil supplier also retain a Marpol compliant sample ?

Although the supplier is responsible for providing a Marpol compliant bunker sample to the vessel, the supplier will only retain a copy of the BDN for a period of three years.   A sample of record will be retained for at least 30 days for quality verification in cases of quality disputes.

10. When a country ratifies the Annex VI to Marpol at a date later then May 19^th 2005, when shall the regulations enter into force?

In countries ratifying Marpol Annex VI after May 19^th 2005, the regulations shall enter into force three months after the ratification.

11. Are the Marpol Annex VI regulations also applicable to a vessel’s fuel oil cargo ?

No. The regulations only apply to fuel oil for combustion purposes delivered for use onboard ships.