Issues related to class and authority

Statutory requirements

Fuels with a flashpoint below 60oC are not allowed for use in merchant vessels, according to SOLAS (Safety Of Life At Sea) 1974. Methanol has a flashpoint of approx. 12oC and therefore considered as an alternative fuel. As a consequence from the EU directives, concerning up- coming sulphur emission regulations in the SECAs, the interest in fuel oil alternatives has grown considerably. To introduce a low flashpoint fuel on a merchant vessel, a risk assessment approach has to be taken according to SOLAS Ch. II-2 Reg. 17. This is to ensure that the proposed system has an equivalent level of safety, from a fire safety perspective, as a conventional fuel oil arrangement.

Classification society requirements

As for today, Lloyd’s Register (LR) has drafted rules for the use of methanol in marine environments. DNV GL has published tentative rules on the same subject. Although LNG still attracts the biggest attention as a sulphur- free fuel, methanol is proven to be a strong alternative. One of the targets in the SPIRETH project was to develop an additional set of class rules that would involve low flashpoint fuels, other than LNG. During the course of the project, a methanol rule draft has been proposed by LR but is yet to be ratified by the Board of Lloyd’s Register Group. In parallel to the rule development work done by LR, DNV GL has done equivalent efforts. In July 2013 they published tentative rules for low flashpoint fuels, including methanol. (To the authors’ knowledge, no other class societies have approached methanol as an alternative to LNG) In the same period, IMO published the drafted IGF code which now addresses methanol as a low flashpoint, sulphur- free, fuel.

LR and DNV GL have taken slightly different paths for the class approval process. The LR Ship rules dictate that when designing an unconventional arrangement, a formal risk assessment approach shall be taken with MSC/Circ. 1023 as a starting- point. This approach is somewhat time- consuming, with the benefits of a well thought through result and great open- mindedness to unconventional solutions. DNV GL has adopted a more prescriptive model, with no requirements for risk assessment sessions. Ratified rules from both Societies are expected within the next couple of years.

What features are subject for classification society approval? 

All features or systems of a ship that may cause multiple casualties or total loss of ship, if failing, are subject for flag approval. Examples: Escape routes, stability and systems for fire- detection and extinguishing. The regulatory framework is outlined in SOLAS and is published by the International Maritime Organization (IMO). 

If the governing flag state have plan approval capacity, they will review the design documentation according to SOLAS.  Example: Swedish Transport Agency. The most common situation today, however, is that the governing flag state does not have permanent staff engaged in plan approval duties. These flag states are referred to as open international registers. Examples: Liberia and Bahamas. The class society is then delegated the task to issue a statutory approval on the flag state’s behalf.

So what is left for class approval? The remaining systems and features that may endanger passengers/crew or result in property damage, if mal- functioning. Examples: Structures and welding, machinery, electric installations and automation.

Of course, there is a thin line between what is subject for flag state approval and class approval. In some areas the scopes are overlapping. Even if a ship’s system is for flag consideration, per definition, it may well be that the contracted class society has their own rules on top of SOLAS. Similarly, a flag state may have stricter national rules than what is required by SOLAS.