NEW NAVIGATOR SHIP MANAGEMENT

Marine Fuel Sulphur Record Book

For the Control of Sulphur
Oxide Emissions
73/78 MARPOL Annex VI Reg. 14 & 18
& Annex 2 Resolution MEPC.96(47)

Regulations for the Prevention of Air Pollution from Ships

Ship Name ………………………………………………………………………………………………………

IMO No. …………………………………………………………………………………………………………

Date Log commenced ………………………………………………………………………………

Owner Name…………………………………………………………………………………

Location of IMO Samples………………… ……………………………………………….

Location of Bunker Delivery Note (BDN)……………………………………………………

SQMS Reference: ……………………………………………………………………………….

Contents
NO. DESCRIPTION PAGE

1 Introduction 3

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2 Regulatory Requirements Overview 3

3 Supplier is to comply with… 3

4 Ship’s Master is to comply with… 3

5 The Log Sheets 4

6 BDN and Statutory Sample compliance checklists 4

7 Letter of Protest 4

8 Ship’s Strategy in compliance to Annex VI Reg.14 5

9 Appendix 1 Checklists to verify Supplier’s compliance to the BDN 6

and Annex VI Fuel Sample

10 Appendix 2 - Letter of Protest 7

11 Log 1 – Bunker Details 8

12 Log 2 – BDN and IMO Annex VI Records 9

13 Log 3 – Custody transfer Log 10

14 Log 4 – Fuel change over Log for Ships entering and leaving a 11
SECA

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1. INTRODUCTION

This MARPOL 73/78 Annex VI Reg.14 & 18 record book allows ships to simply
demonstrate their and the supplier’s level of compliance with this regulation and at the
same time maintain a system to track the statutory sample, sample custody transfer,
BDN and any notes of protest issued.

This logbook does not supersede any flag administration requirements for the
maintenance of Annex VI Reg.14 & 18 records on board ships.

2. REGULATORY REQUIREMENTS OVERVIEW

a. Supplier is to comply with:

 Reg. 18 (7) (b), which states that the Supplier is to provide a compliant
Bunker Delivery Note (BDN)
 Reg. 18 (7) (b), which states that the Supplier is to provide a representative
sample of the fuel oil delivered. This sample is to be used solely for
determination of compliance with Annex VI MARPOL 73/78 by port state
authorities.
 Resolution MEPC. 96(47) Guidelines for the sampling of the fuel oil, which
requires that the IMO sample should be taken at the receiving ship’s
bunker inlet manifold according to specified procedures.
 Reg. 18 (1) (a) & (b), which requires the fuel to be of a specified quality.

b. Ship’s Master is to comply with:

 Reg. 14 (1), which states that the sulphur content of any fuel used on board
shall not exceed 3.5% m/m.
 Reg.14 (4), which requires ships to demonstrate that whilst the ship is
passing through a SOx emission control area (SECA) it is either:
 (4) (a) using fuel which has a sulphur content not exceeding
0.1% m/m or:
 (4) (b) & (c) using an approved exhaust gas cleaning device or
any other technological method which ensures that the total
emission of sulphur oxide from the ship does not exceed 0.4 g
SOx/kW h.
 Reg. 14 (6) for those ships using separate fuels to comply with Reg14 (4) (a)
records must be kept on the completion of any fuel-changeover procedure
when entering and leaving a SECA to verify compliance. The records shall
include the date, time and position of the ship when the fuel changeover is
complete. It shall also record the quantity of the low sulphur fuel in each
tank.
 Reg. 18 (4), which states that the ship is to retain the BDN, readily
available for inspection, on board the ship for a minimum of 3 years.
 Reg. 18 (6), which states that the IMO sample is to be retained under the
ship’s control until the fuel is substantially consumed, but in any case for a
period of not less than 12 months from the time of delivery.
 Resolution MEPC.96 (47) (9), which requires that the ship’s master should
develop and maintain a system to keep track of the retained samples.

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3. THE LOG SHEETS

The record book contains four log sheets with accompanying check lists they are

a) Log 1 – Bunker Details: Covering the key bunkers details linking the independent
analysis report to the bunker operation.
b) Log 2 – BDN and Annex VI Sample records: This notes the compliance record of
the Bunker Delivery Note (BDN) and the Annex VI Statutory representative
sample. It also logs details of any Letters of Protest (LOP) issued and the disposal
dates of the Annex VI sample and the BDN.
c) Log 3 – Custody transfer log: This provides a mechanism by which the ship can
track the movements of the bunker statutory sample.
d) Log 4 – Fuel change over log for ships entering and leaving a SECA.

Note: Log 1 & 2 will need to be completed for each separate bunker. Log 3 & 4 to be
completed when applicable.

4. BDN and Statutory sample compliance check lists

In Log No.2 you are required to identify whether the BDN and Statutory samples are
fully compliant with the requirements of Annex VI Reg. 18.

See Appendix 1 for the two main check lists 7(a) & 7(b).

5. LETTER OF PROTEST.

In event that either the BDN or the statutory sample, or both, have been found to be
non-compliant, a LOP should be issued in accordance with the ship’s standing
instructions. We recommend that the ship’s flag administration is consulted as to
whether they have any procedural requirements for LOP’s.

However if no standing instructions exist then it is recommended that three copies of the
LOP may be issued. One to the supplier, one to the port state authority over seeing the
registration of the suppliers and a final LOP for the ship’s records.

Issuing of the LOP will demonstrate the ship’s understanding of Annex VI requirements
putting the onus on the supplier in the event that a port state authority challenges any
non-compliance identified.

See Appendix 2 for an example of an LOP for the purposes of these regulations. This may
be used in the event that the ship does not already have a standing instruction from its
owner.

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6. Ship’s Strategy in compliance to Annex VI Reg.14

For ease of crew reference it is recommended that the ship operates on of the following
strategies whilst navigating in a SECA.

Option 1 – The ship is not intending to operate in a SECA

Option 2 – All heavy fuel oil carried on board is less than 0.1%m/m Sulphur
Content

Option 3 – Dual Fuel operations with sulphur >0.1% & <3.5% HFO – Change
over procedures will apply.

Option 4 – Exhaust Gas Cleaning System installed

Option 5 – Alternative technological method – please specify.

(Allow 3-5 lines for comments)

Option 6 – Strategy for handling boundary emission regulations, such as those

imposed by the EU and USA – please specify.

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7. Appendix 1 Checklists to verify Supplier’s compliance to the BDN and Annex VI fuel
sample.

a. The BDN must include the following details

Compliant
Record
Y/N
1 Name and IMO number of receiving ship
2 Port of bunkering
3 Date of commencement of delivery
4 Name, address, and telephone number of marine fuel oil supplier
5 Product name(s)
6 Quantity (metric tons) of bunkers delivered
7 Density at 15 deg.C (kg/m3) *
8 Sulphur content (%m/m) † (actual figure)
9 A declaration signed and certified by the fuel oil supplier’s
representative that the fuel oil supplied is in conformity with
regulation 14(1) or (4)(a) and regulation 18(1) of Annex VI.
10 Fuel oil should be tested in accordance with ISO 8217.

b. The Annex VI fuel sample can only be considered in compliance if the following have
been confirmed. (MEPC.96.47)

Compliant
Record
Y/N
1 Sampling point was the receiving ship’s inlet bunker manifold
2 Sample was drawn from an approved sampling device
A means was provided to seal the sampling equipment throughout
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the supply.
4 Primary sample was sealed & attached to sampler
5 Sample was not tampered with during bunkering
Sample was drawn by continuous drip throughout the bunker
6
delivery period
7 Sample collected is not less than 400ml
8 Label with specified information is securely attached. Label to
include: • Date of commencement of delivery • Name and IMO No.
of receiving ship • Method by which sample was drawn • Location
at which the sample was drawn • Name of bunker tanker/bunker
installation • Names and signatures of supplier’s and ship’s
representatives. • Details of seal identification. • Bunker Grade
9. Tamper-proof security seal with unique identification is installed by
supplier in the presence of the ship’s representative.

10. Annex VI Sample Seal details recorded on the BDN – (Note all
samples drawn, signed and witnessed at the inlet manifold should
have their seal details recorded on the BDN)

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Letter of Protest
Non Compliance with MARPOL 73/78 Annex VI 14 & 18

Port:

Date:
Receiving Vessel Name : IMO #

Delivery Vessel/Installation: IMO #

BDN Reference Number:
Annex VI Sample Ref. No.

To Supplier:

Copied to Port State Authority:

On behalf of my principal(s), I <Name and Rank> hereby register the following item(s)
which may be regarded as being non-compliant with reference to MARPOL 73/78 Annex
VI 14 & 18.
Further details as necessary will be advised if requested.

<Signature & Supplier’s Stamp> <Signature & Ship’s Stamp>

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Log No. 1 – MARPOL Annex VI – Bunker Sample BDN Records

Supplier
Bunker Barge Sulphur Content – Fuel loaded Independent
Bunker Port Supplier Registered with Fuel Grade /
Date / Name / BDN / Tested into storage analysis report
Operation No. Name Name Port State Qty (MT)
Time IMO No. (%m/m) tank No. Ref:
Authority
EXAMPLE 28/02/05 Lisbon “Carlos fuel” Yes – No 123456 Carlos/ IFO 380/497 <1,5 / 1,37 2 DB – 275 “VISWA no xxxxx”
09.22 – 987654
12.04
1

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BDN: Bunker Delivery Note

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Log No. 2 – MARPOL Annex VI – BDN Sample Records

Note of Protest
Annex VI
Copy to: Date
Annex VI Compliant Letter Of Date Remarks &
Bunker BDN Sample 1 – Supplier Sample Date BDN
Compliant Y/N Y/N (See Protest Fuel Signature
Operation Reference Seal 2 – Port State Destroyed destroyed >3
(see procedure sampling Issued? Consum of Duty
No. No. Number Authority >12 years
for BDN content) procedures (Y/N) ed Engineer
3 – Vessel months
)
(Y/N)
1–Y Supplier did
06/03/02
EXAMPLE 018XX4321 Y 4567 N – ref…… Y 2–Y not accept
005 / NN
3–N LOP / ABC
1

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Log No. 3 – MARPOL Annex VI – Sample Custody Transfer

PSA custody Date &
Annex VI Port of Name, Signature Address & Remarks &
Ref. To Bunker BDN Ref. Transfer Form Time of
Sample Seal Custody and Stamp of Contact Details Signature of Duty
Operation No. No. Reference Custody
No. Transfer Receiver of Receiver Officer
Number Transfer
(Example) 6 06XX1234 789 Singapore SHA1234067 03-Mar-04 Mah – xxx – stamp ABCDEFGH…. Rdam. PSC reqs.
Sample for ……

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Log No. 4 – MARPOL Annex VI – Fuel Change Over

Quantity of Low Total quantity
Bunker Change
SECA Position of Position of Sulphur Fuel in (MT) of fuel
Operation Over Remarks and Signatures of
Passage – Ship – Ship – Storage tanks (MT) at consumed up to
No. of Fuel Completion Duty Engineer
Start or End Longitude Latitude end of change over change over
Received Date & Time
procedure completion
05-May-2005 S: 05/05/2005 2 DB – 210: [Link] – 24; Changed to lower TBN Cyl. Oil. /
(Example) 3 04 04 48 N 81 43 18 W 4,7
12.45 hrs 14.24.00 Service tk. – 20 s/E “Low Nox”

The Columns are to be completed in accordance with Annex VI Reg.14 (6) – Entering sample in the first line

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