Lloyd’s Register FOBAS Marine Consultancy Services Services are provided by members of the Lloyd’s Register Group Lloyd’s Register, Lloyd’s Register EMEA and Lloyd’s Register Asia are exempt charities under the UK Charities Act 1993. ”Sampling & Test Accuracy under the umbrella of emissions legislation“ Presented by: Timothy Wilson CEng. MIMarEST FOBAS Product Manager & Dr. Anthi Miliou Phd FOBAS EMBS Bunker Summit Athens 2007
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”Sampling & Test · Aluminium plus silicon, mg/kg max. 80 80 80 80 80 ISO 10478 Used lubricating oil (ULO) Zinc, mg/kg Phosphorus, mg/kg Calcium, mg/kg - - - The fuel shall be free
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Lloyd’s Register FOBAS
Marine Consultancy Services
Services are provided by members of the Lloyd’s Register Group Lloyd’s
Register, Lloyd’s Register EMEA and Lloyd’s Register Asia are exempt
charities under the UK Charities Act 1993.
”Sampling & Test
Accuracy under the
umbrella of emissions
legislation“
Presented by:
Timothy Wilson CEng. MIMarEST
FOBAS Product Manager
&
Dr. Anthi Miliou Phd
FOBAS EMBS
Bunker Summit
Athens 2007
Lloyd’s Register FOBAS
Marine Consultancy Services
Environmental legislation on ship emissions
& Improve
air quality
NOx
CO2
VOC
SOx
(PM)
To reduce
acidification
& global warming
Setting limits requires the CORRECT application of recognised international standards
and procedures to demonstrate compliance and resolve disputes
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Two cases of SECA non – compliance?
• 2 spot sample inspections – Klaipeda 2007
• + barge vs ship samples discrepancies
• Why? Who is responsible?
• The analysis of any fuel can be
constructively interpreted given THREE
conditions:
1. Sample is representative
2. Test method is correct
3. Rules for interpretation are applied
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Overview of Marine Fuel Specification – ISO 8217:2005
User‟s Requirements for a fuel
• Safe handling and easy to transfer
• Stable at all stages of operation
• Capable of being adequately cleaned of catalyst fines, dirt and water
• Easy to ignite and combust
• Non- Corrosive
• ISO 8217 covers the points listed above to protect the user
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ISO 8217:2005 Structure
• Classification of fuels through:
• ISO 8217 -1 Categories of marine fuel
• International Statutory Requirements
• IMO – SOLAS – Flash point
• IMO – MARPOL Annex VI (14) – Sulphur
• Tables: 1 & 2
• 1 Requirements for Marine Distillates
• 2 Requirements for Marine Residual Fuels
• 9 - Informative Annexes (3rd 2005 edition)
• When an order is given based on ISO 8217 the fuel required is to meet not only the specifications of Tables 1&2 but also the documents’ and notes in its entirety.
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Grade Changes in 3rd edition
• Distillate fuels
No changes, we still have: DMX, DMA, DMB &DMC
• Residual fuels
Reduced from 15 to 10 removing:
RMC 10, RMH 45, RMK 45, RML 45 & RML55
Category ISO-F-
Characteristic Limit RMA
30
RMB
30
RMD
80
RME
180
RMF
180
RMG
380
RMH
380
RMK
380
RMH
700
RMK
700
Test method
reference
Density at 15 °C, kg/m³ max. 960,0 975,0 980,0 991,0 991,0 1010,0 991,0 1010,0 ISO 3675
•Reproducibility, R : The difference between two test results independently obtained by different operators in different laboratories on nominally identical test material.
•How well can I expect to agree with other laboratories
• Repeatability, r : The difference between successive test results obtained by the same operator with the same apparatus under constant operating conditions on identical test material
•How well can I expect to agree with myself
x
Infinite results
from infinite Laboratories
One result in a grey area exceeding the limit
but within test reproducibility, is NOT a TRUE
figure so when is the fuel compliant?
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MARPOL Annex VI Sulphur Test Method
ISO 8754:2003
Specified Sulphur
Max Limit (% m/m)
Lower Limit - Supplier
95%
Upper Limit - Buyer
95%
4.50 4.28 4.72
1.50 1.42 1.58
0.20 0.18 0.22
0.10 0.09 0.11
„S‟ Test Accuracy to 95% confidence
The Supplier can consider the result
to MEET the regulation with 95%
confidence if his single
result is < or = to 1.42% m/m
The Buyer can consider the sample to FAIL
the regulation with 95% confidence if his
single result is greater than 1.58% m/m
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Buyer and Supplier cannot agree on single result!
1. If results fall into the grey area then the same sample should be re-tested by another laboratory in order to produce further results, within the (R),
• average of each labs (r) and between labs will indicate the true value.
2. If there is still dispute then ISO 4259 stipulates further procedures
for reaching conclusion and resolving dispute:
• Paragraph 10: Rules on acceptance and rejection of results in case of
dispute. This procedure is only for situation where the two labs are
analysing fuel samples that are subdivisions of same representative
sample!
• Paragraph 9: Guidance on the reliability of a single test.
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Setting the stage –
1. +Which Test method
• ISO 8754:2003 is the Sulphur test used in ISO 8217, referred to in the
Appendix V of MARPOL Annex VI. Logical and correct that this is
used.
2. +Laboratory accreditation
• ISO 17025 - important to ensure the highest of technical standards and
test method precision and accuracy are maintained.
3. +Representative sample – apply “best practice”
• ISO/TR 13739 (Soon will be an ISO standard) – SS CP60 by example
4. -The problem is that any avoidance of the implementation of correct
sampling and testing procedures and rules may lead to a ship
The quality of EVIDENCE collected will determine the
representative status of the test result and the success of any
investigation’
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WHERE to draw the sample from?
• MARPOL ANNEX VI MEPC.96(47) Sampling guidelines. Sample to be drawn at the receiving vessel’s bunker manifold.
• ISO 8217 states: “When used in connection with commercial transactions, this International standard specifies the required properties for marine fuels at the time and place of custody transfer”
• “Samples for quality verification can be taken in any location agreed between the parties”
• Custody transfer point = Where Title & Risk changes hands.
Both parties applying best practice avoids mistrust!