Off-specs and bunker licensing discussed at IMO
IBIA voiced support for licensing of bunker suppliers, but urged caution about how to interpret ‘off-specs’ at the 106th session of the IMO’s Maritime Safety Committee that took place from November 2 to 11.
Two papers were submitted to the meeting about fuels that may jeopardize the safety of ships. The submitters of the documents said these would be useful for the Correspondence Group on Development of further measures to enhance the safety of ships relating to the use of fuel oil (CG). This CG, which works between MCS meetings, was re-established at MSC 105. IBIA takes part in the CG with input from the IBIA Technical Working Group. (More info on this link)
One of the papers, MSC 106/18/1, submitted by BIMCO, ICS, INTERCARGO and INTERTANKO provided statistics, based on a set of data from 2020 from a major fuel testing agency, about fuels failing to meet ISO 8217 parameters. The other, MSC 106/INF.19 submitted by Singapore gave details of investigations and actions taken following the supply of bunker fuel containing chlorinated organic compounds in the Port of Singapore earlier this year.
MSC 106/18/1 also pointed to regional differences in off-spec occurrences, and proposed “that Member States, including the individual ports within Member States, and relevant intergovernmental organizations consider implementing and enforcing a licensing scheme for bunker suppliers operating within their jurisdiction to combat the high off-spec occurrence rates in some poorer performing geographical regions”.
Commenting on these papers, IBIA made the following statement at MSC 106:
“We thank the co-sponsors of MSC 106/18/1 in relation to off specification occurrence rates during 2020, highlighting regional differences, which we are aware of. We are very much supportive of the proposal in the document that relevant authorities should be encouraged to consider implementing and enforcing a licensing scheme for bunker suppliers operating within their jurisdiction. The approach of the Maritime and Port Authority of Singapore in connection with the recent case in Singapore of Organic Chlorides described in MSC 106/INF.19 is a prime example of the benefits of a licensing scheme.”
During discussions of the two papers at MSC 106, several delegations supported sending both to the CG on fuel oil safety for consideration.
There was not, however, much appetite for pursuing bunker licensing among Member States. A few questioned the degree to which bunker licensing would be effective in preventing supply of off-spec fuels. Several noted that it is entirely the responsibility of the supplier to provide on-spec fuel.
Several delegations stressed that bunker supplier licensing schemes had already been thoroughly discussed in recent years, both by MSC and the Marine Environment Protection Committee (MEPC), and that implementation of such licensing schemes should be voluntary. Moreover, MSC agreed that bunker licensing should be addressed by MEPC under the remit of MARPOL.
IBIA and BIMCO have submitted a paper to the upcoming MEPC 79 meeting in December. Our document, MEPC 79/INF.24 shares the results of our joint industry survey, which identified broad support among maritime industry stakeholders for adoption of bunker licensing schemes and mass flow metering systems to improve transparency and market conditions.
We submitted this document to MEPC to raise awareness among IMO Member States and stakeholders of the benefits of adopting effective bunker licencing programmes and MFM technology. (Read it on this link: MEPC 79/INF.24)
Off-spec interpretation
In regards to the off-spec data from 2020 presented in MSC 106/18/1, IBIA told MSC 106 that the data came across as overly alarming for several reasons.
“According to ISO 4259, which is incorporated for every individual test method listed in ISO 8217, a fuel is considered off-spec only if the tested value exceeds both the actual limit and the 95% confidence interval for each specific parameter. The data presented in document MSC 106/18/1 does not appear to take the 95% confidence interval into account, hence the percentage of off-specs is greater than if the paper had followed the industry accepted approach to test results. Data from two testing agencies from the start of 2021 to Q3 of 2022 that do take 95% confidence into account show the percentage of off-specs at much lower levels. For the ARA region, for example, where data in MSC 106/18/1 shows off-specs including sulphur at 19%, data from 2021 and 2022 show off-specs including sulphur averaging 6.76% from one fuel testing agency and quarterly averages ranging from 2.4 – 4.3% from another,” IBIA’s Director and IMO Representative Unni Einemo told MSC 106.
“Most importantly, it should be noted that an “off-spec” fuel does not necessarily pose a significant safety risk to the ship. One of the most common off-specs is excess water, which is easily managed at twice the specification limit. A more critical parameter like Al+Si, meanwhile, is harmful even at on-spec concentrations if the fuel is not properly managed onboard, yet fuels testing above the limit may often be safely managed onboard with due care and attention,” she added.
“In conclusion, this paper does not reflect the percentage of oil fuels that present a significant safety risk to the receiving ship, and we would therefor suggest a more selective approach to examining fuel quality data relating to the safety of ships.”
While there was support for, and no objections to, sending the MSC 106/18/1 to the CG on fuel oil safety, some said more information was desirable, such as an indication of the degree to which parameters exceeded ISO 8217 parameters, and the possible influence on safety associated with the off-spec parameters.
It would also be very useful for the work on assessing oil fuel safety issues to receive more information from concrete cases where fuel has been identified as causing an incident, it was noted.
The CG on oil fuel safety will have several rounds of discussions between now and MSC 107, which is scheduled for early June next year. In the first round, the CG will discuss guidelines for sampling procedures to establish flashpoint. (More info on this link)