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
From 1 January 2026 SOLAS II-2/4.2.1.6 requires, before bunkering, a declaration signed and certified by the supplier’s representative that the fuel to be supplied complies with section 2.1, identifying the flashpoint test method. For delivered fuel, the BDN must state the value determined under IMO-acceptable standards or state that it was measured at or above 70 °C. Check both contents and timing; they do not necessarily require two separate sheets. MSC.520(106).
Regulatory Reference
SOLAS II-2/4.2.1.6, introduced by MSC.520(106), requires before bunkering a supplier representative’s signed and certified declaration of §2.1 conformity and the test method. The BDN gives the value determined under IMO-acceptable standards or a statement of measurement ≥70 °C. The method must be appropriate to the product.
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”. Specific cases to distinguish include: 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 without an applicable provision and approval for that fuel makes the batch unusable, not merely poor: that is why the declaration became mandatory.
Section 4.2.1.7 commits Contracting Governments to ensure designated authorities notify IMO of confirmed cases (flashpoint) of supplier non-compliance with §2.1, for transmission to Contracting Governments and Member States. Section 4.2.1.8 addresses appropriate action against non-compliant suppliers; MSC.550(108) adds §4.2.1.9 on fuel safety. Under MARPOL MEPC.362(79), from 1 May 2024 the BDN gives the measured value or the ≥70 °C statement; reporting the value is also permitted at or above 70 °C.
The ordinary limit is 60 °C; it is distinct from the 70 °C BDN statement threshold. The 43 °C cases do not exhaust low-flashpoint fuel regimes: check applicable provisions, including the IGF regime where relevant, and ship approval. A “confirmed case” of flashpoint requires a representative sample analysed by an accredited laboratory under acceptable standards (II-2/3.59); suspicion alone is not confirmation. Where doubt arises, activate ship and Company procedures for investigation and handling of the batch. MSC.520(106) · IMO IGF Code.
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
- Check SOLAS content, pre-bunkering timing and BDN information separately; one document may contain information required by both regimes.
- 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: 16 September 2026 · page fingerprint 8ad6de914680