Efforts have been underway at the IMO for some time to ensure that oil-based bunker fuels, when delivered to ships, comply with the flashpoint limit of 60⁰C stipulated under SOLAS. The subject came up during the run-up to the IMO 2020 sulphur limit, amid concerns about the potential impact on ship safety associated with the move to fuels complying with the 0.50% sulphur limit required under MARPOL Annex VI.
While MARPOL is dealt with by the IMO’s Marine Environment Protection Committee (MEPC), safety aspects are also dealt with by the IMO’s Maritime Safety Committee under an agenda item called “Development of further measures to enhance the safety of ships relating to the use of oil fuel.”
IBIA, with the assistance of our Technical Working Group, has been closely involved in these discussions at IMO meetings, in IMO working groups and in IMO correspondence groups throughout, most recently at the 103rd session of the MSC (MSC 103) in May 2021.
After a week of intense debate at MSC 103, where IBIA had an active delegation supported by industry experts from our technical working group, some elements of the additional regulations under SOLAS are now near completion and on course for approval at MSC 105, which is expected to meet toward the end of the second half of 2022. MSC 103 re-established a correspondence group (CG) to continue this work, which will report to MSC 105 as there’s not sufficient time to have the CG finalise the work prior to MSC 104, which will meet later this year.
The CG has been instructed to:
So where are we with all this? Will it get us closer to the aim of enhancing the safety of ships? There are conflicting views on how to best achieve the goal, which is to prevent supply of bunkers that fails to meet the SOLAS flashpoint limit or contain substances deemed to put ship and crew safety at risk.
It is clear from the desires of the many shipping organisations with consultative status at the IMO, and several Member States, that they want regulations targeting the supply side to prevent fuels below SOLAS limit from being supplied to ships in the first place, and to ensure suppliers face consequences if it still happens.
Discussions on flashpoint regulations during MSC 103
It is hard to summarise progress at MSC 103, but items which are closest to completion include a requirement for Contracting Governments (i.e. signatories to SOLAS) to report confirmed cases where oil fuel suppliers have failed to meet the requirements specified in SOLAS regulation II-2/4.2.1 (including a definition of confirmed cases) and to “take action as appropriate” against suppliers that have been found to deliver fuels that do not comply with SOLAS.
On the subject of mandatory requirements regarding documentation of the flashpoint of the actual fuel batch when bunkering, the majority view appears to support requiring that suppliers should report the actual flashpoint of the fuel delivered to the ship, similar to the MARPOL requirement for reporting the actual sulphur content on the bunker delivery note, as opposed to a declaration that the oil fuel supplied is in conformity with the SOLAS II-2/4.2.1 regulation.
IBIA has been questioning, during our input at IMO on the subject, whether this will make a difference given that suppliers already have to provide a material safety data sheet (MSDS) to the ship, which should guarantee that the fuel meets the SOLAS flashpoint limit, and because the supplier has also entered a contractual obligation to meet the flashpoint limit as fuels are largely sold against ISO 8217 specifications, which include a 60⁰C flashpoint limit.
At MSC 103, IBIA highlighted that we have yet to hear a good reason for requiring the actual flashpoint to be reported to the ship, as opposed to a statement that it meets the 60⁰C limit, because operationally the actual flashpoint should not matter; normal safety procedures still need to be applied. IBIA also explained that it is common practice during fuel testing to stop the test to determine flashpoint once the sample has been heated to 70⁰C or above, because that suggests that the 60⁰C limit has been met and no further testing is considered necessary. As such, the practical considerations and consequences do not appear to merit requiring an actual flashpoint value to be documented.
IBIA also commented on a proposal by ICS and the Cook Islands in MSC 102/6/2 to require a representative sample for the purpose of testing flashpoint to be taken at the time of delivery, which seeks to mandate the sampling location at the ship’s inlet manifold. IBIA told MSC 103: “This goes beyond the provisions for the MARPOL delivered sample, which is a guideline. The realities of bunkering operations means that it is often unsafe for a representative of the fuel supplier to come aboard the ship to witness sampling at the ship’s inlet manifold, and it is also usually impossible to monitor remotely as the ship’s inlet manifold will be completely out of sight from the bunker delivery vessel. Conversely, it is often possible to view sampling at the bunker outlet manifold from the deck of the receiving vessel, making this both safer and more practical.”
What was clear during these discussions was that there is strong desire to put more responsibility on the supply side to provide compliant fuels, but limited understanding of how testing for flashpoint actually works. Any justification for requiring an actual value to be reported as opposed a statement that it is above 60°C is vague.
Following discussion, MSC 103 endorsed an updated work plan aiming to complete measures related to the flashpoint of fuel oil at MSC 105, meaning the correspondence group will have a lot of work to do to provide fully developed draft amendments to SOLAS and associated guidelines.
How big is the problem?
Fuel testing agencies have data on flashpoint from fuels actually delivered to ships. While statistics vary a little between them, ISO/TC28/SC4/WG6, the ISO committee in charge of ISO 8217, has gathered data from most of the major testing agencies, which should give a fair overall representation.
The ISO comparative study showed that for the first half (H1) of 2020, there had been a small increase in distillate marine (DM) fuel samples with a flashpoint of below 60°C compared to during all of 2018, but it was still below 1% of all DM fuel samples. It found that 99.9% of very low sulphur fuel oil (VLSFO) residual marine samples had a flash point meeting the 60°C limit, and that 0.08% had a flash point between 55°C and 60°C. In both 2018 and H1, 2020, more than 99.5% of HSFO samples met the 60°C flashpoint limit. Overall, then, it seems VLSFOs have been no more prone to off-spec flashpoint than HSFOs, while the share of DM samples below the limit showed a small increase during 2020.
Interestingly, an information document submitted to IMO by China (MSC 102/INF.18), reporting on lessons learned from three explosions in fuel oil tanks and two explosions of components of fuel oil booster unit/systems, showed that only one of those cases related to a fuel with a flashpoint below the SOLAS limit, reportedly measured at 37°C. In the other cases, the flashpoint had been measured above, and in some cases well above, 60°C.
The paper drew a clear causal link between the fuel with the flashpoint measured at 37°C and an explosion in a fuel oil storage tank, but the explosions in the other cases were linked to other factors. In the case where the flashpoint was measured at 37°C, it was reported that there was no flame screen fixed in opening of the oil mist box, and that moving flames ignited vapour after the fuel oil in the storage tank was heated
Incidents caused by low flashpoint fuels, fortunately, appear to be very rare. IBIA has previously been informed by the fuel testing arm of Lloyd’s Register, GMT/FOBAS, that LR has no records of incidents caused by low flashpoint fuels from 1970 and up to 2010, only for auto-ignition point.
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