Preventing inadvertent use of low flashpoint: Amendments effective from January 2026

Low flashpoint or other ‘off-specification’ fuel oils are known to risk disabling a vessel’s engines, endangering the vessel and the crew generally and can give rise to safety issues that may also result in significant losses. Besides potential for presence of contaminants which can create problems for the safe consumption of bunkers and cause damage to systems and propulsion machinery, the carriage and consumption of bunkers with a low flashpoint presents an entirely separate safety and fire hazard.

If the fuel flashpoint is below 60o C (except where authorized by SOLAS 4.2.1), or Sulphur content is >0.5% m/m (or > 0.1% in an ECA) the Flag State Administration and Class should be notified, and bunkering stopped immediately. If bunkering has commenced or accidental embarkation has been made, a plan of measures to be taken is to be drawn up with the objective of removing the contaminated/ off-specification fuel as soon as possible, washing and gas-freeing the tanks and associated piping as necessary.

Risk assessment, to apply suitable safeguards whilst Low flashpoint fuel remains on board. Assessment should include:

• Checking and maintaining fuel temperatures in storage tanks at the minimum possible;
• Checking the fuel tank vent gauze condition;
• Keeping tanks ventilated to ensure no accumulation of flammable gasses;
• Prohibiting hot work, smoking on board or source of ignition close to tanks, vents, and piping systems;
• Avoiding oil being stored in tanks adjacent to other tanks or spaces which can be heated and any heating circuits to the tanks containing the oil are to be blanked off;
• Ensuring that the engine room ventilation system is operated continuously;
• Ensuring that any oil leakage is collected safely and not allowed to accumulate in the engine room;
• Ensuring that any tank openings in the engine room (other than to transfer or service pumps) are kept closed;
• Disconnecting non-intrinsically safe electrical apparatus around (at least 3m) affected tank vents.
• Ensuring that tank cross connection valves and suctions between contaminated and compliant fuel are closed and tagged to prevent inadvertent use.
• Fixing appropriate warning signage in way of the tanks and air pipes on deck.
• Sampling of the fuel on board. Samples taken should be formally witnessed by all parties where practicable taking account of MARPOL VI/ Appendix VI and MEPC.182(49). Supporting documentation should be collated to ensure records of all representative samples are recorded.
• Tanks and systems should be prepared and cleaned to receive compliant fuel from an Approved supplier. This may require fuel transfer in the interim. Compliant Fuel must not be mixed with the off-specification fuel.