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Upcoming concentrated inspection campaigns (CICs) by four port state control (PSC) regimes between September 1 and November 30 could involve the verification of fuel sulphur content, Gard reports.

The P&I club says PSC officers pertaining to the Black Sea MOU, Indian Ocean MOU, Paris MOU and Tokyo MOU PSC regimes will be paying particular attention to ships' compliance with MARPOL Annex VI during the PSC inspections.

PSC regimes have already stated that they will be taking the enforcement of the new global 0.5 percent sulphur cap "seriously from 'day one'", Gard notes, so "ship operators should therefore not be surprised if verification of the sulphur content of the onboard fuel is requested as part of the CIC".

This could include a review of documents - such as bunker delivery notes, oil record books, fuel logs and fuel changeover procedures - as well as the taking and analysis of fuel samples at short notice.

Gard therefore advises members to familiarise themselves with the relevant MARPOL Annex VI regulations and CIC criteria well before September 1.

The 'Sulphur Inspection Guidance', published last month by the European Maritime Safety Agency (EMSA), contains information on what to expect from an attending PSC officer.

The tailored CIC checklist/questionnaire to be used by attending PSC officers is expected to be published in August.

Based on experience from previous CICs, Gard assumes the questionnaire will focus on the maintenance and working condition of relevant equipment, such as the incinerator, but will mainly contain operational questions aimed at verifying the crews' familiarity with the ship-specific equipment and procedures.

"As much of the compliance with MARPOL Annex VI is documented by significant recordkeeping, it will be important to ensure that all MARPOL Annex VI documentation is complete and up-to-date prior to entry into any port," Gard stressed.