In general regulation 18 is not directed to ships, rather to fuel oil suppliers and their control by the appropriate authorities together with other regulatory aspects. Regulations 18.9 together with regulations 18.1, 18.3, 18.4 and 18.5 refer to the local control of fuel oil suppliers.

The revised bunker delivery note includes the below supplier’s declaration, according to which the fuel oil supplied to the ship should meet the sulphur limit as per regulation 14.1 (worldwide limit – currently 3.50%) or regulation 14.4 (emission control areas – ECAs). As a proactive measure, the related declaration prevents the supply of fuel oil to ships exceeding the worldwide limit.

As per Resolution MSC.286(71), revised information should be included in the bunker delivery note (BDN), as described here below:

The bunker delivery note should be reviewed carefully as there have been cases where bunker quantity with the wrong sulphur content has been delivered, without being noticed by the vessel’s Master and Chief Engineer. After bunkering, the bunker delivery note should be signed by the supplier’s representative and counter-signed by the vessel’s representative.

The bunker delivery note should be kept on board for three years from the date of delivery to the ship. If a bunker delivery note is not issued as per MARPOL requirements, a letter of protest should be issued to the supplier (copies should be sent to the ship flag state, the local port authority, the ship owner).A copy of letter of protest should be filed on-board and should be available during port state control inspection.

Source: MSC.286(71), MEPC.1/Circ.878

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