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” jointly draw samples at receiving vessel manifold to be sealed by supplier. Further, many barges are not equipped with ap- proved sampling devices. We have seen many instances wherein supplier samples are taken through a spigot on the barge in a short period of time and sealed. This, of course, is not a true representative sample. In the event there is a Coast Guard challenge, the testing process would most likely be done on the Marpol sample. That 500ml of fuel could be the difference in avoiding costly legal battle/fi nes with PSC. By drawing truly representative samples and having them testing by an independent laboratory if there is a determination for off specifi cation sulfur, a letter of protest (basis procedural requirements of ship’s fl ag administration) should be issued with copies to supplier, PSC, and records for the ship. Another issue we see is that the supply community is sell- ing fuel basis an ISO set of standards. This confl icts to some degree with IMO standards governing Marpol. With ISO, one could interpret basis reproducibility and repeatability that a 1.05% fuel is within specifi cation of 1.0%, while the IMO is a bit stricter and would, after verifi cation process, deem a 1.01% fuel out of specifi cation. So what can an owner/operator do to try and protect their interests? For starters, one could negotiate with suppliers to have sulfur levels basis IMO verifi cation standards as opposed to ISO on precision. Prudent procedures would dictate that if there is any suspicion of the levels pushing above 1.00, then do not burn those bunkers in the ECA zone and treat as HS fuel. The next area of training would be the technical aspects. Make sure that crews have a standard operating procedure (SOP) and are profi ciently trained with a change-over calcula- tor. This ensures the high sulfur fuel has been fl ushed out with 1.0% or under entering the combustion chamber, before enter- ing the 200 mile zone. Crews also need an SOP for changing over from a residual fuel to a distillate. We can simply look back to 2009 when CARB (California Air Resource Board) was introduced and numerous vessels lost power during the switchover process. A specifi c changeover practice that has been tested needs to be set up, (in conjunction with engine manufacturer recom- mendations), to ensure no loss of power due to issues such as viscosity. Compatibility of fuels will also need to be tested before the mixing of any two fuels. Circling back to the changing refi nery landscape, as the traditional supply chains are disrupted and less residual is available, the potential increases for incompat- ibility and asphaltenes falling out of suspension. That’s a situ- ation that can’t be reversed and can lead to catastrophic engine failure. In this event, compatibility testing should be done as a standard practice. Opening Day Expectations So what might we expect from the USCG? According to statistics posted on the USCG web site there were a total of 28 vessels detained at US ports in the 1st quarter of 2012 for Marpol Annex VI violations. Looking at other Port State Con- trol areas in 2010, The Netherlands PCS sampled and tested 135 vessels for sulfur verifi cation. From January to July 2010 there were 72 vessels tested of which 5 were not in compli- ance. From July 2010 through December 2010 there were 63 vessels tested of which 46 were not in compliance. Of these 46 vessels, 10 had actions taken against them including fi nes. Given the long standing role the USCG has had with IMO, we expect active enforcement on August 1st. By taking the time to review fundamentals, set up game plans, and practice those skills, your team should be ready to compete in the new season. “ With ISO, one could interpret basis reproducibility and repeatability that a 1.05% fuel is within specifi cation of 1.0%, while the IMO is a bit stricter and would, after verifi cation process, deem a 1.01% fuel out of specifi cation. The Author Rob Leventhal is Vice President of Sales and Marketing for Oiltest Marine Services. He is a member of the Connecticut Maritime Association and IBIA. www.maritimeprofessional.com | Maritime Professional | 57 MP #2 50-64 NEW STYLES.indd 57 5/4/2012 6:30:54 PM
