PORT MARINE CIRCULAR NO. 03 OF 2024 ADOPTION OF TESTING ENHANCEMENTS FOR MARINE FUEL INTENDED TO BE DELIVERED AS BUNKERS IN THE PORT OF SINGAPORE
MARITIME AND PORT AUTHORITY OF SINGAPORE
PORT MARINE CIRCULAR
No. 03 OF 2024
08 February 2024
Bunker Suppliers / Bunker Craft Operators / Bunker Surveying Companies / Bunker
Surveyors / Shipping Community / Laboratory Testing Community
ADOPTION OF TESTING ENHANCEMENTS FOR MARINE FUEL INTENDED TO BE
DELIVERED AS BUNKERS IN THE PORT OF SINGAPORE
- This circular serve to inform all bunker suppliers licensed by the Maritime and Port
Authority of Singapore (MPA) on the implementation of enhanced testing parameters for
marine fuel batches intended to be delivered as bunkers in the port of Singapore in addition
to the existing quality assurance measures. These testing enhancements are intended to be
carried out at the upstream supply chain for system efficiencies and cost effectiveness
compared to doing so for each delivery.
- Arising from the bunker contamination incident in Singapore in February 2022, where
about 200 ships were supplied with High Sulfur Fuel Oil (HSFO) containing high levels of
Chlorinated Organic Compounds (COC) in the Port of Singapore, an Industry Expert Group
(IEG)1 co-chaired by the MPA and Singapore Shipping Association (SSA) was formed to
strengthen the quality assurance of bunkers supplied in the Port of Singapore.
- The IEG had provided its recommendations to MPA in mid-2023, as attached in Annex
A of this circular.
- Taking into account the IEG’s recommendations and industry feedback, the following
testing enhancements (to be carried out upstream) would be mandatory from 1st June 2024
(in addition to existing quality assurance measures):
1 The IEG comprised of experts from international associations such as the International Bunker Industry
Association (IBIA) and the International Council on Combustion Engines (CIMAC), representatives from
fuel oil testing laboratories, bunker suppliers, shipowners, engine manufacturer from MAN Energy, and the
Singapore’s Health Sciences Authority (HSA).
I. For all residual and bio-residual bunker marine fuel supplied in the Port of
Singapore, bunker suppliers must ensure that they do not contain COC above
50mg/kg, and must be free from inorganic acids. Specifically,
a. COC must be tested for using the EN 14077 accredited test method
(concentration of total organic chlorine must not exceed 50mg/kg) and shall
be reported in the “Certificate of Quality” (COQ) provided to receiving
vessels;
b. Inorganic acids must be tested for using ASTM D664 accredited test
method as prescribed in ISO 8217 and the Strong Acid Number (SAN) (in
addition to the Total Acid Number (TAN)) shall be reported in the COQ (i.e.
SAN = 0) provided to receiving vessels;
II. For all distillate and bio-distillate bunker marine fuel supplied in the Port of
Singapore, bunker suppliers must ensure that they are free from inorganic acids,
which must be tested for using ASTM D664 test method as prescribed in ISO 8217
and the SAN (in addition to the TAN) shall be reported in the COQ (i.e. SAN = 0)
provided to receiving vessels.
- Residual marine fuels should also be free from polystyrene, polypropylene and
polymethacrylate. For the general detection of these polymers, the fuel can be tested using
a test method which consists of filtration, microscopic examination, and Fourier-Transform
Infrared spectroscopy (FTIR) analysis to qualitatively determine if they are present in the fuel.
It is recommended that all MPA licensed bunker suppliers maintain proper test records to
indicate that the current batch of bunker fuel supplied as bunkers in the port of Singapore is
free from these polymers. Bunker buyers are also encouraged to consult the bunker suppliers
in advance and have proper contractual agreement for the quality of fuel bunkered. MPA is
working with relevant agencies and stakeholders to enhance polymer testing capabilities and
establish standardised test method for these polymers in Singapore.
- For marine fuel which is blended using batches of different fuel or feedstock, the tests
prescribed in Para 4 must be carried out after the blending, and before being delivered as
bunkers in the Port of Singapore. Blending is not permitted on board the MPA licensed bunker
craft and the COQ must be of the fuel prior loading to the bunker tanker before the product is
delivered as bunkers in the port of Singapore.
- Please refer to Annex B for FAQs. Should you have any queries, please write to us at
bsd@mpa.gov.sg.
CAPT DAKNASH GANASEN
SENIOR DIRECTOR (OPERATIONS & MARINE SERVICES)
for CHIEF EXECUTIVE
MARITIME AND PORT AUTHORITY OF SINGAPORE
ANNEX A
Residual Marine Fuel
Compound Group Recommendation
Residual marine fuels shall not contain chlorinated
organic compounds. De minimis levels are taken as
Chlorinated Organic
when the concentration of total organic chlorine does
Compounds
not exceed 50 mg/kg using the EN 14077 test
method.
Residual marine fuels shall be free of inorganic acids.
The Strong Acid Number (SAN) (in addition to the
Total Acid Number (TAN)) shall be reported within the
Inorganic Acids
Certificate of Quality (COQ) (i.e. SAN = 0) and
according to test method ASTM D664 as prescribed
in ISO 8217.
Residual marine fuels should be free from
polystyrene, polypropylene, and polymethacrylate.
Due to the lack of standardised test methods for the
general detection of polymers, the fuel can be tested
Polymers
using a test method which consists of filtration,
microscopic examination, and Fourier-Transform
Infrared spectroscopy (FTIR) analysis to determine if
they are present in the fuel.
Distillate Marine Fuel
Compound Group Recommendation
Distillate marine fuels shall be free of inorganic acids.
The Strong Acid Number (SAN) (in addition to the
Total Acid Number (TAN)) shall be reported within the
Inorganic Acids
Certificate of Quality (COQ) (i.e. SAN = 0) and
according to test method ASTM D664 as prescribed
in ISO 8217.
ANNEX B
Frequently Asked Questions (FAQs)
No. FAQ Answer
They are preventive measures introduced to reduce
What are these testing the occurrence of bunkering contaminated fuels by
1
enhancements for? sieving out contaminants from the upstream bunker
supply chain.
Are the test No. These testing enhancements are to be carried out
2 enhancements required for the batch of fuel upstream and not for each bunker
for each bunker delivery? delivery.
MPA licensed bunker suppliers must ensure that the
Who is responsible for
bunker fuel that they are supplying in the port of
3 the testing
Singapore conforms with the requirements laid out in
enhancements?
this PMC.
For residual fuel / bio-residual bunker marine fuel, the
COQ of the fuel loaded onto the bunker tanker must
contain the tests results of the COC and SAN. For
polymers, (polystyrene, polypropylene and
polymethacrylate) suppliers are recommended to
maintain proper test records, that the current batch of
bunker fuel supplied is free from polymers.
When must the enhanced
4
testing be carried out? For distillate / bio-distillate bunker marine fuel batches,
SAN must be tested and reported in the “Certificate of
Quality” (COQ).
The testing enhancements are to be carried out after
blending of feedstocks/fuels (if any) in shore/floating
tanks and before being intended to be delivered as
bunkers in the Port of Singapore.
Yes, MPA licensed bunker suppliers are highly
Are bunker suppliers
encouraged to adopt these testing enhancements as
allowed to adopt these
5 early as possible. However, from 1st June 2024,
testing enhancements
bunker suppliers must comply with the requirements of
before 1st June 2024?
this PMC.
Are there testing Yes, there are several laboratories in Singapore which
laboratories capable of have acquired the respective capabilities. Suppliers
6
conducting these testing should approach them for further enquiries.
enhancements available?
Due to the lack of standardised test methods for the
general detection of polymers (polystyrene,
polypropylene and polymethacrylate), the IEG has
hence recommended that the fuel can be tested using
a test method which consists of filtration, microscopic
examination, and Fourier-Transform Infrared
I have concerns due to
spectroscopy (FTIR) analysis to qualitatively determine
the lack of standardised
7
if such polymers are present in the fuel. There are
testing for polymers. How
several laboratories in Singapore that are or will be
can we test for it?
undergoing accreditation by SAC-SINGLAS to perform
the qualitative polymers testing.
MPA is working with relevant agencies to enhance the
polymer testing capabilities in Singapore. More details
will be announced in due course.
No, only three polymers (polystyrene, polypropylene,
Is it compulsory for me to
and polymethacrylate) are recommended to be tested
8 test for all of the
for, as they are identified as detrimental when present
polymers?
in marine fuel.
The testing enhancements are not expected to affect
Will these testing
the current turnaround time to test bunker samples
enhancements affect my
against the existing ISO 8217 testing parameters. As
9 turnaround time or impact
such, MPA does not expect these testing
the bunker supply in
enhancements to have an adverse impact on the
Singapore?
supply system.
The ISO 8217 is expected to be published by early
What happens when the 2024. We will still require MPA bunker suppliers to
10 new ISO 8217 is comply and report the respective testing enhancement
published? results in accordance with the PMC. Further details will
be provided once the standard have been released.
Are these testing The revised edition of ISO 8217 is yet to be released.
enhancements also The final version is expected to be released by early
11
included in the revised 2024.
8217?
Bunker fuel that does not meet the requirements of
Will the fuel be deemed
this PMC must not be supplied as bunkers in
off-spec if they do not
12 Singapore. Licensing action may be taken against the
meet these enhanced
supplier that do not comply with the requirements of
requirements?
this PMC.