Académique Documents
Professionnel Documents
Culture Documents
Authors:
A.A Wright C.Eng., F.I.MarEST
T.S Wilson C.Eng., M.I.MarEST
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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
Executive summary 6
1. Introduction 8
5.2. Canadian study on the setting of the marine oil fuel flashpoint limit 37
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6.4. Amendments to other non-IMO regulations and requirements 46
7.1. Oil fuel grades to which a revised oil fuel minimum limit would apply 49
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.
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.
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.
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.
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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 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.
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2. Flashpoint as a quality parameter
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
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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
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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.
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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.
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.
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Substance Lower Upper Explosive Flash point Auto ignition
Explosive limit limit %v/v °C temperature °C
%v/v
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
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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.
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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
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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.
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.
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
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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.
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
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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:
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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.
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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.
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
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‘…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.
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
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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.
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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
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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.
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.
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.
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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.
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.
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 …’.
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4. Why change the marine oil fuel flashpoint limit?
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
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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
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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.
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.
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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 55
considered as:
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.
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.
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4.3. Effects of reducing the marine oil fuel flashpoint limit
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.
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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.
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.
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.
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
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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.
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.
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
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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.
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Table 1: FOBAS flashpoint summary over year 2010/2011
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.
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>=70 & 60-69 deg C LSMGO (FOBAS) 56-59 & <=55 deg C LSMGO (FOBAS)
70 1.2
60
Average % Samples
1.0
Average % Samples
50
0.8
40
0.6
30
0.4
20
0.2
10
0.0
0
2006 2007 2008 2009 2010 2011 2006 2007 2008 2009 2010 2011
56 - 59 Year <=55
60 - 69 Year >=70
2 per. Mov. Avg. (>=70) 2 per. Mov. Avg. (60 - 69) 2 per. Mov. Avg. (56 - 59) 2 per. Mov. Avg. (<=55)
>=70 & 60-69 deg C HSMGO (FOBAS) 56-59 & <=55 deg C HSMGO (FOBAS)
80
0.9
70
Average % Sam ples
0.8
60 Average % Samples 0.7
50 0.6
40 0.5
30 0.4
20 0.3
10 0.2
0 0.1
2006 2007 2008 2009 2010 2011 0.0
2006 2007 2008 2009 2010 2011
>=70 Year 60 - 69
56 - 59 Year <=55
2 per. Mov. Avg. (>=70) 2 per. Mov. Avg. (60 - 69)
2 per. Mov. Avg. (<=55) 2 per. Mov. Avg. (56 - 59)
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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.
Average % Samples
2.50
Average % Samples
99.50
2.00
99.00
1.50
98.50
98.00 1.00
97.50 0.50
97.00 0.00
2006 2007 2008 2009 2010 2011 2006 2007 2008 2009 2010 2011
60 - 69
>=70 2Year
per. Mov. Avg. (>=70) Year
2 per. Mov. Avg. (60 - 69)
0.10
0.08
0.06
0.04
0.02
0.00
2006 2007 2008 2009 2010 2011
56 - 59 Year <=55
2 per. Mov. Avg. (56 - 59) 2 per. Mov. Avg. (<=55)
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.
0.35
Average % Samples
99.7
0.30
99.6
0.25
99.5
0.20
99.4
0.15
99.3
99.2 0.10
99.1 0.05
99.0 0.00
2006 2007 2008 2009 2010 2011 2006 2007 2008 2009 2010 2011
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56-59 & <=55 deg C LSHFO (FOBAS)
0.16
0.14
Average % Samples
0.12
0.10
0.08
0.06
0.04
0.02
0.00
2006 2007 2008 2009 2010 2011
56 - 59 Year <=55
2 per. Mov. Avg. (<=55) 2 per. Mov. Avg. (56 - 59)
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.
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.
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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.
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.
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
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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.
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.
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’.
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.
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.
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
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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.
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.
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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.
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7. Practical implementation of change
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.
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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).
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 /
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mixing tank hence minimising the release of vapour and such vapour that is
released is vented to a safe position outside the engine room.
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.
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):
‘Distillate oil fuel – Oil fuel which is comprised solely or principally of distillate
fractions of petroleum refining.’
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‘Distillate oil fuel – Oil fuel which conforms to the DM grades given in ISO
8217:2010.’
‘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):
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7.3. Implications of marine distillate oil fuel quality
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
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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.
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
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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.
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
9. References
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
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For further information, please contact FOBAS:
T +44 (0)20 7423 1862 E fobas@lr.org
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APPENDIX I
1
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
Straits Settlements 73°F Abel-Pensky
150°F*
Sweden 22°C Abel
40°C*
Switzerland 23°C Abel
38°C*
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 110°F Tagliabue open cup
Angeles
City of 110°F Tagliabue open cup
Sacramento
City of San 110°F Tagliabue open cup
Francisco
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
2
City of 110°F Fire; Tagliabue cup
Newhaven
Delaware 115°F Fire; Tagliabue cup
City of 110°F Fire
Wilmington
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 110°F Fire; Tagliabue cup
Orleans
Maine 120°F Fire; Tagliabue cup
Maryland 110°F Fire; Tagliabue cup
City of Baltimore 120°F ..
Massachusetts 100°F Tagliabue open cup
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
New Hampshire 100°F Tagliabue open cup
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 110°F Elliott cup
York
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 110°F Fire; Tagliabue cup
Philadelphia
Rhode Island 110°F Tagliabue open cup
South Carolina .. No State law
3
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 110°F Fire; Tagliabue cup
Richmond
Washington 120°F Fire; Tagliabue cup
West Virginia .. No State law
Wisconsin 100°F and Tagliabue cup
120°F fire
City of 110°F ..
Milwaukee
Wyoming 105°F Elliott cup
Zanzibar No standard ..
4
APPENDIX II
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
.1. except as otherwise permitted by this paragraph, no oil fuel with a flashpoint of less than 60°C shall
see footnote
be used;
.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
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
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.
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 rules for the ‘…burning and carrying of liquid fuel..’ in those instances where the ‘…oil fuel the flash point of which
Edition for rules 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 The 1910-1911 edition of Lloyd’s Register’s Rules introduced for the first time requirements for ‘.. internal
Edition 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 in addition to the general rules relating to oil fuels with a flashpoint not below 150oF, required that where the oil fuel
Edition 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 …. the ‘Fitted for liquid fuel’ Register Book entry was replaced by notations ‘Fitted for oil fuel F.P. above 150oF’ or
Edition ‘Fitted for low flash oil fuel’
1930-1931 This Chapter was re-titled to cover ‘… petrol and paraffin engines.’
Edition
1
APPENDIX V (a)
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.
2
APPENDIX V (a)
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.
3
APPENDIX V (b)
Statutory Summary of
SOLAS - Flash Point of Marine Oil Fuel
1
APPENDIX V (b)
Statutory Summary of
SOLAS - Flash Point of Marine Oil Fuel
.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 This brought
Prevent the Illegal or Accidental Use of Low Flashpoint Cargo Oil as Fuel’ was adopted attention to the
practice of illegally
using cargo crude
oil as bunker fuel.
2
APPENDIX V (b)
Statutory Summary of
SOLAS - Flash Point of Marine Oil Fuel
2000 The 2000 Amendments, representing changes adopted by the 72nd and 73rd sessions of Essentially no
MSC, totally replaced the 1981 Chapter II-2. change to flash
point requirements
itself
the use of oil fuel having a flashpoint of less than 60oC but not less than 43oC No subsequent
may be permitted (e.g., for feeding the emergency fire pump’s engines and the change of the
auxiliary machines which are not located in the machinery spaces of category flashpoint
A) subject to the following: requirement
.3.1 fuel oil tanks except those arranged in double bottom compartments shall be through to 2012 –
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.’
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