The Liberia Maritime Authority has published guidance on compliance with the requirements for ships using low-flashpoint fuel.
Marine notice SAF-017 Rev. 1/25 applies to ships using low-flashpoint fuels:
• for which the building contract is placed on or after 1 January 2017;
• in the absence of a building contract, the keels of which are laid or which are at a similar stage of construction on or after 1 July 2017; or
• the delivery of which is on or after 1 January 2021.
It also applies to a ship, irrespective of the date of construction, which converts to using low-flashpoint fuels on or after 1 January 2017, or to a ship using low-flashpoint fuels, which, on or after 1 January 2017, undertakes to use low-flashpoint fuels different from those which it was originally approved to use before 1 January 2017.
It also applies to gas carriers, as defined in SOLAS regulation VII/11.2, that use cargo vapour or boil-off gas other than methane (LNG) as a low-flashpoint gaseous fuel. It does not apply to gas carriers, as defined in regulation VII/11.2, that use methane (LNG) cargo vapour or boil-off gas as fuel. The requirements for this are contained in Section 16 of the IGC Code.
Requirements
Ships using low-flashpoint fuels shall comply with the requirements of the IGF Code, as amended.
The IGF Code, as amended contains regulations to meet the functional requirements for the use of natural gas fuel. Requirements for the use of other low-flashpoint fuels are under development at the IMO and will be added to the IGF Code, as amended, once developed.
Until such time that requirements for other low-flashpoint fuels are developed, it must be demonstrated that the use of another low-flashpoint fuel achieves compliance with the functional requirements of IGF Code, as amended, and that an equivalent level of safety is maintained.
(Also, appliances and/or arrangements of natural gas fuel systems may deviate from those 2 of 6 1/25 SAF-017 Republic of Liberia set out in the Code, provided it is demonstrated that an equivalent level of safety is maintained.)
This equivalence of the alternative design shall be demonstrated as specified in SOLAS regulation II-1/55 and approved by this Administration. The guidelines in MSC.1/Circ.1212/Rev.2 and MSC.1/Circ.1455, as appropriate, are to be used for assessment and approval of the alternative design.
The risks shall be analyzed using acceptable and recognized risk analysis techniques, considering the guidance provided in MSC.1/Circ.1455, and the loss of function, component damage, fire, explosion and electric shock as a minimum. The analysis shall ensure that risks are eliminated wherever possible, and where they cannot be eliminated, are mitigated as necessary.
The IGC Code, as amended, similar to the IGF Code, provides specific provisions for use of liquefied natural gas (LNG) cargo as fuel.
Requirements for the use of other low-flashpoint cargo for fuel are under development at the IMO and the IGC Code, as amended, requires that the same level of safety as natural gas is ensured, to be demonstrated as specified in SOLAS regulation II-1/55.
Accordingly, the same general process and requirements as described in this Marine Notice for ships using low-flashpoint fuels are to be followed for the use of other low-flashpoint cargo as fuel on gas carriers. Refer to sections 4.2 and 4.3 for details for specific fuels.
The notice also contains guidance for other low-flashpoint fuels including ammonia, hydrogen, low-flashpoint oil fuels, LPG and Methyl/Ethyl Alcohol (Methanol/Ethanol). It also briefly covers gas carriers using low-flashpoint fuels other than cargo.
Read the notice in full: Liberia Maritime Authority SAF-017 Rev 1/25