MSC 105: Discussion to continue on sampling to determine flashpoint compliance
What happens next when ships have indicative test results suggesting that the oil fuel supplied may not comply with the minimum 60°C flashpoint limit under SOLAS?
This was among the questions addressed at a working group during the 105th session of Maritime Safety Committee (MSC 105), which met from met from 20 to 29 April.
Having noted that there were several guidelines and advisories in place already, the working group agreed to limit future discussion on the subject to development of sampling procedure guidelines for a “SOLAS sample” similar to the existing “MARPOL sample” taken at the time of delivery to ship. The delivered MARPOL sample is only for the use of relevant authorities to check for compliance.
IBIA suggested to the working group that the existing delivered MARPOL sample, which is also recorded on the bunker delivery note (BDN), could potentially be used to check for flashpoint. It is possible for authorities to take a sub-sample from the MARPOL sample for this purpose; the remaining MARPOL sample can be resealed and kept on the ship. It would not have a negative impact on any subsequent testing for sulphur, should that be required.
After doubts about this approach during initial discussions, support grew. It was noted that requirement for an additional sample besides the sample required under the MARPOL Convention should be avoided. Furthermore, the working group noted the view that the number of cases where a representative sample needs to be analysed to determine the flashpoint is expected to be far below 1% which makes an additional sample an unnecessary burden.
MSC 105 agree to task the Correspondence Group on Oil Fuel Safety, which was re-established, to develop guidelines for sampling procedures, taking into account resolution MEPC.182(59), which contains the 2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI.
An amendment to resolution MEPC.182(59) and/or a joint MSC-MEPC guideline could offer a way forward, allowing a single sample to be available for authorities to check for compliance with flashpoint and/or sulphur to establish compliance.
IBIA intends to continue to take part in the Correspondence Group on Oil Fuel Safety.