IMO hears proposal to change HFO definition

The IMO has begun discissions about a proposal to amend the legal definition of ‘HFO’ to include a pour point limit to address concerns about difficulties in cleaning up potential fuel spills in the Artic.

The proposal by Norway and Iceland was discussed during the IMO’s recent Marine Environment Protection Committee meeting (MEPC 78, 6- 10 June).

Their paper, MEPC 78/14/1, highlighted the difficulty in cleaning up oil spills if the fuel solidifies in water. They suggested that once the ban on use and carriage of heavy fuel oil (HFO) in the Arctic comes into effect, the density can be adjusted by adding more paraffinic components. This, in turn, would make the pour point of the fuel higher, making it more difficult to clean up on the event of a spill in cold Artic waters.

The Arctic HFO use and carriage ban is due to take effect on 1 July, 2024. As previously reported by IBIA, the HFO ban will include most VLSFOs due to the density limit. (More info on this link)

The proposal received support from some member states, while others raised doubts. A number of NGOs with consultative status at IMO pointed to various questions that need to be answered and called for more data. IBIA was among them.

Commenting on the proposal, IBIA’s IMO representative Unni Einemo said:

“The paper proposes to include an upper pour point of 0°C in the HFO definition, in line with the requirements for MGO grades, and winter grades of MDO as well as RMA and RMB grade fuels. It should be noted, however, that marine distillate grades may also have a high paraffinic wax content. MGOs have been known to form solidified wax deposits in fuel tanks during operations in cold winter conditions, as MGO tanks are typically not heated and may be close to the outer skin of the ship.

It would be good to understand more about how MGOs with high paraffinic content behave when spilled in cold waters too, and the impact that would have on oil spill recovery.

Cold flow properties are an important operational aspect, and need to be known in order to ensure fuels are kept above temperatures when they start to form wax crystals or waxy sludge onboard ships. But rewriting the HFO definition by introducing an upper pour point of 0°C would mean that some fuels that are actually distillates would be classified as HFO. This would be confusing as HFO is widely understood to be products containing residual fuel oil.

If there is a case to control pour point because of how the fuel behaves in case of an accidental oil spill, it seems more appropriate to specify a limit on pour point for fuels used in the Arctic, rather than rewriting the definition of HFO.

IBIA also lent its support to a suggestion put to MEPC from ISO that it may be more appropriate to develop a separate notation for ‘Polar Fuel Oils’ or ‘Polar fuels’ with details on the specific fuel characteristics for fuels that can be used in polar regions.

Other valid questions raised included if maybe it was more appropriate to improve the design of oil spill response equipment, and the potential impact on fuel properties and the propensity to emit black carbon if there is a move to restrict paraffinic content in fuels used in the Artic. Paraffinic fuels typically have very good ignition and combustion characteristics and may therefore emit less black carbon, or soot, than more aromatic fuels.

MEPC 78 agreed to forward the proposal from Norway and Iceland to the next session of the sub-Committee on Pollution Prevention and response (PPR 10) to consider the proposal further.

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