Ship Fuel Safety: Flashpoint Declaration
Before every bunkering operation, the supplier must now certify the fuel's flashpoint in writing: a fire-safety requirement, distinct from the already-familiar environmental compliance of the Bunker Delivery Note.
Operational Explanation
The amendments introduced by resolutions MSC.520(108) and MSC.550(108), in force from 1 January 2026, require every ship taking on fuel to be provided in advance, before bunkering, with a declaration signed and certified by the fuel supplier's representative, attesting the compliance of the flashpoint with SOLAS safety requirements, indicating the test method used.
This is a fire safety requirement (SOLAS Chapter II-2), distinct from the Bunker Delivery Note already familiar in the MARPOL context: the Bunker Delivery Note must now also state the flashpoint according to a recognised standard, or a declaration that the flashpoint has been measured at 70°C or above. The reference test method is ISO 2719:2016, Procedure A (for distillate fuels) or Procedure B (for residual fuels). Administrations are also required to notify the IMO and take action against suppliers in confirmed cases of non-compliant fuel.
Regulatory Reference
SOLAS Chapter II-2, amendments from Resolutions MSC.520(108) 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).
Scope of Application
Every ship taking on fuel for its own use, and every fuel supplier delivering fuel on board.
Procedure / How to Complete It
- Verify, before every bunkering operation, receipt of the supplier's signed and certified declaration on the fuel's flashpoint.
- Check that the Bunker Delivery Note states the flashpoint per the recognised standard, or the appropriate declaration of compliance at 70°C or above.
- Verify that the test method indicated is consistent with ISO 2719:2016 Procedure A (distillates) or B (residuals).
- In the event of a missing or incomplete declaration at the time of bunkering, formally raise the non-conformity with the supplier before proceeding.
- Report to the Company and, if necessary, to the flag Administration any case of fuel found non-compliant with the flashpoint requirement.
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.
Real Cases
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) |
PSC Observations
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.
Checklist
- Supplier's signed and certified declaration on the flashpoint verified before bunkering
- Bunker Delivery Note verified for the presence of the flashpoint data or the declaration of compliance at 70°C+
- Test method indicated verified as consistent with ISO 2719:2016
- Flashpoint non-conformities formally reported to the supplier and, if necessary, to the Company/Administration