fire risk, flashpoint

IMO to develop guidelines for dealing with ‘off-spec’ flashpoint incidents

A fuel with flashpoint below 60°C is not only outside the 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.

The IMO’s Maritime Safety Committee (MSC), which currently has an agenda item called “Development of further measures to enhance the safety of ships relating to the use of oil fuel,” is working on additional regulation to prevent fuels with flashpoint below the SOLAS threshold from being supplied to ships.

In connection with this, it is also working on 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).”

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 MSC (MSC 103) in May 2021.

At MSC 103, progress was made on the regulatory aspects, while discussion on the guidelines resulted mainly in defining further work and aspects to consider.

IBIA has contributed to the draft elements of such guidelines in a correspondence group, providing pragmatic suggestions for dealing with cases where the initial indicative test result is only slightly below the limit.

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 shipʹs 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. There 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.

Following discussion, MSC 103 endorsed an updated work plan aiming to complete measures related to the flashpoint of fuel oil at MSC 105, including draft amendments to SOLAS and the above-mentioned guidelines. The work will be done in an IMO correspondence group which will report to MSC 105, which is expected to take place toward late in the first half of 2022.

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