Commercial Vessel Compliance

6/21/2016: Update from Rear Adm. Paul Thomas on the voluntary fuel sampling program

From the desk of Rear Adm. Paul Thomas, assistant commandant for prevention policy

In March 2016, the U.S. Coast Guard, with the assistance of the Environmental Protection Agency (EPA), initiated a voluntary fuel sampling program in the ports of Los Angeles/Long Beach and Baltimore. The pilot was initiated in response to industry concern that bunker suppliers are not being held accountable for the accuracy of the bunker delivery notes (BDNs) and that these suppliers should be part of the Unites State’s enforcement effort of the 0.1 percent sulfur requirement in the North American emissions control area (ECA). The pilot program was implemented to assess the accuracy of BDNs and determine if regular, wide-spread testing was appropriate.

U.S. Coast Guard port state control examiners requested samples from 47 vessels during the pilot program. Thirty seven of those agreed to provide two samples each (taken at the fuel line near the engine and at the fuel service or day tank) as part of the voluntary program. Of the 74 total samples, nine samples from six vessels came back as over 0.1 percent sulfur; the rest were all under 0.1 percent. The bunker delivery note (BDN) for all of these samples indicate sulfur levels of 0.1 percent or below.

Of the nine samples over 0.1 percent, eight ranged from 0.101 percent to 0.155 percent. Nearly all of those samples were within a statistical confidence interval that could possibly be the result of error in the analysis itself. Our examiners also concluded the position of the drain cocks on fuel tanks made contamination of the sample possible. A ninth sample came back at 0.387 percent, but since this sample came from the fuel tank and the sample from the fuel line on the same vessel tested below the 0.1 percent level, examiners concluded this sample was likely contaminated and not representative of the low-sulfur fuel oil that that vessel received and was burning.

The pilot program showed that vessel use of 0.1 percent fuel and the quality of fuel and accuracy of BDNs is generally satisfactory. While we do not intend to extend the voluntary fuel oil sampling program at this time, the Coast Guard and EPA will retain the capability to do periodic sampling and may conduct future operations to continue to verify compliant fuel use and that supplied fuel meets the 0.1 percent requirement as shown on the BDN. We remain committed to ensuring compliance with MARPOL Annex VI, and we likewise encourage vessel operators to conduct their own testing for this purpose.

The Coast Guard will continue to examine BDNs and log entries to ensure compliance with MARPOL Annex VI and we will exercise our authority to take fuel oil samples as part of expanded MARPOL compliance exams when needed.

I thank the vessel Masters and crews, the Coast Guard units, and the EPA analysis teams that participated in this voluntary sampling program. We welcome your comments on this initiative.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.