IBIA contributed to a discussion at the International Maritime Organization (IMO) last week regarding the potential impact on ship safety associated with meeting demand for fuels complying with the 0.50% sulphur limit that is due to take effect on 1 January 2020.
The 98th session of the IMO’s Maritime Safety Committee (MSC 98) had two papers to consider on the subject.
MSC 98/22/8 submitted by Brazil and Chile expressed concerns about the effects the 2020 requirement will have on on-board safety, specifically with regards to flashpoint. The paper noted that the official availability study presented to the 70th session of the IMO’s Marine Environment Protection Committee (MEPC 70) had stated that a potential reduction in the minimum flashpoint of fuel oil “would certainly help improve fuel availability” to meet the 0.50% sulphur limit in 2020.
It asked, therefore, for the MEPC to clarify whether the decision to implement the 0.50% sulphur limit in 2020 is conditional upon a reduction in the flashpoint limit of 60ºC, and to request the Sub-Committee on Ship Systems and Equipment (SSE) to study any on-board safety problems that may arise from lowering the 60ºC flashpoint limit stipulated under SOLAS.
Also up for discussion was MSC 98/22/10 submitted by Brazil, which in addition to concerns about flashpoint pointed to papers submitted to MEPC 70 by IBIA and ISO that had raised concerns about the quality of fuel oil blends that are anticipated to enter the market to meet the 0.50% sulphur limit relating to stability and challenges regarding compatibility of various blends.
Brazil said that the work on effective implementation of the 0.50% sulphur limit in 2020 to be undertaken by the MEPC should not focus on enforcement “but rather on exploring what actions, including preparatory and transitional measures to address any expected impact on fuel and machinery systems, uncertainties in general and potential safety concerns, may be taken to ensure truly consistent, safe and effective implementation of the global cap from 2020 onwards, and, as a result, secure the necessary compliance.“
IBIA prepared a statement prior to the meeting highlighting that although the terms of reference for the availability study, set at MEPC 68 in 2015, requested the contractor to model the possible adjustment of the marine fuel oil flashpoint limit to 52°C, the conclusion presented to MEPC 70 that there would be sufficient refinery capacity to meet both marine and non-marine demand for fuel in 2020 did not rely on lowering the flashpoint limit from the current SOLAS requirement of 60°C. This point was also specified by the IMO Secretariat before opening discussions on the two papers.
Addressing MSC 98 in plenary, IBIA’s IMO representative added: “Furthermore, this committee [MSC], at its 96th session in May 2016, decided that all safety concerns with regard to ships using low-flashpoint fuels should be addressed in the context of the IGF Code only, and to not reopen discussion on the possibility of amending the minimum 60°C flashpoint requirement in SOLAS.”
IBIA noted that this means fuels provided to the marine sector in 2020 will still need to meet a minimum flash point of 60°C as per the SOLAS requirement to be commercially viable.
Most member state delegations that spoke concluded that there is no requirement to reopen a discussion on whether meeting demand in 2020 will require a reduction of the current flashpoint limit in SOLAS, and noted that any further considerations of low flashpoint fuels should be dealt with under the auspices of the IGF Code (International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels).
Despite that, a number of member states and industry NGO delegations were supportive of the proposal from Chile and Brazil, demonstrating that many are concerned that the safety of ship and crew are being compromised in order to meet the 0.50% sulphur limit in 2020.
“We agree that there is a need to keep a close eye on the safety implications associated with efforts to meet demand for fuels complying with the 0.50% sulphur limit that is due to take effect on 1 January 2020,” IBIA told MSC 98.
Even a small amount of a low flashpoint blend component could cause the resultant blend to be off-spec, hence caution is required when choosing blend components, IBIA explained.
“The general consensus in the market today is that refineries and other parties in the marine fuel supply chain are aware of the 60°C flashpoint limit and as such will take due care to ensure products offered to the marine fuels market comply with the SOLAS requirement,” IBIA told MSC 98.
This may not be enough to reassure IMO member states, however, because flashpoint is seen as a critical safety parameter.
One member state delegation stressed that there have been “numerous reports” over the past few years of fuels failing to meet the minimum flashpoint limit being supplied to ships. MSC 98 also heard a proposal, put forward during discussions, to make it mandatory to include flashpoint on the bunker delivery note. This received significant support, but there were also objections, so it was not formally put forward to MEPC.
MSC 98 agreed that the way forward on flashpoint was to encourage interested parties to submit proposals to the Sub-Committee on Carriage of Cargoes and Containers (CCC) to develop specific requirements for low-flashpoint fuel oils within the context of the IGF Code.
CCC has an on-going agenda item relating to revisions to the IGF Code to add new chapters for low-flashpoint fuels which are materially different from LNG and therefore very different safety requirements. On member state informed MSC 98 that it will submit the results of a study on the use of low flashpoint distillate fuels to the next session of CCC. To date, CCC has only discussed a new chapter on using methanol as a marine fuel.
Aside from the issue of flashpoint, IBIA and other delegations noted that there are other uncertainties surrounding potential safety concerns relating to the fuel oil blends that are anticipated to come into the market to meet the 0.50% sulphur limit.
MEPC 71 will consider a draft justification and scope for a ‘new output’ [*] prepared by the Sub-Committee on Pollution Prevention and Response (PPR) on consistent implementation of the 0.50% sulphur limit. The draft scope already includes a note to consider the potential impact on fuel and machinery systems, but it was agreed, following discussions at MSC 98, to request MEPC 71 to explicitly add to the scope considerations on the safety implications relating to using fuel blends to meet the 0.50% sulphur limit.
If this is approved at MEPC 71, the PPR Sub-Committee will be asked to report to MSC on any safety issues that may be identified with regard to low-sulphur fuels.
[*] A ‘new output’ means adding a new work item to the agenda of an IMO committee.