PSC deficiency code 14604: Bunker delivery notes
Area 14 Pollution prevention (MARPOL)
Every delivery of fuel oil for combustion comes with a bunker delivery note (BDN) from the supplier and a sealed sample. The note records what was delivered, including sulphur content and the supplier's declaration; the sample lets a port State check it. The inspector's doubt is whether the ship can show what fuel it has on board and that it was compliant when delivered.
What the inspector looks at
The chief engineer is usually asked for the BDN file, then for the sample locker.
- a BDN for every bunkering in the last three years, ready to produce
- content: ship name and IMO number, port, date delivery started, supplier's contact details, product, quantity in metric tonnes, density at 15°C, sulphur content
- the supplier's signed declaration, with the applicable sulphur limit marked
- a retained sample for each delivery, sealed, labelled and signed
- samples stored outside the accommodation, away from heat and sunlight
- seal numbers on labels and, where recorded, on the BDN
- Oil Record Book bunkering entries matching BDN dates and quantities
Common findings
- Bunker delivery note for last bunkering not on board
- BDN does not state sulphur content
- Supplier's declaration on BDN not completed
- Representative sample of last bunkering not retained
- Sample label incomplete, seal number not recorded
- Fuel oil samples stored in engine control room
- Quantity in Oil Record Book does not match BDN
The rule behind it
MARPOL Annex VI, regulation 18.5, requires fuel delivered to ships that need an IAPP Certificate to be documented by a BDN with at least the information in appendix V. Regulation 18.6 keeps the note on board, readily available, for three years after delivery, and 18.7 lets port State officers inspect and copy it. Under 18.8.1 a representative sample goes with the note, sealed and signed by the supplier's representative and the master or officer in charge when bunkering is completed. The ship keeps it until the fuel is substantially consumed, and at least 12 months from delivery. The 2009 sampling guidelines (MEPC.182(59)) cover drawing, labelling and storing it.
Action codes you are likely to see
A missing signature or incomplete label put right during the visit is often 10. A BDN or sample the supplier can still provide usually gets 17 or 16. A missing note isn't itself on the IMO list of detainable deficiencies. The list does include master and crew not familiar with essential air pollution procedures, which IMO's guidance defines to include bunkering procedures tied to BDNs and retained samples, so a serious case may be treated as a ground for detention (30). See action taken codes.
How to close it
The chief engineer and the office purchasing team own this. Get a copy of any missing BDN from the supplier through the agent. Start a sample log with BDN number, seal number, delivery date and earliest landing date, and move samples to a proper locker. Keep copies, the log, photos and corrected Oil Record Book entries with the Form B. If notes went missing more than once, review the bunkering procedure under ISM.