The International Bunker Industry Association (IBIA) has submitted proposals to the Maritime Safety Committee regarding new fuel oil flash point regulations during its meeting from May 31 to June 9. The committee will discuss developing further measures surrounding ship safety and bunker fuel supply. IBIA submitted four proposals to MSC 107 in response to draft sampling guidelines and ideas discussed in the Correspondence Group Report. The main concern with the current regulations is a lack of understanding, and IBIA has suggested a Uniform Interpretation (UI) of SOLAS Chapter II-2 to clarify the meaning of regulatory text.
It is also requesting approval of a corresponding user interface for MARPOL Annex VI, which requires flash point documentation for the bunker delivery note. MSC 107 will also review draft joint MSC-MEPC sampling guidelines developed by the Correspondence Group. IBIA suggests that the guidelines should consider practicality, safety and consistency with established industry practices. In particular, it is important to have the sample taken by qualified personnel, but the current regulation is confusing and requires clarification.
IBIA and ISO have advised against mandating compliance with ISO 8217:2017 as it would lead to unjustified claims for fuel unbunkering. The IBIA and ISO joint paper argues that fuel that has been safely managed with due care and attention on board can become the subject of claims even if it is entirely safe. IBIA concludes by proposing changes to the draft MSC-MEPC Sampling Guidelines to accommodate practical considerations of sample integrity and vial size, including the addition of a general rule in SOLAS in line with regulation 18 of MARPOL Annex VI. They suggest that the positioning of the sampling equipment at the bunker manifold of either the receiving ship or the bunker tanker should be agreed between the receiving ship and the supplier in advance.
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IBIA would like IMO to improve the new flash point regulations

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