Mr. Raghuvir C Bhavnani, Vice President – Global Marketing of VISWA LAB is analysing the quality concerns over the revised rules for marine bunker fuels
It is not rare to come across poor quality marine bunker fuels even though these met the test parameters of the standard ISO 8217:2005 and /or ISO 8217:2010/2012. Often marine bunker fuel are seriously deficient in quality, resulting in damage to ship’s machinery that too at a very critical time. The user, that is, the ship staff is at a loss since the fuel meets the test requirements of table 1 and table 2 of ISO 8217:2005 and/or ISO 8217:2010/2012 standards, but still the leads to machinery problems.
Such cases of machinery damage lead to disputes between ship owners and suppliers. Supplier’s defence is generally that the test requirements of ISO 8217 have been met and thus is absolved of any responsibilities for damage to the machinery.
The user will counter the above argument by referring to clause 5 of the standard which reads as below:
- The fuel shall confirm to the characteristics & limits given in table 1 or table 2, as appropriate when tested in accordance with the methods specified.
- The fuel shall be a homogeneous blend or hydrocarbons derived from petroleum refining. This shall not be preclude the incorporation of additives intended to improve some aspects of the fuel’s characteristics and performance. The fuel shall be free from both inorganic acids and used lubricating oils.
- Fuels shall be free from any material that renders the fuel unacceptable for use in marine applications.
- The fuel shall be free from bio-derived materials other than ‘de minimis levels of FAME (FAME shall be in accordance with the requirements of EN 14214 or ASTM D 6751). In the context of this international standard, “de minimis” means an amount that does not render the fuel unacceptable for use in marine applications. The blending of FAME shall not be allowed. Note: see Annex A.
- The fuel shall not contain any additive at the concentration used in the fuel or any added substance or chemical waste that:
- Jeopardizes the safety of the ship or adversely affects the performance of the machinery: or
- Is harmful to personnel: or
- Contributes to overall additional air pollution.
Therefore, if the ship owners / user can establish that the supplied fuel was causing the following:
- Jeopardizes the safety of the ship or adversely affects the performance of the machinery: or
- Is harmful to personnel: or
- Contributes overall to additional air pollution.
Similar requirements are also included in the IMO MARPOL Annex VI – Regulation 18.
This quality clause 5 in ISO standard is now proposed to be reworded in 2016 version, of standard, the draft of which is under circulation. The proposed wording of clause 5 in ISO 8217:2016 if adopted, would read as under.
The fuel shall be free from any material at a concentration that causes the fuel to be unacceptable for use in accordance with the scope of this international standard.
Note: Determining the concentration of a material that causes the fuel to be unacceptable for use is not straightforward and it may not be practical to require detailed chemical analysis for each delivery of the fuels beyond the requirements listed in table 1 or table 2 of this international standard. A better understanding is needed of the impact of specific chemical species and the respective critical concentration at which detrimental effects are observed on the operational characteristics of the marine fuels. To this end, the marine industry is undertaking a study to identify the specific chemical species that either be found or likely to be present in marine fuels. The study also seeks to identify the critical concentration at which detrimental effects (such as lacquer or deposit formation), if any are observed and equipment operations impaired.
The reference to jeopardizing the safety of the ship, adverse effects on machinery performance, harm to personnel, contribution to air pollution is being dropped. The amended clause says only that the fuel should be free from any material at concentration that causes a fuel to be unacceptable. It goes further and negates this requirement “unacceptable” by stating in the note that what is “unacceptable” is not known implying that any chemical at any concentration may be present and the user has to live with it and the supplier will be shielded by any claims for damages due to bad quality of the fuels.
I strongly recommend that the user community (shipowners) through their national or flag state or classification society to vote against the change!
The user community may also put forward their wishlist of what other changes they may like to see such as reduction in cat-fine levels, determining the cloud point and cold filter plugging point, reduction in permissible water levels, more effective tests for acidity, list of unacceptable blend components etc.
Please ACT FAST!
Time is running out!
Written by Raghuvir C Bhavnani
Vice President – Global Marketing of VISWA LAB
Above article has been initially published in MFAME and is reproduced here with the kind permission of the editor
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
[divider]
About Raghuvir C Bhavnani
Raghuvir C. Bhavnani, Vice President – Global Marketing of VISWA LAB Raghu graduated from Marine Engineering College Calcutta in 1964. Earned a Bachelor’s degree in History and Economics from Osmania University in 1980 and a Bachelor’ degree in Law , International law as special subject , from University of Bombay in 1984. Holds First Class Certificate Of Competency – Steam Ships and Motor Ships (Government of U.K. ). Authorised ASME Code Inspector for Boilers and Pressure Vessels by State Of Vermont, U.S.A.
Sailed as Engineer Officer for ten years from 1964 to 1974 including three years as Chief Engineer on VLCCs and Passenger Liners. Served with American Bureau Of Shipping from 1974 to 2009 and was the Country Head for India / Sri Lanka / Bangladesh / Maldives. Currently Vice President – Global Marketing, VISWALAB since June 2009. Viswalab is the second largest marine fuel / lubes testing laboratory in the world. Fellow of Institute of marine Engineers (India) and Past President of the Institute from 2005 to 2007.
