In the run-up to the 0.50% sulphur limit under MARPOL Annex VI taking effect, many concerns were raised that the change in fuel quality to comply with “IMO 2020” would have a detrimental impact on ship safety.
MARPOL is dealt with by the IMO’s Marine Environment Protection Committee (MEPC), but concerns about fuel quality led to the IMO’s Maritime Safety Committee to take on an agenda item called “Development of further measures to enhance the safety of ships relating to the use of oil fuel.” The work on this agenda item has, in the first instance, focused on the flashpoint limit of 60⁰C stipulated in the International Convention for the Safety of Life at Sea (SOLAS). After that, attention will turn to “oil fuel parameters other than flashpoint”.
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 that goal. One part of it 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. Another part of it is to ensure good fuel management and safety procedures on ships.
Many shipping organisations with consultative status at the IMO, and several Member States, want regulations targeting the supply side to prevent fuels below the SOLAS limit from being supplied to ships in the first place, and to ensure suppliers face consequences if it still happens.
How big is the problem?
A fuel with flashpoint below 60°C is not only outside ISO 8217 specification, it is also a breach of SOLAS regulations, and hence is regarded as a critical parameter with ‘off-specs’ getting a lot of attention. In the course of deliberating flashpoint regulations at the IMO, IBIA, with the assistance of our Technical Working Group, has looked into the subject in detail, including a variety of studies
Fuel testing agencies have data on flashpoint from fuels actually deliveredto ships. While statistics vary a little between them, ISO/TC28/SC4/WG6, the ISO committee in charge of ISO 8217, has recently 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, it seems VLSFOs have been no more prone to off-spec flashpoint than HSFOs used to be, 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 obtained information from Lloyd’s Register that it has no records of incidents caused by low flashpoint fuels from 1970 and up to 2010, only for autoignition point. There were cases of fuels testing below the 60°C flashpoint limit during this period but they do not appear to have caused
For flashpoint (FP) to be the cause of a liquid to ignite, there needs to be a significant concentration of accumulated vapour and an ignition source, e.g. a spark or open flame. This combination is rare as long as normal safe working procedures and maintenance are observed.
Accumulation of flammable vapour from oil fuels, to the extent that it represents a fire-risk, will be limited to enclosed spaces with lack of ventilation. Explosive vapours may form inside fuel tank headspaces but this is a known risk and therefore safety procedures and tank design are well established around venting and avoidance of ignition sources nearby.
Back in 2014, the 94th session of MSC was assessing a proposal to reduce flashpoint limit in SOLAS chapter II-2 from 60°C to 52°C for marine distillate fuels. Ultimately, that proposal was rejected for various reasons, including safety concerns but also because the 60°C limit is now embedded across so many global regulations that it would be almost impossible to untangle it.
There was, however, some very interesting information coming through. Document MSC 94/18/5 explained that the SOLAS flashpoint requirement for oil fuel was reassessed by the IMO’s Sub-Committee on Fire Protection (FP) during its consideration of the fire safety of future passenger ships in 1966-1967. At that time, it was proposed that the minimum flashpoint requirement for fuel should be changed from 43°C to 60°C. The change, which was accepted, appears to have been based on a general qualitative safety improvement rather than a systematic analysis of fuel properties or known risks or casualties.
So, we are stuck with the 60°C SOLAS flashpoint requirement, although review of fire casualty records shows that the majority of machinery space fires are the result of loose or broken fuel line fittings that allow pressurized fuel to spray onto heated surfaces. In this situation, the potential ignition of the fuel spray is governed by the fuel’s autoignition temperature and not its flashpoint. The auto-ignition temperature for all marine diesel fuels is generally accepted to be 250°C, and will not be affected by a change in flashpoint.
Efforts have been underway at the IMO for some time on the fuel oil safety issue, but the postponement of many IMO meetings in 2020 due to the Covid-19 pandemic, and time constraints once virtual meetings were set up, has slowed things down. Progress was made, however, 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:
Further develop, with a view towards finalization, draft SOLAS amendments relating to reporting of confirmed cases where oil fuel suppliers have failed to meet IMO flashpoint requirements. Draft SOLAS amendments on actions against oil fuel suppliers that have been found to deliver oil fuel that does not comply with minimum flashpoint requirements. Further develop mandatory requirements regarding the documentation of the flashpoint of the actual fuel batch when bunkering. Further develop guidelines for ships to address situations where indicative test results suggest that the oil fuel supplied may not comply with SOLAS regulation II-2/4.2.1 (which says that no fuel oil with a flashpoint lower than 60 degrees Centigrade shall be used, unless specifically permitted). Collect information on and consider possible measures related to oil fuel parameters other than flashpoint.
After MSC 103, the 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. Another alternative would be for the BDN to contain 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 determine flashpoint, to stop the test 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.
Another part of the work on the fuel oil safety agenda item at MSC is developing “guidelines for ships to address situations where indicative test results suggest that the oil fuel supplied may not comply with SOLAS regulation II-2/4.2.1 (which says that no fuel oil with a flashpoint lower than 60 degrees Centigrade shall be used, unless specifically permitted).”
At MSC 103, IBIA told the committee: “Fuels testing below 60°C are relatively rare and, unless the flashpoint is significantly below the 60°C limit, normal safety procedures prevent accidents. To our knowledge, no accidents have been reported as a result of a flashpoint measured a few degrees below 60°C. When fires or explosions have occurred, it has been due to other factors. Moreover, safety procedures and equipment must surely be designed to tolerate flashpoint slightly below the limit, in the same way that all safety systems are designed to withstand conditions beyond a specified limit. You would not expect an elevator with a sign that its maximum capacity is 1200 kg to suddenly start falling dangerously fast if the load goes to 1300 kg.
“In fact, when ship operators receive a test result indicating a flashpoint slightly below 60°C they see the risk as manageable. Their main concern is that they are now potentially in breach of the SOLAS regulation. This puts the ship in a very difficult position as it has implications for the ship’s insurance and class status.
“With this in mind, we urge the Committee to develop guidelines in line with pragmatic and workable measures which are already widely used, in cases where ships have indicative test results suggesting that the fuel as supplied is slightly below the limit. Debunkering is not a trivial matter and could in fact create a bigger risk to the safety of the ship and crew than venting the tank to allow the volatile elements causing the flashpoint to test below the limit to safely evaporate. In the majority of cases, venting and then retesting of fuel in the tank onboard has been shown to bring the flashpoint into compliance with the SOLAS limit. We strongly believe this would be in the best interest of all parties concerned. We believe this approach would also address the concerns raised in paragraph 8 to 10 of MSC 103/6 and the proposal in paragraph 16 of MSC 102/6/1.”
The comments IBIA referred to from MSC 103/6 said: “Japan is specifically concerned that some required measures may cause deviation of the ship’s voyage from the planned route or undue delay of the voyage resulting in a negative incentive for carrying out the ship’s voluntary tests,” which would be undesirable, and so “measures taken in case of indicative test results obtained from the ship’s own tests, should be thoroughly deliberated “.
Meanwhile, paragraph 16 of MSC 102/6/1 by China, noted “the possible implementation difficulties in de-bunkering non-compliant fuel oil” and that a proposal requiring to debunker non-compliant fuel oil needs to be carefully considered.
The guidelines will be further considered in the Fuel Oil Safety correspondence group, which IBIA participates in. In addition to IBIA’s pragmatic proposal, the working group on fuel oil safety at MSC 103 prepared a list of items to be addressed by the guidelines. They include Proof of non-compliance (e.g. second independent test, testing plan) communication (what information, who must be informed) and relations with various authorities. The list also includes items such as fuel handling, fuel properties and hazards.
The working group agreed that provisions on measures that could affect the planned voyage of a ship should be considered carefully, taking into account the severe implications for the ship, crew and owner as well as the actual risk emanating from the use of fuel with a flashpoint below 60°C in the specific case.
MSC 103 in May 2021 had only a brief discussion on “other parameters”, as development of flashpoint measures took up most of the available time. A work plan was drawn up for items to be progressed, much of it closely related to the development of the ISO 8217 fuel quality standard. Items the IMO wants to look at more closely to enhance the safety of ships include fuel oil stability, compatibility, cold flow properties, acid number, cat fines, the use of low viscosity fuels, and finally the most complex aspect regarding “unusual components” in fuel oil.
Several informative documents have been provided to the IMO’s work on this subject, including the Joint Industry Guidance document published in September 2019 called “The Supply and use of 0.50% – sulphur marine fuel” which IBIA took part in developing. This document highlights that, apart from the responsibility of suppliers in providing fuels that comply with IMO regulations and meet ISO 8217 specification, onboard fuel management is critical. The huge variability in IMO 2020 compliant fuels, especially with regards to key handling characteristics such as viscosity and cold flow, along with increased risk of fuels being incompatible with other fuel batches, means diligent onboard fuel management is probably more critical than ever to ensure the fuel reaches the engine without incident.
One element that was discussed at MSC 103 was a call for implementing licensing schemes for bunker suppliers, which some Members States insist is necessary while others are not in favour or convinced it is the best strategy. The outcome was an agreement that MSC “invited Member States to consider the implementation of licensing schemes for bunker suppliers operating in their jurisdiction”, with a reference to the need for collaboration with MEPC.
At the time of writing, the 76th session of the IMO’s Marine Environment Protection Committee was due to consider an “indicative example” for a voluntary Member State licensing scheme for bunker suppliers. A proposal submitted by a group of shipping organisations has been considered and developed further in a correspondence group, which IBIA has taken part in.
If approved, the indicative example of a bunkering licence will be added as an annex to the official IMO Guidance for best practice for Member State/coastal State (MEPC.1/Circ.884). IBIA is in favour of bunker supplier licencing schemes and while the indicative example in the Appendix provides a possible framework, we also note that it may not be fit for purpose in all Member States. They may wish to use the indicative example, or adapt it for their use, or they may prefer such licensing to be undertaken by local authorities.
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