The Evolution of ISO 8217 standard from 2005 to 2016 Draft
8th February 2016 09:31 GMT

INTRODUCTION

The draft ISO 8217:2016 standard has recently been released and is circulated for comments from the fuel users of the shipping industry. Voting on changes to the draft standard is open and must be made before April 4, 2016. Table 1 and Table 2 numbers have not been changed but very substantial subtle changes have been made in the text of the standard.

PARA 5 GENERAL REQUIREMENTS

Para 5 is a very important part of the 8217 standard. In fact, this is the only section that provides protection to the fuel buyer outside of requirements to meet the number in Table1 for Distillate fuel and Table 2 for Residual fuels. Bunker fuel users know very well that meeting the numbers in Table 1 and 2 means nothing from the point of view of fuel quality. Almost all of the fuels do meet ISO 8217 specifications listed in Table 1 or 2. What Para 5 does is to provide protection to the fuel user if the fuel, though it meets the requirement of Table 1/Table 2, contains substances, chemical waste, adulteration etc. which cause machinery problems and machinery damage and also affects the health of those dealing with the fuel and adds to additional air pollution.

Some of the fuel related problems which have been documented numerous times are listed below.

  1. Piston rings breakage of main engine
  2. Severe filter choking bringing the ship to a halt and causing blackouts
  3. Severe choking of purifiers
  4. Wear on the rubbing surface (fuel pumps and valves) due to acidic content of the fuel.
  5.  And many others.

Let us now study the changes made from 2010 version (which is practically identical to the 2012 standard except for the H2S test method listed in Table 1/Table2) to the 2016 draft.

Para 5.1 and 5.2 of 2010 standard have been integrated into Para 5.1 of 2016 draft.

Para 5.2 has been worded in a very ingenious way (similar to the wording in Annex B of 8217:2010). This goes on to say that the fuel shall be free of any material at a concentration that causes fuel to be unacceptable for use. It then continues that determining the concentration through chemical analysis is not possible (similar to Para d of Annex B in 8217:2010). “A special study” has to be undertaken to determine this. Who is carrying out this study? Who are the participants? Why no results even after 6 years?

What is questionable is that why, after a gap of 6 years, the same excuse that chemical analysis cannot give clear results? A standard test method for “Determination of Chemical Species in Marine Fuel Oil by Multi-Dimensional GCMS” has been published by ASTM D7845 in 2013. The statement in the Draft 8217:2016 that “Multiple labs cannot detect contaminants with no standardized approach” is no longer true. Why can’t we specify this standard for chemical contaminants? Are we not giving an excuse to some of the unscrupulous suppliers to shirk the responsibility for the quality of the fuel supplied? Under UK law, the “Fitness of Purpose” clause is very important and enforceable. If the fuel supplied, instead of helping the engine run, causes problems and damages the machinery, how will it meet the criteria of “Fitness for Purpose”? It is not enough that the fuel meets the requirements of Table 1/Table 2.

There is also a shocking omission of para 5.5 of ISO 8217:2010 (which was part of para 5.1 of 8217:2005) in the new draft. This para specifically provides protection to the fuel buyer against machinery damage, adverse health effects to ship staff and contribution to overall air pollution.

To sum up, the new para 5 does not protect the fuel buyer from problems and damages caused by the fuel. It also provides enough loopholes for some of the unscrupulous suppliers to evade responsibility. Also, the proposed changes are contrary to the wording of Regulation 18 (Quality clause) of Marpol Annex VI which are in line with the wording in para 5 of ISO 8217:2005 version.

TEST METHODS

6.16 Aluminium plus silicon

In this section, a very interesting addition has been made “The Aluminum + Silicon limits in Table 2 restrict the catalyst fines to levels at which fuel treatment plants onboard (settling tanks, centrifuges and filters) when operated in accordance with the best practice and the manufacturers operating procedures are expected to reduce the catalytic fines to an acceptable level at Engine Inlet.”

What this would mean is that the supplier can supply fuels upto a limit of 60 ppm (for ISO 8217:2010/2012) and 80 ppm (for ISO 8217:2005) for Aluminum + Silicon. With the permitted variation, the 60 ppm limit can go upto 72 ppm and 80 ppm can go upto 96 ppm. The Engine Maker is restricting the catfines to 15 ppm and even less at Engine Inlet.  Class NKK note on Engine Makers Limits which is even lower at 7 ppm. This means that if the supplier supplies at 60 ppm and the Engine Maker insists it has to be 15 ppm, the onboard treatment plant must function with at least 75% efficiency. As we all know, onboard treatment plants are not monitored regularly. The most important onboard treatment plant are the centrifuges. When the ship is new, the catfine removal efficiency can be 80% or more but we have seen, after testing many samples, that after about one year, the efficiency in catfine removal can vary from 20% to 60%. How do we therefore control the quantum of catfines entering the engine?

Let us look at another picture. The supplier has license to supply upto 60 ppm catfines. However, the global average for catfines is only 22 ppm. Why is the supplier asking for 60 ppm? This is just to cover any stray cases where the catfines can exceed 22 ppm and the supplier has enough cushion to still be “within specs”.

What about the fuel user? If the purifier is not running properly or if he is not monitoring the purifier efficiency regularly, he could end up with fuels with catfines in excess of 15 ppm entering the engine. He has no recourse.

Why can’t we change the specification limit to make the catfines limit say 25 ppm? This way, even if the onboard fuel treatment is not very efficient, the amount of catfines entering the engine will not be that high. The onus of protecting the engine should not be passed on to the ship staff and the fuel treatment plant onboard. It should rightly be passed on to the supplier. He is currently able to maintain 22 ppm. Let him accept 25 ppm as the limit. He has all the facilities. It is not fair to ask the shipboard fuel user to fix this problem. By inserting the wording in italics above in the first paragraph, the supplier is off the hook. The onus has been passed on to the poor Engineers on the ship. These Engineers cannot even ask for a purifier efficiency test to be carried out every time they bunker. The shipping companies will not be willing to spend the extra expenditure.

It is no wonder that catfines are the single most important reason for damage to machinery.

THE ABOVE COMMENTS ARE INTENDED TO HELP IMO AND ISO TO PROVIDE A STANDARD THAT WILL BE RESPECTED AND ACCEPTED BY ALL PLAYERS AND NOT BE PERCEIVED AS BIASED IN FAVOR OF ONE GROUP.


Dr. Ram Vis,
8th February 2016 09:31 GMT

Comments on this Blog
Ara Barsamian - Refinery Automation Institute
12th February 2016
Dr. Vis, bravo! I am happy somebody knowledgeable speaks out against shoddy standards work...which are becoming "millstones around the neck" of buyers..
Julie Henderson
27th February 2016
Respectable Refiners will continue to supply fit for use products others may not - supplying low grade cheaper materials
Ara Barsamian - Refinery Automation Institute
27th February 2016
Julie:

It's a question of economic survival, both for refiners, traders, suppliers, etc. If you can't make money to pay your bills, all the specs in the world will not help.

Total's CEO, which I highly respect, stated more closures of EU refineries...I'm sure it will happen elsewhere because there is an excess of refining capacity. When crude drops to $15 to $20/bbl, more will disappear...and we will see unprecedented cut-throat competition among the survivors.

Coming up with unrealistic specs as Dr. Vis mentioned, will just acerbate the situation.

What will happen? Life goes on, and the specs will be ignored...like the IMO desperate effort to justify 0.5% Sulfur specs while billions, yes, capital B, still don't have food or clean water...pathetic...
Sanjeev Gupta
3rd April 2016
I appreciate the efforts of Dr. Vis in enumerating the daft of 2016 standards.

Standards have been revised and pondered time and again with implementation of 2005, 2010, 2012 and now 2016 drafts and guidelines. But among all the guidelines, the potential clauses to shield the buyer's interest kept diminishing.

As rightly coined by Dr. Vis, "Who is carrying out this special study?"

Environment is a responsibility, shared by every nation, but not with throwing piles of legislations and standards, without any lead time to implement and train the people who are at the end of the phase called "implementation".

Setting ever lowering standards for Sulphur content is a boon, but is it controlled properly?
Caroline Clarke - SCM Services Pty Ltd
9th April 2016
salutations,
Thank you for sharing Dr Ram Vis. The details to respectfully acknowledge industry stakeholders attention to particulate matters noteworthy. The topic canvassing thresholds, tolerance and transparency, fit for, transition on operational standards. Suffice to regard assumptions stakeholders inventory capacity equipped to deliver/apply. To regard omissions and inclusions. To primary and secondary perhaps canvass to merit normative fit for food for thought all the best kind regards caroline
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PRODUCT AVAILABLE IN ROTTERDAM/ CI DIP AND PAY IN SELLER EX-SHORE TANK.

Russia D2 50,000-150,000 Metric Tons FOB Rotterdam Port.

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12th September 2017
We Can supply Aviation Kerosene,Jet fuel (JP 54-A1,5), Diesel (Gas Oil) and Fuel Oil D2, D6,ETC in FOB/Rotterdam only, serious buyer should contact or if you have serious buyers my seller is ready to close this deal fast contact us below:now base email us (neftegazagent@yandex.ru)

PRODUCT AVAILABLE IN ROTTERDAM/ CI DIP AND PAY IN SELLER EX-SHORE TANK.

Russia D2 50,000-150,000 Metric Tons FOB Rotterdam Port.

JP54 5000,000 Barrels per Month FOB Rotterdam.

JA1 Jet Fuel 10,000,000 Barrels FOB Rotterdam.

D6 Virgin Fuel Oil 800,000,000 Gallon FOB Rotterdam.

E-mail: neftegazagent@yandex.ru
E: neftegazagent@mail.ru
E: neftegazagent@yahoo.com

Best Regards
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Skype: neftegazagent

Thank You

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