MEPC 77 to discuss mandatory flashpoint on the Bunker Delivery Note
Appendix V of MARPOL Annex VI requires sulphur content and density to be included in the bunker delivery note (BDN). Should inclusion of flashpoint also be made mandatory?
The 77th session of the IMO’s Marine Environment Protection Committee (MEPC 77) which meets 22-26 November, is expected to consider draft amendments to amend Appendix V – Information to be included in the bunker delivery note (Regulation 18.5) by adding “Flashpoint (°C)” to the list of information, below “Sulphur content (% m/m)”.
It follows deliberations in a correspondence group a while back, and is linked to parallel work at the IMO’s Maritime Safety Committee (MSC) amid concerns that the IMO 2020 sulphur limit would lead to a significant increase in flashpoint off-specs. The SOLAS Convention requires fuels to have a minimum 60°C flashpoint.
IBIA has participated in both the MEPC and MSC work on this subject, and has been among the few objecting to this all along, for the following reasons:
A – Flashpoint (FP) has to be above 60°C both under SOLAS and ISO 8217 and hence no fuel with FP below this limit should be released for supply in the first place.
B – Very few fuels with FP below the limit (off-specs) are supplied and even when this has happened, very little evidence has been seen that it has caused explosions/fires on ships (unless the FP is extremely low, which is very rare). Most fuel-related fire incidents on ships have been caused by autoignition rather than the fuel’s FP.
C – Unlike sulphur and density, which are currently the only quality parameters required on the BDN, as long as FP it is above the 60°C minimum limit, it should have no bearing on operation of the ship. Accurate sulphur content, however, is needed to calculate fuel changeover between ECA and non-ECA areas. Density has a bearing on the operation of the ship (fuel treatment) and in determining fuel quantity. Flashpoint, meanwhile, does not have a bearing on operation of the ship as normal fire and explosion risk safety procedures should still be observed even if the FP is above 60°C.
D – It is normal practice prior to releasing fuel oil for marine use to stop the FP test once a FP above 70°C has been established as it is then safe to say that the 60°C minimum limit has been met. To require FP to be reported accurately if above 60°C would require testing to go on beyond establishing that the limit has been met, which is of little or no use.
E – We do not believe adding mandatory flashpoint reporting to the BDN under appendix V in MARPOL Annex VI would make any real difference to the number of 60°C off-specs. FP above 60°C is already guaranteed by the provision of Material Safety Data Sheets required by SOLAS and commercial contracts based on ISO 8217, which also stipulate a minimum 60°C flashpoint limit for residual and distillate marine fuels.
F – If it is felt that the BDN must do more to ensure suppliers make every effort to provide fuel complying with the 60°C flashpoint limit in SOLAS, we would propose instead to amend the declaration by the fuel oil suppliers representative to certify compliance, as follows (amendments shown as strikethrough and underlined text):
“A declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with regulation 14(1) or (4)(a) and regulation 18(1) of this Annex, and regulation SOLAS II-2/4.2.1“
In short, we cannot to see reasonable justification for requiring a flashpoint value to be recorded on the BDN (unlike sulphur and density), while the safety aspect is already well covered in existing SOLAS provisions and in ISO 8217.
Moreover, MSC is likely to adopt SOLAS amendments calling for mandatory reporting of confirmed cases where suppliers have provided non-compliant fuel, and calling for authorities to “take action as appropriate” against suppliers if they do.