IBIA welcomes signs that work could get underway at the International Maritime Organization (IMO) on developing the legal framework specifically for ships to use diesel with flashpoint below 60°C. This will not entail a possible change in the SOLAS flashpoint limit, as the IMO has previously agreed that all discussion regarding fuels with a flashpoint below 60°C can only take place within the context of the IGF Code (International Code of Safety for Ships using Gases or other Low-flashpoint Fuels).
Germany presented the first part of a major study intended to establish whether there is a particular risk related to using low-flashpoint diesel on ships to an IMO meeting last week. One of the conclusions of this study, submitted to the 4th session of the Sub-Committee on Carriage of Cargoes and Containers (CCC 4), was that the flashpoint criterion is not commonly used in other industry sectors and that flashpoint as the only fuel related safety parameter is not sufficient.
Germany also informed CCC 4 that the country is willing to look into developing a formal safety assessment (FSA) study and possibly draft provisions for ships to be fuelled by low-flashpoint diesel.
The German initiative was welcomed by the Sub-Committee though several member states expressed reservations and concerns that it may reopen the discussion about revising the SOLAS flashpoint limit.
There have been attempts in recent year to revise the 60°C minimum for marine distillates and align it with the minimum flashpoint limit for automotive diesel, which is 52°C in the US and 55°C in Europe. Studies presented to the IMO had suggested it would be safe to reduce the SOLAS flashpoint limit for these fuels to 52°C and thereby widen the supply pool of fuels complying with lower sulphur limits, but the IMO’s Maritime Safety Committee (MSC), at its 96th session in May 2016, firmly shut the door on amending the SOLAS flashpoint limit.
This means ships still need fuels to meet the minimum 60°C flashpoint limit in SOLAS.
The only legal framework for using fuels with a lower flashpoint is the IGF Code, which entered into force on January 1, 2017. It was developed, in the first instance, to deal with LNG, but its general requirements nevertheless applies to all vessels above 500 gross tonnage that install low flash point fuel systems. Specific regulations for other low-flashpoint fuels can be added as new chapters to the Code, but in the meantime, ships installing fuel systems to operate on other types of low flashpoint fuels will need to individually demonstrate that their design meet the Code’s general requirements.
Germany is fully onboard with keeping discussions about using low-flashpoint diesel within the context of the IGF Code, and only asked a working group set up during CCC 4 to undertake a preliminary assessment of what further information and issues should be addressed by a future FSA study.
Due to time-constraints, the WG did not get around to undertaking this assessment, but Germany appears to be committed to carrying on with the study and to submit substantial papers to the next meeting of CCC, expected to take place in September 2018.
Comments in plenary during CCC 4, however, included remarks that further safety assessments on low flashpoint diesel use need to go beyond vapour and also address issues such as management of fuel leakages, the possible need for more ventilation, and approval of appropriate equipment. Risk analysis must be comprehensive and exhaustive, it was noted.
IBIA welcomes Germany’s initiative as the safety provisions for ships using LNG as a fuel are substantially different from the what would be required to operate safely with diesel fuels with a flashpoint between 52°C and 60°C. Providing specific IGF Code provisions for ships to operate on these fuels would clarify these requirements for all ships, compared to the current situation where ships would need to individually demonstrate that their design meet the Code’s general requirements.
Report by Unni Einemo