Dear Editor,

All marine fuels related products are bought and sold within the worldwide standard of ISO 8217:1996 or 2005 specifications (ISO - the International Organization for Standardization), which were introduced to establish the values of parameters from oil and marine fuel products. Within the ISO 8217 standard there are test methods described which have to be used to be sure if a parameter is within or out of the ISO 8217 specifications. For sulphur testing the ISO 8754 method is applicable.   
 
At this moment it is still not clear for a lot of people in the oil industry and shipping when an analysis of the sulphur content is in line with the requested regulations. But the exact interpretation of the methods is described in the latest DIRECTIVE 2005/33/EC of the European Parliament and of the Council and in the IMO regulations.
 
In the DIRECTIVE 2005/33/EC (Article 6 - Paragraph 2) it is clearly stated that the only test method to verify if a sulphur content of heavy fuel oil and marine fuels is within the requested specifications/regulations have to be done according the ISO 8754 or PrEN ISO 14596 test method.

In the IMO regulations it is also clearly stated that that the test method for the sulphur content has to be done according the ISO 8754 test method. This would mean that everything should be very easy and clear when a sulphur is IN or OUT of specifications, and would mean that marine fuel oil with a maximum 1.50% m/m Sulphur product has a mathematic tolerance up to 1.58% m/m according the ISO 8754 method!
 
The IMO wants to make alterations in the MEPC.1/Circ.614 for the sulphur limits in fuel and fuel oil verifications, which will not be in line anymore with the method ISO 8754 as described in the regulations from IMO and the DIRECTIVE 2005/33/EC. This alteration would mean that the ISO 8754 test method is applicable, but the tolerance as described in the reproducibility and repeatability can/will not be used, which is also in breach with the mathematic tolerance of mentioned test method as described in the ISO 8217 specifications.
 
This alteration is also in breach with the regulations and ISO specifications thus will/can cause a lot of time and money consuming arbitration cases when the MEPC.1/Circ.614 will become applicable in October 2009.
 
Why does IMO try to make alterations in the sulphur testing procedure, which will mean that the test methods mathematically tolerance from the worldwide accepted and used ISO 8217 specifications will become useless and is in breach with the DIRECTIVE 2005/33/EC regulations.

An implementation of the MEPC.1/Circ.614 in October 2009 should be unacceptable for mentioned reasons!