IBIA seeks member feedback on potential IMO proposal to include flashpoint on the BDN
A proposal was aired last week at the 98th session of the Maritime Safety Committee (MSC 98) to make it mandatory to include the flashpoint on the bunker delivery note (BDN).
The proposal was put forward to plenary on the final day of the meeting during a debate on what impact the shift to a 0.50% sulphur limit may have on the safety of ships, in particular the risk of fuels with flashpoint lower than the minimum 60°C limit required by SOLAS.
The International Maritime Organization (IMO) already places a mandatory requirement on the BDN to include Density at 15°C (kg/m3 ), sulphur content (% m/m) and a declaration that the fuel supplied is in conformity with regulation 18.3 of MARPOL Annex VI. [*]
The proposal to include flashpoint on the BDN was not put forward in any of the documents submitted to MSC 98, and it has not been formally proposed in any of documents submitted to the 71st session of the IMO’s Marine Environment Protection Committee (MEPC 71), which will meet in the first week of July.
MSC 98 nevertheless discussed whether it should ask MEPC to consider adding a field in the BDN for flashpoint. It was noted during the debate that fuel quality is a long-standing issue at MEPC, but as there were divergent views; MSC would not take any action. Delegations were asked to think of the most appropriate way forward.
It was clear from the discussion at MSC 98 that a number of member states and industry NGOs represented at the IMO were in favour of the idea, making it quite likely that the proposal will come up again during discussions at MEPC 71 and/or at future MSC/MEPC sessions.
With this in mind, IBIA would like to hear feedback from its members on these two questions:
1) Is it a good idea to include flashpoint on the BDN?
2) If this proposal comes up during discussion at MEPC 71 or other IMO meetings, how would you like IBIA to respond?
Please send your comments before the end of this week to IBIA’s IMO Representative:
Unni Einemo: firstname.lastname@example.org
Your comments will be treated in confidence.
*Regulation 18.3 states: “Fuels derived from petroleum refining must be free from inorganic acid; may not include added substance or chemical waste that jeopardizes ship safety or adversely affects machinery performance, is harmful to personnel, or contributes to additional air pollution.”