INSTRUCTION MANUAL – PART 2 OF 2

MARPOL ANNEX VI & REGULATORY GUIDELINES

Revision 1 : JULY 12
 Introduction and Revised Marpol Annex VI

4 Appendices
Revised MARPOL ANNEX VI Bunker Sample Record Guidelines (Proposed By DNVPS)
Example – Revised MARPOL ANNEX VI Bunker Sample Record Form
Example –Revised MARPOL ANNEX VI Bunker Sample Record
DNVPS Guidelines For Issuing Notification Related to revised MARPOL ANNEX VI
Example – Revised MARPOL ANNEX VI Notification Related to Documents & Procedures
Example – Revised MARPOL ANNEX VI Notification Related to Fuel Quality
Revised MARPOL ANNEX VI - Sampling Procedures Checklist
 Introduction and Revised MARPOL Annex VI
Introduction
Part 2 of 2 of the Instruction Manual contains guidelines and a number of examples that illustrate how to fill out the
Notification Form so as to assist vessels in ensuring compliance with the Revised MARPOL Annex VI regulations.

Revised MARPOL Annex VI

The revised Annex VI of MARPOL 73/78 “Regulations for the prevention of Air Pollution from ships” entered into force on
1 July 2010, and applies to all ships, fixed and floating drilling rigs and other platforms. Ships of 400 gross tons and above
engaged in international voyages involving countries that have ratified the conventions are required to hold an
International Air Pollution Prevention Certificate (IAPP Certificate) and will be subject to associated periodical surveys
and port state controls.

This certificate must be provided onboard newbuildings keel-laid after 19 May 2005 upon delivery. For ships keel-laid
before this date, the IAPP certificate must be on board at the first scheduled drydocking after 19 May 2005, but not later
than 19 May 2008.

The implementation of Annex VI means, among other things, that fuel quality and bunkering procedures are statutory
requirements and are subject to surveys, both by flag states (normally delegated to classification societies) as well as
port state control.

Details and explanations relating to documentary and procedural requirements are found in Resolution MEPC.
182(59) 2009 “Guidelines for the sampling of fuel oil for determination of compliance with the Revised Annex VI of
MARPOL 73/78”. For the most updated information, please visit www.imo.org.

From a fuel quality perspective, the following requirements apply:

Regulation 18 Fuel Oil Quality

Reg.18.3 requires that fuel oil supplied to ships is to be free from inorganic acids, or chemical wastes that could jeopardise
the safety of the ship, cause harm to ship personnel, or which would contribute overall to additional air pollution.

Bunker Delivery Notes:

It is a requirement that any fuel oil for combustion purposes delivered to and used onboard shall be recorded by means of
a Bunker Delivery Note (BDN). This BDN is identical to the Bunker Delivery Receipt (BDR) or Bunker Receipt. A BDN
shall therefore be presented for every barge delivery and for every fuel grade delivered.

The BDN is required to contain the following:

• Name and IMO number of receiving ship
• Bunkering port
• Date of commencement of delivery
• Name, address, and telephone number of marine fuel oil supplier
• Product name
• Quantity (metric tons)
• Density at 15 °C (kg/m³)
• Sulphur content (% m/m)
• A declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in
conformity with regulations 14 and 18 (i.e. that the fuel supplied has a sulphur level as required and
specified in the BDN and that the fuel is free from inorganic acid, does not include any added substance or
chemical waste which either jeopardises the safety of ships, adversely affects the performance of the
machinery, causes harm to personnel, or contributes overall to additional air pollution).

Regulation 14 requires that the actual sulphur content in marine fuel is to be stated in two decimal places in the BDN
and that terms such as “less than” or “max” are not acceptable.

Further, Resolution MEPC.182(59) recommends that the seal number of the associated MARPOL Annex VI fuel sample
is included in the BDN for cross-reference purposes.

The BDN is to be kept on board and readily available for inspection at all times. Both the ship and the supplier are
required to retain the BDN for a period of three years after the fuel oil has been delivered on board.

MARPOL Annex VI Fuel Oil Samples

Regulation 18 requires that every BDN is to be accompanied by a representative sample of the fuel oil delivered, taking
into account the guidelines in Resolution MEPC.182(59).

1
On completion of the bunkering operation, the sample is to be sealed and signed by the supplier's representative and the
receiving ship's master or officer in charge. This sample must be retained under the ship's control until the fuel oil has
been substantially consumed, but in any case for a period of not less than 12 months from the time of delivery. Although
MEPC.182(59) specifies that the volume of the sample bottle should be no less than 400 ml, Intertanko has
recommended that the sample volume is not to be less than 750 ml due to the potential need for repetitive testing. The
volume of the DNVPS sample bottle is in accordance with the Intertanko recommendation.

As per the revised MARPOL Annex VI, it is the supplier's responsibility to provide a representative MARPOL sample
to the ship. This sample can only be used by a Port or Flag State Authority. The referred to guideline in Resolution
MEPC.182(59) specifies that the MARPOL sample is to be a representative sample, taken at the ship manifold, using a
continuous drip or auto-sampler throughout the entire duration of the bunkering. Experience indicates that suppliers
do not always adhere to these requirements and sometimes do not provide receiving ships with the MARPOL
samples at all. Therefore, DNVPS recommends that the ship prepares a fourth sample bottle (a "DNVPS MARPOL"
sample) in the event the supplier fails to meet his obligations. More details on the DNVPS recommendation are given
in Part 1 of 2 of the Instruction Manual.

Sampling Procedures
Resolution MEPC.182(59) specifies that the fuel sample is to be obtained at the receiving ship’s inlet bunker manifold
and is to be drawn continuously throughout the bunker delivery period. The term “continuously drawn” means a
continuous collection of drip sample throughout the delivery of bunker fuel. Permitted sampling devices are further
clarified as either manual valve-setting continuous-drip sampler (equivalent to the DNVPS line sampler),
time-proportional automatic sampler, or flow-proportional automatic sampler.

On board bunkering procedures have to be amended to reflect the MARPOL Annex VI requirements and this can be
achieved by referring to the guidelines in this instruction manual.

The DNVPS line sampler, sample bottle labels and recommended procedures for sampling and sample preparation
are in accordance with the above requirements.

Sample Inventory
Resolution MEPC.182(59) also covers sample storage location. The samples are to be kept in a safe storage location,
outside the ship's accommodation and where personnel would not be exposed to vapours which may be released from
the samples. Further, the retained sample should be stored in a sheltered location preferably at a cool/ambient
temperature, where it will not be subject to elevated temperatures or exposed to direct sunlight. On tankers, the cargo
sample locker would be considered a suitable storage space. Alternatively, a locker with openings for adequate air flow
may be considered, if it is located in a well-ventilated area of the engine room and at a safe distance from ignition sources
and hot surfaces.

An inventory system (eg. record book) should also be developed to keep track of the retained samples. For your
reference, DNVPS has enclosed a sample inventory record book guideline and form in this Part 2 of 2 of the
Instruction Manual.

Supplier's Responsibility
While most IMO conventions place full responsibility on ships and the shipowners, Regulation 18 imposes a certain
responsibility on the suppliers.

MARPOL Annex VI also contains instruments to encourage port states to ensure that suppliers fulfil their obligations.
Port states are required to:

• Maintain a register of local fuel oil suppliers;

• Ensure local suppliers provide the BDN and sample, certified by the fuel oil supplier that the fuel oil meets the
requirements of regulations 14 and 18;
• Ensure local suppliers retain a copy of the BDN for at least three years for inspection and verification by the Port
State as necessary;
• Take appropriate action against fuel oil suppliers found to have delivered fuel oil not compliant with the
requirements stated on the BDN;
• Inform the Flag Administration of any ship receiving fuel oil found to be non-compliant with the requirements of
regulations 14 or 18 of MARPOL Annex VI;
• Inform IMO for transmission to Parties to the Protocol of 1997 of all cases where fuel oil suppliers have failed to
meet the requirements specified in regulations 14 or 18.

Notwithstanding the suppliers' responsibilities and the instruments available, previous experience from port state
controls indicates that it is advisable for owners/managers themselves to ensure compliance. In order to safeguard the
ship from the non-compliance, and in accordance with MEPC.181(59) “2009 Guidelines for Port State Control under
the Revised MARPOL Annex VI”, it is recommended that a Letter of Protest is issued in case the suppliers fail to meet
the requirements of Annex VI.

2
Regulation 14 - Sulphur Oxide (SOx) and Particulate Matter (PM)
The two Emission Control Areas now in force are the Baltic Sea (implemented on 19 May 2006 under MARPOL Annex
VI and 11 August 2006 under the EU Sulphur Directive) and the North Sea and English Channel (implemented on 22
November 2007 under MARPOL Annex VI and 11 August 2007 under EU Sulphur Directive). MARPOL Annex VI
currently specifies that the sulphur content of any fuel oil used on board ships shall not exceed 4.50% m/m and that
the sulphur content of fuel oil used on board ships in an ECA does not exceed 1.00% m/m. The North American
Emission Control Area (ECA) is expected to enter into force on 1 August 2011, with 12-month grace period; e.g.
expected to be enforced from 1 August 2012.

Ship operators should also be aware that the fuel sulphur limits apply to all marine fuel oils (heavy fuel oils, marine
diesel oils and gas oils) and regardless of use on board (ie. in combustion engines, boilers, gas turbines etc.). Bunker
specifications and contracts as well as charter parties need to reflect required sulphur levels worldwide and in the ECAs
where relevant to the ship's trading patterns. It is also imperative that the crew verifies that the sulphur content
specified in the BDN is in accordance with these specifications and contracts.

Change-Over procedures
Currently, when approaching an ECA, the ship must switch to a fuel with sulphur content not exceeding 1.00% m/m
and the changeover must be completed before entering the ECA.

For ships with standard fuel oil system configurations (one service tank and one settling tank), this will involve filling
the settling tank with low sulphur fuel oil, adequate treatment and subsequent channelling of this fuel to the service
tank, as well as flushing the fuel service piping systems to remove all fuel oil with sulphur level above 1.00%.

As per regulation 14.6, change-over procedures are mandatory from 1 July 2010 and should be developed, specifying
the necessary precautions to be taken and the time needed for such change-over. DNVPS may assist in developing such
procedures. Please contact your local DNVPS customer service managers or email [email protected]. Additionally,
the time and ship's positions at the completion of the change-over must be recorded in a logbook, together with details
of the tanks involved and fuel used. While not a regulatory requirement, the ship should also consider recording
similar details at the start of the change-over. DNVPS recommends using the engine room log book or the deck log
book for recording all fuel change-over details.

Other regulations related to marine fuels

Regional fuel regulations are emerging. With effect from 1 January 2010, the European Union Directive 2005/33/EC
requires all ships at berth in the EU community ports to use MGO with maximum 0.1% sulphur content. The state of
California in USA has also implemented requirements for the use of low sulphur diesel and gas oil within 24nm of the
Californian coast line. For further updates on regional regulations, please contact your local DNVPS customer service
manager or email [email protected].

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 REVISED MARPOL ANNEX VI
BUNKER SAMPLE RECORD GUIDELINES
(PROPOSED BY DNVPS)

Bunkering Operation ID No Guidelines

Date of Bunkering Indicate date bunkering was performed (start and completion).
Bunker Grade(s) Indicate Product’s name/Grade as per Bunker Delivery Note (BDN) or
specification. ISO grades preferably to be used.

Quantity (MT) Indicate quantity received in Metric Tons. Low sulphur fuel consumption
within ECAs is a statutory requirement and may therefore be subject to
third party verification/control. Accordingly, it is recommended that
increased focus is put on bunker quantity measurements and testing of
density to ascertain that the quantity received is in accordance with BDN
value.

Port of Bunkering Indicate the Port where the bunkering operation was performed.
Name of supplier Indicate Name of supplier.
Bunker barge(s)/Terminal(s) Name Indicate Name of bunker barge (s) or bunker terminal(s).
Supplier Registration with Port State Answer with YES, NO or UNKNOWN with respect to whether the
Authorities supplier is registered with Port State Authorities or not. Note that
MARPOL Annex VI does require Port States to maintain such a register.
Although not a requirement, it is recommended that only registered
suppliers are used.

BDN in compliance with the Revised Answer with YES or NO. It is a requirement for every barge delivery/fuel
MARPOL Annex VI grade supplied to the ship to be accompanied by a BDN. The BDN is to
contain Name and IMO No. of receiving ship, Port, Bunkering date,
Supplier’s name/ address/telephone no., Product name, Quantity (MT),
Density at 15ºC (kg/m3), Sulphur content* (% m/m) and a declaration
signed by the Supplier’s rep. stating that the fuel is in conformity with the
applicable paragraph of regulation 14.1 or 14.4 and Regulation 18.3 of
the Revised MARPOL Annex VI. If the BDN does not contain all the
required information and declaration, a Notification should be issued.
The BDN is to be retained onboard for min. 3 years.

MARPOL sample received from supplier Answer with YES or NO. Note that every BDN is to be accompanied by
a MARPOL sample representative of the fuel supplied. The sample is to
be retained onboard for min. 12 months. The sample is to be min. 400 ml
and provided with a label with information regarding location where
sample was taken (Ship’s manifold)**, Sampling method, Bunker date,
Name of bunker barge/pier, Receiving ship’s name and IMO No., Sample
seal number and Bunker grade. Every sample is to be sealed by supplier
and label is to be signed by the Officer in charge of the bunkering and the
suppliers’ rep. It is the supplier’s responsibility to provide such a sample.
If the supplier does not provide a MARPOL, sample, a Notification
should be issued and the separate MARPOL sample taken by the ship’s
crew in accordance with the DNVPS Instruction Manual should be
maintained onboard together with the supplier’s sample.

4
Supplier’s MARPOL sample Answer with YES or NO. The “2009 Guidelines for the sampling of fuel oil for
taken with continuous drip determination of compliance with the Revised MARPOL Annex VI"
sampler [MEPC.182(59)] specify that the representative MARPOL sample is to be
continuously drawn throughout the bunkering period and is to be obtained either by
a manual valve-setting continuous drip sampler or an automatic sampler. The
sampling equipment and the attached receiving container are to be sealed throughout
the bunker delivery period. If the supplier’s sample is not taken using a continuous
drip or auto-sampler, Notification should be issued and the separate MARPOL
sample taken by the ship’s crew in accordance with the DNVPS instruction manual
should be maintained onboard together with the supplier’s sample.

Supplier’s MARPOL sample Answer with YES or NO.“2009 Guidelines for the sampling of fuel oil for
taken at ship’s manifold determination of compliance with the Revised MARPOL Annex VI" [MEPC.182
(59)] specify that the MARPOL sample is to be continuously drawn at the receiving
ship’s manifold. In case the supplier does not take the MARPOL sample at the ship’s
manifold, a Notification should be issued and the separate MARPOL sample taken
by the ship’s crew in accordance with the DNVPS instruction manual should be
maintained onboard together with the supplier’s sample. If there are operational
constraints such as vacuum problems that prohibit samples to be taken at the ship’s
manifold, the details of the sampling point should be recorded separately e.g. at barge
manifold.

Notification issued Answer with YES or NO. The Notification should be referred to in the BDN.

MARPOL sample seal Nos. MARPOL Sample bottle seal number(s) are to be specified. Note that it is
recommended that all seal number(s) related to bunker samples taken are recorded in
the BDN (SS 600:2008 requirement in Singapore).

Other sample sent for fuel Answer with YES or NO. Applicable if the vessel sends other fuel samples for fuel
quality testing quality testing. The MARPOL sample is to be retained onboard and not be used for
commercial disputes i.e. the sample is only handed over to a Port or Flag State
Authority*** upon request.

Sulphur content (%m/m) Indicate the sulphur content as stated on the BDN.

Stored in Tank No. and Indicate in which tank(s) the received fuel was stored, and specify Quantity in each
quantity tank.

Date when fuel was Indicate the Date that the quantity of the fuel bunkered was substantially consumed.
substantially consumed

Sample disposal date The Disposal date should be indicated. All samples should be stored onboard for a
minimum of 12 months or until the fuel was substantially consumed - whichever is
sooner.

Sample given to Port or Flag The Date on which the sample was given to an Authority for verification should be
State Authority*** indicated with Port and Name of authority, if applicable. A receipt should always be
obtained. In case the supplier’s sample has not been taken as per the Revised
MARPOL Annex VI requirements, both the supplier’s sample and the DNVPS
MARPOL sample, and a copy of the letter of protest should be handed over.
Footnote :
* Two decimal places
** As per MEPC 182.(59) “2009 Guidelines for the sampling of fuel oil for determination of compliance with the Revised MARPOL Annex VI"
*** As per MEPC.181(59) “2009 Guidelines for Port State Control under the Revised MARPOL Annex VI”, the ship is to send a Notification to
its Flag State and the bunker Port State in the event of detected non-compliance. It is recommended that a copy is also sent to the bunker supplier.
As per Regulation 18.8.2 if an Administration requires the representative sample to be analyzed, it shall be tested in accordance with the
procedure set forth in Appendix VI of the Revised MARPOL Annex VI, “Fuel Verification procedure for MARPOL Annex VI fuel oil samples”.

5
 EXAMPLE – REVISED MARPOL ANNEX VI BUNKER SAMPLE RECORD FORM

Ship Name
IMO Number
Date of bunkering
Bunker Port

Bunker Grade (s)

Quantity (MT)
Name of supplier
Bunker barge (s) / terminal (s) name
Supplier Registration with Port State Authority
BDN in compliance with Revised MARPOL Annex
VI requirements
MARPOL sample received from supplier
Supplier’s MARPOL sample taken by continuous
drip sampler
Supplier’s MARPOL sample taken at ship’s manifold
Notification issued
MARPOL seal number (s)
Other fuel sample sent for fuel quality testing

Sulphur level (% m/m) - as stated in BDN*

Tank (s) used for received bunkers
Date which received bunkers has been consumed
Sample disposal date
Sample given to Authorities
Comments

* Two decimal places

Signature of Master / Chief Engineer

6
 EXAMPLE – REVISED MARPOL ANNEX VI BUNKER SAMPLE RECORD

Ship Name Test Ship

IMO Number XXXXXXX
Date of bunkering 1 July 2010
Bunker Port Bunker Port

Bunker Grade (s) RMG 380 DMB

Quantity (MT) 1000 250
Name of Supplier Supplier A Supplier B
Bunker barge (s) / terminal (s) name Barge 1 Barge 2

Supplier Registration with Port State Unknown Unknown

Authority

BDN in compliance with Annex VI Yes Yes

requirements

MARPOL sample received from Supplier Yes Yes

Supplier’s MARPOL sample taken by No Yes

continuous drip sampler

Supplier’s MARPOL sample taken at ship’s No Yes

manifold

Notification issued Yes No

MARPOL seal number (s) Supplier’s MARPOL sample : Supplier’s MARPOL

2121-2005 sample : 3100-2005
Ship MARPOL sample : 100000000

Other fuel sample sent for fuel quality testing Yes No

Sulphur level (% m/m) - as stated in BDN 2.70% 0.99%
Tank (s) used for received bunkers HFO No. 1P (500) MDO No. 1C (250)
HFO No. 1S (500)
Date which received bunkers has been consumed 19th July 2010 19th July 2010
Sample disposal date Requested by Authority -

Sample given to Authorities 10th August 2010, Port No

Comments Notification issued due to sample not Supplier MARPOL
being taken in accordance with Revised sample taken as per
MARPOL Annex VI and thus not Revised MARPOL Annex
accepted as official MARPOL sample. VI requirements and kept
Independent MARPOL sample taken by on board as official
ship crew as per DNVPS instructions and
maintained onboard. Both the Ship’s MARPOL sample.
MARPOL sample and the Supplier’s
sample delivered to port state together
with copy of Notification.

Signature of Master / Chief Engineer

7
 GUIDELINE FOR ISSUING NOTIFICATION RELATED TO REVISED MARPOL ANNEX VI

The vessel’s Master is obliged to issue a Notification to the Bunker Port State Administration and Flag State
Administration if the bunker supplier fails to comply with MARPOL Annex VI requirements. The obligation to issue
such Notifications is stated in Resolution MEPC.181(59) “2009 Guidelines for Port State Control under the Revised
MARPOL Annex VI”.

As it is also recommended that a Notification is issued to the bunker supplier, a combined document titled “Notification
to Authorities is proposed”.

It is recommended that a copy of the Notification is filed together with the relevant Bunker Delivery Note in the Bunker
Delivery Note file onboard.

The vessel’s Master should note the following possible non-compliance situations and choose the relevant item(s) to be
quoted in the Notification:

1 A Bunker Delivery Note was not provided for every delivery/grade.

The Bunker Delivery Note did not contain all the required information. (In this section further elaboration is
2 needed to state which information was not given. Refer to further explanation under Regulation 18.5 and
Appendix V)
3 A MARPOL Annex VI sample did not accompany each Bunker Delivery Note.
4 The MARPOL Annex VI sample(s) was not taken at receiving ship’s manifold as per MEPC.182 (59) 1).
The MARPOL Annex VI sample(s) was not taken by continuous drip sampler or auto-sampler as per MEPC.182
5
(59) 1).
The MARPOL Annex VI sample(s) was not provided with a seal and a label containing the required information.
6 (In this section, further elaboration is needed to state which information was not given. Refer to further
explanation under Regulation MEPC.182 (59) 1) Item 8).
The subsequent fuel quality test results or onboard experiences indicate that the fuel does not comply with Reg.14
7 (i.e. sulphur level as specified in BDN or confirmations/clauses) or Reg.18 (fuel oil quality) of Annex VI to
Revised MARPOL Annex VI.

8 Other (please specify):

Footnote:

1) MEPC.182(59):

For the sake of good order, please note that MEPC.182(59) is the “2009 Guidelines for the sampling of fuel oil for
determination of compliance with the Revised MARPOL Annex VI”, which is referred to in Reg.18.8.1 and which the
IMO has invited Governments to apply from the date of entry into force of MARPOL Annex VI.

Note that while in Singapore the custody transfer samples shall be taken at the manifold of the ship, in accordance with
SS 600:2008 and MEPC.182(59), a few Port States such as Panama have accepted that the sample is taken at barge
manifold. The UK Authorities may give similar exemptions on a case-by-case basis. Evidence of such acceptance should
however be obtained. If the Port State Authority has accepted such deviations from MEPC.182(59), then Flag and other
Port State Administrations are obliged to accept the same.

8
Further explanation of the possible non-compliance situations related to Regulations 14 and 18 of MARPOL Annex VI
are follows :

Regulation Description
18.5 A Bunker Delivery Note was not provided for every delivery and grade supplied.

The Bunker Delivery Note did not contain the required information as follows:
- Name and IMO No. of receiving ship
- Port
- Date of commencement of delivery
- Name, address and telephone no. of marine fuel oil supplier
- Product name
- Quantity (metric tons)
- Density at 15ºC (kg/m•) - as per ISO 3675
18.5 and App.V - Sulphur content (% m/m)- as per ISO 8754
- Declaration signed and certified by the suppliers rep. that the fuel supplied is in conformity
with Reg.14.1* or 14.4** and Reg.18.3*** of the Revised MARPOL Annex VI.

* The sulphur level in the fuel supplied shall not exceed 4.50% prior to 1 January 2012 and
3.50% on and after 1 January 2012

** The sulphur level in the fuel supplied shall not exceed 1.00% from 1 July 2010 and 0.10% on
and after 1 January 2015

*** The fuel is to be free of inorganic acids and not include any added substance or chemical
waste which either jeopardizes the safety of ships or adversely affects the performance of the
machinery, or is harmful to personnel, or contributes overall to additional air pollution.

18.8.1 A MARPOL Annex VI sample did not accompany each Bunker Delivery Note.

MEPC.182(59) The MARPOL Annex VI sample(s) was not taken at the receiving ship’s manifold.
Items 6
MEPC.182(59) The MARPOL Annex VI sample(s) was not taken by a continuous collection of drip sampler
Items 4 & 6 throughout the delivery of fuel (i.e. by continuous drip sampler or auto-sampler).

The MARPOL Annex VI sample(s) was not provided with a label containing the required
information as follows:
- Location at which, and the method by which, the sample was drawn
- Date of commencement of delivery
MEPC.182(59) - Name of bunker tanker/bunker installation
Items 8 - Name and IMO number of the receiving ship
- Signatures and names of the supplier's representative and the ship's representative (provided
accepted as representative)
- Details of (tamper- proof) seal identification
- Fuel grade (Bunker grade)

9
 The representative fuel sample taken simultaneously with the onboard MARPOL sample and
tested by DNV Petroleum Services indicates that the sulphur level in the fuel is above 4.50% (and
14.1
3.50% on and after 1 January 2012) and above the declared sulphur content in the Supplier’s
Bunker Delivery Note. 1)

The representative fuel sample taken simultaneously with the onboard MARPOL sample and
tested by DNV Petroleum Services indicates that the sulphur level in the fuel is above 1.00 % (and
14.4
0.10% on and after 1 January 2015) and above the declared sulphur content in the Supplier’s
Bunker Delivery Note. 1)

It has been confirmed that the bunkered fuel contains inorganic acids or any added substance or
18.3 chemical waste which either jeopardizes the safety of ships or adversely affects the performance of
the machinery, or is harmful to personnel, or contributes overall to additional air pollution. 1)

Footnote:

1) Guidelines for Notification to Administrations:

It is important to note that if the Flag or Port State Administration requires further investigation (verification testing), it
is the representative onboard MARPOL sample(s) which is/are the governing sample(s) for determination of sulphur level
and fuel quality under MARPOL Annex VI.

In the Notification the Administration as per the Revised MARPOL Annex VI Regulation 18.8.2, should be advised to
request the ship to forward the representative onboard MARPOL sample to an ISO 17025 accredited laboratory of their
choice, ISO 17025 accredited for conducting the sulphur test, for verification testing. The Administration should be
informed that prior to testing, the laboratories experience in fuel testing and attendant test procedures and methods, as well
as the calibration, condition and suitability of the laboratory equipment used, should be verified to be acceptable. Testing
should be extended to include basic parameters such as Density, Viscosity, Vanadium, Sulphur and Nickel to establish the
identity of the fuel in case of a future dispute. Water content should also be confirmed as high water content may impair
test precision.

Further, the Flag/Port Administration should be advised to invite the ship owner or one of his representatives to witness
the breaking of the seal and the verification testing of the sample. He should also be advised to invite the Flag/Port
Administration in the referred to bunkering port and the supplier to witness same.

A copy of the BDN and fuel quality test reports (if relevant) should be attached with the Notification sent to the relevant
parties.

10
 Name of Ship:
Flag:
IMO Number:
Owner/Manager:

To: The Flag State Authority

Fax/Email:

To: Bunker Port Authority

Fax/Email:

To: Supplier
Fax/Email:

CC: DNV Petroleum Services

Fax/Email:

NOTIFICATION:
Bunkering Date:
Bunkering Port and Country:
Bunker Supplier Name:
Barge/Terminal/Truck:
Issuing Date of Notification:

This is to record that during the above stated bunkering, the supplier failed to comply with the requirements of the
Revised MARPOL Annex VI as follows:

We hereby lodge a protest to the supplier to reserve rights for any future consequences on this matter. We hereby also
notify the relevant Authorities in accordance with the requirements of MEPC.181(59).“2009 Guidelines for Port
State Control under the Revised MARPOL Annex VI”.

The Authorities are hereby requested to consider initiating actions as specified in Reg.18.9 of the Revised MARPOL
Annex VI.

Yours faithfully,

(Name of Master of Vessel) (Signature of Master of Vessel and Vessel’s Stamp)

11
 EXAMPLE 1: NOTIFICATION RELATED TO DOCUMENTS & PROCEDURES

Name of Ship: XXXX

Flag: XXXX
IMO Number: XXXX
Owner/Manager: XXXX

To: The Flag State Authority XXXX

Fax/Email: XXXX

To: Bunker Port Authority XXXX

Fax/Email: XXXX

To: Supplier XXXX

Fax/Email: XXXX

CC: DNV Petroleum Services XXXX

Fax/Email: XXXX

NOTIFICATION:
Bunkering Date: XXXX
Bunkering Port and Country: XXXX
Bunker Supplier Name: XXXX
Barge/Terminal/Truck: XXXX
Issuing Date of Notification: XXXX

This is to record that during the above stated bunkering, the supplier failed to comply with the requirements of the
Revised MARPOL Annex VI as follows:

1. Bunker Delivery Note:

The Bunker Delivery Note received did not specify sulphur level for the 380 cSt fuel, as required by
the Revised MARPOL Annex VI Reg.18.5 / Appendix V.

2. MARPOL Sample
The source of the MARPOL sample provided by the supplier is not known as it was not taken in the
presence of the ship’s staff and was not taken at the receiving ship’s manifold and was not taken using
a continuous drip sampler as required by MEPC.182(59). Based on the above the supplier’s sample is
not accepted as a representative and official MARPOL sample. The ship has taken its own MARPOL
sample using a continuous drip sampler and at the ship’s manifold as per MEPC.182(59).

We hereby lodge a protest to the supplier to reserve rights for any future consequences on this matter. We hereby also
notify the relevant Authorities in accordance with the requirements of MEPC.181(59).“2009 Guidelines for Port
State Control under the Revised MARPOL Annex VI”.

The Authorities are hereby requested to consider initiating actions as specified in Reg.18.9 of the Revised MARPOL
Annex VI.

Yours faithfully,

(Name of Master of Vessel) (Signature of Master of Vessel and Vessel’s Stamp)

12
 EXAMPLE 2: NOTIFICATION RELATED TO FUEL QUALITY

Name of Ship:
Flag:
IMO Number:
Owner/Manager:

To: Bunker Port Authority XXXX

Fax/Email: XXXX

Bunkering Date:
Bunkering Port and Country:
Bunker Supplier Name:
Bunker Barge/Terminal/Truck:
Issuing Date of Notification :

To: The Flag State Authority XXXX

Fax/Email: XXXX

To: Supplier XXXX

Fax/Email: XXXX

CC: DNV Petroleum Services XXXX

Fax/Email: XXXX

Notification
This is to record that during the above stated bunkering, the subsequent fuel quality test results or onboard
experiences indicate that the fuel does not comply with Reg.14 (i.e. sulphur level as specified in BDN or
confirmations/clauses) or Reg.18 (fuel oil quality) of the Revised MARPOL Annex VI.

1. Fuel Quality
The representative fuel sample taken simultaneously with the onboard MARPOL sample has been tested by DNV
Petroleum Services with the result as per the attached copy of the fuel quality test report. The report indicates that:
- the sulphur level in the fuel supplied exceeds 4.50% prior to 1 January 2012 and 3.50% on and after 1 January
2012 and above the declared sulphur content in the supplier’s Bunker Delivery Note (Copy attached) and/or* ;

- the sulphur level in the fuel supplied exceed 1.00% from 1 July 2010 and 0.10% on and after 1 January 2015 in
ECA and above the declared sulphur content in the supplier’s Bunker Delivery Note (Copy attached) and/or*;

- The fuel is not free of inorganic acids and/or* includes added substance or chemical waste which either
jeopardizes the safety of ships or adversely affects the performance of the machinery, or is harmful to personnel,
or contributes overall to additional air pollution*.

13
 In the event further investigation is required, the representative onboard MARPOL sample is the governing sample
for determination of fuel quality under MARPOL Annex VI.

It is therefore recommended that the Administration as per the Revised MARPOL Annex VI Regulation 18.8.2
formally requests the ship to forward the representative onboard MARPOL sample to an ISO 17025 accredited
laboratory of their choice, for verification testing. Prior to testing, the laboratories’ documented experience in fuel
testing and attendant test procedures and methods, as well as the calibration and condition and suitability of the
laboratory equipment used, should be verified to be acceptable.

Testing should include basic parameters such as Density, Viscosity, Vanadium, Sulphur and Nickel to establish the
identity of the fuel in case of a future legal dispute and to include extended testing if necessary for verification of
inorganic acids, added substance or chemical waste which either jeopardizes the safety of ships or adversely
affects the performance of the machinery, or is harmful to personnel, or contributes overall to additional air
pollution.

We would further appreciate it if one of our representatives is invited to witness the breaking of the seal and the
verification testing of the sample. It should also be considered to invite the bunker Port Administration and the
supplier to witness the seal-breaking and verification testing.

We hereby lodge a protest to the supplier to reserve rights for any future consequences on this matter. We hereby also
notify the relevant Authorities in accordance with the requirements of MEPC.181(59) “2009 Guidelines for Port State
Control under the Revised MARPOL Annex VI”.

The Authorities are hereby requested to consider initiating actions as specified in Reg.18.9 of the Revised MARPOL
Annex VI.

Yours faithfully,

(Name of Master of Vessel) (Signature of Master of Vessel and Vessel’s Stamp)

Footnote :

* Include only the applicable statement(s) for parameter(s) indicating violation of Reg.14 (i.e. sulphur level as specified in BDN or confirmations/clauses) or
Reg.18 (fuel oil quality) of the Revised MARPOL Annex VI.

14
DNV Petroleum Services
MARPOL ANNEX VI – SAMPLING PROCEDURES CHECKLIST

Check that the Bunker Delivery Note (BDN) contains information in accordance with the Revised MARPOL
Annex VI and keep this document onboard for minimum 3 years. Pay particular attention to fuel sulphur level
stated on the BDN. If the BDN does not contain all the required information, a Notification should be issued *.

Invite the supplier to witness sampling and sign “Request to witness sampling form”.

Clarify whether the supplier will provide the MARPOL sample and whether he will take this sample at the ship’s
manifold using a continuous-drip sampler or other sampling device approved as MARPOL Annex VI compliant.
Invite the supplier to accept the ship’s MARPOL sample as the official MARPOL sample.

Take representative fuel samples at the ship’s manifold using a continuous-drip line sampler and a clean cubitainer
with security seal.
Fill minimum 4 liters of sample in the cubitainer.

Cap and shake the cubitainer. Fill 4 sample bottles. Fill each bottle 1/3 at a time. Shake between each pass.

Seal sample bottles.

Complete 3 DNVPS fuel quality testing sample bottle labels and 1 DNVPS MARPOL sample bottle label. Sign all
labels, jointly with the supplier’s representative (if accepted) and attach them to the sample bottles.

Offer one bottle of sample to the supplier’s representative (commercial sample).

Retain one bottle of sample onboard (commercial sample).
Forward one bottle of sample for testing to the DNVPS laboratory together with the Chief Engineer’s form and a
copy of the BDN (commercial sample).
If the supplier is providing a MARPOL sample taken at the ship’s manifold using a continuous-drip sampler or
other approved device, the following is recommended:
• The supplier’s sample is the official MARPOL sample and the DNVPS MARPOL sample prepared by the ship’s
crew may not be needed in this case.
• Check however that the supplier’s MARPOL sample bottle label contains all the information required under the
Revised MARPOL Annex VI.
If the supplier is not providing the MARPOL sample, or if the sample has not been taken at the ship’s manifold
and/or not taken using an approved sampling device, the following is recommended:
• Issue a Notification *.
• Retain the MARPOL sample prepared by the ship onboard **.
• If the supplier accepts to use the ship’s MARPOL sample as the official MARPOL sample, then a Notification is
not needed.
Retain the MARPOL sample(s) onboard (to be handed to Port or Flag state Authority only) in a dry and safe
location. This sample is to be retained onboard until the fuel bunkered has been substantially consumed, but not less
than 12 months.
Record MARPOL sample details in a Sample Inventory Log ***.
Footnotes:
* Suggested format for Notification to supplier, Flag State and Port State Administration is included.
** In case of Port State Control, both the supplier’s sample and the MARPOL sample prepared by the ship should be presented,
together with the BDN and the Notification highlighting non-compliance.
*** Guidelines for Sample Inventory Log are also included.

15
 DNVPS HQ / DNVPS Singapore DNVPS Rotterdam DNVPS Houston
27 Changi South Street 1 Zwolseweg 1 318 North 16th Street
Singapore 486071 2994 LB Barendrecht
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The Netherlands
Tel: + 65 6779 2475 Tel: + 1 281 470 1030
Tel: + 31 10 292 2600
Fax: + 65 6779 5636 Email: [email protected] Fax: + 1 281 470 1035
Email: [email protected] Email: [email protected]

DNVPS Fujairah DNVPS Oslo

Port of Fujairah
Veritasveien 1
P.O. Box 1227
United Arab Emirates N-1363 Hovik, Norway
Tel: + 971 9 2228152 Tel: + 47 67 57 9900
Fax: + 971 9 2228153 Email: [email protected]
Email: [email protected] URL: www.dnvps.com

DNV is a global provider of services for managing risk. Established in 1864, DNV is an independent
foundation with the objective of safeguarding life, property and the environment. DNV comprises
300 offices in 100 countries, with 9,000 employees.

All rights reserved; no part of this publication may be reproduced without the written permission of DNV Petroleum Services. DNVPS/MARPOLGUIDE/V0R1/0712