The Worldwide Bunker and Business Affiliation (IBIA) on Monday (7 June) revealed an replace relating to discussions of extra flashpoint laws on the 103rd session of the Maritime Security Committee (MSC 103) which occurred in distant periods held between 5 to 14 Could 2021.
Efforts have been underway on the IMO for a while to make sure that oil-based bunker fuels, when delivered to ships, adjust to the flashpoint restrict of 60⁰C stipulated underneath SOLAS. The topic got here up in the course of the run-up to the IMO 2020 sulphur restrict, amid considerations in regards to the potential affect on ship security related to the transfer to fuels complying with the 0.50% sulphur restrict required underneath MARPOL Annex VI.
Whereas MARPOL is handled by the IMO’s Marine Atmosphere Safety Committee (MEPC), security points are additionally handled by the IMO’s Maritime Security Committee underneath an agenda merchandise referred to as “Improvement of additional measures to boost the security of ships regarding the usage of oil gasoline.”
IBIA, with the help of our Technical Working Group, has been intently concerned in these discussions at IMO conferences, in IMO working teams and in IMO correspondence teams all through, most just lately on the 103rd session of the MSC (MSC 103) in Could 2021.
After every week of intense debate at MSC 103, the place IBIA had an lively delegation supported by trade specialists from our technical working group, some parts of the extra laws underneath SOLAS at the moment are close to completion and on the right track for approval at MSC 105, which is predicted to fulfill towards the top of the second half of 2022. MSC 103 re-established a correspondence group (CG) to proceed this work, which can report back to MSC 105 as there’s not enough time to have the CG finalise the work previous to MSC 104, which can meet later this 12 months.
The CG has been instructed to:
- Additional develop, with a view in the direction of finalization, draft SOLAS amendments regarding reporting of confirmed instances the place oil gasoline suppliers have failed to fulfill IMO flashpoint necessities.
- Draft SOLAS amendments on actions towards oil gasoline suppliers which were discovered to ship oil gasoline that doesn’t adjust to minimal flashpoint necessities.
- Additional develop obligatory necessities relating to the documentation of the flashpoint of the particular gasoline batch when bunkering.
- Additional develop pointers for ships to handle conditions the place indicative check outcomes counsel that the oil gasoline provided could not adjust to SOLAS regulation II-2/4.2.1 (which says that no gasoline oil with a flashpoint decrease than 60 levels Centigrade shall be used, until particularly permitted).
- Acquire info on and take into account doable measures associated to grease gasoline parameters aside from flashpoint.
So the place are we with all this? Will it get us nearer to the purpose of enhancing the security of ships? There are conflicting views on the best way to greatest obtain the purpose, which is to forestall provide of bunkers that fails to fulfill the SOLAS flashpoint restrict or include substances deemed to place ship and crew security in danger.
It’s clear from the wishes of the various shipping organisations with consultative standing on the IMO, and a number of other Member States, that they need laws concentrating on the availability aspect to forestall fuels beneath SOLAS restrict from being provided to ships within the first place, and to make sure suppliers face penalties if it nonetheless occurs.
Discussions on flashpoint laws throughout MSC 103
It’s onerous to summarise progress at MSC 103, however objects that are closest to completion embody a requirement for Contracting Governments (i.e. signatories to SOLAS) to report confirmed instances the place oil gasoline suppliers have failed to fulfill the necessities laid out in SOLAS regulation II-2/4.2.1 (together with a definition of confirmed instances) and to “take motion as applicable” towards suppliers which were discovered to ship fuels that don’t adjust to SOLAS.
As regards to obligatory necessities relating to documentation of the flashpoint of the particular gasoline batch when bunkering, the bulk view seems to assist requiring that suppliers ought to report the precise flashpoint of the gasoline delivered to the ship, much like the MARPOL requirement for reporting the precise sulphur content material on the bunker supply observe, versus a declaration that the oil gasoline provided is in conformity with the SOLAS II-2/4.2.1 regulation.
IBIA has been questioning, throughout our enter at IMO on the topic, whether or not this can make a distinction on condition that suppliers have already got to offer a cloth security knowledge sheet (MSDS) to the ship, which ought to assure that the gasoline meets the SOLAS flashpoint restrict, and since the provider has additionally entered a contractual obligation to fulfill the flashpoint restrict as fuels are largely offered towards ISO 8217 specs, which embody a 60⁰C flashpoint restrict.
At MSC 103, IBIA highlighted that we’ve got but to listen to purpose for requiring the precise flashpoint to be reported to the ship, versus an announcement that it meets the 60⁰C restrict, as a result of operationally the precise flashpoint shouldn’t matter; regular security procedures nonetheless have to be utilized. IBIA additionally defined that it’s common follow throughout gasoline testing to cease the check to find out flashpoint as soon as the pattern has been heated to 70⁰C or above, as a result of that implies that the 60⁰C restrict has been met and no additional testing is taken into account needed. As such, the sensible issues and penalties don’t seem to benefit requiring an precise flashpoint worth to be documented.
IBIA additionally commented on a proposal by ICS and the Prepare dinner Islands in MSC 102/6/2 to require a consultant pattern for the aim of testing flashpoint to be taken on the time of supply, which seeks to mandate the sampling location on the ship’s inlet manifold. IBIA instructed MSC 103: “This goes past the provisions for the MARPOL delivered pattern, which is a suggestion. The realities of bunkering operations signifies that it’s typically unsafe for a consultant of the gasoline provider to come back aboard the ship to witness sampling on the ship’s inlet manifold, and it’s also often not possible to watch remotely because the ship’s inlet manifold might be utterly out of sight from the bunker supply vessel. Conversely, it’s typically doable to view sampling on the bunker outlet manifold from the deck of the receiving vessel, making this each safer and extra sensible.”
What was clear throughout these discussions was that there’s robust want to place extra accountability on the availability aspect to offer compliant fuels, however restricted understanding of how testing for flashpoint really works. Any justification for requiring an precise worth to be reported as opposed an announcement that it’s above 60°C is obscure.
Following dialogue, MSC 103 endorsed an up to date work plan aiming to finish measures associated to the flashpoint of gasoline oil at MSC 105, which means the correspondence group can have plenty of work to do to offer totally developed draft amendments to SOLAS and related pointers.
How massive is the issue?
Gasoline testing companies have knowledge on flashpoint from fuels really delivered to ships. Whereas statistics fluctuate slightly between them, ISO/TC28/SC4/WG6, the ISO committee in command of ISO 8217, has gathered knowledge from many of the main testing companies, which ought to give a good general illustration.
The ISO comparative examine confirmed that for the primary half (H1) of 2020, there had been a small enhance in distillate marine (DM) gasoline samples with a flashpoint of beneath 60°C in comparison with throughout all of 2018, however it was nonetheless beneath 1% of all DM gasoline samples. It discovered that 99.9% of very low sulphur gasoline oil (VLSFO) residual marine samples had a flash level assembly the 60°C restrict, and that 0.08% had a flash level between 55°C and 60°C. In each 2018 and H1, 2020, greater than 99.5% of HSFO samples met the 60°C flashpoint restrict. Total, then, it appears VLSFOs have been no extra susceptible to off-spec flashpoint than HSFOs, whereas the share of DM samples beneath the restrict confirmed a small enhance throughout 2020.
Apparently, an info doc submitted to IMO by China (MSC 102/INF.18), reporting on classes discovered from three explosions in gasoline oil tanks and two explosions of parts of gasoline oil booster unit/methods, confirmed that solely a type of instances associated to a gasoline with a flashpoint beneath the SOLAS restrict, reportedly measured at 37°C. Within the different instances, the flashpoint had been measured above, and in some instances effectively above, 60°C.
The paper drew a transparent causal hyperlink between the gasoline with the flashpoint measured at 37°C and an explosion in a gasoline oil storage tank, however the explosions within the different instances had been linked to different components. Within the case the place the flashpoint was measured at 37°C, it was reported that there was no flame display mounted in opening of the oil mist field, and that transferring flames ignited vapour after the gasoline oil within the storage tank was heated
Incidents attributable to low flashpoint fuels, thankfully, look like very uncommon. IBIA has beforehand been knowledgeable by the gasoline testing arm of Lloyd’s Register, GMT/FOBAS, that LR has no data of incidents attributable to low flashpoint fuels from 1970 and as much as 2010, just for auto-ignition level.
Picture credit score and supply: International Bunker and Industry Association
Revealed: 9 June, 2021