Simple measures can be put in place to standardise testing systems, writes Rahul Choudhuri
Throughout its 25-year history, the practice of bunker fuel sampling has often shown itself to be a messy and complicated business.
Bunker supply, on the whole, has evolved into a convoluted chain involving many parties. Perhaps for this reason, decisions on fuel sampling are influenced by the individual players’ vested interests.
Contradictory as it may seem, with the implementation of MARPOL Annex VI, the industry now urgently needs clearer direction. All parties in the bunker supply chain must specifically agree on common practices within the new regulatory framework.
Among these practices, sampling procedures remain a debatable issue.
DNV Petroleum Services, a leading provider of marine fuel quantity measurement services, has been monitoring the progress of major bunkering ports in coping with MARPOL Annex VI.
The worldwide bunker sampling situation today can be summarised as follows:
- Singapore is the only bunker port that has a standard sampling methodology. There is talk of Gibraltar’s intention to implement a similar sampling requirement under its bunkering code of practice, but whether this will be a port requirement remains unclear;
- in Singapore, custody transfer sampling, i.e. sampling at the ship manifold, has been successfully enforced. However, CP60, the Singapore code of practice for bunkering, allows for alternative sampling at the barge side if there are physical limitations with the receiving ship’s bunker manifold or with the type of sampling equipment in use;
- generally, sampling is carried by the supplier mostly on the barge side. In one major bunker port, sampling carried out by suppliers at the barge manifold is de rigueur;
- less than 40 per cent of bunker deliveries worldwide involve joint sampling at the ship manifold;
- in a major bunker port where joint sampling at ship manifold is not the norm, one supplier has recently indicated that it will accept ship manifold sampling, provided an independent surveyor is appointed, preferably acting for both supplier and receiving vessel. This suggests that positive changes are possible with better communication;
- in major bunker ports, suppliers are still taking non-representative samples in
5 per cent of deliveries. This may be a spot sample or something prepared beforehand at the terminal. The situation is much worse in minor ports where improper sampling methods are used by the barges about 60 per cent of the time; - barges in minor bunker ports have improper sampling equipment in the majority of cases encountered by DNVPS. This could be due to poor understanding of sampling procedures.
Following the implementation of MARPOL Annex VI on 19 May, DNVPS conducted a study on actual practices. With four major bunkering (A–D) ports included in the study, the company observed that:
- major port A requires the MARPOL sample to be taken at ship manifold together with all other commercial samples;
- major port B allows the MARPOL sample to be taken at ship manifold but suppliers take their commercial samples on the barge;
- major port C allows the MARPOL sample to be taken at either location;
- major port D allows only the MARPOL sample to be taken on the barge and suppliers may charge extra for ship manifold sampling;
- in the minor bunker ports, the situation is much worse, with MARPOL samples being taken only partially by the suppliers;
- not all major port suppliers are following the recommended MARPOL documentation by stating the MARPOL sample seal number on the Bunker Delivery Note;
- not all minor ports are making an effort to follow proper BDN requirements under MARPOL. DNVPS continues to see BDNs presented in obsolete formats;
- generally, oil majors have demonstrated better documentation control for bunker deliveries.
Singapore, the world’s biggest bunker port, warrants special attention.
To be considered valid under CP60 requirements, all samples taken during each fuel delivery must have their seal numbers entered on the BDN. This is irrespective of whether the samples have labels and other accompanying documents countersigned by both parties to support their authenticity.
DNVPS frequently receives samples from receiving vessels with seal numbers missing on the BDN. Why the ship staff has been unable to get the seal numbers entered on the delivery note is not fully known, but the supplier clearly has a role to play in ensuring that seal numbers of all legitimate samples are accounted for.
Nevertheless, sample authentication should not depend solely on a single seal number. By requiring all sample bottles to be counter-sealed by both the receiving vessel and the supplier, we can perhaps control the incidence of sample tampering more effectively.
To ensure a smooth delivery in Singapore, ship operators must be aware that
it is the supplier’s obligation under CP60 to ensure all samples taken during bunker sampling are properly documented and have seal numbers recorded on the BDN.
The ship crew should also check that the sampling, sealing and distribution of sample bottles meet CP60 requirements.
If this is not done, the ship master should report any supplier’s non-conformance to the MPA.
For its part the MPA, in recent meetings with the industry, has also reiterated its commitment to continually improve practices in the local bunker supply chain.
Certain problem areas have been identified in bunker fuel sampling.
A good sampling location is one where a line sampler can be properly fitted at the manifold and where the crew can conduct the sampling process safely and monitor the progress conveniently during the bunkering operation.
Although many valid sampling methods and locations are available in the petroleum industry, DNVPS advocates continuous drip sampling at the point of custody transfer, i.e. ship manifold.
Bunker fuel sampling today unfortunately remains constrained by inconsistency in sampling location and the equipment used. In some cases, poor bunker manifold design prevents adherence to proper sampling procedures.
There is also little support for joint sampling, which would be equally beneficial to the receiving vessel and the supplying barge.
The presence of multiple samples in a fuel quality dispute blocks speedy resolution, while tampering and other forms of cheating are still prevalent.
Perhaps more disturbing is the possibility that loopholes in rules and regulations may be manipulated by those intending to cheat.
To remove ambiguity in bunker fuel sampling and promote universal practices, local port authorities must support the MARPOL/MEPC sampling guidelines.
Ideally, only one sampling location should be adopted and a proper, continuous-drip line sampler used for every fuel delivery.
It would also help if both receiving vessel and supplier agree on one set of sample bottles for distribution.
Each sample bottle should be sealed and have its label signed by both the receiving vessel and the supplier.
Wherever required, the seal numbers of the fuel samples should be entered on the BDN.
Lastly, port authorities will need to put in place strong deterrents to discourage fraud.
Having fair and transparent practices in place is the best way to assure fuel buyers that they get what they pay for. In return, the suppliers will also enjoy repeat custom. It’s a win-win situation.
Rahul Choudhuri is an expert on bunkering practices. For more information on bunker quantity surveys or other marine fuel management services, email singapore@dnvps.com
This article was originally published in Lloyd’s List, and is protected by copyright
Date: 2005-12-22