All Ships Required To Have Sampling Points For Taking ‘In-Use’ Samples
Amendments to MARPOL Annex VI, adopted at the 75th session of the IMO’s Marine Environment Protection Committee, will require all ships that do not have designated sampling points for taking so-called in-use samples to have them fitted.
The amendments to MARPOL Annex VI will enter into force on 1 April, 2022.
For a ship constructed before 1 April 2022, in-use sampling point(s) must be fitted or designated not later than the first renewal survey as identified in regulation 5.1.2 of MARPOL Annex VI on or after 1 April 2023.
The requirements for having a designated sampling point for in-use fuel are not applicable to a fuel oil service system for a low-flashpoint fuel for combustion purposes for propulsion or operation on board the ship.
The purpose of in-use samples is to draw a representative sample of the fuel that is actually in use on a ship. This has, in fact, been the most common practice in European Union countries for several years when port State control authorities have undertaken detailed inspections to check that ships were complying with emission control area (ECA) limits and/or sulphur limits for ships at berth in EU ports.
IMO guidelines for drawing in-use samples are already in place, and are referenced in the amendments of appendix VI of MARPOL Annex VI that were adopted at MEPC 75. These make it clear that a delivered sample, if tested, must meet the relevant limit to be “considered to have met the requirement”. In-use and on board samples, meanwhile, “shall be considered to have met the requirement” provided the test result is not higher than the applicable limit + 0.59R (where R is the reproducibility of the test method). In other words, the 95% confidence principle is applied to in-use and on board samples.