IBIA Wants IMO to Improve New Flashpoint Regulations

The International Bunker Industry Association (IBIA) has submitted proposals to the Maritime Safety Committee (MSC 107) which will be meeting later this week in a bid to improve understanding and workability of new flashpoint regulations for fuel oil.

MSC 107 will meet from 31 May to 9 June and will continue discussion on an agenda item for the development of further measures to enhance the safety of ships relating to the use of fuel oil. In essence, the aim is to introduce increased control on the supply of bunker fuels. The initial focus was on flashpoint, but discussions have also been going on in a Correspondence Group on the subject of “possible measures related to oil fuel parameters other than flashpoint.”

IBIA has authored four submissions to MSC 107 under this agenda item, mainly in response to draft sampling guidelines and other ideas discussed in the report of the Correspondence Group.

In November 2022, MSC 106 adopted amendments to Chapter II-2 of SOLAS regarding flashpoint “to further enhance the safety of ships using conventional oil-based fuel oils”.

IBIA has observed that the regulatory text for information to be provided by the bunker supplier regarding flashpoint is causing a lot of confusion and has therefore proposed a unified interpretation (UI) of SOLAS chapter II-2 to help clarify the meaning of the regulatory text. It is now asking for a corresponding UI to be approved for MARPOL Annex VI, which has added a flashpoint documentation requirement for the bunker delivery note.

MSC 107 will also consider draft joint MSC-MEPC sampling guidelines. These were developed by the Correspondence Group after it was agreed that the delivered MARPOL sample (for sulphur verification) can also be used to confirm flashpoint.

IBIA makes proposals about the draft MSC-MEPC guidelines regarding the sampling location, saying they should take into account safety, practicality and alignment with established industry practice. “We argue that the most important aspect of the statutory sample to be retained by the ship is that it is representative of the fuel delivered, so it is essential that the sample is drawn by skilled personnel.  Our paper, having described the issues in detail, concludes by proposing that the joint MSC-MEPC Guidelines should allow the sampling equipment to be positioned at the bunker manifold of either the receiving ship or the bunker tanker, as agreed between the receiving ship and supplier in advance. We have also proposed modifications to the draft MSC-MEPC sampling guidelines to reflect practical considerations regarding sample integrity and sample bottle size.”, including adding a general regulation in SOLAS in line with Regulation 18 of MARPOL Annex VI. An alternative proposal put forward is to reference a fuel standard, which would in essence make compliance with ISO 8217:2017 mandatory.

IBIA and ISO have submitted a joint paper which advises against mandating ISO 8217, as this would likely generate many unjustified demands for debunkering fuels which are either perfectly safe, or may be safely managed onboard with due care and attention.