1 INTRODUCTION
                     
                     
                     
                     1.1 MARPOL Annex VI contains requirements that apply to
                        fuel oil used on board ships. Regulation 14 of MARPOL Annex VI sets limits on the
                        sulphur content of fuel oil used on board ships, both within designated SOX
                        Emission Control Areas (regulation 14.4) and outside those areas (regulation 14.1). Regulation 18.3 contains requirements that fuel oil delivered
                        to and used on board ships shall not jeopardize the safety of ships or adversely affect
                        the performance of machinery.
                     
                     
                     
                     
                     1.2 Fuel oil purchasers are responsible for correctly specifying the fuel oil which is to
                        be supplied. It is the responsibility of the supplier to deliver fuel oil which is
                        compliant with the agreed specification.
                     
                     
                     
                     
                     1.3 These best practices are intended to assist fuel oil purchasers/users in assuring the
                        quality of fuel oil delivered to, and used on board ships, with respect to both
                        compliance with the MARPOL requirements and the safe and efficient operation of the
                        ship.
                     
                     
                     
                     
                     1.4 These best practices are recommended for all ships and should also be taken into
                        account in those cases where fuel oil purchasing decisions are made by the ship
                        charterer pursuant to a chartering agreement. Under such a charter agreement,
                        communication between the owner and the charterer is paramount. It is recommended that
                        clear requirements on these communications should be included within the appropriate
                        charter party clause.
                     
                     
                     
                     
                     1.5 It should be noted that, under MARPOL Annex VI, compliance with regulation 14 begins with sourcing and purchasing compliant
                        fuel oil and mitigating the risk of poor quality fuel oil being delivered to the
                        ship.
                     
                     
                     
                     
                     1.6 These best practices do not comprehensively address fuel oil handling procedures
                        subsequent to fuel oil loading:
                     
                     
                     
                     
                        - 
                           
                           
                           
.1 on board fuel oil management is an important element of preventing operational
                              issues and sulphur non-compliance. Improper handling of fuel oil on board may
                              lead to non-compliance with MARPOL requirements, even if the fuel oil received was
                              compliant;
                           
                           
                           
                         
                        - 
                           
                           
                           
.2 marine fuel oil completely meeting a recognized standard, such as ISO 8217
                              purchase specifications, still requires fuel oil treatment before it meets most
                              manufacturers' requirements for combustion, particularly residual grades;
                           
                           
                           
                         
                        - 
                           
                           
                           
.3 to ensure continued compliance once compliant fuel oil is delivered on board,
                              ships should have suitable procedures and documents for use and safe handling of
                              fuel oil on board. These procedures should form part of the company's Safety
                              Management System (SMS) as required by the ISM
                                 Code, supported by equipment operating and maintenance manuals;
                              and
                           
                           
                           
                         
                        - 
                           
                           
                           
.4 each ship should be provided with on board fuel oil change over procedures
                              (where applicable). Crew members should receive appropriate familiarization in
                              implementing these procedures.
                           
                           
                           
                         
                     
                     
                     
                     
                     1.7 When developing their onboard procedures, ship operators should also consider the
                        guidance provided by existing industry practices and standards, for example those
                        published by the International Organization for Standardization (ISO).
                     
                     
                     
                     
                     1.8 There is increasing interest in low sulphur fuel oils, which are being developed as
                        an alternative to conventional marine heavy fuel oils or low sulphur distillate oils
                        specified by ISO 8217 Petroleum products – Fuels (class F) – Specifications of marine
                        fuels. These fuel oils may be blends which carry a higher risk of incompatibility with
                        other fuels than is the case with more traditional fuel oils, and therefore it may be
                        necessary to clean storage tanks and fuel piping before handling such fuel oils.
                        Machinery and fuel oil handling systems may require modification in order to use such
                        fuel oils safely and reliably.
                     
                     
                     
                     
                     1.9 Fuel oil purchasers considering the use of such fuel oils should engage with
                        suppliers to establish any special requirements for such products and perform a detailed
                        technical analysis, including issues of compatibility and whether it will be necessary
                        to make modifications and adjustments to machinery and fuel oil handling systems before
                        ordering the product.
                     
                     
                     
                     
                     1.10 It should be noted that unintended contamination of a product may happen in any part
                        of the supply chain, including on board bunker barges. This is especially important for
                        0.10% sulphur fuel oil since any contamination with higher sulphur content fuel oil is
                        likely to result in that batch of fuel oil becoming non-compliant.
                     
                     
                     
                     
                     2 DEFINITIONS
                     
                     
                     
                     2.1 SOLAS
                              Convention: International Convention for the Safety of Life at Sea,
                        1974, as amended.
                     
                     
                     
                     
                     2.2 MARPOL
                              Convention: International Convention for the Prevention of Pollution
                        from Ships, 1973, as amended.
                     
                     
                     
                     
                     2.3 ISM
                              Code: International Safety Management Code.
                     
                     
                     
                     
                     2.4 Fuel oil purchaser/Purchaser: Secures and pays for bunkers delivered to a ship
                        at the operator side (user) and not a trader. Can be a shipowner's operator or a
                        charterer's operator; and often used in contracts as counterpart of the supplier.
                     
                     
                     
                     
                     2.5 Trader: The trader buys bunkers from a physical supplier and sells to a
                        purchaser without holding the product physically.
                     
                     
                     
                     
                     2.6 Broker: The broker is used by purchasers and physical suppliers to facilitate
                        buying and selling of fuel oil.
                     
                     
                     
                     
                     2.7 Physical supplier/Supplier: Buys, owns and stores fuel oil and sells bunkers.
                        Distributes bunkers from pipelines, trucks and/or barges. May blend products to meet the
                        customer's specifications. May own or charter a distribution network or may hire a barge
                        provider from supply to supply. Issues the bunker delivery note (BDN).
                     
                     
                     
                     
                     2.8 Shipowner: The company which holds the International Safety Management
                        Document of Compliance for the ship under the ISM
                           Code.
                     
                     
                     
                     
                     2.9 Quality-oriented fuel oil supplier: A fuel oil supplier with a quality
                        management system certified in accordance with an internationally recognized standard
                        (ISO 9001 or equivalent), and which may be registered with the Member State and/or
                        licensed, where such licensing/accreditation schemes are in place; and therefore can be
                        expected to be on time, meet the statutory requirements, supply the quantity and quality
                        stated on the BDN, provide support and be able to address relevant issues.
                     
                     
                     
                     
                     3 GOALS
                     
                     
                     
                     3.1 The best practices set forth in this document reflect a set of goals intended to
                        assure the quality of fuel oil used on board ships, as follows:
                     
                     
                     
                     
                        - 
                           
                           
                           
.1 support informed decision-making by fuel oil purchasers;
                           
                           
                         
                        - 
                           
                           
                           
.2 guide fuel oil purchasers in ordering fuel oil of the correct specification
                              and implementing measures to confirm that the fuel oil delivered is compliant
                              with this specification;
                           
                           
                           
                         
                        - 
                           
                           
                           
.3 encourage proper interactions between the ship crew responsible for fuel oil
                              handling and all other parties (including the fuel oil supplier) from when fuel
                              oil is ordered up to the point of delivery;
                           
                           
                           
                         
                        - 
                           
                           
                           
.4 mitigate or minimize risk for technical or administrative problems emanating
                              from bunkering of fuel oil;
                           
                           
                           
                         
                        - 
                           
                           
                           
.5 avoid disputes in the supply process; and
                           
                           
                         
                        - 
                           
                           
                           
.6 promote compliance with all aspects of regulations 14 and 18 of MARPOL Annex VI which specify the permissible
                              sulphur content in fuel oil and the quality of marine fuel oil.
                           
                           
                           
                         
                     
                     
                     
                     
                     3.2 The best practices provided in section 4 are intended to assist fuel oil purchasers
                        to achieve the above goals.
                     
                     
                     
                     
                     3.3 Where a ship is exempted from some of the provisions of MARPOL Annex VI under regulation 3 of the Annex, or will comply with the requirements
                        of the Convention using an equivalent means under regulation 4 of the Annex, fuel oil purchasers should consider
                        any conditions attached to the exemption or equivalent means which may affect fuel oil
                        purchasing.
                     
                     
                     
                     
                     4 BEST PRACTICES
                     
                     
                     
                     General
                     
                     
                     
                     4.1 The fuel oil purchaser should ensure that the fuel oil ordered is correctly specified
                        considering the ship's known technical capabilities and intended area of operation.
                        These requirements should be communicated to the charterer in those cases where the
                        charterer purchases the fuel oil (see paragraph 1.4).
                     
                     
                     
                     
                     4.2 In addition to these guidelines, fuel oil purchasers should also refer to ISO 13739
                        Petroleum products – Procedures for transfer of bunkers to vessels, relevant national
                        standards such as SS 524: 2014 – Singapore Specification for quality management for
                        bunker supply chain (QMBS), SS 600 – Singapore Standard Code of Practice for Bunkering,
                        and to industry best practices such as recommendations published by CIMACfootnote.
                     
                     
                     
                     
                     4.3 It should also be noted that engine and equipment manufacturers may have set
                        additional requirements for the quality of fuel oil to be used and those should also be
                        taken into account.
                     
                     
                     
                     
                     Choice of fuel oil supplier
                     
                     
                     
                     4.4 Fuel oil purchasers should strive to purchase fuel oil from quality-oriented fuel oil
                        suppliers. The following questions are intended to help fuel oil purchasers to identify
                        quality-oriented fuel oil suppliers:
                     
                     
                     
                     
                     4.4.1 Is the fuel oil supplier included in a local or national registry?
                     
                     
                     
                        - 
                           
                           
                           
Verify that the supplier is listed on the register of local
                              suppliers of fuel oil required to be maintained by the Parties to MARPOL Annex VI pursuant to regulation 18.9.1 of MARPOL Annex VI. Inclusion on such
                              a register is not a substitute for purchaser due diligence since the regulation 18.9.1 register is simply a list of local
                              fuel oil suppliers and the qualifications for inclusion on the register may vary
                              significantly between ports and Administrations. This information should be
                              easily accessible, in most cases the information should be available on the
                              internet.
                           
                           
                           
                         
                     
                     
                     
                     
                     4.4.2 Does the fuel oil supplier have a license issued by the coastal State or a local
                        port authority?
                     
                     
                     
                     
                     
                     
                     
                     4.4.3 Does the fuel oil supplier have a quality management system (QMS) in place?
                     
                     
                     
                        - A quality-oriented fuel oil supplier should have a QMS meeting
                           the requirements of ISO 9001 Quality management systems – Requirements and ISO 14001
                           Environmental management systems – Requirements with guidance for use (or equivalent
                           national standards). The QMS should include references to the standards which the
                           supplier will adhere to along with any independent third party accreditation of the
                           QMS or elements of the QMS.
                        
 
                     
                     
                     
                     
                     4.4.4 Does the fuel oil supplier have procedures for fuel oil transfer operations?
                     
                     
                     
                     
                     
                     
                     4.4.5 If fuel oil will be delivered using barges or tankers, fuel oil purchasers should
                        request that information on quality assurance for these vessels should be included
                        within the information provided on their QMS (see paragraph 4.4.3).
                     
                     
                     
                     
                     4.4.6 Fuel oil purchasers should consider utilising other sources of information,
                        assessment methods and the reviews and experiences of other purchasers. Although third
                        party reviews and information may be of assistance to fuel oil purchasers, caution
                        should be exercised in placing undue reliance on third party opinion since it may be
                        incomplete or contain errors. These other sources of information and assessment methods
                        may include:
                     
                     
                     
                     
                        - 
                           
                           
                           
.1 consulting the reviews of others (where available) and seeking the views of
                              other purchasers of fuel oil;
                           
                           
                           
                         
                        - 
                           
                           
                           
.2 requesting that the supplier provides references from existing customers;
                           
                           
                         
                        - 
                           
                           
                           
.3 use of local knowledge, consulting local agents;
                           
                           
                         
                        - 
                           
                           
                           
.4 use of statistics. Various sources collect data concerning fuel oil supplier
                              activities which may be used by fuel oil purchasers to help them ascertain if a
                              fuel oil supplier is quality-oriented;
                           
                           
                           
                         
                        - 
                           
                           
                           
.5 reviewing information made public by Member States pursuant to
                              regulation 18.9 of MARPOL Annex VI, in particular any
                              information submitted to the Organization regarding failures by fuel oil
                              suppliers to meet the requirements of regulations 14 and/or 18 of MARPOL Annex VI;
                           
                           
                           
                         
                        - 
                           
                           
                           
.6 where available, consulting lists which grade suppliers by the quality of the
                              fuel oils supplied through testing agency data; and
                           
                           
                           
                         
                        - 
                           
                           
                           
.7 any other sources of information and assessment procedures a purchaser may
                              have in defining the reputability of the fuel oil supplier within the context of
                              this guidance.
                           
                           
                           
                         
                     
                     
                     
                     
                     4.4.7 Fuel oil testing statistics may help identify supplier-specific trends for sulphur
                        compliance and other quality parameters. Note, however, that caution is needed when
                        using this data, for example, samples which are tested above the specification limit but
                        within ISO 4259 Petroleum products – Determination and application of precision data in
                        relation to methods of test - are sometimes incorrectly reported as off-specification,
                        resulting in the statistical analysis being misleading.
                     
                     
                     
                     
                     4.4.8 It should be noted that testing agencies may not necessarily have information on
                        supplier quality of service or ability to deliver the right quantity.
                     
                     
                     
                     
                     Contracting
                     
                     
                     
                     4.5 The contract specifies the fuel oil to be supplied, and how the supplier will fulfil
                        the contractual agreement.
                     
                     
                     
                     
                     4.5.1 Where the charterer supplies the fuel oil it should be recognized that the
                        "purchaser" (the charterer) is not the same as the "user" (the ship), and their
                        interests are not necessarily aligned. In these cases, the technical requirements of the
                        user/ship should be communicated to, and taken into account, by the purchaser even when
                        the commercial interests of the "purchaser" and "user" differ.
                     
                     
                     
                     
                     4.5.2 Fuel oil purchasers may purchase fuel oil directly from a physical supplier or they
                        may utilize the services of traders or brokers when purchasing fuel oil. Traders buy and
                        sell fuel oil and carry the financial risk associated with buying and selling. A broker
                        usually works on commission and does not buy and sell the bunkers, hence they do not
                        carry the financial risk associated with buying and selling.
                     
                     
                     
                     
                     4.5.3 Purchasers should require that suppliers follow best practices with regard to fuel
                        oil quality, including a quality assurance system (see paragraph 4.4.3), and confirm
                        that procedures are in place if non-compliant fuel oil is detected or delivered.
                     
                     
                     
                     
                     4.5.4 Bunker specifications and any requirements for bunkering procedures should be
                        stated in the contract. The contract should:
                     
                     
                     
                     
                        - 
                           
                           
                           
.1 state the quantity ordered. This is usually in metric tonnes by
                              mass; however, other units are sometimes used. The unit used should be clearly
                              stated. The required maximum sulphur content of the fuel oil should meet the
                              applicable requirements of regulation 14 of MARPOL Annex VI;
                           
                           
                           
                         
                        - 
                           
                           
                           
.2 include a detailed technical specification for the fuel oil along with
                              acceptable quality parameters;
                           
                           
                           
                         
                        - 
                           
                           
                           
.3 where the fuel oil is to be specified with reference to ISO 8217 Petroleum
                              products – Fuels (class F) – Specifications of marine fuels, clearly state which
                              edition is to be used (i.e. 2005, 2010, 2012 or 2017; use of the latest edition
                              of specification is encouraged but this may not be practical in all countries)
                              or, when available, ISO/PAS 23263; and
                           
                           
                           
                         
                        - 
                           
                           
                           
.4 for non-ISO 8217 standard fuel oils, as a minimum the
                              specification should require that the fuel oils need to meet the requirements of
                              regulations 18.3.1 and 18.3.2 of MARPOL Annex VI, and SOLAS chapter II-2.
                           
                           
                           
                         
                     
                     
                     
                     
                     4.5.5 If fuel oil which is outside the requirements of regulation 14.1 or 14.4 of MARPOL Annex VI is ordered for use with an approved
                        alternative means of compliance such as exhaust gas cleaning systems, this should be
                        communicated to the supplier.
                     
                     
                     
                     
                     4.5.6 Fuel oil purchasers should include a requirement in their Quality assurance (QA)
                        system to check and approve the quantity to be ordered and quality requirement prior to
                        transmitting their order to the supplier.
                     
                     
                     
                     
                     Documentation
                     
                     
                     
                     4.6.1 Bunker delivery notes (BDNs), as required by regulation 18 of MARPOL Annex VI, should be provided by the
                        supplier. Text on the BDN should as a minimum include the requirements of appendix V of MARPOL Annex VI.
                     
                     
                     
                     
                     4.6.2 In case the product supplied differs in handling characteristics from
                        traditional/mainstream fuel oils, the supplier should provide a guide/publication of
                        best practice which includes recommendations for storage and handling of the supplied
                        product.
                     
                     
                     
                     
                     Fuel oil receiving on board, sampling and testing
                     
                     
                     
                     4.7.1 There should be appropriate record keeping on board, especially with
                        regard to maintaining the oil record book required by MARPOL Annex VI and MARPOL Annex I, regulation 17. Detailed guidance for making entries into the oil
                        record book is provided in MEPC.1/Circ.736/Rev.2 on Guidance for the recording of
                           operations in the Oil Record Book Part I – Machinery space operations (all
                           ships), as revised.
                     
                     
                     
                     
                     4.7.2 The receiving ship should have procedures for bunkering, fuel oil handling, and
                        storage of fuel oil, including spill, pollution and emergency response. Shipboard
                        emergency plans addressing different categories of emergencies are required under the
                        provisions of both the SOLAS and MARPOL
                        Conventions, the ISM Code and supporting guidance, including:
                     
                     
                     
                     
                        - 
                           
                           
                           
.1 resolution A.1072(28) on Revised
                                 guidelines for a structure of an integrated system of contingency planning
                                 for shipboard emergencies provides guidance for integrated emergency
                              response planning; and
                           
                           
                           
                         
                        - 
                           
                           
                           
.2 regulation 37 of MARPOL Annex I requires
                              ships to have a shipboard oil pollution emergency plan (SOPEP), guidance for
                              developing the SOPEP is provided by resolution MEPC.54(32) on Guidelines for the
                                 development of shipboard oil pollution emergency plans, as amended by
                              resolution MEPC.86(44).
                           
                           
                           
                         
                     
                     
                     
                     
                     4.7.3 Detailed guidance for bunkering procedures, including a sample bunkering checklist,
                        may be found in various available guidance documents, for example chapter 25 of the
                        International Safety Guide for Oil Tankers and Terminals (ISGOTT).
                     
                     
                     
                     
                     4.7.4 Clear communications should be established between the receiving ship and supplier
                        (bunker barge, truck or terminal) and emergency stop and response actions agreed prior
                        to any bunkering activities commencing.
                     
                     
                     
                     
                     4.7.5 Handling onboard should, so far as is possible, avoid co-mingling of fuel oils in
                        tanks or fuel oil lines in order to minimize cross contamination.
                     
                     
                     
                     
                     4.7.6 A representative fuel oil sample should be collected during the bunkering process.
                        Guidelines for collecting the MARPOL sample are provided in resolution MEPC.182(59) on 2009 Guidelines for the sampling of fuel oil
                           for determination of compliance with the revised MARPOL Annex VI.
                     
                     
                     
                     
                     4.7.7 The use of cameras arranged to witness and record bunkering and sampling processes
                        could be considered.
                     
                     
                     
                     
                     4.7.8 It is recommended that the fuel oil purchaser has a sample of fuel oil collected
                        during bunkering analysed to confirm that it complies with the agreed specification in
                        the contract. Sample analysis should be performed by an independent laboratory and
                        according to relevant international test standards accredited to ISO/IEC 17025 General
                        requirements for the competence of testing and calibration laboratories or an equivalent
                        national standard. Accredited laboratories in a particular country should be listed on
                        the national accreditation bodies' website. It is also recommended that laboratories
                        have an ISO 9001 Quality management systems – Requirements, or equivalent, quality
                        management system. Where possible, it is recommended that fuel oil should not be used
                        until this analysis has been completed.
                     
                     
                     
                     
                     4.7.9 Purchasers should confirm the accreditation or certification of the laboratory they
                        intend to use, in particular they should check whether any accreditation is general in
                        nature (overall lab practices) or for specific analytical methods.
                     
                     
                     
                     
                     4.7.10 The contract terms and conditions should stipulate how the laboratory analysis
                        will be carried out in the case of disputes.
                     
                     
                     
                     
                     4.7.11 In some circumstances it is not necessary to make full laboratory analyses before
                        using the fuel oil which has been delivered (e.g. fuel oil is frequently supplied on
                        contract with same supplier).
                     
                     
                     
                     
                     4.7.12 Where an analysis is required by the Administration then the analysis should be
                        carried out in accordance with the verification procedures of the Administration.
                     
                     
                     
                     
                     4.7.13 While a fuel oil purchaser/user may choose to use ISO 13739, ISO
                        4259, or other testing protocols, it should be mindful that MARPOL Annex VI sets out the procedures for compliance and
                        enforcement, including Appendix VI fuel verification procedure for MARPOL Annex VI fuel oil samples. Guidance is also provide in
                        resolution MEPC.182(59) on 2009 Guidelines for the sampling of
                           fuel oil for determination of compliance with the revised MARPOL Annex VI, and the Guidelines for onboard sampling for
                           the verification of the sulphur content of the fuel oil used on board ships
                        (MEPC.1/Circ.864). If a different test or a different
                        accreditation is desired, it can be specified in the fuel oil purchase contract itself.
                        However, that contract will not override the requirements of MARPOL Annex VI with respect to determining compliance with the
                        mandatory standards in a compliance or enforcement action brought by a flag, port, or
                        coastal State.
                     
                     
                     
                     
                     Dispute resolution
                     
                     
                     
                     4.8 Dispute handling/resolution arrangements in case of dispute should be specified in
                        the contract.