Bunkering Operations and Fuel Quality Control
MARPOL VI/18 governs the BDN and representative sample, not a universal checklist; from 2026 SOLAS requires the supplier declaration/test method and a BDN with measured flashpoint or a statement measured at or above 70°C.
Operational Explanation
MARPOL VI/18 governs the BDN and representative sample, not a universal checklist; from 2026 SOLAS requires the supplier declaration/test method and a BDN with measured flashpoint or a statement measured at or above 70°C.
Regulatory Reference
MARPOL Annex VI/18; SOLAS II-2/4.2.1.6 and MSC.520(106). Checklist from SMS/terminal/local/contract practice.
For ships subject to the relevant MARPOL VI/18 requirements, retain the BDN aboard for at least three years after delivery. Keep the representative sample under the ship’s control until the fuel is substantially consumed and for at least twelve months. Identify seal, label and link to the BDN; a commercial laboratory sample does not automatically replace the regulatory sample. IMO: MARPOL VI/18.
The SOLAS declaration must be available before bunkering, signed and certified by the supplier’s representative, with conformity statement and flashpoint test method. The 70°C threshold concerns the documentary alternative to a measured value: it does not replace the general 60°C fuel-use limit with 70°C, subject to applicable exceptions. IMO MSC.520(106).
Where MARPOL VI/18.8.1 applies, on completion of bunkering the representative sample must be sealed and signed by the supplier’s representative and the master or officer in charge of the operation. This is a regulatory sample requirement, distinct from the supplier’s SOLAS declaration. First verify applicability to the ship and fuel, including the specific provisions for gas and low-flashpoint fuels. IMO — MARPOL VI/18.8.1. BDN / MARPOL sample.
Scope of Application
Every bunkering; compliance below 60°C is assessed against the exact approved SOLAS arrangement, not only an emergency-generator exception.
Procedure / How to Complete It
- Complete the ship/terminal checklist required by SMS and port.
- Before bunkering verify the supplier's signed/certified SOLAS declaration and test method.
- Verify BDN: measured flashpoint or statement measured at or above 70°C.
- Keep the SOLAS declaration distinct from the MARPOL-delivered sample.
- Assess below-60°C branches only when expressly permitted and approved.
Practical Example
A BDN states the measured flashpoint: the team also checks declaration and test method against the ship's approved arrangement.
What Typically Goes Wrong
Attributing the checklist to MARPOL, checking only ≥60°C on the BDN, or treating 43°C emergency generator as the sole branch below 60°C.
Common Mistakes Mistake Library
| Mistake | Consequence | How to Avoid It |
|---|---|---|
| Attributing the checklist to MARPOL, checking only ≥60°C on the BDN, or treating 43°C emergency generator as the sole branch below 60°C. | Non-compliant decision or treatment | Follow the approved arrangement and applicable sources |
What the PSCO Checks
Operational Tips
- Separate current requirement, class/maker, SMS and voluntary guidance.
- Do not improvise tests, thresholds or intervals.
- Record deviations and corrective action.
Preparation checklist
- Applicable checklist complete
- Signed/certified declaration
- Test method available
- BDN flashpoint compliant
- MARPOL sample distinct
FAQ
Related Topics
Last substantive revision of this page: 16 September 2026 · page fingerprint 8dd5274eb88e