Bunkers in the Americas: Marpol Annex VI Compliance

Monday, May 16, 2005
In follow-up to our announcement regarding Marpol Annex VI, Chemoil is pleased to re-iterate its full compliance as it pertains to bunker suppliers. Any fuel supplied will strictly conform with regulation 14(1) or 4(a) and regulation 18(1) of Marpol 73/78 Annex VI. Additionally, our delivery documentation (BDN, Sample Label) will contain all the required information for Marpol compliance.

Regarding sampling procedures it is our interpretation that the guidelines put forth in the Annex are just "guidelines" and as such are not mandatory procedures. We view the true objective is to provide a representative sample of the fuel being supplied. To this end, Chemoil will provide a Marpol sample that is drawn, sealed, labeled, and signed in accordance with Marpol guidelines. However, due to local practice, regulations, and available equipment, this is likely to be done at the delivering barge out-flange. As always, a vessel representative will be invited to participate in this sampling process. The overall question of sampling location, from a practical standpoint, has created much debate and many interpretations of the Annex exist.

We appreciate and respect that some of our valued customers view these sampling guidelines as mandatory and have established internal policy requiring ship side (Marpol) sampling. Chemoil would like to continue working closely with all our customers and, as such, we can arrange to have a Chemoil Representative on board the vessel during Marpol sampling when requested beforehand. Sampling and related equipment would continue to be the responsibility of the vessel. If having a sellers representative on board is required it can be done at an additional cost that would appear on the bunker invoice. At the time of placing a bunker nomination it should be made clear if this additional service is required. At this same time we can provide a cost estimate related to this added service. If a Marpol Sample drawn at the barge outflange is acceptable then this, of course, will be provided with no additional cost.

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