MEPC adopts BDN flashpoint reporting requirement

The IMO’s Marine Environment Protection Committee has adopted an amendment to appendix V of MARPOL Annex VI that will require bunker suppliers to provide information about flashpoint in the Bunker Delivery Note (BDN).

The adopted amendment says:

“The flashpoint (°C) specified in accordance with standards acceptable to the Organization*, or a statement that the flashpoint has been measured at or above 70ºC.”

The footnote specifies the testing standard to be used as ISO 2719:2016, Determination of flash point – Pensky-Martens closed cup method, Procedure A (for Distillate Fuels) or Procedure B (for Residual Fuels).”

This new requirement under MARPOL Annex VI will enter into force on 1 May, 2024.

The text of the new requirement has been aligned with amendments to SOLAS chapter II-2 that were adopted by the Maritime Safety Committee (MSC) in November this year. That will enter into force on 1 January, 2026. (More information on this link)

During MEPC 79, IBIA made interventions in plenary to support issues pointed out by IMarEST in MEPC 79/3/5 about the text in the amendment having unfortunate unintended consequences.

IMarEST had pointed out that the text up for adoption did not make it clear that it only related to “oil fuels” as defined in SOLAS chapter II-2. As such, the MARPOL amendment, as it stands, would also require the flashpoint of a fuel such as methanol, which is covered by the IGF Code (but not SOLAS Chapter II-2) to be documented in the BDN.

While the Committee acknowledged that this was not the intention, it still favoured adopting the text as it was. It was widely recognised, however, that in making this amendment to MARPOL Annex VI, a further amendment would be required to MARPOL Annex VI, regulation 18.4 to include low flashpoint non-gaseous fuels. This is likely to happen at a future session of MEPC.

IBIA also highlighted how the text, as adopted, could cause confusion during discussions at the drafting group on mandatory amendments at MEPC 79.  We therefore want to reiterate some important messages about what this new requirement actually means:

Firstly, there is no change to the flashpoint limit; it continues to be no less than 60°C for all oil fuels unless specifically provided for use in emergency generators, where oil fuel with a flashpoint of not less than 43°C may be used. ISO 8217 Table 1 (Distillates) has one grade for this purpose, namely DMX, with a minimum flashpoint of 43°C. All other ISO 8217 grades for marine distillates and marine residual fuels specify a 60°C minimum for flashpoint.

Secondly, the closed-cup flashpoint test will provide a specified temperature when an ignition source produces a “flash” in the sample. If this flash occurs at a temperature below 70°C, this exact temperature must be reported on the BDN. If, however, the sample is heated to 70°C or above without producing a flash, there won’t be an actual measured flashpoint temperature to report, but this is sufficient to meet the requirement for a statement that the flashpoint has been measured at or above 70°C.

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