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MARINE NOTICE 62
Version No. 1.0
Issue Date 04/05/2022
Effective Date 04/05/2022
MARPOL Annex VI -Fuel Oil Sulphur Limit
Notice to ship owners, managers, Masters, Approved Nautical Inspectors, Recognised
Organisations and surveyors
This Notice supersedes BMA Information Bulletin No.183
1. Purpose
1.1. This Notice outlines the position of the Bahamas Maritime Authority (BMA) on the
requirements of Annex VI of the International Convention for the Prevention of
Pollution from Ships (MARPOL Annex VI) in relation to Regulation 14, addressing
sulphur oxides (SOx) emissions and fuel oil sampling and Regulation 18, addressing
fuel oil availability and quality.
1.2. Amendments to MARPOL Annex VI are scheduled to enter into force on 01 November
2022. Any references to Articles, Regulations and Interpretations in this Notice are
references to the November 2022 version of MARPOL Annex VI, as amended, unless
stated otherwise. Where regulation numbers have changed, the previous regulation
number is shown in the footnotes.
1.3. For ease of use, provisions relating to MARPOL Annex VI, other than Regulations 14
and 18, are addressed in Marine Notice 61.
1.4. The provisions of Regulation 27 (formerly Regulation 22A, as stated in MEPC.1/Circ.897
– Cross reference tables for amendments to MARPOL Annex VI1) of MARPOL Annex VI,
in respect of fuel consumption data collection and reporting, are addressed separately
in Marine Notice 63.
2. Application
2.1. This Notice applies to all ships on all voyages.
1 https://wwwcdn.imo.org/localresources/en/OurWork/Environment/Documents/Air%20pollution/MEPC.1-Circ.897.pdf
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MARINE NOTICE 62
2.2. Additional local or regional limitations for marine fuel oil sulphur content for ships
operating in Emission Control Areas or specific geographic regions may apply
concurrently to MARPOL requirements.
3. Background
3.1. A global limit of 0.50% on sulphur content for fuel oil used on board merchant ships
was implemented on 01 January 2020.
3.2. In addition, the carriage for use of non-compliant fuel oil on ships without an
approved alternative means of compliance (such as Exhaust Gas Cleaning System
(EGCS)) is prohibited as of 01 March 2020. This prohibition nonetheless does not apply
to fuel oil carried on board as a cargo.
3.3. The global sulphur limit is a mandatory requirement and is applicable to all ships on all
voyages, covering all fuel carried on board for consumption – this includes fuel oil used
in emergency systems (emergency generator, lifeboats, rescue boat, etc.).
3.4. It is the Company’s2 responsibility to assess the potential effect of continuous use of
low-sulphur fuel oil or sulphur abatement technology on the ship’s machinery and
equipment. Where concerns exist, equipment makers and Classification Societies
should be consulted to find a technical solution.
3.5. Concerns about the safety of ship and machinery do not exempt the ship from the
requirement to bunker and/or consume compliant fuel oil. However, if non-compliant
fuel oil has been bunkered due to concerns that the quality of the compliant fuel oil
available would cause operational or safety problems on board the ship, the concerns
should be thoroughly documented in a Fuel Oil Non Availability Report (FONAR). See
Section 4 below.
3.6. Paragraph 3.5 does not affect exceptions due to genuine emergency situations, as per
the provisions of Regulation 3.1.
3.7. Enforcement of Regulation 14 runs in parallel with enforcement of compliance with
local and regional requirements related to sulphur oxide emission.
3.8. In ports where the discharge of wash water from open loop EGCS (scrubbers) is not
permitted, ships fitted with open loop/hybrid EGCS may be expected to consume
2“The Company” is the owner or any other organisation or person, such as the manager, or the bareboat charterer,
who has assumed responsibility for the operation of the ship
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MARINE NOTICE 62
compliant fuel oil or to switch to closed loop mode. Documents related to changeover
procedure and records should be kept on board.
4. Compliant Fuel Oil Availability and Fuel Oil Non-Availability Report
(FONAR)
4.1. It is largely expected that marine fuel oil bunker producers and traders are able to
satisfy the global shipping demand for compliant fuel oil with sulphur content below
0.50%.
4.2. Compliant fuel oil should be available in all bunkering locations. It is nonetheless
advisable for the Company to place timely enquiries with regular bunker suppliers
and/or charterers who are responsible for bunker stemming.
4.3. Where fuel oil for ship’s consumption is being provided by the charterers, it is
recommended that consideration be given to the introduction of a fuel oil quality
clause within the charter party. The clause should stipulate the Company and
charterers’ duties in respect of fuel oil procurement from outside sources, as well as
outline the responsibilities of each party in respect of fuel oil supply, storage,
preparation and handling to ensure that the fuel oil on board remains compliant, in
case of any future disputes or potential sanctions by Port State Control.
4.4. Where, despite all reasonable efforts, compliant fuel oil is not received at the
scheduled port of call, and no feasible alternative exists, the ship will be required to
prepare and submit a Fuel Oil Non-Availability Report (FONAR) as indicated in Section 5
of IMO Resolution MEPC.320(74).
4.5. The submission of a FONAR does not exempt the ship from the requirement to
consume compliant fuel oil. The FONAR provides documented background information
to the Coastal State authorities of the port(s) of destination, as well as the BMA, to
determine whether any enforcement actions or penalties may be applicable in each
individual case. Notwithstanding the submission of a FONAR, the Company must try to
obtain compliant fuel oil at the earliest opportunity.
4.6. The FONAR should be prepared and sent as soon as it is determined that the
ship/operator will be unable to procure compliant fuel oil and preferably before the
ship leaves the port/terminal where compliant fuel oil cannot be obtained.
4.7. FONARs should be submitted to both the BMA and the Coastal State authorities of the
port(s) of destination.
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MARINE NOTICE 62
4.8. In addition to submission of a FONAR, the BMA strongly recommends that the Master
prepares a Letter of Protest addressed to the local authorities in the port(s) where
compliant fuel oil was not available.
4.9. Follow-up actions may be considered when arranging the supply of compliant fuel oil
following bunkering of non-compliant fuel oil under a FONAR:
i. De-bunker any remaining non-compliant fuel oil at the first port where compliant
fuel is available , and;
ii. Specific preparations to ensure bunker tanks and fuel transfer, treatment and
preparation systems are sufficiently cleaned and are suitable for compliant fuel oil
without the risk of contamination by residues of non-compliant fuel oil. Such
actions may include tank cleaning, system pipelines and equipment flushing or
mechanical cleaning.
4.10. FONARs and all related documents, including any applicable emails, are to be retained
on board for inspection for at least three (3) years following the date of submission of
the FONAR.
4.11. The BMA will report details of submitted FONARs to the IMO Global Integrated
Shipping Information System (GISIS)3.
4.12. FONARs should not be prepared and submitted where a ship receives commercial
sample analysis results alleging that any controlled parameters are out of allowed
limits, including sulphur content or flash-point temperature.
5. Handling of non-compliant fuel oil and potential disputes
5.1. Guidance for Port State Control on how to address non-compliant fuel oil has been
provided by IMO in Circular MEPC.1/Circ.881.
5.2. As per the provisions of Regulation 18.2.2, a ship should not be required to deviate
from its intended voyage or unduly delay the voyage in order to achieve compliance.
5.3. Starting from 01 April 2022 the competent authority of a Party to MARPOL Annex VI
may draw samples of in-use and/or on-board fuel oil and conduct their own analysis as
outlined in Regulation 14.13 and IMO Circulars MEPC.1/Circ.864/Rev.1 and
MEPC.1/Circ.889. See Section 7 below.
3 MARPOL Annex VI » Notification (imo.org)
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MARINE NOTICE 62
5.4. Interpretation of such sample testing results should be based on the provisions
outlined in Part 2 of Appendix VI to the Annex.
5.5. The BMA recognises the guidance offered in the Part 2 of Appendix VI to the Annex
may leave certain room for erroneous interpretation due to being taken outside of the
MARPOL process. Being based upon provisions of ISO 4259:2017-2/AMD 1:2019, which
does not allow to account for factors related to merchant marine environment,
interpretation of sample testing results may potentially give grounds to arising a
dispute between the ship, or the Company, and the authorities of a Party who has
initiated the testing.
5.6. In case of any such disputes concerning the interpretation of the testing results the
BMA may offer the Company to review the testing results and provide a comment, as
appropriate.
5.7. It should be nonetheless recognised where in-use and/or on-board fuel oil sample
drawn by a competent authority of another Party may have returned a testing result
rendering such fuel oil in question as non-compliant the competent authority of the
Party, acting as a Regulator to the Convention, may reject the BMA comments.
6. Bunker Delivery Notes (BDNs)
6.1. In accordance with Regulation 18.5, the sulphur content of fuel oil supplied onboard is
to be confirmed from the supplier’s Bunker Delivery Note (BDN), which shall contain
the information specified in Appendix V of Annex VI.
6.2. BDNs shall be kept readily available for inspection on board for a period of not less
than three (3) years after the fuel oil in question has been delivered on board.
6.3. In cases where a BDN is not provided by the supplier, the Master or responsible officer
should document that fact. A letter of protest is to be sent to the supplier, copied to
the BMA.
6.4. The BDN shall be accompanied by a representative sample (“MARPOL delivered
sample”) which is to be sealed and signed by the Master or officer in charge of the
bunker operations on completion of bunkering and retained under the ship’s control
until the fuel oil is substantially consumed, but in any case not less than 12 months
from the time of delivery.
6.5. It is recognised that some ships engaged on short voyages may consume small parcels
of bunker fuel more rapidly than others. In such cases, representative samples of fuel
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MARINE NOTICE 62
already consumed may be retained in an appropriate shore side facility under control
of the Company.
7. Sampling of fuel oil
7.1. New sample categories of “in-use sample” and “on-board sample” have been
introduced to facilitate competent authorities of Parties to MARPOL to determine
whether the fuel oil used on board, or carried for use on board, meets the sulphur
content requirements of Regulation 14.1 or 14.4. Such sampling and testing will be
initiated, conducted and testing results interpreted by the competent authority of the
Party acting under the provisions of Regulation 14.
7.2. For this purpose, ships constructed on or after 01 April 2022 shall be fitted with in-use
sampling points on fuel systems, as required by Regulation 14.10 and 14.11.
7.3. Ships constructed before 01 April 2022 shall be fitted with in-use sampling points on
fuel systems by not later than the first IAPP renewal survey on or after 01 April 2023.
7.4. Ships using only low flash-point marine diesel oil/marine gas oil/gas fuel may be
exempted from the new in-use sampling point requirements.
7.5. The Company should identify locations and determine suitable arrangements of
sampling points as outlined in MEPC.1/Circ.864/Rev.1 and MEPC.1/Circ.889.
7.6. In-use and on-board samples will be analysed by an accredited laboratory on behalf of
the competent authorities of the Party conducting the inspection and sampling.
Results of sample tests will be used by the Party to establish whether a ship is
consuming and/or carrying a compliant fuel.
7.7. Though in-use and on-board samples are not formally considered as MARPOL samples
(“MARPOL delivered sample”) under Regulation 18.8.1, the results from testing of in-
use and on-board samples may be used to form a definitive judgement by the
competent authority of the Party taking the samples to establish any penalties or
mandatory actions in relation to a ship’s compliance with Regulations 14.1 and 14.4.
7.8. The Company may arrange, under its own initiative, routine commercial sample
testing for the purpose of determining the physical properties of the received fuel for
machinery and equipment settings and adjustment.
7.9. The Company may find during routine commercial sample testing of bunkered fuel
oil that the properties of the fuel may differ from those described in the BDN.
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MARINE NOTICE 62
7.10. Where routine commercial sample testing of a fuel oil sample indicates that the
properties of the fuel delivered differs substantially from that described on the Bunker
Delivery Note, the Company and/or bunker supplier may request permission from the
Administration to have the representative MARPOL sample tested in accordance with
Appendix VI of MARPOL Annex VI. The Company and/or bunker supplier is responsible
for all costs associated with testing of the MARPOL sample.
7.11. Correspondence related to commercial sampling may be kept separately from the
required MARPOL records. However, for the sake of transparency it may be made
available to third parties, as appropriate. However, the ship, or the Company, is not
under any mandatory obligation to disclose the results of commercial sampling testing
to any third party.
8. Operations in Sulphur Emission Control Areas (SECAs)
8.1. While operating in a Sulphur Emission Control Area (SECA), as defined in Regulation
14.3, the sulphur content of fuel oil used on board ships shall not exceed 0.10% m/m.
8.2. Ships operating in SECAs may carry different grades of fuel oils. In such cases,
sufficient allowance should be made for the fuel oil service system to be fully charged
with low sulphur fuel prior entering the SECA. Such changeovers should be
documented in the Bahamas MARPOL Annex VI Record Book or an acceptable
alternative as set out in BMA Information Notice 011.
8.3. All Bahamian ships shall comply with the requirements of Directive (EU) 2016/802
whilst alongside in European ports. Similar local and/or regional sulphur oxide
emission reduction legislative provisions may apply where a ship is operating in other
specific geographical area. The BMA cannot issue exemptions from the provisions of
EC Directive or other similar non-Bahamian legislative provisions.
9. Miscellaneous Provisions
9.1. The provisions of Regulation 14 apply to all ships on all voyages. However, emissions
from marine diesel engines that are solely dedicated to the exploration, exploitation
and associated offshore processing of sea-bed mineral resources, including oil and
gas, are exempt from the provisions of MARPOL Annex VI, in accordance with
Regulation 3.3.1.
9.2. The provisions of Regulation 18 do not apply to the use of hydrocarbons that are
produced and subsequently used on site as fuel, as per Regulation 3.3.2. This may be
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MARINE NOTICE 62
applied in respect of Floating Production Storage and Offloading units (FPSOs),
Floating Storage and Offloading Units (FSO/FSU), etc.
9.3. Where a unit that has been using hydrocarbons produced on site as fuel leaves the
production site without compliant fuel being available on board, a FONAR should be
submitted to the applicable authorities and compliant fuel delivered at the earliest
opportunity.
9.4. Where a gas is used as fuel, the requirements of the International Code of Safety for
Ships Using Gases or Other Low Flashpoint Fuels (IGF Code) and the relevant
Classification Society rules should be followed.
10. Queries
10.1. Any queries relating to MARPOL Annex VI should be addressed to the ship’s
Classification Society in the first instance. Alternatively, please contact
[email protected] or any BMA office.
10.2. Queries relating to local and/or regional emission reduction legislative provisions that
may apply to a ship in specific geographical area should be address to the coastal state
authorities in waters under whose jurisdiction the ship intends to operate.
10.3. Queries relating to specific requirements applicable in ports and estuaries should be
addressed to the Port Authorities prior to ship arrival. Customarily such inquiries are
best to be routed via a dedicated husbandry agent nominated at the location.
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Revision History
Version Description of Revision
1.0 First Issue
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