MSC completes work on fuel oil safety with another SOLAS amendment
In December 2018, at its 100th session, the IMO’s Maritime Safety Committee (MSC 100) agreed to add a new item to its agenda to address concerns about fuel oil safety. The subject arose from discussions around the safe implementation of the new 0.50% sulphur limit under MARPOL Annex VI, known as IMO 2020. (More information on THIS LINK)
Since then, IBIA has been deeply involved in the work on this MSC agenda item, namely “Development of further measures to enhance the safety of ships relating to the use of fuel oil“. There have been four fuel oil safety working groups dedicated to this item during MSC meetings, as well as four comprehensive rounds of discussions in a corresponded group on fuel oil safety between MSC meetings.
The first outcome of this work were amendments to SOLAS Chapter II-2 relating to flashpoint. These including mandatory documentation from suppliers regarding flashpoint, mandatory reporting of flashpoint non-compliance by suppliers, and mandatory “action as appropriate” against oil fuel suppliers found to deliver non-compliant fuels. These SOLAS amendments are expected to enter into force on 1 January, 2026. The SOLAS amendments are very similar to requirements under MARPOL Annex VI regarding sulphur limits.
In connection with this, MSC has also developed draft joint MSC-MEPC sampling guidelines for a statutory sample taken during delivery to ship, to have a single sample to be used by relevant authorities to determine if the fuel, as delivered, complies with the SOLAS flashpoint requirement and/or relevant sulphur limits under MARPOL.
Once MSC had agreed on these new flashpoint regulations under SOLAS, focus turned to complex discussions on possible regulations to address fuel oil safety concerns other than flashpoint.
MSC 107 had three proposals to consider on this subject. One was to adopt in SOLAS a general safety requirement in line with regulation 18 of MARPOL Annex VI. Another was to reference a fuel standard, in essence making ISO 8217:2017 mandatory. Both of these were outcomes of discussions in the correspondence group prior to MSC 107, as detailed in MSC 107/6, the report of the correspondence group on fuel oil safety. A third proposal came from China in MSC 107/6/2, suggesting to require groups of chemical compounds to be listed in Material Safety Data Sheets (MSDS). After some discussion, MSC agreed that only the first proposal was viable and tasked the fuel oil safety working group to finalise the draft amendment. IBIA supported this way forward.
The working group proceeded to develop a new general SOLAS regulation with text similar to MARPOL Annex VI, regulation 18.3.1.1.3 as follows: “Oil fuel delivered to and used on board ships shall not jeopardize the safety of ships or adversely affect the performance of the machinery or be harmful to personnel.”
MSC 107 agreed to this draft new SOLAS regulation, which adds a new paragraph to Regulation 4 on Probability of ignition to SOLAS chapter II-2. Formal adoption of this draft new SOLAS regulation II-2/4.2.1.9 will be up for formal adoption at MSC 108 in the spring of 2023.
With regards to the other possible measures related to oil fuel parameters other than flashpoint, the IMO noted that there is ongoing research into parameters that can have a detrimental impact on fuel safety. However, as there were no concrete proposals for any further regulatory actions at this stage, MSC 107 agreed with the conclusion of the fuel oil safety working group that currently, work under the output on “Development of further measures to enhance the safety of ships relating to the use of fuel oil” is completed.
As the oil fuel safety work comes to an end, another workstream begins. MSC agreed to establish a correspondence group on a new output (agenda item), namely “Development of a Safety Regulatory Framework to Support the Reduction of GHG Emissions from Ships Using New Technologies and Alternative Fuels”. Work on this new output is expected to be ongoing for many years to come.