flashpoint of marine distillate oil fuels...8 of 57 flashpoint of marine distillate oil fuels for...

Flashpoint of

Marine Distillate Oil Fuels Issues and implications associated with the harmonization of the minimum flashpoint requirement for marine distillate oil fuels with that of other users

Prepared for the Danish Shipowners’ Association

by Lloyd’s Register FOBAS

Our Ref: FOBAS/001386/2011 - 4 Submitted: 27 January 2012 Authors: A.A Wright C.Eng., F.I.MarEST T.S Wilson C.Eng., M.I.MarEST

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"Neither Lloyd’s Register FOBAS nor Lloyd's Register make any representations or warranties about the accuracy or suitability of the information contained in this paper for any purpose. In no event will Lloyd’s Register, its subsidiaries, or any member of the Lloyd’s Register Group be liable to any third party for any direct, indirect, consequential or other damages or loss of any kind arising as a result of such third parties direct or indirect reliance on the contents of this paper. The contents of this paper is copyright of Lloyd's Register. It is confidential and may also be legally privileged. It should not be reproduced or used without written permission."

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Special thanks is extended to the ‘Danish Maritime Fund’ for the funding given to enable this study to be carried out

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Contents

Flashpoint of Marine Distillate Oil Fuels 1

Executive summary 6

1. Introduction 8

2. Flashpoint as a quality parameter 10

2.1. Flashpoint testing 10

2.2. Flashpoint of products and mixtures 12

2.3. The use of flashpoint as a safety measure 13

2.4. Fire safety aspects related to oil products 14

3. Flashpoint as applied to marine oil fuels 17

3.1. Statutory control requirements 18

3.2. Classification society requirements 23

3.3. Oil fuel specifications 27

3.4. Expression of oil fuel flashpoint limits 28

4. Why change the marine oil fuel flashpoint limit? 30

4.1. Impact of MARPOL Annex VI on marine oil fuels 30

4.2. Non-marine oil fuels 32

4.3. Effects of reducing the marine oil fuel flashpoint limit 34

5. Potential effect on safety of changing minimum flashpoint limit 35

5.1. Causes of machinery space fires 35

5.2. Canadian study on the setting of the marine oil fuel flashpoint limit 37

5.3. Flashpoint of marine oil fuels – a statistical view 37

6. Flashpoint harmonisation and regulatory implications 43

6.1. Amendment of the SOLAS Convention 43

6.2. Phrasing of SOLAS amendment 44

6.3. Amendment of other IMO instruments 45

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6.4. Amendments to other non-IMO regulations and requirements 46

6.5. Alternative to amending the SOLAS Convention 46

7. Practical implementation of change 49

7.1. Oil fuel grades to which a revised oil fuel minimum limit would apply 49

7.2. Revised minimum flashpoint limit 51

7.3. Implications of marine distillate oil fuel quality 53

7.4. Implications on ship arrangement and equipment requirements 55

8. Appendices 56

9. References 56

10. Acknowledgements 56

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Executive summary

Annex VI to the MARPOL Convention, which controls air pollution from ships, sets a schedule for a dramatic reduction of oil fuel sulphur limits. In 2015 the sulphur limit will be reduced to 0.10 % in Emission Control Areas, which will by then cover the Baltic and the North Sea together with the North American and US Caribbean areas and in 2020 for the limit outside those areas it is intended that it will be reduced to 0.50 %. These changes imply that in a few years the majority of ships will be operating on distillate grade fuels rather than the residual fuel oil generally used today. It is widely recognised that this transition, over a very short time span, will impose an unprecedented increase in the demand on the production of those compliant fuels. Today there is already a significant price difference between distillates and residuals, and this difference is expected to soar as a market reaction to the higher demand for distillates. That part of global shipping which for practical reasons do not compete with other transport modes may be able to absorb the additional cost and to some extent pass it on to consumers, but for short sea shipping, which in general is competing with land based transport, the additional cost will impose a potentially unsupportable burden. Under such circumstances it would be highly desirable to maximise marine oil fuel availability by avoiding any unnecessary differences in oil fuel specifications between the marine and other industries. Lloyds’ Register FOBAS has carried out a study, commissioned by the Danish Shipowners’ Association and funded by the Danish Maritime Fund, to determine possible issues and implications associated with a harmonization of the minimum flash point requirement for marine distillate oil fuels with that of auto diesel, taking into account ship safety, the impact on other marine regulations and how such change could be implemented in practise. Flashpoint is a long established parameter used to categorise the apparent fire risk associated with oil fuels and similar products. However, the flashpoint value as determined by analysis represents the temperature at which sufficient quantity of ignitable vapour was generated under the very particular conditions of that test. Therefore, the flashpoint temperature does not represent a ‘safe’ / ‘unsafe’ transition point; under real world situations a potentially ignitable vapour concentration could exist in the headspace of tanks where the oil fuel is at a temperature below the stated flashpoint. Conversely, where the oil fuel in a tank is at a temperature above the flashpoint the vapour concentration in the headspace may not be in an ignitable condition. In either case there needs to be an ignition source for combustion to occur. In reality, in marine applications, an oil fuel fire is initiated through leakage or pipe failures allowing the fuel to


come into contact with surfaces above its autoignition temperature rather by vapour ignition. Nevertheless flashpoint has been used as a safety parameter in petroleum safety legislation from the outset albeit at times against somewhat arbitrarily set limits or due regard to the fact that it was an empirical value. The first classification society Rules for oil fuels in 1903 included a 150°F flashpoint limit, together with other requirements aimed at avoiding the ignition of any vapour generated, although until 1962 the Rules still provided for the use of petrol or other low flashpoint fuels in engine rooms. Although to many the 60°C minimum flashpoint for general service fuels given in the SOLAS Convention may seem one of the bed-rocks of marine legislation this only came in with the 1981 amendments. The first three SOLAS Conventions (1914, 1929 and 1948) had placed no limit on oil fuel flashpoint and even the 1960 Convention only required that for ‘new’ passenger ships that the fuel used by internal combustion engines was to have a flashpoint of not less than 43°C – a provision essentially carried over to the current 1974 Convention as originally adopted. Due to legislation aimed at reducing sulphur emissions from shipping there is expected to be a dramatic increase in the marine distillate fuel demand. At present the slightly lower flashpoint limits applicable to automotive diesel (above 55°C in EU, minimum 52°C in US) preclude the supply of that otherwise identical fuel to the marine market hence impeding supply and increasing costs. Hence it is proposed that the marine distillate oil fuel minimum flashpoint limit should be harmonised with that applied to automotive diesel by means of an amendment to the SOLAS Convention thereby giving shipping access to a wider oil fuel supply chain. In this there is seen as being no inherent increase in fire risk resulting from such a change which should be applicable without modifications to existing ships. In providing for the use of automotive diesel, which widely contains a limited bio derived component, in marine applications this opens the prospect of associated operating problems. However, while the industry has only limited experience in this area it is expected that with awareness of the issues and the necessary attention to the appropriate procedures these should be manageable.


1. Introduction

Currently virtually all the fuel used by shipping is derived from petroleum. This fuel can be broadly divided into the distillate and residual oil fuel grades and, apart from certain particular exceptions, is currently limited to a minimum flashpoint of 60oC. This is in contrast to the flashpoint limit applied to, for example, European automotive diesel fuel where the requirement is that flashpoint is to be above 55oC. Consequently, while in all other respects marine distillate and automotive diesel fuels can be identical, these few degrees difference in minimum allowable flashpoint requires that in Europe the distillate fuel supply chain to ships has to be maintained segregated from that of the automotive diesel market. This is a situation which also applies in many other areas of the world, such as the US, where the marine flashpoint limit is higher than that applied to the local automotive fuel market. The particular significance of this lack of inter-changeability is that there is an increasing demand in the marine market for 0.10% maximum sulphur oil fuel. At present this in response to the EU Sulphur Directive’s ‘At Berth’ requirements however, from 1 January 2015, this limit will also apply to the Emission Control Areas established for sulphur oxides and particulate matter control (ECA-SOx) under MARPOL Annex VI which will dramatically accentuate demand. Additionally, it is scheduled that from 1 January 2020 that a maximum sulphur limit of 0.50% will apply to all marine fuel oils used outside the ECA-SOx areas. In general sulphur limits of 0.10% and 0.50% will not be met by use of residual oil fuels thus putting particular pressure on marine distillate fuel availability and supply capacity. In this circumstance it would be of particular benefit to the marine industry if the supply of distillate fuels to ships were not constrained by this limited difference in minimum flashpoint requirements. The objective of this study has been to identify and outline the possible issues relating to aligning the marine distillate fuel minimum flashpoint requirement with that applied to automotive diesel. In order to provide the required historical and technical perspective on this issue, a detailed review of flashpoint as a fuel test parameter, both in general and as specifically applied to marine fuels has been undertaken. This also focuses on how marine fuel flashpoint limits have evolved over time and the inter-relationship between flashpoint and other safety related factors. The background to the pressures to change the marine fuel flashpoint limit in order to align with that of automotive fuels is also examined. The prime consideration in considering any reduction in the marine distillate flashpoint limit must be that it does not compromise either ship or personnel safety. Consequently, this aspect is considered in detail based on the actual fire and ignition risks onboard and past experience of fuel flashpoints. In the marine industry ship and personnel safety risks are controlled by a complex web of interlinking controls. The implications arising from a change to the marine


distillate fuel flashpoint limit on other regulatory requirements and controls are considered together with how such a change could be introduced. Finally there are the issues of how such a change would be implemented in practice and the effect on shipboard operations. A central consideration in this would be that while the principal driver to change has been the marine distillate supply situation whether such a change should also apply to the residual fuel oil grades.


2. Flashpoint as a quality parameter

All petroleum products when exposed to the atmosphere tend to emit hydrocarbon vapours and on heating this rate of emission will be increased. For products with low rates of emitting these vapours and at low temperatures, the resulting ambient concentration, while being detectable (for example, as an odour), can be insufficient to be ignited by the application of a ignition source. Products which more readily emit such vapours, either due to their nature or prevailing temperature and ambient conditions, can result in concentrations which could be so ignited; such ignition will initially be momentary but thereafter, as the vapour concentration increases, ignition once started will be sustained. Although at the other end of the scale, in instances of very high hydrocarbon concentrations, ignition will not be possible. However, it must be recognised that flashpoint relates only to the resistance of a fuel to release vapours which could be ignited under the specific conditions of the test method applied; it infers no other in-service performance characteristics such as ignition rating (i.e. Cetane Number or Cetane Index) or clean burning combustion performance.

2.1. Flashpoint testing

The flashpoint of a product or a fuel (as a mixture of various products) is the lowest temperature of the sample at which the application of a flame causes the vapour above the sample to ignite and the resulting flame to propagate across the exposed surface of the sample under the specified conditions of the particular test being conducted. In practice, the actual flashpoint obtained is extremely dependent on the test method used to the point that it is meaningless to quote a value without giving the method by which the value was obtained. Due to the sensitivity of result to test method, flashpoint testing should be seen as a means of ranking products or fuels under reference conditions rather than describing actual response under in-service conditions. The primary basic difference in flashpoint testing is between the closed and open cup methods. As indicated by their terminology, the former traps the evolved vapours within an enclosed chamber to which the test flame is periodically applied whereas in the open cup method the vapours are allowed to dissipate. Consequently, while the open cup procedure may appear to be more akin to service conditions it introduces an addition element of variability to the test result therefore the more controlled conditions of the closed cup method have resulted in it, rather than the open cup, being the specified method in


most instances where flashpoint is controlled. Open cup methods will of course always result in higher flashpoint values than those obtained by closed cup testing but with such wide margins and variability that such findings are generally considered meaningless in practical terms. Flashpoint test methods have evolved over the years, to both enhance accuracy and to ease operation, and some test methods have been discontinued. Within the closed cup category current there are a number of possible standard test methods including: Pensky-Martens Abel Equilibrium Of these the Pensky-Martens Closed Cup (PMCC) method is the widely adopted method for marine fuels. In order to control reproducibility and to allow for comparison between different test laboratories the test equipment and procedures are specified in the standard test methods as published by the International Standards Organisation (ISO) and the various national standards bodies. In the case of PMCC flashpoint, the test reference is ISO 2719:2002 for which procedure A is used for distillates and procedure B for residual oil fuel. In this test a portion of the oil being analysed is placed in the test cup up to the given filling mark and heated at a given rate while being continuously stirred. The differences between Procedures A and B are in these heating and stirring rates. Starting at a point some 23oC ± 5oC below the expected flashpoint an ignition source is directed through an opening in the test cup lid at 2oC or 1oC intervals (depending on whether the expected flashpoint is above or at / below 110oC) at which points the stirring is interrupted. The lowest temperature at which the application of the ignition source causes the vapour from the test portion to ignite and propagate over the surface of the liquid is recorded and amended according to a given formula which provides for the difference between ambient and standard (101.3 kPa) barometric pressure to give the flashpoint as reported rounded to the nearest 0.5 oC. As with all standard test methods there are given limits of repeatability and reproducibility. Repeatability for residual oil fuels is 2.0oC and for distillates it is given by a formula – for 60oC it would be 1.7oC. In terms of reproducibility for residual oil fuels this is 6.0oC and for distillates it is given by another formula – for 60oC it would be 4.3oC. When comparing single test results to a specification value it is normal to use the 95% confidence criteria which would give that the lowest values considered as not being outside a 60oC specification limit would be 56.5oC for residual oil fuel or 57.5oC for distillates. The test method gives that the sample should be drawn from the fuel consignment to be tested into a container which is thereafter tightly sealed and stored in a manner which minimises vapour loss and pressure build-up (i.e. not in


sunlight) and at a temperature which does not exceed 30oC. In instances where these requirements are not followed the resulting test determined flashpoint will be higher than it otherwise would have been by an unpredictable amount. Since the requirement in respect of flashpoint is usually to know that it is above the specified minimum limit value rather than to know the actual value marine oil fuel testing services, such as Lloyd’s Register FOBAS, will normally use tests such as ASTM D7094-04(2009) ‘Standard Test Method for Flashpoint by Modified Continuously Closed Cup Tester’ as an initial screening tool. In this method, the ignition source is applied to the sample portion at a set temperature (70oC in the case of FOBAS) above the specification limit to determine whether it momentarily ignites and the flame propagates across the sample surface. In using this approach only if a flash is obtained is the actual flashpoint determined using the ISO 2719:2002 method.

2.2. Flashpoint of products and mixtures

A particular petroleum product such as dodecane (C12H26) has a flashpoint of 74oC whereas octadecane (C18H38) has a flashpoint of 165oC. A mixture of these two products will have a flashpoint between the two values but which will be much closer to the lower value, irrespective of the actual ratio of the components. In the case of a petroleum distillate fuel which can be considered as being comprised of an extensive range of hydrocarbon structures differing in both carbon/hydrogen composition and the manner in which those carbon and hydrogen atoms are combined, the overall flashpoint will be a function of the various components but will be heavily influenced by the lowest flashpoint / most volatile component. In general, the lighter a hydrocarbon (of a particular hydrocarbon type) the lower its flashpoint will be. Furthermore, since the tendency of a particular petroleum product to emit hydrocarbon vapour increases as its temperature increases the use of flashpoint as a means to indicate the fire risk associated with that product appears self evident although in reality this is not the full story since a product could still generate a potentially hazardous vapour at a temperature below the flashpoint (which is an empirical – not real world – value) under actual in-service conditions. Therefore flashpoint value does not, and never has, represented a ‘safe’ / ‘unsafe’ boundary line. Consequently from the outset of the petroleum industry flashpoint has been used, somewhat incorrectly, as means of distinguishing between those products for which greater care and attention is required as to storage and use.


2.3. The use of flashpoint as a safety measure

Historically petroleum, much of which was obtained from natural seepages, had been used for a variety purposes. However, even before Drake’s much celebrated drilling of an oil well in Pennsylvania in 1859 there was an established Scottish oil shale industry which had been the driver to the initial development of oil refining whereby the raw product is separated into a number of specific products each with its own areas of application. The early principal demand for petroleum products was for kerosene as lamp oil, and in this respect the establishment of the Pennsylvania oil fields as the ‘first’ oil field was propitious as the crude oil produced yielded around 70-80% of the processed quantity as the required product. This left however around 15-25% of the processed quantity, there being around 5% losses, as material which was either too light or too heavy to be readily used as lamp oil, in the case of the latter this was fairly easy to exclude since lamp oil including such material would be smoky and hence commercially unattractive. In the case of the lighter fraction - broadly termed naphtha (raw petrol / gasoline), for which at that time there were only limited markets as such finishing products, solvents or anaesthetics - it was necessary to exclude their inclusion from the lamp oils and this led to the practice of using flashpoint as an early quantity control measure. In view of the flammable nature of petroleum products, particularly the ‘lighter’ products, it was readily seen that it was necessary to control the places and manner in which they were stored, particularly in urban areas, and the port areas in which they were landed. At that time from conventional type ships with holds the oil having been shipped, particularly in the early days, in wooden barrels (hence that as the standard unit of measure still used today by many oil companies). In the UK petroleum related legislation commenced with the Petroleum Act of 1862. In this ‘petroleum’ was defined as ‘… including any product thereof that gives off an inflammable vapour at a temperature of less than 100oF …’. The adoption of 100oF as the criteria was taken on the arbitrary basis that such a temperature would be unlikely to be exceeded as the normal ambient temperature of a storage facility in the UK. However, since no test method to determine flashpoint was specified the Act was largely unworkable. In 1868 an amending Act was introduced which included a specified open cup method. These two Acts were replaced by the 1871 Act which initially included the previous limit and test method however there was a general intent to change the basis to a closed cup test as this was recognised as being more reliable, this led to considerable debate as to what was the closed cup equivalent to 100oF open cup. This was eventually settled as being 27oF difference between the original open cup and the later closed cup value given the test method used, hence the 1879 amendment of the Act included a flashpoint limit of 73oF by a specified closed cup test. This constituted the basis of UK legislation through to the twentieth century.


Legislation with regard to petroleum developed in an equally uncertain fashion around the world, often being highly influenced by local factors or incidents. Despite this, flashpoint remained the key defining parameter; albeit being given variously as open or closed cup and by a wide range of test methods. A summary of these requirements as they existed world-wide in 1913 is given in Appendix I. The specific application of flashpoint as a means of controlling marine oil fuels is the subject of Chapter 3.

2.4. Fire safety aspects related to oil products

With regard to safety in general there are however further characteristics which provide other information as to the risk associated with a particular fuel. As noted in the introduction to this section, the resulting hydrocarbon vapour concentration in the atmosphere above a fuel product (the headspace) under given conditions can be flammable, that is sustain combustion once initiated, but there are both lower and upper bounds to these concentrations and indeed, before the general use of inert gas to replace the atmosphere in tanker tanks containing crude oil residues after discharge, these were maintained in either a ‘too lean’ or too rich’ condition during tank washing operations. The lower (lean) bound of this concentration is termed the ‘lower flammability limit’ (LFL) or ‘lower explosive limit’ (LEL) – combustion, once initiated will be so rapid in such a space as to appear explosive. The upper (rich) bound being the ‘upper flammability limit’ (UFL) / (UEL). Examples of the LFLs / LELs and UFLs / UELs of a number of substances are given in Figure 1.


Substance Lower Explosive limit

%v/v

Upper Explosive limit %v/v

Flash point °C

Auto ignition temperature °C

Diesel fuel 0.6 7.5 >62 250

Benzene 1 8 −11 560

Butane 2 9 — 365

Ethane 3 12 — 515

Ethanol 3 19 12 363

Ethylene glycol 3 22 111 400

Ethylene 3 34 — 305

Glycerol 3 19 199 370

Hydrogen 4 76 — —

Methanol 6 37 11 385

Pentane 1 8 −40 285

Propane 3 12 — 515

Styrene 1 6 31 490

Figure 1 – Examples of LEL and UEL

By the use of hydrocarbon gas monitors it is possible to give an indication of the condition of the headspace at various levels in a tank as being a percentage of the LFL (or LEL), usually expressed as xx % LFL (LEL). Typically one level of caution will be at say 25% LFL with the highest level of caution at 50% LFL. In practice the %LFL is only an indication of the tank headspace composition, one aspect in this being that the hydrocarbon monitors are calibrated against specific hydrocarbons (such as methane, pentane or hexane) as opposed to the full range of hydrocarbon species, at widely varying compositions, which will be emitted in practice. The LFL of a tank headspace is itself the result of a wide range of factors of which the flashpoint of the product in that tank is only one element, the temperature of the product, exposure of the heating coil / product above the surface, whether the oil has been agitated or churned, the rate of air changes of the headspace all dramatically affect the resulting % LFL. Consequently, a fuel at a temperature well below its flashpoint is capable of emitting light hydrocarbons into the tank’s headspace which could accumulate (reflected in increasing %LFL values) even to the point of reaching or exceeding the LFL. Therefore the headspace of any tank containing either oil fuel or a hydrocarbon product must be considered as hazardous, irrespective of flashpoint. A further consideration in assessing risk is that of autoignition. This is the temperature at which a fuel will ignite in the absence of an ignition source however the particular nature of the manner of temperature application will affect the temperature at which this ignition occurs. Hence a different result would be obtained, for example, depending on whether a fuel was sprayed onto,


or positioned as a droplet on, a heated metal surface – indeed the nature of the surface itself could affect the response obtained. Consequently, in order to give a comparable result there are standardised tests, for example, ASTM E659-78 (2005) in which the fuel under test is heated in a specified manner in a defined test vessel. Additionally, it should be noted that while the flashpoint determined for a particular fuel is mainly dependent on the most volatile component present, irrespective of its proportion, in the case of autoignition temperature this will be more a function of the bulk of the fuel in question. Examples of the flashpoints and autoignition temperatures for various marine oil fuels and lubricants are given in Figure 2.

Flashpoint (°C) Auto-ignition point (°C)

Heavy oil fuel 65~80 min. 400

Intermediate oil fuel 380 60~75 min. 250

Intermediate oil fuel 180 60~75 min. 250

Medium oil fuel 60~75 min. 250

Marine diesel oil 60~75 min. 250

Marine gas oil 60~75 min. 250

Cylinder oil 210~240 min. 320 Lubricating oil

System oil 250~255 min. 320

Figure 2 – Examples of flashpoints and autoignition temperatures of a number

of marine products


3. Flashpoint as applied to marine oil fuels

Within shipping the terms ‘oil fuel’ and ‘fuel oil’ tend to be used in a very general and interchangeable manner when describing the liquid fuels typically used to provide the power required to drive and maintain the ship, its systems and the persons onboard. However, within the various regulations under which ships operate there are very specific definitions. The term ‘oil fuel’ as used in MARPOL Annex I (regulation 1.5) is defined as ‘…any oil used as a fuel in connection with the propulsion and auxiliary machinery of the ship in which such oil is carried.’ with the term ‘oil’ further defined (regulation 1.1) as ‘…petroleum in any form including crude oil, fuel oil, sludge, oil refuse, and refined products (other than those petrochemicals which are subject to Annex II of the present Convention) and, without limiting the generality of the foregoing, includes the substances listed in appendix 1 to this Annex.’ – that appendix lists a wide range of materials which are liquid fuels as used onboard or carried as cargoes. In contrast MARPOL Annex VI defines ‘fuel oil’ as ‘…any fuel delivered to and intended for combustion purposes for propulsion or operation on board a ship, including distillate and residual fuels’. Hence this latter definition also potentially includes a range of fuels from non-petroleum sources as well non-liquid fuels, i.e. gas fuels such as those loaded and stored onboard as LNG. Consequently, in this study the term ‘oil fuel’ is generally used to describe the liquid, petroleum derived, fuel used in most ship’s combustion machinery systems, where a wider scope to this term is intended that is specifically mentioned. Furthermore, in this study the term ‘distillate oil fuel’ is generally used to identify those oil fuels which do not require heating above ambient temperatures to achieve the required injection viscosity rather than the various generic terms such as ‘gas oil’ or ‘diesel oil’. In contrast the term ‘residual oil fuel’ is used where it is specifically required to identify those fuels which do require heating to achieve the required injection viscosity (and also for transfer and treatment) and which are principally comprised of the residual (non-distillable) fractions from petroleum refining. Oil fuels have been used by ships as fuel since just before the start of the twentieth century. Initially this was for boiler firing where they started to replace coal as the fuel due to having the advantages of easier handling, both during loading and in use, an ability to be stowed in otherwise difficult to access parts of a ship’s structure together with higher energy densities. As boiler fuels there were limited technical quality requirements (water and insoluble sediment being the main parameters) and hence represented a valuable means of using a considerable part of that portion of the crude oil as refined which was not usable as lamp oil (essentially what today would be broadly termed as kerosene) which at that time represented the principal product demand. However, in so using that ‘residue’ it was necessary, on safety grounds, to ensure that it did not


also include those lighter fractions (such as the gasoline fractions) for which at time there was insufficient demand relative to potential supply. A decade after the introduction of oil fuel firing of steam boilers, internal combustion engines started to be fitted as the main propulsion machinery and of course these used liquid petroleum oil fuel from the outset albeit of a higher quality than that capable of being used for boiler firing, effectively distillate type fuels. Over the next forty or so years the use of petroleum derived oil fuels completely superseded coal as fuel for boiler firing while at the same time there was considerable growth in the number of motorships. Through to the 1980’s there were strong demands for both steamships and motorships, each having their own advantages but over this period motorships, other than the smaller or highly specialist ships, generally changed over from using distillate fuel to residual oil fuels which themselves represented ever more limited proportion of the barrel, and hence a more processed product that required blending with lighter, cutter stocks, in order to be usable onboard. Since the 1980’s virtually all new buildings have been motorships.

3.1. Statutory control requirements

Ships in international trade are generally subject to both statutory and classification society requirements. Statutory controls are implemented by the ship’s flag State Administration but can also be subject to port State inspection. The bulk of these statutory controls originate from the various Conventions, Codes and Guidelines developed by the International Maritime Organization (IMO) although Administrations can introduce their own specific requirements and also approve particular arrangements for ships operating within their own waters. One of the key roles of IMO is to facilitate international trade by providing a common basis for the certification of ships in terms of such aspects of safety and pollution prevention thereby avoiding a multitude of different, potentially contradictory, local requirements, each with their own certification and inspection regimes. In terms of marine oil fuel flashpoint this is currently controlled under the Safety of Life at Sea (SOLAS) Convention. The first three SOLAS Conventions predate the formation of IMO and hence were in the form of inter-government treaties. The first two treaties dated 1914 (which did not enter into force) and 1929 contain no requirements in respect of the minimum flashpoint of oil fuels used onboard ships. In fact it was only in the third SOLAS Convention, dated 1948, which entered into force in 1952, that mention was first made of ‘flashpoint’ and then only in relation to ‘new passenger’ ships, as defined, where the emergency source of power was an engine driven emergency generator in which case the ‘…fuel used shall have a flashpoint of not less than 110oF (or 43.3oC)…’ – Chapter II Part C regulation 22. IMO, as a specialised United Nations technical organization, was formed in 1948 (until 1982 under the title of the Inter-Governmental Maritime Consultative


Organization - IMCO) and thereafter took on responsibility for the further development of the SOLAS Convention. Within the IMO structure the SOLAS Convention falls under the remit of the Maritime Safety Committee (MSC). The 1960 SOLAS Convention, which entered into force in 1965, introduced the requirement that for ‘new’ ships as defined by that Convention that ‘... no internal combustion engine shall be used for any fixed installation in a passenger ship if its fuel has a flashpoint of 110oF (or 43oC) or less...’ – Chapter II Part C regulation 31. Furthermore, where the emergency source of power was an engine driven emergency generator the ‘…fuel used shall have a flashpoint of not less than 110oF (or 43oC)…’ – Chapter II Part C regulation 25 (passenger ships) or regulation 26 (cargo ships). Although the requirements of this Convention were generally applied to ‘new ships’ constructed on or after its entry into force date, Administrations were also to ensure that ships built on or after the entry into force of the 1948 Convention then complied with the Chapter II requirements of that Convention. Additionally, the Administration was to decide if any of the new provisions of the 1960 Convention Chapter II which were not in the earlier version should be applied to existing ships. The 1974 SOLAS Convention (which remains today as the base SOLAS text albeit extensively amended) included, for the first time, the tacit acceptance procedure in order to facilitate ongoing amendments. Furthermore, the tacit acceptance procedure allowed for a definite entry into force date to be given from the outset – subject only to the proviso that there had not been the required level of objection prior to the entry into force date to block its introduction. These amendments can range from specific additional requirements which, in the light of experience, are seen as necessary (or even editorial corrections) through to extensive and fundamental revisions. In this it should be seen that the SOLAS Convention is continually evolving to take into account changed conditions and new requirements; hence at any one time there will be amendments which are being developed through to ones on the point of entering into force. This on-going development is well reflected in the working title typically used to describe the Convention - ‘SOLAS 74 as amended’. The 1974 Convention, which entered into force in 1980, was principally based on the 1960 Convention together with the subsequently proposed amendments which had not entered into force through there being insufficient positive support. This introduced the following requirements:

i) for ‘new passenger ships’ carrying more than 36 passengers – ‘…no oil fuel with a flashpoint of less than 60oC (140oF)(closed cup test) …..shall be used as fuel, except in emergency generators, in which case the flashpoint shall not be less than 43oC (110oC)…provided that the Administration may permit the general use of fuel oil having a flashpoint of not less than 43oC (110oF) subject to such additional precautions as it may consider necessary and on condition that the


temperature of the space in which such fuel is stored or used shall not be allowed to rise within 10oC (18oF) below the flashpoint of the fuel…’ – Chapter II-2 Part B regulation 33.

ii) for ‘new passenger ships’ carrying not more than 36 passengers – ‘..no internal combustion engine shall be used for any fixed installation in a ship if its fuel has a flashpoint of 43oC (110oF) or less (closed cup test)…..’ Chapter II-2 Part C regulation 49.

Hence there were no minimum fuel flashpoint requirements in respect of either ‘new cargo ships’ or ‘new tankers’ other than those carried over from the 1960 Convention, now given in Chapter II-1, in respect of the emergency source of electrical power where that was to be provided by ‘…a generator driven by a suitable prime-mover with an independent fuel supply ….the fuel used shall have a flashpoint of not less than 43oC (110oF)…’ - Chapter II-1 Part C regulation 26 (there being similar requirements in respect of the flashpoint of fuel used in passenger ship emergency generator engines – regulation 25). These emergency generator requirements were applicable to ‘new ships’ although the Administration could decide whether they were also to be applied to ‘existing ships’. While SOLAS 74 amendments are generally applied to ‘new ships’ constructed on or after the entry into force date of those amendments they also usually introduce a further requirement that ‘existing ships’ comply with the amendments applicable to Chapter II requirements which were previously adopted and which at that time were given as applying to ‘new ships’. These requirements in respect of the flashpoint of the oil fuel used by emergency generator engines, in both passenger and cargo ships have, despite the various re-writes of Chapter II-1 been retained through to the present day, now Chapter II-1 regulations 42 and 43. However these should be seen as means of ensuring that more rugged and reliable compression ignition type engines were used for such purposes rather than spark ignited engines with all their attendant requirements on charged batteries, clean and well adjusted spark plugs with high tension leads intact and not shorting to earth in order to function. Hence this provision is directed at the assured provision of lighting and power in emergency situations, not in avoiding a potential fire risk. The adoption into the 1974 Convention of the 60oC minimum flashpoint limit for those oil fuels used onboard the ‘..more than 36..’ passenger ships in fact almost exactly matched an amendment to the 1960 Convention, adopted in 1967, for such ships which had never entered into force since there had not been the required level of acceptance under the previous arrangement for amendments. The 1967 amendment had proposed a new Part H applicable to ‘new’ passenger ships carrying more than 36 passengers within which regulation 110 would have prohibited the use of oil fuel with ‘… a flashpoint of less than 61oC (141oF) (closed cup test) as determined by an approved flashpoint apparatus…’. The difference in this flashpoint limit between the 1967 and the 1974 texts reflects a debate which was on-going at that time within IMCO (as it was then termed) as


to the categorization of products to be covered by the Dangerous Goods Code which was being developed as the first IMCO code of practice. Although 60oC was fairly widely adopted within the industry the UN Committee of Experts together with other subsidiary bodies and a number of Governments had adopted a limit of 61oC. The outcome of this was that IMCO decided to standardize requirements at this point as being at 60oC, rather than 61oC, recognising that there would be differences between how products would be considered within the different schemes. In adopting 60oC as the limit the main technical arguments were that 60oC directly and exactly corresponds to 140oF (the Fahrenheit scale then being still in widespread use) whereas 141oF corresponds to 60.555..6oC, which rounded to 61oC and which when then back converted to oF gives 141.8oF which then rounds to 142oF. Additionally it was considered that the values of 61oC or 141oF indicated an unjustified level of precision and criticality to what was an arbitrary division. In the 1981 Amendments to SOLAS 74, Chapter II-2 was completely replaced both in terms of layout and requirements. These 1981 Amendments, which entered into force September 1984, introduced the following requirements, as regulation 15, that: ‘The following limitations shall apply to the use of oil as fuel:

.1 Except as otherwise permitted by this paragraph, no oil fuel with a flashpoint of less than 60oC shall be used.

.2 In emergency generators oil fuel with a flashpoint of not less than

43oC may be used.

.3 Subject to such additional precautions as it may consider necessary and on condition that the ambient temperature of the space in which such oil fuel is stored or used shall not be allowed to rise within 10oC below the flashpoint of the oil fuel, the Administration may permit the general use of oil fuel having a flashpoint of less than 60oC but not less than 43oC.

.4 In cargo ships the use of fuel having a lower flashpoint than

otherwise specified in this paragraph, for example crude oil, may be permitted provided that such fuel is not stored in any machinery space and subject to the approval by the Administration of the complete installation.

The flashpoint of oils shall be determined by an approved closed cup method.’

In November 1985 Assembly Resolution A.565(14), ‘Recommended Procedures to Prevent the Illegal or Accidental Use of Low Flashpoint Cargo Oil as Fuel’, was


adopted. This brought attention to the practice of illegally using cargo crude oil as bunker fuel. A cross reference to this resolution was subsequently added to regulation 15.1 to highlight the dangers inherent in using crude oil in systems not designed to handle such oil as a fuel. The 2000 Amendments, representing changes adopted by the 72nd and 73rd sessions of MSC, totally replaced the 1981 Chapter II-2. However, in terms of the flashpoint requirements, the earlier text was essentially retained (there were certain editorial amendments), with two exceptions, in the revised layout as Part B regulation 4 section 2.1 of that Chapter. The first of these exceptions was that the previously included requirement that ‘…flashpoint be determined by an approved closed cup method.’ was moved to regulation 3 (definitions). The second exception was sub-paragraph .3 which was replaced by the following:

‘.3 the use of oil fuel having a flashpoint of less than 60oC but not less than 43oC may be permitted (e.g., for feeding the emergency fire pump’s engines and the auxiliary machines which are not located in the machinery spaces of category A) subject to the following: .3.1 fuel oil tanks except those arranged in double bottom

compartments shall be located outside of machinery spaces of category A;

.3.2 provisions for the measurement of oil temperature are provided on the suction pipe of the oil fuel pump;

.3.3 stop valves and/or cocks are provided on the inlet side and outlet side of the oil fuel strainers; and

.3.4 pipe joints of welded construction or of circular cone type or spherical type union joint are applied as much as possible.’

Although since the incorporation of those 2000 Amendments there have been numerous subsequent amendments to SOLAS, both editorial (including layout) and technical, the flashpoint requirements have not been further amended. The full text of the current regulation, SOLAS Chapter II-2 regulation 4.2.1 is given in Appendix II. In 2007 SOLAS was amended to include the requirement that a Material Safety Data Sheet (MSDS) was also to be provided with each oil fuel consignment bunkered; previously it had only been required for oil cargoes. However the wording of this requirement was ambiguous, hence in 2009 it replaced by revised text. In the meantime the actual content of the recommended content of the MSDS itself had itself been amended, although in both the original and revised versions it was required that the oil fuel’s flashpoint was to be given; albeit in practice that this is often in the form of ‘... flashpoint above 60oC …’ rather than the actual value. In 2009 MSC Circular 1321 (MSC.1/Circ.1321) was published. This provided guidelines for measures to prevent fire in ships’ engine rooms and pump rooms.


In terms of oil fuel flashpoint, while repeating the limits as given in SOLAS, it also recommended that oil fuel in storage should not be heated to within 10oC below the oil fuel’s flashpoint except in the case of settling, service and other system tanks which met certain criteria. As of January 2012, in respect of the 1974 SOLAS Convention there are 161 Contracting States or Parties which represented 98.91% of the world’s gross tonnage. Additionally the Convention has been twice amended by Protocols; in 1978 (covering matters related to tanker safety - 116 States / Parties (96.31%)) and in 1988 (covering amended survey procedures - 99 States / Parties (95.18%)). However, even for that proportion of world shipping registered in States which are not signatories they still need to comply with the relevant requirements when operating in the water’s of Contracting States or Parties. A further statutory development was the entry into force in 2005 of MARPOL Annex VI in respect of controlling air pollution from ships. As part of this there are controls on ‘fuel oil quality’ however this is only in respect of excluding materials which are harmful to personnel, onboard machinery or the wider environment. The Annex has however also had the effect of making the Bunker Delivery Note a statutory document of prescribed minimum content however this does not include flashpoint as part of those requirements although that has always been, and continues to be, given; albeit often as ‘…greater than 60oC.. ‘ rather than as a reported test value. In addition to the controls on international shipping separate statutory controls will often be applied to commercial inland waterways craft. In the case of EU countries these are covered by the requirements of Directive 2006/87/EC which gives the technical requirements relating to inland waterways vessels. Chapter 8 of those requirements gives that ‘…only internal combustion engines burning fuels having a flashpoint of more than 55oC may be installed…’. While the oil fuel used by such engines is controlled in respect of environmental factors these do not directly cover flashpoint.

3.2. Classification society requirements

Lloyd’s Register first accepted the use of oil fuel on a classed ship in 1898, and between then and 1902 a number ships using oil fuel were classed. At that stage there were no class Rules for oil fuel fired boiler installations consequently these were considered on a case-by-case basis with the general requirement that the oil fuel flashpoint was not to be below 200oF. In a separate development in November 1901, following representation from an oil company, the British Colonial Office decided to allow oil fuel having a flashpoint of not less than 150oF to be supplied as bunkers to ships in Hong Kong. At that time Lloyd’s Register was developing Rules for oil fuel burning installations and on the basis of the preceding experience and developments introduced rules for the


‘…burning and carrying of liquid fuel..’ in those instances where the ‘…oil fuel the flashpoint of which as determined by Abel’s close test does not fall below 150o Fahrenheit.’. Ships where the design and arrangement met those requirements would be eligible for the entry “Fitted for liquid fuel” to be made in the Register Book. These requirements first appeared in the 1903-1904 edition of the Rules for Steel Ships as Section 48 and are reproduced in Appendix III. The adoption of a 150oF as the minimum limit for bunkers supplied in Hong Kong, and as subsequently adopted as the Rule requirement, could be seen in relation to the prevailing local, shore-side, requirements. At that time in Hong Kong the storage of petroleum products was covered by ‘The Dangerous Goods Ordinances of 1873 as amended 1884, 1899, 1901 and 1902’. These principally related to controlling the fire risk presented by storing kerosene. Lubricating oils and petroleum having a flashpoint above 150oF (albeit no test method was specified) were exempt from the provisions of that Ordinance and hence logically that would have set the minimum requirement for oil fuel supplied as bunkers so avoiding legal restrictions on the oil fuel storage and supply arrangements. Additionally, it could be assumed that existing flashpoint limits around the world would have influenced the setting of the minimum marine oil fuel flashpoint requirement, which would have been naturally set on the conservative (high) side since the overriding requirement was that of safety. From a review of the limits applied at the time, only India set a limit of 200oF above which no requirements existed (and therefore possibly the initial adoption of 200oF by Lloyd’s Register), all other countries having lower limits – Appendix I – and from these it can be seen that despite the wide variations in values (some open cup other closed – or as given at the time ‘close’ – cup) and test methods the adoption of 150oF minimum for marine oil fuel was indeed a rational choice on the basis of prevailing regulations. The 1910-1911 edition of Lloyd’s Register’s Rules introduced for the first time rules covering ‘.. internal combustion engines for marine purposes..’. These engines were given as being fuelled by petrol, paraffin or ‘heavy oil’. Included in the rules were requirements, specific to those fuels as applicable, covering fuel tanks and fittings, the fuel handling and service systems and the containment of any leakages. In this context the term ‘heavy oil’ should be understood as being what would today be considered as a gas oil type fuel. Consequently from the outset of the use of internal combustion engines in ships there existed the possibility of using oil fuels with flashpoints below 150oF, this was highlighted in the 1913-1914 edition in which, in addition to the general rules relating to oil fuels with a flashpoint not below 150oF, required that where the oil fuel had a flashpoint below 150oF the oil fuel system arrangement was to be submitted for special consideration. In the 1914-1915 edition the requirements for ‘… internal combustion engines (other than of the diesel type) …’ were separated off from those covering diesel type engines in order to cover the specific points related to


the use of such non-diesel type engines, in particular the issues related to using petrol or paraffin as the fuel. In the 1930-1931 edition this Chapter was re-titled to cover ‘… petrol and paraffin engines.’ In the 1913-1914 edition of the Rules the ‘Fitted for liquid fuel’ Register Book entry was replaced by notations ‘Fitted for oil fuel F.P. above 150oF’ or ‘Fitted for low flash oil fuel’, although the former resulted in the anomaly that it was to be assigned in those instances where the flashpoint of the oil fuel used did not fall below 150oF. The 1948-1949 edition limited the assignment of the ‘..above 150oF ..’ notation only to steamships and resolved the anomaly by referring only to oil fuels of flashpoint above 150oF, it also discontinued the practice of assigning the ‘Fitted for low flash oil fuel’ notation. In the 1952 edition the practice of assigning such notations in general was discontinued – reflecting that by this time the use of oil fuel had become such standard practice that the notation was superfluous. The 1962 edition of the Rules marked the first time that the flashpoint of the oil fuel used in general, unrestricted, service was explicitly limited, to not less than 150oF. This was in contrast to the previous practice of indirectly limiting it by specifying the design and arrangements suitable for oil fuel of such a flashpoint. In this edition the requirements in respect of ‘…piping for petrol and paraffin engines ..’ were not included on the basis that there was ‘..no present day application…’. In the case of emergency generators a flashpoint of not less than 110oF was given as permissible. Additionally it was given that flashpoints lower than 150oF could be used in ships intended for service in restricted geographical areas where it could be ensured that the temperature of the machinery or boiler spaces it which it would be used would always be 30oF below the flashpoint of the fuel. In these instances the safety precautions and the arrangements for storage and pumping needed to be specially considered although in no instances was the flashpoint to be less than 130oF when used in boilers or less than 110oF if used in engines. The 1962 edition also permitted that a quantity of fuel with a flashpoint below 110oF could be carried for special purposes, i.e. aviation spirit, subject to special consideration. In contrast other classification societies around this time had different requirements in respect of the unrestricted service oil fuel flashpoint limit. For example, the American Bureau of Shipping Rules for 1966 gave that in no case was the flashpoint of oil fuel used in boilers to be lower than 120oF and that where it was intended to use oil fuel with a flashpoint below 150oF this would be subject to special consideration and was not to be heated to more than 100oF in storage tanks. Germanischer Lloyd in their 1967 Rules had a general service oil fuel flashpoint limit of above 65oC although, subject to special consideration, oil fuel of flashpoints of 65oC or below could be used if stored and used outside the engine room. Bureau Veritas Rules for 1965 give the unrestricted service


flashpoint requirement as 55oC and above with oil fuels with a flashpoint below that value, but not below 43oC, only being permitted for emergency engines. In the 1968 edition of the Lloyd’s Register Rules the flashpoint limits were given primarily in oC with the previous oF values given in brackets alongside. This highlighted the point that 150oF, for example, does not exactly convert to a round oC value; what had previously been a 150oF limit was given as 65.5oC (as opposed to 65.555…6oC). Similarly the 110oF limit was changed to 43oC (≡ 43.33...oC) with the 30oF differential given as 16.5oC (≡ 16.66…7oC). In the 1972 edition of the Rules the unrestricted service flashpoint requirement was lowered to be ‘…not less than 60oC…’, although that for emergency generators the limit value of not less than 43oC was retained. This thereby aligned the unrestricted class flashpoint requirement with that being finalised at that time as the tighter limit within the SOLAS Convention. For the geographically limited ships the flashpoint limits as given in the earlier editions was retained however the differential between the temperature of the machinery or boiler spaces in which the oil fuel was used and its flashpoint was reduced to 10oC. With regard to the geographical area limited ships the 1974 edition retained the 10oC differential requirement but deleted the practice of specifying absolute minimum flashpoints for oil fuels used in oil fired boilers or engines. Instead it was required that the flashpoint was not to be less than 43oC unless specially approved. The 1982 edition introduced the general requirement that oil fuel in storage and service tanks was not to be heated to within 10oC of its flashpoint. In this context ‘service’ tanks would have included settling tanks. In the 1983 edition, while retaining both the unrestricted and geographical limited controls on oil fuel flashpoints, it was further given that lower flashpoint values could be permitted provided that such fuels were not stored in the machinery spaces and that the complete installation was required to be specifically approved. The 1982 requirement, that oil fuel in tanks was not to be heated to within 10oC of its flashpoint, presented particular practical difficulties, both as the actual flashpoint was not normally known (unless a representative sample of the oil fuel as bunkered had been specifically analysed – an approach which shipowners and operators were only then starting to take but which was still very much in the minority) and as the sizing of both purifier and engine oil fuel pre-heaters as installed had generally been on the basis of temperatures around 70oC in the settling tank (a temperature level itself required to promote settling out of water and solid deleterious materials) and 90-95oC in the service tank. Hence in 1984 the requirement was modified by allowing a temperature higher than 10oC


below the flashpoint provided that certain requirements were met, although in practice those requirements only represented the typically existing arrangements as regards the air pipe closures and locations of drains. In 2003 the geographical limit requirement covering all oil fuels used onboard was replaced by a more general clause permitting oil fuel with a flashpoint below 60oC but not less 43oC to be used but only for emergency engines located outside the machinery spaces. The current Lloyd’s Register Rules concerning oil fuel flashpoint and special fuels are given in Appendix III. In these, as with those of the other classification societies, the unrestricted requirement is that oil fuel flashpoint is not to be less 60oC although there are provisions for lower flashpoint fuels subject to special consideration and stored outside the machinery spaces thus mirroring the current SOLAS requirements.

3.3. Oil fuel specifications

In addition to oil fuel flashpoint limits introduced either through statutory controls or classification society rules the oil fuel will also be purchased against whatever specification the supplier and receiver have mutually agree to as part of the commercial agreement between those parties. The first specifically marine oil fuel specification was British Standard BSMA 100:1982, the MA indication that it was one of the marine series of specifications. Although a national standard it readily achieved world-wide usage. In terms of flashpoint the limit was given as 60oC minimum for all grades (both distillate and residual fuels) apart from a minimum of 43oC applicable to a distillate fuel used only for emergency purposes in engines located outside the machinery spaces. Subsequently the International Organization for Standardization (ISO) took on the role of developing and publishing marine fuel specifications as ISO 8217. The first version was produced in 1987 and this followed the approach given by the BSMA100 standard. Hence the ‘emergency use only’ distillate, designated DMX grade, was given as 43oC minimum whereas the other grades were given as 60oC minimum. The second (1996) and third (2005) editions of the specification retained these flashpoint limits. The fourth edition of the ISO 8217 specification (published in 2010) adopted the convention that the limits for the various listed parameters should be in accordance with the reporting requirements of the applicable test procedure; in the case of flashpoint this is ISO 2719. Hence, while the same flashpoint limits were retained, these were now given to a precision of one decimal place; hence DMX grade is given as 43.0oC minimum and the other grades as 60.0oC minimum.


In addition to these specifications the engine builders generally issue their own specifications which tend to be modelled on the ISO specification. Furthermore, some ship-owners will add further parameters, often on the basis of experience, to the ISO specification. However, in none of these instances are the flashpoint limits amended from those given in the ISO specification. Naval ships only use distillate type fuels in both diesel engines and gas turbines. While some of this fuel is, of necessity, obtained against the commercial specifications such as ISO 8217 navies have their own fuel specifications. Typical of these is the NATO F-76 specification (DEF STAN 91-4 Issue 8) the current version of which gives the flashpoint as 61oC minimum. As noted above the oil fuel used by EU inland waterways vessels is not itself controlled in terms of flashpoint. However, theses vessels will use oil fuel conforming to the EN590:2009 specification in which it is given that the flashpoint is to be above 55oC, additionally up to 7% by volume of biodiesel (as fatty acid methyl esters FAME) is permitted by this specification therefore the resulting product is not solely derived from petroleum sources.

3.4. Expression of oil fuel flashpoint limits

Generally the temperature scale now used in regulations and specifications for flashpoint is oC, even in US EPA regulations. This thereby avoids the problems resulting from conversion between oF and oC where, apart from certain cases such as 140oF / 60oC, the exact equivalent is not a similarly round figure. Over time flashpoint has been expressed in a variety forms including: ….not less than xxoC … ….minimum xxoC …. …..xxoC and above… …..more than xxoC … …..greater than xxoC … This has resulted in the past in a certain amount of confusion where different ways of expressing the limit have been used. The current, unrestricted, SOLAS and class requirements are now aligned as ‘…not less than 60oC …’. Additionally, it is to be noted that flashpoint limits have often be introduced in respect of the arrangements suitable for such oil rather than in terms of the oil fuel itself. A particular approach in this respect has been by requiring that only engines using oil fuels with a flashpoint above the specified limit are to be installed, however engines are not flashpoint sensitive and, as noted above, this requirement would appear to be related to assured starting rather than fire risk. As regards engine performance, an engine which operates with a fuel of flashpoint, for example, of 61oC will operate equally well with a comparable fuel but of 59oC flashpoint since, as noted in the previous Chapter, flashpoint is no


indicator of ignition or combustion performance characteristics. This flashpoint insensitivity extends further, the performance of an engine will not be affected by even major variations in the flashpoint, rather it will be other factors related to the fuel’s composition (of which flashpoint is no more than a incidental consequence) which affect performance. The performance of boilers and other continuous combustion devices is also not affected by flashpoint variations; where performance sensitivity does occur it is again the reaction to other fuel composition factors.


4. Why change the marine oil fuel flashpoint limit?

It is anticipated that upcoming changes to the exhaust emission controls applied to shipping, primarily as a result of MARPOL Annex VI, will have a substantial impact on the type of marine oil fuel used. At present most ships use residual oil fuel however it is anticipated there will be major shift to using distillates with potentially significant impacts on oil fuel supply availability. Under these circumstances it would be advantageous to maximise the oil fuel supply opportunities for the marine industry and hence avoid any artificial barriers, such as the marginal difference in minimum flashpoint requirements which currently exists between marine and the non-marine fuels as used in road transport / shore-side industrial and utility type applications.

4.1. Impact of MARPOL Annex VI on marine oil fuels

Alongside SOLAS, the IMO’s MARPOL Convention is one of the other major international control regimes applicable to shipping. The MARPOL Convention limiting pollution from international shipping was extended in 1997 from it original five Annexes covering oil pollution, bulk and packaged chemicals, inshore sewage and garbage, to also cover air pollution by means of the addition of Annex VI. This covers a number of pollution sources; exhaust emissions, ozone depleting substances (certain refrigerants and fire fighting compounds), volatile organic compounds (cargo hydrocarbons) and incineration. In terms of exhaust emissions these only cover nitrogen oxides (NOx) and sulphur oxides (SOx) together with certain aspects related to fuel oil quality. The Annex entered into force in 2005 and was extensively revised in 2008, as of January 2012 there are 68 Contracting States or Parties which represent 91.16% of the world’s gross tonnage. As with the SOLAS Convention these States or Parties transpose the IMO text into their own national legislation which is then applied, as applicable, to ships registered in those countries. As with other IMO Conventions, ships registered in non-signatory States are nevertheless required to comply with the various requirements when operating in the waters of Contracting States or Parties. The Annex VI NOx control requirements apply to most diesel engines over 130 kW and are divided into three Tiers. The applicable Tier is set by the ship’s keel laying date (or, for additional / certain replacement engines, the installation date). These controls do not directly affect the grade of oil fuel used since the certified NOx emission value is that obtained under reference conditions which include the use of a distillate fuel during the Parent Engine test, irrespective of the grade of oil fuel to be used in service. However, while the Tier I and Tier II requirements have been met by ‘in-engine controls without consumables’, Tier III will generally require some form of advanced emission control to be fitted (such


as selective catalytic reduction units or exhaust gas recirculation) which may well require the use of some form of distillate type fuel. Tier III is scheduled to apply to ships keel laid on or after 1 January 2016 when operating in Emission Control Areas established to limit NOx emissions (ECA-NOx) which currently will comprise an area up to 200 nm around much of the US and Canadian Atlantic, Gulf and Pacific coasts, some areas around Hawaii (together termed the North American ECA) plus an area around Puerto Rica and the US Virgin Islands (termed US Caribbean ECA). It is possible that over time additional areas may be established. Outside these areas, Tier II NOx limits will apply. While the Tier III NOx controls would potentially result in an incremental increase in distillate demand, starting in 2016, as more ships subject to those requirements enter into service the scheduled changes to the SOx controls are expected to result in a far more abrupt and substantial effect on distillate oil fuel demand. In the Annex SOx emissions are controlled by limiting the sulphur content of the oil fuel as used and these controls are applicable to all ships, irrespective of date of build. Currently these requirements are that fuel oils used within Emission Control Areas established to limit SOx and related particulate matter emissions (ECA-SOx) are limited to maximum 1.00% sulphur. ECA-SOx are currently the Baltic and North Sea, from August 2012 the North American ECA area and from January 2014 also the US Caribbean ECA area but as with the ECA-NOx it must be expected that additional areas would be established over time. Outside these areas (or prior to their introduction date) a maximum sulphur limit of 3.50% from 1 January 2012 applies. However, from 1 January 2015 this ECA-SOx maximum sulphur limit is reduced to 0.10%. Furthermore from 1 January 2020 (although this date is subject to review by IMO in 2018 taking into account fuel oil availability) the maximum sulphur limit applicable outside ECA-SOx reduces to 0.50%. The reality of marine oil fuel production is that while a sulphur limit of 1.00% can be met using residual oil fuels, limits of 0.10% and 0.50% will only generally be met by distillate type oil fuels, albeit in the latter case the fuel oil could nevertheless contain a limited residual fuel oil component (this could be termed a ‘heavy blended diesel oil’). Therefore the Annex VI 0.10% maximum fuel oil sulphur requirement will substantially add to the existing demand for such fuel oils as used by all ships while ‘At Berth’ in EU ports resulting from the Sulphur Directive. Similar requirements exist in a number of other areas and again it is quite possible that other local controls – either statutory or voluntary – will further add to this demand. While Annex VI provides for the use of equivalent means to comply with the SOx emission requirements both inside and outside the ECA-SOx it is as yet unclear as to the likely level of take-up of those alternatives. Such equivalents could be through the use of natural gas (loaded and stored on board as LNG) with negligible sulphur content or by the fitting of exhaust gas cleaning systems. As


yet the use of LNG (outside the use of boil-off gas on LNG tankers) is very much at the introductory stages and will involve substantial investments to establish the necessary bunker facilities and commitment by shipowners to this type of fuel. While there are a number of exhaust gas cleaning systems currently potentially available, their application to date is very limited and should also be considered to still be at the introductory stage; as much due to the fact that the current limits require only limited departure from established practice and hence the associated capital investment is generally not currently seen as being sufficiently justified. To put marine oil fuel usage into a global context it is necessary to compare it to the current demand from other users. In refinery terms ‘middle distillates’ includes oil fuel grades such as jet fuels, kerosene, automotive diesel and gas oil and hence includes the oil fuel bunkered by ships as distillate grade fuel. The latest BP Statistical Review, dated June 2010, gives this as around 4 million tonnes per day (over the period 2006-2009 there has been relatively limited change in this value). Estimates of marine oil fuel consumption vary considerably, there being no single authority responsible for collating that data. A study undertaken by IMO (BLG 12/INF.10) examined a number of estimates of marine oil fuel consumption as well as making its own assessment and came to the conclusion that for the year 2007 this was around 369 million tonnes per year (within a range of 332-406 million tonnes) of which some 20% was considered to be distillate, the remainder residual oil fuel. Hence, this could be approximated to 0.2 million tonnes / day of distillate and 0.8 million tonnes / day residue oil fuel. Therefore if the bulk of the existing (not taking into account the increased demand resulting from the forecast growth in marine trade) residual oil fuel demand was transferred to distillate it would represent close on 25% of the global demand for all middle distillates with inevitable major impacts on availability and hence price. Under such circumstances it would be highly desirable to avoid any issues which artificially impede the marine industry’s access to fuel.

4.2. Non-marine oil fuels

Currently the distillate used by road transport and other shore based industries in Europe is generally limited to a minimum flashpoint of above 55oC by the EN 590 specification. In other parts of the world other flashpoint limits apply as shown in Figure 3.


Flashpoint oC for Auto-Diesel USA Min 52 Australia Min 61.5 Canada >40 EU >55 Japan Min 50 Brazil Min 52 India Min 35 Global Average considered as:

55

Figure 3 – Examples of automotive diesel minimum flashpoint limits

It is therefore generally not possible to supply to ships from the road transport / shore-side industry oil fuel pool other than where it is known to be not less than 60oC flashpoint. Consequently, due to this difference in minimum flashpoint requirements refiners and fuel distributors need to maintain two parallel supply streams for a product which is otherwise potentially identical. Typically distillate oil fuels are generally manufactured to a flashpoint limit of 60oC or above. In practice due to the shore-side distribution chain of such fuels in pipelines and delivery tankers there can be some very minor pick-up of more volatile fuels which, due to the sensitivity of flashpoint, can act to reduce the flashpoint at the point of end-user delivery, hence the margin provided in the automotive fuel requirements. Since this is the deeply established operating procedure within the non-marine fuel supply system there is, and will be, no pressure or demand to increase the various production flashpoint targets to, for example, around 65oC thus providing that at the point of end-user delivery that flashpoint would generally be above 60oC. Given that the quantity of distillate fuel used by the land based industries far outweighs that used by shipping (even if it were to convert to entirely using distillate fuel) there is no prospect of achieving harmonisation instead by raising the minimum flashpoint of non-marine fuels to 60oC (which in any case would require the co-ordinated action of a multitude of authorities world-wide); there being seen to be no resulting technical or safety gains, only complications and costs from such a change to a deeply established parameter. However, it should also be seen that since there is equally, for example, in Europe no impetuous to reduce the non-marine fuel flashpoint limit. Consequently an alignment of the marine minimum flashpoint requirement to the non-marine value would not be a precursor to later pressures for further reductions.


4.3. Effects of reducing the marine oil fuel flashpoint limit

The alignment of marine and non-marine flashpoint limits would be seen as being comparable to the reduction of the flashpoint limits from 150oF (65.6oC) used by many parties initially to the 60oC generally applied today. The intent being that this would be applied universally to both existing ships and subsequent new buildings. This proposal is therefore totally separate from the development of the International Gas Fuel (IGF) Code which is intended to eventually provide for the use of a range of very low flashpoint fuels (such as natural gas / methane, methanol or other such fuels) in specifically arranged and equipped ships. The key driver to this alignment of minimum flashpoint requirements is to avoid, what is in effect a marginal difference in an arbitrarily set empirical parameter, limiting shipping’s access to fuel particularly at a time when it is expected there will be widespread demand pressures. Additionally by removing the existing barrier between marine and non-marine fuels this would act to avoid a premium being applied to marine fuel due to the segregated distribution and supply arrangements. At present there are a number of incidents each year where non-marine fuels have been supplied to ships with the result in some instances that the flashpoint is 1-4oC below the 60oC limit. In these cases there is a need for time and effort input from the shipowner, the ship’s Administration, classification society and insurance parties to achieve effectively no purpose since in virtually all cases the fuel is subsequently used in the same manner as usual. The alternative, which could be insisted on, is that the fuel be off-loaded. This is a lengthy process as most ship’s transfer pumps have nowhere near the capacity of the pumps used to supply the fuel in the first place. Furthermore, the opportunities to discharge such fuels are limited, with a consequent impact on the ship’s operating schedule, together with cost implications.


5. Potential effect on safety of changing minimum flashpoint limit

No change to the marine oil fuel oil minimum flashpoint requirement could be considered if it any way jeopardised either crew or ship safety. However, oil fuel originated fires in engine rooms are not generally the result of the ignition of oil fuel vapour by open flames or similar sources. As shown by LR data reviewed from 1970 to 2011, engine room oil fuel fires are typically initiated through oil fuel or lubricating oil, either in the form of a liquid or as a droplet spray, coming into direct contact with hot surfaces thereby causing the oil fuel to ignite spontaneously due to having reached its autoignition temperature. This normally occurs where there is a failure of the oil fuel or lubricant containment arrangements either in the form of a total or partial failure of a pressurised pipe (or flexible hose) or through seepage at connections. Similarly, fires in oil fuel tanks are typically initiated as a result of hot work (i.e. welding) on the exterior surface of the tank wall plating causing oil adhering to the interior tank wall surface to ignite spontaneously (having reached the autoignition temperature) which then spreads over the available oil surfaces and, on attaining the required conditions, also to the oil vapour in the tank headspace resulting in a fire-ball effect.

5.1. Causes of machinery space fires

Although oil fuel flashpoint is the given ‘head-line’ parameter in SOLAS, and elsewhere, as regards machinery space fire safety the actual means adopted to prevent these fires are specifically directed at the preventing fuel oil (and other potentially flammable materials such as lubricants and hydraulic oils) coming into direct contact with surfaces which could be at or above the oil’s autoignition temperature. Therefore the relevant section of the SOLAS regulations, Chapter II-2 Part B Regulation 4, deals with avoiding the probability of ignition primarily by requiring that oil fuel systems and component equipment are to be designed and maintained to avoid leakages, that tank gauging arrangements are such that oil leakage (as a result of operating procedures or component failure) are avoided, that where leakages do occur these are readily detected, that – in the case of failure of high pressure fuel injection – there is a secondary containment arrangements, that oil fuel systems are located away from potential ignition sources and that high temperature surfaces which could come into contact with leaking or sprayed oil are duly insulated with impervious materials. Similarly in the IMO Marine Safety Committee Circular MSC.1/Circular.1321 ‘Guidance for measures to prevent fire in engine-rooms and cargo pump-rooms’ the whole emphasis is on the prevention of oil fuel leakage but, where it does, to avoid it being ignited spontaneously by contact with high temperature surfaces rather than avoiding the oil fuel being heated to temperatures at or


above its flash point or avoiding exposure of oil vapours to open ignition sources. This is the key and fundamental issue in any discussion of oil fuels and fire safety, not whether flashpoint varies between one fuel and another by a few degrees. Where there are restrictions on oil fuel temperature related to the oil’s flashpoint, as in Lloyd’s Register Rules (Part 5 Chapter 14 2.1.4) which cover those cases where it is to be heated above 10oC below its flashpoint, these do not preclude such heating but rather require that there are certain precautions applied which are intended to avoid the vapour so produced from coming into contact with a possible ignition source. Therefore where oil fuel vapour will be generated in, for example, settling and service tanks, that vapour is vented directly to atmosphere through air pipes closed with flame trap screens. At other points in the oil fuel system where oil vapours could be released such as vent and drain connections on oil fuel tanks, pipes and equipment these are either led to closed systems or, where open, positioned so that any vapour released does not accumulate and are well away from possible ignition sources such as electrical switchgear. As detailed in Chapter 3, the introduction of a general oil fuel minimum flashpoint limit of 60oC within the SOLAS regulations only occurred with the 1981 Amendments. Prior to this the minimum flashpoint requirement had, in some instances, been higher due to classification society requirements. The resulting lowering of minimum flashpoint for some ships, as a result of that standardisation, was seemingly not accompanied by any increase in fire or other related incidents. Conversely, those ships which had been previously subject minimum flashpoint limits lower than the 60oC adopted had apparently not previously shown any greater risk of fire or other related incidents. As given in SOLAS Convention, and reflected in current classification society rules, the minimum flashpoint requirement for oil fuels used for emergency engines is 43oC and opposed to the 60oC otherwise required. However, this lower limit, applied in order to provide for such fuels having satisfactory cold performance characteristics (pour point, cold filter plugging point, cloud point) which could affect fuel supply to engines, has also similarly not been associated with any particular increased risk of fires or other related incidents with those engines. On a wider front, for example in the EU, all automotive and much of the industrial / utility oil fuels are supplied on the basis that the minimum flashpoint is above 55oC yet these users are not identified as being at any greater risk of fire than users of oil fuel restricted to a minimum flashpoint of 60oC. Where fires do occur in machinery spaces these are not the result of the ignition of oil fuel (or other product) vapour by an open flame or other ignition source which would have been avoided had the flashpoint of the oil been a few degrees higher, in this it is important to recognise that the ‘ambient condition’ (i.e. unpressurised) temperature of a flame from oil fuels or petroleum gases are in the relatively narrow range of around 1950oC - 2100oC hence would


potentially ignite the vapour given off from an oil fuel of, for example, flashpoint 50oC as readily as those from a fuel of flashpoint 60oC. As outlined in Chapter 2, the flashpoint test is a means of providing a reproducible reference value under very specific conditions and therefore it is not the temperature at which an oil transforms from a ‘safe’ to an ‘unsafe’ condition or the temperature at or above which, if subjected to in service, an ignitable vapour concentration will be produced or conversely below which such a vapour concentration could not be produced. Overall therefore it can be seen that while flashpoint provides a means to segregate hydrocarbon products into various ‘hazard’ ranges, for example minimum flashpoints below or above ambient, this is essentially to categorise the type of fire risk present with such products (gas or liquid escape from the contained system) rather than being used as a parameter by which potential fire risk could be finely graded such that, for example, a 2oC lower flashpoint represents a x % greater likelihood of fire.

5.2. Canadian study on the setting of the marine oil fuel flashpoint limit

In researching the question of marine oil fuel flashpoint limits a paper from 1982 which commented on data assembled and developed as part of a study sponsored by the Canadian Department of National Defence. This is reproduced as Appendix VI as an example on other investigations on this issue which have identified that some reduction in minimum flashpoint limit from 60oC, in this instance it was proposed that 40oC could be applied, would not be associated with increased fire risk.

5.3. Flashpoint of marine oil fuels – a statistical view

In considering the possible effect of a change to the minimum marine oil fuel flashpoint value it is of course necessary to consider what the experience has been to date in respect of the actual flashpoint of marine oil fuels against the existing limit value. However, there is no systematic arrangement for the evaluation of marine oil fuel, either as supplied or as used, and therefore no representative body of world-wide data which would provide an overall review as to the actual flashpoints of marine oil fuels either across the product range or on a geographic or other basis. For each consignment of oil fuel the supplier should provide a Material Safety Data Sheet (MSDS) and a Bunker Delivery Note (BDN). The MSDS is required under SOLAS Chapter VI regulation 5-1 and, in accordance with Resolution MSC.286(86) covering the recommended data to be given, is to include flashpoint information but this is generally given as a minimum value rather


than the actual value for the particular consignment supplied. Historically the provision of the BDN and the extent of information given therein was a purely commercial issue however under MARPOL Annex VI reg. 18.5 its supply and the inclusion of certain minimum information content is now statutory requirement. However, these content requirements do not extend to include flashpoint. Consequently, in practice a BDN, in terms of flashpoint, may give no information, a printed minimum value, an entered minimum value or an entered actual value although there will be no indication of how the supplier will have arrived at that value or its reliability. The shore based testing of samples of the oil fuel as delivered to ships is an established practice in order that the shipowner / operator is aware of the quality of the product supplied and can optimise its utilisation. FOBAS, and others, have been providing such services since the 1980s however participation in these services is a commercial matter. Currently it is estimated that samples as sent to the testing services represent around 25-35% of bunker deliveries world-wide. Even then, of those companies which do participate these may not send in samples either from all grades of oil fuels loaded (some owners have historically not tended to include distillate samples since they had a greater confidence as to the supplied quality) or all ports (some owners may only send in from certain ports or suppliers where they have concerns). Consequently it must be recognised that data from the oil fuel testing organisations considered either collectively (as in the IMO Fuel Oil Sulphur Content Monitoring programme) or individually only reflects the samples submitted rather than being a statistically based overview of world-wide oil fuel supply. Nevertheless such data do represent the largest bodies of existing data in respect of the actual quality of oil fuel as supplied to ships and due to the range and number of inputs are not unduly skewed by any local or temporary issues. The FOBAS analysis programme for samples of oil fuel as supplied has always included the flash point test. Originally the actual value was determined, however early on it was recognised that this detail gave no added worth-while information and consequently the test has since been undertaken on a go-no go basis (currently using the ASTM D7094-04(2009) method) set at 70oC. The FOBAS experience is reflected in the statistics summarised below in Table 1 for low and high sulphur residual fuel oil (HFO) and distillates (MGO) as an indicative example. It is evident from these findings that generally the existing flashpoint limit is not the general controlling parameter in the manufacture of marine oil fuels. Whilst this past data cannot predict degree of shift in the future it does provide a base line from which to gauge such changes particularly as regards a post 2015 perspective.


Table 1: FOBAS flashpoint summary over year 2010/2011

Flashpoint oC =>70 60- 69 >55<60 <=55 % of total samples HFO all >97 >1.5 <0.05 <0.05 HSHFO S>1.0 >98 >1.5 <0.1 0 LSHFO S<1.0 >99 <0.3 <0.1 <0.05 MGO all >63 >35 <1.0 <0.5 HSMGO S>0.1 >73 >25 <0.5 <0.5 LSMGO S<0.1 >53 >45 <0.9 <0.2

Of those samples found to be under 60oC flashpoint, over any current period, the distillate fuels indicate some 5 to 10 fold higher risk as compared to residual fuels of being below the limit. In the case of the distillate fuels for the actual flashpoint values a higher proportion are within the range 56-59oC. Incidences of flash points dropping to 35-40oC are more probable with residual fuels; however these fortunately remain as incidental isolated occurrences. The inference of this is that the below limit distillate fuels have in fact been supplied through the automotive supply system and this is borne out when investigating these further since the are invariably fuels supplied by road tanker rather than by barge or pipeline. In contrast the FOBAS experience is that where below limit residual fuels are supplied the reason is generally the inclusion of a low flashpoint component such as kerosene. The incidences of below limit distillate fuels appears, from the FOBAS data (see Figure 4), to have interestingly shown a slight downward trend over time, however it should be noted these represent a fluctuating range of between 0.2 and 0.8% of the bunkers drawn under the FOBAS scheme. It should also be borne in mind that there is also the difficulty of disentangling the fact that it is now more common for distillate samples to be forwarded for testing than before. This increase would be inferred as being related to the introduction of the EU’s Sulphur Directive requirements with a consequent increase in demand for tightly controlled sulphur distillates which could be seen as a potential forerunner of the implications resulting from the 2015 reduction in the MARPOL Annex VI ECA-SOx fuel oil sulphur limit.


>=70 & 60-69 deg C LSMGO (FOBAS)

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Figure 4 – FOBAS data distillate (MGO) flashpoint trends


For HSHFO (Figure 5) it should be noted that over the five year period the moving trend in flashpoint is downward by about 2% from the ‘above 70oC’ to the ‘60-69oC’ zone. In this category the ‘below 60oC’ flashpoint fuels are steady over the past three years having previously peeked in 2007 and 2008.

>=70 deg C HSHFO (FOBAS)

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Figure 5 – FOBAS data high sulphur residual oil fuel (HSHFO) flashpoint trends

Interestingly the LSHFO group (Figure 6) shows more of the fuels in the ‘above 70oC’ category but again with a trend of moving into the ‘60-69oC’ range. Of those ‘below 60oC’ there is a slight rise in instances over the last few years but the generally low figures again reflect that these are only incidental cases especially in the period of 2006-2008.

>=70 deg C LSHFO (FOBAS)

99.099.1

99.299.3

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Figure 6 – FOBAS data low sulphur residual oil fuel (LSHFO) flashpoint trends When the flashpoints of these distillate and residual grade fuels are found to be in the range 56-59oC the usual response of class and flag State has been to allow their usage but with added attention to avoiding situations where any resulting oil fuel vapour could be exposed to a potential ignition source rather than demanding the oil fuel be discharged ashore. In none of the cases encountered have there been any reported incidents. A further point concerning the establishment of the flashpoint of an oil fuel once loaded is that this can in practice change over time due the fairly rapid dissipation of the more volatile component responsible for that low result, noting that the resulting flashpoint of a mixed product is more a function of the most volatile component present rather than its relative proportion. Case History: FOBAS recently tested an IFO 380 fuel and as part of that determined the flashpoint as being 40oC. The supplier subsequently confirmed this finding from tests on their own retained sample. Consequently arrangements were put in place to remove the fuel from the ship subject to final checks on samples drawn from the ship’s bunker tanks. The results of which however gave that flashpoint of the oil fuel in the two tanks into which it had been loaded had, by that time, risen to 67oC and 55oC respectively as determined in respect of two different composite samples taken from upper, middle and lower positions of those tanks. Overall the FOBAS experience is that in approximately 60 - 70% of cases where a low flashpoint (< 60oC) has been detected in the oil fuel as loaded the volatile fractions responsible for that finding have subsequently dissipated into the atmosphere within a short period of time thereby when samples are later drawn from the fuel in storage its flashpoint has risen to above the required 60 oC minimum.


6. Flashpoint harmonisation and regulatory implications

As discussed in earlier Chapters there are significant linkages within the various regulations which apply to shipping and the imposition of a minimum flashpoint limit. However, it would be identified that the key starting point of any change would be with the Maritime Safety Committee (MSC) of the International Maritime Organization (IMO) since this is the only central body world-wide dealing ship safety matters. As all IMO Member States are potentially represented in MSC this would provide the widest possible forum for this issue of flashpoint harmonisation to be considered. In this there is not only the question of amending the SOLAS Convention itself but the consequential effect of such a change on other IMO Conventions, Codes and other instruments which would also need to be considered. Provided that such a change was effected within IMO then, due to the international representation within MSC, the resulting changes to other non-IMO regulations and requirements could be expected to be more a matter of procedure rather than principle. However, to effect such a change to the SOLAS Convention is most likely to be a long and involved process consequently an alternative approach is given although this would result in a far less wide reaching outcome.

6.1. Amendment of the SOLAS Convention

The Marine Safety Committee normally meets either once or twice a year on an alternating basis. These meetings are usually scheduled for around May and November. For the year 2012 the MSC 90th Session (MSC 90) is to be held 16 – 25 May and the MSC 91 is scheduled for 26 – 30 November. Hence MSC 92 will be around May 2013. In order to allow for translation into the IMO working languages, and for consideration by interested parties before any IMO meeting, there are set deadlines for submissions which are given in the Provisional Agenda issued shortly after the preceding meeting. These latest submission dates are rigorous enforced. In the case of MSC 90 the deadline for submissions containing proposals for new and unplanned outputs is 14 February. In the case of MSC 91, as the realistic date for any submission on amending the existing flashpoint requirements, this deadline would be expected to be set around late September 2012. Any submission to MSC on the issue of amending the existing flashpoint requirements is unlikely to be considered solely by MSC in view of the interconnections of the various IMO Conventions, Codes and Guidelines. Input on such an amendment would most probably sought from at least the Marine Environment Protection Committee (MEPC) and one or more of the specialist Sub-Committees, in this instance most likely the Fire Protection (FP) Sub-Committee. As with MSC, MEPC meets alternatively once or twice a year, typically around April and October in even years and around July in odd years. Following MSC 91 the next scheduled MEPC meeting would therefore be around


July 2013, MEPC 65. FP typically meets once every year normally around January / February with the next scheduled meeting, FP 56, in January 2013 however that would probably be too soon for a new work item from MSC 91 and would therefore not be scheduled until FP 57 (around January 2014) at the earliest – provided that MSC was in basic agreement that the question should be considered. With either MEPC or FP it could be expected that the consideration of a proposal to amend the minimum flashpoint limit would not be resolved at a single meeting and hence it could be well be not until MEPC 66 ( ~ April 2014) and FP 58 ( ~ January 2015), at the earliest, that these bodies would report back to MSC. Hence the earliest that MSC could be in a position to approve an amendment to the SOLAS Convention would be at MSC 95 (around May 2015). Having approved an amendment then it will normally be adopted at the following meeting which, on the above basis, would be MSC 96 (around May 2016) provided that there are no substantive objections to either the proposed change or those required to any other IMO requirements. Having been adopted as an amendment to the SOLAS Convention this would then be subject to the tacit acceptance procedure – this provides that the amendment will be deemed to have been accepted unless over a period of not less than 12 months from its adoption that more than one third of the Contracting Governments to the Convention or Contracting Governments the combined merchant fleets of which constitute not less than 50% of the gross tonnage of the world’s merchant fleet have notified their objection. Following acceptance an amendment enters into force 6 months later – typically either 1 January or 1 July (in order to avoid a multiplicity of entry into force dates over a year). Consequently, on the basis of adoption at MSC 96, the entry into force could be estimated as being scheduled for 1 January 2018.

6.2. Phrasing of SOLAS amendment

In the case of SOLAS the term flashpoint is defined as ‘…the temperature, in oC, (closed cup test) will give off enough flammable vapour to be ignited, as determined by an approved flashpoint apparatus …’. Hence no specified test method is given despite the fact that the design of the instrument used and procedures covering such matters as the rate of stirring and heating, the method of applying the ignition source, the identification of ignition and the manner of reporting can all affect the result obtained and reported. The lack of any defined method may be rooted in the different national test arrangements which existed in the past for this parameter. However in view of the general harmonisation of test methods world-wide to use those given in the ISO test series (albeit that these may be referenced by their national equivalent) it would be questioned whether this lack of uniformity should not now be addressed by MSC by specifying the ISO Pensky-Martens closed cup test method for the determination of flashpoint – ISO 2719:2002. It is noted that there are reservations concerning the specific mention of ISO test methods in IMO instruments which Member Governments will put into their national legislation


since ISO methods can, and are, amended over time (for example, to improve accuracy or to counter identified issues or new concerns). However by specifying the issue year (2002 in this instance) the method and all associated procedures are unalterably fixed. Currently in SOLAS Chapter II-2 Part B reg 4.2.1 the general service flashpoint requirement is given as ‘…no oil fuel with a flashpoint of less than 60oC shall be used …’ whereas, for example, in the European Standard for automotive diesel fuel, EN 590, expresses this as ‘…above 55oC …’ as determined by ISO 2719. This therefore raises the issue of how any amendment to the minimum flashpoint requirement would be worded given that the intent is to harmonise with the automotive market and also how the limit value itself should be stated. This aspect is discussed further in Chapter 7. ISO 2719:2002 gives that the test result should be ‘…rounded to the nearest 0.5oC …’. Hence, neither the current SOLAS values (taking into account the 43oC also specified for certain applications) nor the EN 590 conform to this convention. In the latter case it would be understood that a test result value of 55.0oC would not be acceptable whereas 55.5oC would be acceptable. Consequently it would be proposed that if the intent is that the European automotive limit was to be applied – see following Chapter - then the revised SOLAS wording should follow that of the current EN 590 but with the value given to one decimal place.

6.3. Amendment of other IMO instruments

Over and above the issue of flashpoint and personnel / ship safety any proposal to amend the minimum oil fuel flashpoint limit would be expected to have wide ranging implications on other IMO Conventions, Codes and Guidelines. These would divide essentially into ‘ship’ and ‘oil fuel / cargo’ related aspects. In the former this would include extending the existing provisions as regards the assignment of hazard status and zoning to remain applicable to the revised flashpoint limit. In the case of the latter the intent should be to retain the existing requirements but now to include oil fuels covered by the revised minimum flashpoint limit. It will need to be investigated as to what impact a change in the minimum oil fuel flashpoint limit would have on other IMO flashpoint related requirements including those contained within:

a) other parts of SOLAS b) MARPOL Convention – specifically Annexes I, II & III (it would be expected

that there would be no effect on Annexes IV, V or VI) c) IBC Code


d) IMDG Code e) IGF Code (see below) which is currently under development

Also it would need to be investigated what would be the effect of the changed minimum flashpoint limit on the various IMO Guidelines, for example MSC.1/ Circular 1321‘Guidelines for measures to prevent fires in engine-rooms and cargo pump-rooms’.

6.4. Amendments to other non-IMO regulations and requirements

If SOLAS were to be amended to provide for a lower minimum flashpoint limit this would also have a world-wide effect on other regulations and requirements including:

a) National authority regulations b) Port / canal authority regulations c) Classification Society Rules d) Insurance requirements

In this there is again the case of whether the flashpoints limits given in these controls apply due to simply matching the SOLAS requirement or whether they result from those authority’s or organisation’s own risk assessments which have established independent reasons for the minimum oil fuel flashpoint values given. Additionally any change to the SOLAS minimum flashpoint requirement would need to be considered in respect of its impact on industry specifications, codes and guidance documents. As above, it would need to be assessed whether existing references to a minimum flashpoint of 60oC are just to be in conformity with SOLAS, as would be expected, or are the result of independent assessment and identification of particular risk factors. In the case of ISO 8217:2010, the marine oil fuel specification, for example the flashpoint values currently given are simply reflecting the SOLAS position and hence there should be no issue in those values being amended following any change to the SOLAS requirement. Since in Europe, for example, the oil fuel used by trucks and barges is required to conform to the EN 590 requirement there would be no issue if the flashpoint of the cargo (oil fuel bunkers) carried was also so limited.

6.5. Alternative to amending the SOLAS Convention

The above discussion has been on the basis of amending the SOLAS Convention requirement as given in Chapter II-2 Part B reg 4.2.1.1. The key benefit of this approach is that all existing arrangements and procedures onboard ships would be able to utilise the oil fuel which may be supplied in accordance with this


revised flashpoint limit and that there would no longer be any requirement to segregate the shore-side oil fuel delivery arrangements between land based and marine users. However, as highlighted by the above, to achieve this is going to be a very long and involved process with widespread implications throughout the shipping and associated supporting industries. Furthermore there is no certainty that MSC, or the other potentially involved parties within IMO, would be mindful to agree to such a change on the basis that there is no technical or safety concern requiring that change and that in retaining the existing requirement would be the more ‘risk adverse’ approach which could not be faulted in the future should there be any incident however actually unrelated to flashpoint. Consequently an alternative approach could be to address this issue on a ship by ship basis utilising the provision given by SOLAS Chapter II-2 Part B reg 4.2.1.4 which provides that ‘….in cargo ships the use of fuel having a lower flashpoint than otherwise specified in paragraph 2.1 (i.e. 60oC) ….may be permitted provided that such fuel is not stored in any machinery space and subject to the approval by the Administration of the complete installation …’. Historically, this allowed to use of natural gas as a fuel in the case of liquefied natural gas carriers where heat flow into the cargo during the course of the voyage results in a certain amount of boil-off gas which if not utilised onboard (re-liquefaction not generally being an option) would need to be vented to atmosphere and hence represent both a air pollution issue (methane, the primary component of natural gas, is around 21 times more effective as a green-house gas than CO2) and also the waste of a resource. Additionally, during the 70’s, there were some tankers constructed which had the capability to safely use crude oil loaded as cargo also as a main boiler fuel together with a number of one-off cases of other unconventional fuels being utilised through this provision. However, in view of the growing interest in using fuels which, under normal ambient conditions, exist as either gases or low flashpoint liquids on ships other than LNG tankers in order to meet environmental requirements relating to the prevention of air pollution from ships MSC has initiated work on developing a Code covering such fuels with the intent that this would provide for a uniform approach to the approval by Administrations as referenced in the above noted SOLAS requirement. This Code, known as the IGF Code (despite also covering some liquid fuels), is currently scheduled for completion in 2013. As an interim measure Guidelines covering the use of natural gas in ships other that gas carriers have already be adopted by MSC (Resolution MSC.285(86). The Bulk Liquids and Gases (BLG) Sub-Committee is currently working on the next stage of development of the draft Code which would extend the scope to include petroleum gases (propane / butane), ethanol, methanol, hydrogen and dimethyl-ether with specific provisions as appropriate to each fuel.


Therefore it could be considered whether an alternative approach which would allow the use of oil fuels with a flashpoint meeting, for example, the EN 590 requirement (above 55oC) would be to have these included as a fuel type to be covered by the IGF Code. Since the particular provisions which would be required to load, store and use such fuels would be expected to be essentially those as currently required the additional workload on the Code drafting process resulting from this extension should be minimal. The key advantage of this approach is that it is an existing IMO work item with core text already in place and with a scheduled completion date although even when developed it would be fully expected that it will be subjected to on-going amendments in the light of actual experience in applying it to the fuels as covered and as other fuel types are proposed as possible marine fuels. The next BLG meeting, BLG 16, is 30 January – 3 February 2012 and therefore too late to make any input to that meeting (other than verbal input by a participant at that meeting) which is required to make further progress on this issue with the objective of completion at the BLG 17 meeting which would probably be scheduled for early 2013. There will probably be an intercessional correspondence group working on the draft text. The drawbacks to this IGF Code approach are however that:

a) ships wanting to use such fuels would need to be individually so certified, taking into account and arrangement or operating requirements imposed by the relevant section of the IGF Code as so developed

b) ships would not be able to readily accept one-off instances of such fuels being supplied

c) it would be necessary to retain segregated shore-side delivery systems


7. Practical implementation of change

The practical aspects relating to a possible change to oil fuel minimum flashpoint divide between:

a) to which oil fuel grades should the change apply b) how that change of flashpoint limit should be presented c) the possible implications on the oil fuel supplied d) the implications on ship arrangement and equipment requirements

7.1. Oil fuel grades to which a revised oil fuel minimum limit would apply

Since the principal driver to lower the marine oil fuel flashpoint limit is to broaden the availability of distillates through harmonisation between shore-side and marine requirements, there is the question as to whether this change to the marine limit value should be confined to the distillate grades only or whether it should be generally applicable and hence also cover the residual oil fuel grades.

It would on the face of it seem a matter of course to include all grades of oil fuels, as this has been the general case to date in both shore-side and marine practice and on the assumption that to do otherwise would unnecessarily complicate delivery arrangements and procedures. However there are a number of reasons for considering the application of the reduction in the minimum flashpoint limit only to the distillate grades.

In the first instance there is not the issue of slightly lower flashpoint residual oil fuels used by shore-side industries being delivered, or potentially available for supply, to marine users. Secondly, it needs to be recognised that the variability of flashpoint tends to be greater in residual oil fuels by nature of the product itself since it typically represents a complex mixture of various cutter stock and residual stream components. Furthermore, as handling onboard ship requires significant temperatures in order to bring the viscosity of residual oil fuels down to workable levels (30-40°C for transfer, ~ 70-75°C in the settling tank, ~ 90-95°C in the service tank) this increases the risk of releasing pockets of volatile components over time. This temperature issue does not occur for the distillates since, by definition, such oil fuels do not require heating to achieve injection viscosities (where heating is required this is only in respect of keeping such fuels sufficiently above their pour point that they remain in a liquid condition and even when required typically necessitates no more than a temperature of around 15°C to be maintained). Consequently with distillate oil fuels there is a much reduced tendency for volatile components to be released during normal storage, handling and use.


A further point to consider is that relatively high viscosity fuels (700 – 1200 cSt at 50°C) are being increasingly used and due to changes in the oil fuel market this is a tend which would be expected to continue if not accelerate. Such oil fuels of course requires yet higher handling temperatures to enable effective and timely transfer from barge to ship, with figures of up to 60°C typically being given as being applied. Should these oil fuels have a flashpoint which was below the transfer temperatures then this could complicate the delivery requirements thus impeding their use (although as always it is necessary to bear in mind that a quoted flashpoint value relates to the evolution of ignitable vapour under the particular test conditions and does not necessarily reflect the temperature under actual service conditions that such vapours would commence to be emitted nor does it reflect a ‘safe’ / ‘unsafe’ boundary line).

In terms of delivery arrangements it would be noted that for any mixture of products the resulting flashpoint is highly dependent on the lowest flashpoint of the components used rather than their proportions. However, distillate oil fuels represent a premium product and therefore will in most instances be carried in either dedicated or clean tanks, not least since with the imposition of a 0.10% sulphur limits (see Chapter 4) distillate oil fuels which are produced to that limit will have extremely limited tolerance to residual admixture and still be in compliance. Although in some supply situations deliverable grade distillates will be used as a blend component to trim certain characteristics of the residual oil fuel to meet the purchaser’s specification (for example density or sulphur content) the FOBAS experience, for example, of oil fuels produced to meet the MARPOL Annex VI ECA-SOx requirements (together with the relative cost of those fuels) clearly indicates that these fuels are not simply ‘blended-down’ residuals but rather manufactured from quite different component streams. In practice where admixture between the distillate and residual grades can occur (particular if not delivering tightly limited sulphur content distillates) during delivery is at the bunker hose through where this is used for all grades of oil fuel supplied but even here the usual practice is to first supply the residual and then the distillate since the latter is used to ‘wash’ through the common lines – a practice which results in the ISO 8216-1 specification description of the DMB distillate grade in the ISO 8217 specification as ‘general purpose, may contain a trace of residuum’ – hence the tendency is for a minor amount of residual material to be incorporated into the distillate rather than the other way round. Consequently if the distillate had a lower minimum flashpoint limit than the residual it would not tend to have the effect of depressing the residual oil fuel flashpoint.

Admixing on board is minimised, under Lloyd’s Register Class rules for example, by requiring that the residual and distillate fuel systems are kept segregated up to the service tanks. This ensures that mixing between distillate and residual oil fuels only occurs in the service tanks (although it is usual that there are separate residual and distillate service tanks) or in the fuel oil service system. In the latter case this is typically arranged as a closed system with spill back to a buffer /


mixing tank hence minimising the release of vapour and such vapour that is released is vented to a safe position outside the engine room. Consequently, due to the factors outlined above, it would seem preferable to retain the 60°C minimum flashpoint limit for the residual oil fuel grades while harmonising the distillate oil fuel limit with that applied in the automotive and other shore-side industrial sectors. As outlined in earlier sections of this study any change in minimum oil fuel flashpoint should be generally applicable without any changes to existing ship arrangements and equipment. To limit such as change only to ‘new’ (as discussed in Chapter 6 in relation to the possible inclusion of oil fuels slightly below 60°C flashpoint into the IGF Code being developed) or otherwise refitted ‘existing’ ships would have the overwhelming drawback that it would require the establishment of a dual system of marine distillate oil fuel supply thus directly contrary to the overall and central objective of opening up the supply of marine oil fuels for use by ships currently in service.

7.2. Revised minimum flashpoint limit

As outlined in Chapter 6 the current SOLAS requirement for general use oil fuel is given as ‘…no oil fuel with a flash point of less than 60°C shall be used …’ whereas in the European Standard for automotive diesel fuel, EN 590, this is given as ‘…above 55°C …’ together with the issues of the precision to which the limit is to be given and whether the means used to determine flashpoint should be defined. Ideally any changes to the SOLAS requirements should be minimised and in view of the proposal that the change should be applied only to distillate grade oil fuels. On this basis it would be proposed that SOLAS Chapter II-2 Part B reg. 4.2.1.1 should be amended to read (added text underlined): ‘.1. except as otherwise permitted by this paragraph, no oil fuel with a flashpoint of less than 60.0°C shall be used except in the case of distillate oil fuel where the flashpoint shall be above 55.0°C ;’ Consequent on this change it would be necessary to introduce a new definition into Chapter II-2 Part A reg 3: ‘Distillate oil fuel – Oil fuel which is comprised solely or principally of distillate fractions of petroleum refining.’ Alternatively, this could be given as:


‘Distillate oil fuel – Oil fuel which conforms to the DM grades given in ISO 8217:2010.’ On the point of stating a defined method for establishing flashpoint SOLAS Chapter II-2 Part A reg. 3.24 should be amended to read (added text underlined, deleted text scored through): ‘24. Flashpoint is the temperature in degrees Celsius (closed cup test) at which a product will give off enough flammable vapour to be ignited, as determined by an approved flashpoint apparatus the ISO2719:2002 test method.’ However to adopt the ‘..above 55°C..’ limit is to follow the European automotive fuel requirements. In contrast ships bunker oil fuel on a worldwide basis and for oil fuels to be used in ECA-SOx areas at least some of these will need to have been bunkered outside those areas since ships are required to use compliant oil fuels from the point of entry. In this respect it would be noted that, in addition to the existing ECA-SOx of the North Sea and Baltic, the North American ECA-SOx enters into effect from 1 August 2012 and that since this extends up to 200 nm from much of the coasts will considerably add to the quantities of ECA-SOx compliant oil fuel required (which from 1 January 2015 will be limited to 0.10% maximum sulphur – hence a distillate). Therefore consideration should be given to instead aligning the distillate oil fuel flashpoint limit with that applicable to US automotive diesel for which the minimum allowable flashpoint is 52°C. If this route was to be followed the resulting amendment to SOLAS Chapter II-2 Part B reg. 4.2.1.1 would read (added text underlined): ‘.1. except as otherwise permitted by this paragraph, no oil fuel with a flashpoint of less than 60.0°C shall be used except in the case of distillate oil fuels where the flashpoint shall not be less than 52.0°C ;’ Although in this it would be noted that the Canadian automotive diesel flashpoint limit is 40°C and that the Canadian Pacific and some of its Atlantic coasts are included within the North American ECA-SOx. In considering a reduction in the minimum flashpoint limit it is important to note that, as at present, the resulting flashpoint of distillate oil fuels as supplied will not be such as to just meet the limit requirement. Although not part of this study, comment from the oil industry has been that even with automotive diesel there is a significant range in flash point values above the given minimum and this would not be expected to change over the foreseeable future.


7.3. Implications of marine distillate oil fuel quality

As has been highlighted in earlier Chapters, flashpoint has no connection with fuel ignition or combustion performance. Since the intent of this harmonisation of the marine distillate oil fuel flashpoint limit with that of the automotive industries is that it would provide for automotive diesel to be delivered to ships then the problems which are encountered with those automotive fuels would also be encountered by ships. Generally automotive breakdowns are not related to fuel quality as received other than where there have been gross mishandling or processing issues. The automotive delivered fuel quality issues of possible concern to the marine industry are the risk of the delivery of petrol (gasoline) by mistake or the performance of bio-diesel in marine systems. The incorrect delivery of petrol into forecourt / petrol station diesel fuel tanks typically occurs at unmanned sites. In the marine context, where all oil fuels are received onboard by the ship’s staff together with the readily detected odour and other characteristics of petrol as well as the requirements for bunker delivery note information this concern can reasonably be discounted. Currently bio-diesels are first generation products (technically Fatty Acid Methyl Ester – FAME) produced from a wide range of organic materials. The automotive standards of EN 590 and ASTM D975 for EU and US respectively, both have at least a 5%-7% renewable fuel blend requirements and currently this is in the form of FAME. Hence it must be expected that by allowing automotive fuel to be supplied then there may be significant FAME component in the fuel supplied to ships. This issue has been raised and addressed in the international marine fuel standard ISO 8217:2010 which stipulates specifically that there is to be only ‘de minimis ’ levels of FAME present hence retaining its purpose of being a solely petroleum derived standard. This position also reflected the fact that some shore-side experience of FAME blends indicated that it may not be well suited to typical onboard storage and handling conditions and furthermore, due to its fundamentally different nature, it could affect the performance of devices such as bilge water overboard discharge monitors. In this of course the development of a specification, such as ISO 8217, has to proceed on the precautionary approach basis and hence new aspects cannot be introduced until they have shown to not compromise performance. However the ISO 8217 committee is working towards a specific bio-diesel fuel grade taking into account the concerns relating to the use of FAME blends (or even 100% FAME) in marine applications, recognising the possibility that FAME, or other bio derived products, could be present in marine fuel not only in the future but already now. At the same time guidelines are being drawn up by the


CIMAC working group dealing with fuels to provide a best practice approach for managing bio-diesel fuel onboard ship. As part of this process, information is being collated from cross industry global experiences in respect of the use of FAME onboard ship together with laboratory research on specific concerns which have been raised such as water separating characteristics, compatibility with residual fuels and material compatibilities. This recognises that with due care and attention FAME blend products could be manageable under normal ship operational trade patterns. One key area of concern however is with the use of FAME blend products in lifeboat and emergency engine machinery, where long term storage under extreme conditions and limited frequency of fuel usage from their individual storage tanks may increase the rate of oxidation, microbial activity and sludge deposition. This too should be capable of being covered by a more focused onboard management process and potentially a rethink on the design and management of such tanks taking into account not only the FAME implication but in the knowledge that the characteristics of distillates fuels generally could be expected to change with the introduction of a wider range of other bio derived products into the market. The extent by which FAME is already in marine distillates is quite apparent. It is also general knowledge that inland waterway vessels in Europe are now using EN 590 distillate grade fuel which invariably contains a significant FAME component without apparent widespread problems although in such instances storage periods onboard are relatively short. FOBAS has also detected that many distillates are being supplied to the larger yachts (essentially small passenger ships) which are 5%-7% FAME blends (and with flashpoints just meeting the require 60oC limit) and while some problems appear to be encountered these have not been unmanageable. FOBAS has seen evidence of automotive fuels already slipping in to the wider marine supply chain (probably due to the demand for low sulphur (less than 0.10%) diesel) as seen by those incidents, as shown in Chapter 5, where the flashpoint of the distillate oil fuel supplied is a few degrees below the 60oC limit. This is verified by the ultra low levels of sulphur content (aimed at meeting the 0.001% automotive sulphur limit) and qualitative evidence of a FAME component. Typically, the remoter bunker stations and those used by fishing boats and pleasure craft can be expected to be supplying products which already contain some FAME. Consequently, while there have been some reports of handling issues where higher levels of FAME have been present these have mainly been specific projects where there has been particular focus on observing the consequences of FAME use onboard. Therefore the experience to date has been that the generally unintentional usages of the limited FAME blends associated with automotive diesel may in some instances have resulted in operating problems these were not unmanageable in a marine engineering context. In view of the above it would be suggested that the problems likely to be encountered from


the use of FAME at automotive diesel blend levels are such that they should be capable of being dealt with given a wider awareness of the appropriate means of storing and handling such fuels and this concern should not therefore be a factor that would block the move to harmonise marine and automotive flashpoint limits. In any-case it is also worth considering, in view of the increase in distillate demand, that the marine industry should in the future expect a wider variance in marine distillate oil fuel quality than it has traditionally encountered whereas automotive diesel will, by the nature of its core market, be a much more uniform product.

7.4. Implications on ship arrangement and equipment requirements

From this study it has not been possible to identify any existing arrangements or equipment requirements which would be affected by the proposed limited reduction in the minimum distillate oil fuel flashpoint limit although this should not be considered an exhaustive review. However given that oil fuel tanks are already vented to ‘safe’ positions with air pipes closed by flame screens and that any fuel tank gauging systems do not have any exposed electrical contacts it is not seen that this should be an issue. The only identified point that would result from this reduction in flashpoint limit is related to the air shipment of samples for analysis and this relates to a regulatory, rather than practical, issue. The categorisation and packaging requirements for air freighting marine oil fuel samples for analysis is defined by the flashpoint with samples typically labelled ‘…Flashpoint: Above 60.5oC (141oF) ….’ in order to comply with the relevant International Air Transport Association (IATA) requirements the dividing line on hazard categorisation. If the flashpoint limit is subsequently lowered (and hence the necessarily assumed flashpoint of the product type in general) and the dividing line is not changed, there is nevertheless the provision to freight ‘hazardous’ material, as it would then so be designated, using a specifically designed packaging. This will no doubt add some cost but it means that samples could still be landed and shipped to laboratories as required and hence should not be considered as a reason to not change the minimum flashpoint limit.

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8. Appendices

I 1913 Table of Standard Flashpoints

II SOLAS Chapter II-2 Reg. 4.2.1

III 1903 Rules for Steel Ships Section 48

IV Lloyd’s Register Rules Flash Point - General Requirements

V (a) Lloyd’s Register Requirements summary overview from 1898

V (b) SOLAS – Statutory Summary overview from 1914

VI Canadian study on setting a marine oil fuel flashpoint limit

9. References

References consulted include:

i) Lloyd’s Class Rules and technical library

ii) IATA Dangerous goods regulations

iii) Canadian Institute of Marine Engineers Paper 28 Jan 1982 by Richard E. Stone C.D., C.I.M.E., P Eng.

iv) Lloyd’s Register FOBAS – fuel analysis statistics

v) ISO 8217: 2010 and ISO 8216:2010

vi) SOLAS 1974 As Amended

vii) OCIMF - The flammability hazards associated with the handling storage and carriage of residual fuel oils. (December 1989)

viii) IMO Library

ix) IP Standard Test Methods

10. Acknowledgements

The authors would like to express their deepest thanks to many across the bunker industry who have offered support, information advice and guidance to enable this study to be completed


For further information, please contact FOBAS: T +44 (0)20 7423 1862 E [email protected]

71 Fenchurch Street, London EC3M 4BS, UK www.lr.org

Lloyd's Register is a trading name of the Lloyd's Register Group of entities. Services are provided by members of the Lloyd's Register Group. For further details, please see our website www.lr.org/entities

APPENDIX I

1

1913 - TABLE OF STANDARD FLASH-POINT AND METHODS OF TESTING COUNTRY FLASH-POINT METHOD OF TESTING Antigua 83°F Abel Australian Commonwealth 73°F Abel-Pensky New Zealand 110°F Open test South Australia 73° F Abel-Pensky Tasmania 73° F Abel-Pensky Austria 70° F Abel Bahamas .. No regulations Barbados 83° F Abel Belgium .. .. Antwerp .. .. Bermuda 73° F ? Abel Britain 73° F Abel British Baluchistan and British Burma .. See India British Guiana 85° F Abel, or Abel-Pensky British Honduras 100° F Open test Canada 85° F Abel Cape Colony .. No regulations Ceylon 76° F Abel-Pensky China .. No regulations Cyprus .. No standard test Denmark 73°F Abel-Pensky Copenhagen 70°F Abel Dominica 100°F Open test Falkland Islands .. No regulations Fiji 78°F Abel France 95°F Granier Gambia 95°F Abel Germany 21°F Abel-Pensky Gibraltar 73°F Abel Gold Coast .. No regulations Greece No standard .. Grenada 80°F Abel Guernsey 73°F Abel-Pensky Holland 21°C Abel Hong Kong 150°F* None specified

76°F India 200°F*

Abel-Pensky

Isle of Man 73°F Abel Italy 21°C None specified Genoa 21°C Abel Rome 30°C Abel Naples 21°C None specified

95°F Jamaica

140°F* Abel

2

Japan 86°F Close test Osaka 21°C Abel Jersey 73°F Close test Labuan No standard .. Malay States 73°F Abel-Pensky Malta 76°F Abel Mauritius 73°F Abel Montserrat 83°F Abel Natal No standard .. Newfoundland No standard .. New Brunswick No standard .. Nigeria (Southern) No standard .. North Borneo No standard .. Norway 22°C Abel Portugal No standard .. Romania 23°C Abel-Pensky Russia 28°C Abel-Pensky St. Christopher and Nevis 83°F Abel St. Lucia 95°F Abel St. Vincent 83°F Abel-Pensky Seychelles 90°F Apparatus deposited with

Customs Sierra Leone 95°F Abel Spain .. No standard

73°F Straits Settlements 150°F*

Abel-Pensky

22°C Sweden 40°C*

Abel

23°C Switzerland 38°C*

Abel

Trinidad and Tobago 95°F Abel Turkey No standard .. United States- Alabama 120°F Fire; Tagliabue cup Arizona .. No regulations Arkansas 130°F Fire; Tagliabue cup California .. No State law City of Los

Angeles 110°F Tagliabue open cup

City of Sacramento

110°F Tagliabue open cup

City of San Francisco

110°F Tagliabue open cup

Colorado 110°F Fire; Tagliabue cup City of Denver 110°F Tagliabue open cup Columbia 120°F Fire; Tagliabue cup Connecticut 110°F Tagliabue open cup City of Meriden 125°F Fire

3

City of Newhaven

110°F Fire; Tagliabue cup

Delaware 115°F Fire; Tagliabue cup City of

Wilmington 110°F Fire

Florida .. No State law Georgia 100°F Elliott cup Idaho 120°F Fire; Tagliabue cup Illinois 150°F Fire; Tagliabue cup Indiana 120°F Tagliabue open cup Iowa 105°F Elliott cup Kansas 110°F Foster cup Kentucky 130°F Fire; Tagliabue cup Louisiana 125°F Tagliabue open cup City of New

Orleans 110°F Fire; Tagliabue cup

Maine 120°F Fire; Tagliabue cup Maryland 110°F Fire; Tagliabue cup City of Baltimore 120°F ..

100°F Tagliabue open cup Massachusetts 110°F Fire; Tagliabue cup

Michigan 120°F Foster cup Minnesota 120°F Fire; Minnesota cup Mississippi .. No State law Missouri 150°F Fire; Tagliabue cup Montana 110°F Probably Tagliabue cup Nebraska 112°F Foster cup Nevada .. No State law

100°F Tagliabue open cup New Hampshire 120°F Fire; Tagliabue cup

New Jersey 100°F Elliott cup City of Newark 110°F Fire New Mexico 120°F Fire; Tagliabue cup New York (State) 100°F Elliott cup City of Brooklyn 110°F Fire; Tagliabue cup City of New

York 110°F Elliott cup

City of Syracuse 110°F Fire; Tagliabue cup North Carolina 100°F Elliott cup North Dakota 105°F Foster cup Ohio 120°F Foster cup Oklahoma Territory 120°F Tagliabue open cup Oregon 120°F Fire Pennsylvania 110°F Fire; Tagliabue cup City of

Philadelphia 110°F Fire; Tagliabue cup

Rhode Island 110°F Tagliabue open cup South Carolina .. No State law

4

South Dakota 105°F Elliott cup Tennessee 120°F Tagliabue open cup Texas .. No State law Utah 110°F Tagliabue open cup Vermont 110°F Fire; Tagliabue cup Virginia .. No State law City of

Richmond 110°F Fire; Tagliabue cup

Washington 120°F Fire; Tagliabue cup West Virginia .. No State law

100°F and Wisconsin 120°F fire

Tagliabue cup

City of Milwaukee

110°F ..

Wyoming 105°F Elliott cup Zanzibar No standard ..

APPENDIX II

SOLAS Capter II-2 Reg 4.2.1. SOLAS - International Convention for the Safety of Life at Sea - Chapter II-2 - Construction - Fire protection, fire detection and fire extinction - Part B - Prevention of fire and explosion - Regulation 4 - Probability of ignition - 2 Arrangements for oil fuel, lubrication oil and other flammable oils - 2.1 Limitations in the use of oils as fuel

2.1 Limitations in the use of oils as fuel . The following limitations shall apply to the use of oil as fuel:

.1. except as otherwise permitted by this paragraph, no oil fuel with a flashpoint of less than 60°C shall be used; see footnote

.2. in emergency generators oil fuel with a flashpoint of not less than 43°C may be used;

.3. the use of oil fuel having a flashpoint of less than 60°C but not less than 43°C may be permitted (e.g., for feeding the emergency fire pump’s engines and the auxiliary machines which are not located in the machinery spaces of category A) subject to the following:

.3.1. fuel oil tanks except those arranged in double bottom compartments shall be located outside of machinery spaces of category A;

.3.2. provisions for the measurement of oil temperature are provided on the suction pipe of the oil fuel pump;

.3.3. stop valves and/or cocks are provided on the inlet side and outlet side of the oil fuel strainers; and

.3.4. pipe joints of welded construction or of circular cone type or spherical type union joint are applied as much as possible; and

.4. in cargo ships the use of fuel having a lower flashpoint than otherwise specified in paragraph 2.1, for example crude oil, may be permitted provided that such fuel is not stored in any machinery space and subject to the approval by the Administration of the complete installation.

APPENDIX IV

Lloyd’s Register Rules on Flashpoint for oil fuel – Rulefinder Version 9.16 (July 2011) - Lloyd’s Register Rules and Regulations - Rules and Regulations for the Classification of Ships, July 2011 - Main and Auxiliary Machinery - Machinery Piping Systems - Oil fuel - General requirements

Section 2 Oil fuel - General requirements

2.1 Flash point

2.1.1. The flash point (closed cup test) of oil fuel for use in ships classed for unrestricted service is, in general, to be not less than 60°C. For emergency generator engines a flash point of not less than 43°C is permissible.

2.1.2. The use of oil fuel having a flash point of less than 60° but not less than 43° may be permitted for emergency generators, emergency fire pumps, engines and auxiliary machines which are not located in machinery spaces subject to the requirements of 4.19.

2.1.3. The use of fuel having a lower flash point than specified in 2.1.1 or 2.1.2 may be permitted in cargo ships provided that such fuel is not stored in any machinery space and the arrangements for the complete installation are specially approved.

2.1.4. In general, oil fuel in storage and service tanks is not to be heated to a temperature exceeding 10°C below its flash point. Higher temperatures will be considered where:

(a). The tanks are vented to a safe position outside the engine room and, as in the case of all oil fuel tanks, the ends of the ventilation pipes are fitted with gauze diaphragms.

(b). Openings in the drainage systems of tanks containing heated oil fuel are located in spaces where no accumulation of oil vapours at temperatures close to the flash point can occur.

(c). There is no source of ignition in the vicinity of the ventilation pipes or near the openings in the drainage systems or in the tanks themselves.

2.1.5. The temperature of any heating medium is not to exceed 220°C.

APPENDIX V (a)

Classification Society Requirements Summary from 1898 Lloyd’s Register - Flash Point of Marine Oil Fuel

1

Year Event Page 1898 Lloyd’s Register first accepted the use of oil fuel on a classed ship ….. and between then and 1902 a number ships

using oil fuel were classed No Class Rules for oil fired boilers – case by case consideration with the general requirement that the oil fuel flashpoint was not to be below 200oF.

1901 British Colonial Office decided to allow oil fuel having a flash point of not less than 150oF to be supplied as bunkers to ships in Hong Kong. - LR developing for oil burning installations

1903-1904 Edition for rules

rules for the ‘…burning and carrying of liquid fuel..’ in those instances where the ‘…oil fuel the flash point of which as determined by Abel’s close test does not fall below 150o Fahrenheit.’. Ships ……eligible for the entry “Fitted for liquid fuel” to be made in the Register Book

1902 Hong Kong the storage of petroleum products was covered by ‘The Dangerous Goods Ordinances of 1873 as amended 1884, 1899, 1901 and 1902’

1910-1911 Edition

The 1910-1911 edition of Lloyd’s Register’s Rules introduced for the first time requirements for ‘.. internal combustion engines for marine purposes..’. These engines were given as being fuelled by petrol, paraffin or ‘heavy oil’

from the outset of the use of internal combustion engines in ships there existed the possibility of using oil fuels with flash points below 150oF, was highlighted

1913-1914 Edition

in addition to the general rules relating to oil fuels with a flashpoint not below 150oF, required that where the oil fuel had a flashpoint below 150oF the oil fuel system arrangement was to be submitted for special consideration…….., in particular the issues related to using petrol or paraffin as the fuel

1913-1914 Edition

…. the ‘Fitted for liquid fuel’ Register Book entry was replaced by notations ‘Fitted for oil fuel F.P. above 150oF’ or ‘Fitted for low flash oil fuel’

1930-1931 Edition

This Chapter was re-titled to cover ‘… petrol and paraffin engines.’

APPENDIX V (a)


2

Year Event Page 1948-149 Edition

The 1948-1949 edition limited the assignment of the ‘..above 150oF ..’ notation only to steamships and resolved the anomaly by referring only to oil fuels of flashpoint above 150oF, it also discontinued the practice of assigning the ‘Fitted for low flash oil fuel’ notation

1952 Practice of assigning such notations was discontinued – reflecting that by this time the use of oil fuel had become such standard practice that the notation was superfluous.

1962 the first time that the flashpoint of the oil fuel used in general, unrestricted, service was explicitly limited, to not less than 150oF In the case of emergency generators a flashpoint of not less than 110oF was given as permissible In this edition the requirements in respect of ‘…piping for petrol and paraffin engines ..’ were not included on the basis that there was ‘..no present day application… In the case of emergency generators a flashpoint of not less than 110oF was given as permissible

1962 Flash Points < 150 oF could be used in restricted geographical areas… temperature of the machinery or boiler spaces which it would be used in would always be 30oF below the flash point. …. in no instances was the flashpoint to be less than 130oF when used in boilers or less than 110oF if used in engines.

1966 American Bureau of Shipping Rules for 1966 gave that in no case was the flashpoint of oil fuel used in boilers to be lower than 120oF and that where it was intended to use oil fuel with a flashpoint below 150oF this would be subject to special consideration and was not to be heated to more than 100oF in storage tanks

1967 Germanischer Lloyd in their 1967 Rules had a general service oil fuel flash point limit of above 65oC although, subject to special consideration, oil fuel of flashpoints of 65oC or below be used if stored and used outside the engine room

1965 Bureau Veritas Rules for 1965 give the unrestricted service flashpoint requirement as 55oC and above with oil fuels with a flashpoint below that value, but not below 43oC, only being permitted for emergency engines.

APPENDIX V (a)


3

Year Event Page 1968 Lloyd’s Register Rules the flashpoint limits converted to oC with the previous oF values given in brackets alongside.

……a 150oF limit was given as 65.5oC. Similarly the 110oF limit was changed to 43oC with the 30oF differential given as 16.5oC

1972 In the 1972 edition of the Rules the unrestricted service flashpoint requirement was lowered to be ‘…not less than 60oC…’, although that for emergency generators the limit value of not less than 43oC was retained …. differential between the temperature of the machinery or boiler spaces in which the oil fuel was used and its flashpoint was reduced to 10oC.

1982 Differential between the temperatures of the machinery or boiler spaces in which the oil fuel was used and its flashpoint was reduced to 10oC.

1983 oil fuel in storage and service tanks was not to be heated to within 10oC of its flashpoint. In this context ‘service’ tanks would have included settling tanks.

1984 …. allowing a temperature higher than 10oC below the flashpoint provided that certain requirements were met, although in practice those requirements only represented the typically existing arrangements as regards the air pipe closures and locations of drains.

2003 general clause permitting oil fuel with a flashpoint below 60oC but not less 43oC to be used but only for emergency engines located outside the machinery spaces.

APPENDIX V (b)

Statutory Summary of SOLAS - Flash Point of Marine Oil Fuel

1

Year Event + Comments Page 1914 1929

Inter Governmental Treaties – no requirements for minimum flash point of oils fuels on ships

1948 (In force 1952)

‘new passenger’ ships, as defined, that where the emergency source of power was an engine driven emergency generator the ‘…fuel used shall have a flashpoint of not less than 110oF (or 43.3oC)…’ – Chapter II Part C regulation 22

1948 IMO, as a specialised United Nations technical organization, was formed in 1948 SOLAS convention for ‘new’ ships as defined by that Convention that ‘..no internal combustion engine shall be used for any fixed installation in a passenger ship if its fuel has a flash point of 110oF (or 43oC) or less..’ – Chapter II Part C regulation 31.

1960 (In force 1965)

Furthermore, where the emergency source of power was an engine driven emergency generator the ‘…fuel used shall have a flashpoint of not less than 110oF (or 43oC)…’ – Chapter II Part C regulation 25 (passenger ships) or regulation 26 (cargo ships).

1974 SOLAS Convention (which remains today as the base SOLAS text albeit extensively amended) included, for the first time, the tacit acceptance procedure in order to facilitate ongoing amendments.

1974 (In force 1980)

i) for ‘new passenger ships’ carrying more than 36 passengers – ‘…no oil fuel with a flashpoint of less than 60oC (140oF)(closed cup test) …..shall be used as fuel, except in emergency generators, in which case the flashpoint shall not be less than 43oC (110oC)…provided that the Administration may permit the general use of fuel oil having a flashpoint of not less than 43oC (110oF) subject to such additional precautions as it may consider necessary and on condition that the temperature of the space in which such fuel is stored or used shall not be allowed to rise within 10oC (18oF) below the flashpoint of the fuel…’ – Chapter II-2 Part B regulation 33.

Hence there were no minimum fuel flashpoint requirements in respect of either ‘new cargo ships’ or ‘new tankers’ other than those carried over from

APPENDIX V (b)


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Year Event + Comments Page 1974 (In force 1980)

For ‘new passenger ships’ carrying not more than 36 passengers – ‘.no internal combustion engine shall be used for any fixed installation in a ship if its fuel has a flashpoint of 43oC (110oF) or less (closed cup test)…..’ Chapter II-2 Part C regulation 49.

the 1960 Convention, now given in Chapter II-1, in respect of the emergency source of electrical power

1967- 1974 Debate which was on-going ~(60 or 61oC) at that time within IMCO (as it was then termed) as to the categorization of products to be covered by the Dangerous Goods Code which was being developed as the first IMCO code of practice. Outcome was 60oC

1981 (In force 1984)

Amendments to SOLAS 74 Chapter II-2 completed .1 Except as otherwise permitted….., no oil fuel with a flashpoint of less than 60oC (140oF) shall be used. .2 In emergency generators oil fuel with a flashpoint of not less than 43oC may be used .3….. such oil fuel is stored or used shall not be allowed to rise within 10oC below the flashpoint of the oil fuel,…… .4 In cargo ships the use of fuel having a lower flashpoint than otherwise specified in this paragraph, for example crude oil, may be permitted provided that such fuel is not stored in any machinery space and subject to the approval by the Administration of the complete installation. The flashpoint of oils shall be determined by an approved closed cup method

1985 In November 1985 Assembly Resolution A.565(14), ‘Recommended Procedures to Prevent the Illegal or Accidental Use of Low Flashpoint Cargo Oil as Fuel’ was adopted

This brought attention to the practice of illegally using cargo crude oil as bunker fuel.

APPENDIX V (b)


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2000 The 2000 Amendments, representing changes adopted by the 72nd and 73rd sessions of MSC, totally replaced the 1981 Chapter II-2.

Essentially no change to flash point requirements itself

the use of oil fuel having a flashpoint of less than 60oC but not less than 43oC may be permitted (e.g., for feeding the emergency fire pump’s engines and the auxiliary machines which are not located in the machinery spaces of category A) subject to the following: .3.1 fuel oil tanks except those arranged in double bottom compartments shall be

located outside of machinery spaces of category A; .3.2 provisions for the measurement of oil temperature are provided on the suction

pipe of the oil fuel pump; .3.3 stop valves and/or cocks are provided on the inlet side and outlet side of the oil

fuel strainers; and .3.4 pipe joints of welded construction or of circular cone type or spherical type union

joint are applied as much as possible.’

No subsequent change of the flashpoint requirement through to 2012 –

2007 SOLAS was amended to include the requirement that a Material Safety Data Sheet (MSDS)

2009 MSC Circular 1321 (MSC.1/Circ1321) published ….. oil fuel in storage should not be heated to within 10oC below the oil fuel’s flashpoint except in the case of settling, service and other system tanks which met certain criteria…

October 2011 1974 SOLAS Convention there are 161 Contracting States or Parties… 98.91% of world’s gross tonnage

flashpoint of marine distillate oil fuels...8 of 57 flashpoint of marine distillate oil fuels for...

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