Ship Fuel Safety: Flashpoint Declaration
For ships to which SOLAS II-2/4.2.1.6 applies, fuel documentation must state the flashpoint or prescribed declaration under a standard acceptable to IMO.
Operational Explanation
New SOLAS II-2/4.2.1.6 requires the prescribed flashpoint information before bunkering for ships within its scope that carry oil fuel. This SOLAS safety requirement remains distinct from MARPOL BDN rules.
Regulatory Reference
SOLAS Chapter II-2, amendments from Resolutions MSC.520(106) and MSC.550(108), in force from 1 January 2026: mandatory supplier declaration on the flashpoint before bunkering; the Bunker Delivery Note updated with the flashpoint data per the ISO 2719:2016 test method (Procedure A or B).
The declaration exists to verify a threshold, however, and the threshold should be stated. It is Regulation II-2/4.2.1.1: “except as otherwise permitted by this paragraph, no oil fuel with a flashpoint of less than 60°C shall be used”. There are two derogations and they must be kept apart: paragraph 4.2.1.2 allows fuel with a flashpoint of not less than 43 °C in emergency generators; 4.2.1.3 allows 43 °C more generally, but subject to conditions on tank location, temperature and valves. A declared flashpoint below 60 °C on a ship that falls under neither derogation makes the batch unusable, not merely poor: that is why the declaration became mandatory.
The package in force from 1 January 2026 adds three further paragraphs: 4.2.1.7 commits Contracting Governments to report confirmed cases of fuel with a flashpoint below 60 °C to the IMO; 4.2.1.8 calls for action against non-compliant suppliers; and resolution MSC.550(108) inserts 4.2.1.9, under which oil fuel delivered to and used on board “shall not jeopardize the safety of ships or adversely affect the performance of the machinery or be harmful to personnel”. On the MARPOL side, the flashpoint figure enters the Bunker Delivery Note through resolution MEPC.362(79), in force since 1 May 2024: the value stated if below 70 °C, otherwise a statement that it was measured at or above 70 °C. MARPOL contains no minimum flashpoint threshold, however: that one is SOLAS's alone.
Scope of Application
Ships to which SOLAS II-2/4.2.1.6 applies and which carry oil fuel, including those brought within scope by II-2/1.2.5. MARPOL BDN rules remain distinct and do not by themselves extend the SOLAS duty to every unit receiving fuel.
Procedure / How to Complete It
- Confirm SOLAS II-2 applicability to ship and fuel.
- Check that the BDN states flashpoint determined under a standard acceptable to IMO and applicable to the product, or carries the prescribed declaration.
- Use ISO 2719 A/B as an applicable reference, not the only permitted wording without checking the latest IMO list and product.
- Retain declaration and checks under ship procedure.
Practical Example
Example: at the time of bunkering, the responsible officer verifies that the supplier's declaration is signed, certified and consistent with the Bunker Delivery Note before authorising the start of the fuel transfer, treating the absence of the declaration as a non-conformity to be resolved before proceeding.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Bunkering started without having received the supplier's signed declaration on the flashpoint | Non-compliance with the new SOLAS requirement and risk of fuel with an unverified flashpoint on board | Treat receipt of the declaration as a precondition for starting bunkering, not as a subsequent formality |
| Supplier's declaration confused with the Bunker Delivery Note alone for MARPOL purposes, without verifying the specific flashpoint data | SOLAS safety requirement not actually verified despite complete MARPOL documentation | Separately verify the SOLAS safety requirement (flashpoint) and the MARPOL requirement (fuel quality/environmental compliance) |
What the PSCO Checks
Operational Tips
- Don't confuse the SOLAS flashpoint declaration with the MARPOL Bunker Delivery Note: they are two documents with different regulatory bases and purposes, both now required.
- Always verify the presence of the supplier's declaration before authorising the start of bunkering, not after the fact.
- In the event of a missing or doubtful declaration, raise the non-conformity with the supplier before proceeding, not after completion of the operation.
Preparation checklist
- SOLAS II-2 applicability checked
- Supplier declaration present
- IMO-acceptable standard and product checked
- ISO 2719 not treated as sole absolute option
- BDN and records retained
FAQ
Related Topics
Last substantive revision of this page: 13 August 2026 · page fingerprint 5fc85a4e5fbb