European Maritime Safety Agency issues study on standards and rules for bunkering of gas-fuelled ships
EMSA publishes Final Report for Study on standards and rules for bunkering of gas-fuelled ships, according to the press release. Maritime environmental regulations and the continuous development of the economic operation of ships let to the development of numerous gas-fuelled ships and ship designs. Currently about 30 gas-fuelled vessels are operating mostly in the Baltic Sea and Norwegian waters most of them on the authority of the Norwegian administration. Hence, Norway had early on experience with gas as fuel for ships and initiated the development of the IMO’s international ‘Guidelines on Safety for Natural Gas-Fuelled Engine Installations in Ships’ in 2004.
These interim guidelines (MSC Resolution 285.(86)) were adopted in June 2009 and focus on the use of natural gas on board of vessels and the requirements for the installations on board. Besides the interim guidelines, the use of LNG as a maritime fuel for ships is not formally recognized by IMO rules. To facilitate the approval process for gas-fuelled vessels a code for the use of gas as ship fuel is being developed. This ‘International Code of Safety for ships using gases or other low flashpoint fuels (IGF Code)’ is still under development and will cover safety and operational issues for gas-fuelled seagoing vessels. In comparison to the above mentioned guidelines, the IGF Code will have the status of an internationally adopted and legally binding regulatory instrument.
Regarding the bunkering of LNG, the IGF Code will define requirements for the bunkering systems onboard the receiving vessel and general operational requirements regarding the preparation, post processing, responsibilities and communication focusing the (receiving) gas-fuelled ship. No specific operational guidance taking into account all types of bunkering modes and requirements for each kind of transfer system for all facilities involved are considered.
To close the gap regarding the bunkering of LNG as fuel for ships in the regulatory framework, another Norwegian initiative led to the establishment of the Working Group 10 (WG 10) within the Technical Committee 67 (TC 67) of the International Organisation for Standardisation (ISO) in 2011. The objective of the ISO TC 67WG 10 is the development of international guidelines for bunkering of gas-fuelled vessels focusing on requirements for the LNG transfer system, the personnel involved and the related risk of the whole LNG bunkering process. The members of the WG 10 decided to develop a technical report as a high level document to be finalized by 2014. For the time being, with experiences of bunkering of LNG being not widespread, Working Group 10 is not able to develop an international standard for bunkering LNG.
While regulations for the use of gas on seagoing vessels and the related bunkering guidelines are already under development, similar activities for inland vessels have just started. Unlike the rule framework for seagoing vessels, the transport of LNG by inland tankers is not allowed. Within the ‘European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN)’ the necessary entry of LNG within the cargo list is missing, which leads to the prohibition of transport via inland waterways tanker. For both unregulated items, the transport of LNG as cargo by inland waterway tanker and the use of LNG as fuel for inland waterway Report No. CL-T-SM2012.005 Date 2013-02-15 Germanischer Lloyd 8 vessels, activities are initiated to develop necessary appendixes of the ADN and the Rhine Vessel Inspection Regulations.
The existing guidelines of the ‘International Society of Gas Tanker and Terminal Operator (SIGTTO)’ and those by the ‘International Oil companies Marine Forum (OCIMF)’ describe the handling and transport of LNG as cargo.
However, these documents cannot directly be used for regulating the bunkering of LNG as ship fuel due to the fact that these documents are dealing with the transport and transfer of large quantities of LNG as cargo and handled by an experienced crew on ships and terminals. For the bunkering of LNG as ship fuel, safety requirements given by SIGTTO and OCIMF may be adapted for the handling of smaller amounts of LNG, a bunkering process which takes place at any berth within harbour areas, between different types of bunker sources and receiving vessels as well as handling by crews with little or no experience in daily handling of LNG and in the presence of passengers on board of the vessels.
In summary, the regulatory framework for bunkering of LNG as fuel for ships including relevant regulations of the LNG supply chain (transport on inland water ways) is not available for the time being but can be based on other existing standards and guidelines e .g .the SIGTTO ‘Ship to Ship Transfer Guideline’ for the Ship to Ship bunkering or the ISO 28460 ‘Ship to shore interface and port operations’ for the Terminal to Ship bunkering of LNG. Gaps (an overview of all gaps is provided in chapter 10) related to LNG bunkering could be addressed by a possible common EU regulatory instrument (i.e. legislation, recommendations or guidelines) with focus on:
- The definition of the bunkering process
- Common risk assessment procedure for approval processes
- Common risk evaluation criteria
- Common safety distances for bunkering processes
- Environmental aspects due to the release of methane
- EU wide procedures for the definition of gas quality and sampling
For all possible LNG bunkering activities and related processes the general safety principle as stated in the Draft
LNG bunkering of the ISO TC 67 Working Group 10 should be followed:
“Safety should be the primary objective for the planning, design and operation of facilities for the delivery of LNG
as marine fuel”.
Stringent international regulations on emissions are forcing the shipping industry to rethink its fuelling options. The IMO’s Marine Environmental Protection Committee has introduced emission controls, which will increasingly affect international shipping over the next decade. The introduction of Emission Control Areas (ECA’s) in European, U.S. and Canadian territorial waters means that ship owners must begin to consider alternatives to traditional heavy fuel oil. One solution is the switch to LNG as ship fuel.
Due to the number of activities within the field of rule development for gas as ship fuel and bunkering of LNG the objective of this report is to provide a detailed description of the existing rule framework related to all elements of the bunkering supply chain, focusing on the LNG bunkering of gas-fuelled vessels wherefore the rule development activities have recently been started. A gap analysis identifies the existing and foreseeable remaining items and the possible need for any further rule development regarding bunkering LNG at an EU level.
Based on the gap analysis and further input from stakeholder interviews and conferences, this final report of the “study on standards and rules for bunkering gas-fuelled ships” provides recommendations for possible common EU wide guidelines for bunkering gas-fuelled ships.
