TECHNICAL AND REGULATORY NEWS No.

12/2021 – STATUTORY

NEW MARPOL REQUIREMENT ON

DESIGNATED FUEL OIL SAMPLING POINTS
Relevant for ship owners and managers, design offices, shipyards and flag states. June 2021

The 0.50% global sulphur limit for fuel oil used or carried for use has been in force since
1 January 2020. Three months later the so-called carriage ban took effect which prohibits
carriage of fuel exceeding the global sulphur limit in the fuel oil tanks. To follow up on the
new requirement and enable PSC to take representative samples of the fuel oil being used
onboard, in-use sampling points needs to be designated. This statutory news summarizes
the sampling point requirement.

• MARPOL delivered sample1) – this is the traditional sample

taken during bunkering, accompanying the Bunker Delivery
Note (BDN) and which represents the fuel oil delivered on
board.
• In-use sample2) – this is a new sample meant to represent
the fuel oil in use at the time and for which sampling points
shall be designated.
• On board sample3) – this is a new sample meant to repre-
sent the fuel in the fuel oil tanks, i.e. fuel oil intended to be
used or carried for use.

Application of the requirement Designating sampling points

The new requirement is introduced through Amendments
to MARPOL Annex VI given in Resolution MEPC.324(75)
adopted November 2020 and will enter into force (EIF)
on 1 April 2022. The deadline for designating the in-use
sampling points is dependent on the IAPP renewal survey
for each ship:
• Existing ships which are keel laid before 1 April 2022 will
be required to designate sampling points no later than the
first IAPP renewal survey on or after 1 April 2023.
• Newbuilds keel laid on or after 1 April 2022, sampling
points needs to be in place and designated on delivery.
The sulphur requirements in MARPOL applies to all fuel oil
intended for combustion purposes for both propulsion and
on board operations, meaning that all fuel oil systems serving
main engines, auxiliary engines, boilers, incinerators, IG gen-
erators, emergency equipment and other consumers shall
be fitted with designated sampling points. The only exemp-
tion is fuel oil service systems for low-flashpoint fuel having a
flashpoint less than 60°C.
Fuel oil samples under MARPOL
Following the new amendments there are now three defined
fuel oil samples under MARPOL, each provided with a set of
IMO guidelines:
“Designating” is meant to clearly identify the sampling point
to be used for the purpose of taking the “In-Use sample” as
per MARPOL Annex VI. This should be done by marking the
sampling points and identify it on the relevant piping diagram.
When designating sampling points consideration should be
given to possible fuel oil cross-contamination and service
tank arrangements. The different fuel oil grades being used
to be considered and the location should be as close to the
consumer as safely feasible, considering fuel oil temperature,
pressure and flowrate. For a common fuel oil supply line serv-
ing one or more consumers, a single sampling point may be
acceptable.
Verification of compliance will be followed up at the first IAPP
renewal survey on or after 1 April 2023, confirming the number
and location of designated sampling points. On completion
of the IAPP renewal survey the new IAPP Certificate will reflect
that the vessel is fitted with designated sampling points.
Fitting of new sampling points
While the preferred solution may be to designate already
existing sampling points, fitting and designating new sampling
points may in some cases be the only option. For such cases,
DNV will not require any formal drawing approval, unless
modifications other than fitting sampling points are done to

1)
MEPC.182(59) - 2009 GUIDELINES FOR THE SAMPLING OF FUEL OIL FOR DETERMINATION OF COMPLIANCE WITH THE REVISED
MARPOL ANNEX VI
2)
MEPC.1/Circ.864/Rev.1 - 2019 GUIDELINES FOR ON BOARD SAMPLING FOR THE VERIFICATION OF THE SULPHUR CONTENT OF THE
FUEL OIL USED ON BOARD SHIPS
3)
MEPC.1/Circ.889 - 2020 GUIDELINES FOR ON BOARD SAMPLING OF FUEL OIL INTENDED TO BE USED OR CARRIED FOR USE ON
BOARD A SHIP

DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime DNV GL Disclaimer of Liability Page 1/2
the piping system, e.g. additional drainage. Please see the
annex to this newsletter for practical advice on fitting of addi-
tional sampling points in addition to the IMO guidelines 2).
Early compliance
As for many new environmental requirements we observe
that many ship managers seek to comply ahead of the
required deadlines and to document the same towards third
parties. This is also the case with this regulation, and DNV will
therefore offer early compliance upon request, documented
by a Statement of Compliance before EIF of the MARPOL
Amendments (1 April 2022) and a new IAPP certificate if
confirmation is done on or after EIF. For vessels given a State-
ment of Compliance this will also automatically be shown
on the first IAPP certificate issued after EIF. Confirmation of
early compliance may be done as part of an annual survey or
ordered as a remote survey.
DNV Compliance Planner is now available in
My Services
A new service, called Compliance Planner, has now been
introduced and is available in the My Services Fleet Status
on Veracity. The DNV Compliance Planner is a unique tool
providing an overview of your fleet’s compliance to future
regulations, and the sampling point requirements will be
made visible in the tool. Here you can opt for early compli-
ance or include the scope as part of the renewal survey,
either for individual ships or on a fleet level.
Appendix
Fitting of new sampling points.
• Existing sampling points should be designated as far as
possible. If not, new designated sampling points to be fit-
ted and verified.
• Different fuel oil grades to be used shall be taken into
account and the sampling point location to be downstream
of the in use fuel oil service tank and as close to the con-
sumer as safely feasible, considering FO temperature, pres-
sure and flow-rate.
• The sampling points shall be provided with a shut-off valve
and preferably also with a self-closing valve.
• Sampling valves shall be provided with caps to prevent
leakage when not in use.
• Sampling valves shall be easily accessible in a well-lit and
ventilated location.
DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime
Recommendations
We recommend designating existing sampling points as far as
practicable and feasible. In case fitting and designating new
sampling points, utilizing existing connections (e.g. manom-
eters) and existing drip trays/drainage should be considered.
Test out the newly launched DNV Compliance Planner where
the sampling point requirement is visible.
References
• MEPC.324(75) - Procedures for sampling and verification
of the sulphur content of fuel oil and the Energy Efficiency
Design Index (EEDI)
• MEPC.1Circ.864/rev.1 - 2019 Guidelines for on board sam-
pling for the verification of the sulphur content of the fuel
oil used on board ships
Contact
CONTACT
For customers:
DATE – Direct Access to Technical Experts via My Services on Veracity.
Otherwise:
Use our office locator to find the nearest DNV office.
• Sampling valves shall be so located that any drip or spray
cannot reach a hot surface, electrical equipment or other
source of ignition.
• Sampling valves shall be made of ductile material, such as
nodular cast iron or steel (DNV GL Rules Pt.4 Ch.6 Sec.2 1.5).
• Pressure ratings of flanges/valves - shall not be lower than
the maximum working pressure of the FO system, and not
lower than 14 bar (DNV GL Rules Pt.4 Ch.6 Sec.5 4.3.8)
• Pipe thickness - shall not be less than as required by DNV
GL Rules Pt.4 Ch.6 Sec.9.
• Drip trays shall be arranged below the sampling points to
ensure suitable drainage to a drain tank.
• The installation shall be subjected to a function test.
• The sampling point to be designated and clearly marked
both in the ER and on the relevant piping diagram.
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