Guidance on training requirements for seafarers working onboard vessels using low-flashpoint fuels issued by Isle of Man

The Isle of Man Ship Registry issued the Technical Advisory Notice TAN 003-24 concerning guidance on training requirements for seafarers working onboard vessels using low-flashpoint fuels other than LNG.

This notice was published on 19 April 2024.

1. Introduction
The transition towards a greener future in the maritime industry from traditional carbon-heavy ‘dirty’ fuels to ‘cleaner’ low-carbon or carbon-neutral fuels is moving forwards at a rapid pace. With many vessels now being designed or retro-fitted to take advantage of these fuels, either running entirely on gas (single fuel) or with engines capable of running on gas and oil fuels (dual-fuel). Due to the rapid pace of this transition, there are no current regulations from IMO covering the training required for seafarers working on board such vessels. This notice serves as interim guidance for training requirements of seafarers working on board Manx ships until training requirements are finalised by the IMO.

2. Types of Alternative Fuel
There are several types of alternative fuels (“IGF fuels”) in various stages of development throughout the industry, in particular, this notice focuses on vessels using the below substances as marine fuel:

• Ammonia
• Biofuels
• Methanol / Ethanol
• Dimethyl Ether (DME)
• Hydrogen
• LNG/LPG

The Isle of Man Ship Registry notes that some vessels are also being designed ‘fully-electric’ i.e. they use batteries as their primary source of power. Such vessels are outside the scope of this notice as it pertains to training requirements, however operators are encouraged to contact the Ship Registry if they have any questions relating to this area.

3. The IGF Code
The International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code) provides an international standard for ships, other than vessels covered by the IGC Code, operating with gas or low-flashpoint liquids as fuel and is currently the only international standard providing a framework for the use of alternate fuels on ships.

The IGF Code applies to ships to which part G of SOLAS Chapter II-1 applies, that is, all ships using low flash-point fuels:

1. for which the building contract is placed on or after 1 January 2017;
2. in the absence of a building contract, the keels of which are laid or which are at a similar stage of construction on or after 1 July 2017; or
3. the delivery of which is on or after 1 January 2021.

With the exception of gas carriers complying with the IGC code, any ship that converts to using low-flashpoint fuels on or after 1 January 2017 shall be treated as a ship using low-flashpoint fuels on the date the conversion commenced.

The IOMSR recognises that many dual-fuel engines, whilst capable of running on low-flashpoint fuel, currently run solely on marine fuel oil and the vessel does not carry any low-flashpoint fuel onboard. For the avoidance of any doubt, the IOM Ship Registry interprets the requirements of SOLAS Chapter II-1 Part G to apply to any vessel actually carrying low-flashpoint fuel (that is not cargo) on board, irrespective of whether it is currently in use or not, and thus, the STCW training requirements detailed below will apply.

In this sense, where a vessel is capable of using fuel subject to the IGF code but is not carrying IGF fuel, then the vessel does not necessarily fall within the scope of the IGF code handling requirements and standard training requirements for the fuel being used, i.e. MDO/HFO, would apply. However, if carrying IGF fuel (in use or not) the training requirements specific to the IGF fuel type will be necessary.

The code is still under active development and as such only focuses upon the use of LNG as fuel. Other alternate fuels, such as LPG, ammonia or hydrogen, fit within the framework of the code but it should be recognised that the rules pertaining to their use and safe handling are still under development. As such, seafarers trained in the requirements of the IGF code should not be deemed “fully competent” with respect to the use of such fuels on board ships until the guidelines are fully developed.

4. STCW Requirements
There are two levels of training available for seafarers working on board vessels using fuels subject to the IGF code:

• Certificate in Basic Training for service on ships subject to the IGF Code
• Certificate in Advanced Training for service on ships subject to the IGF Code

Both the Basic and Advanced qualifications are subject to the STCW requirement for refresher training. This means that seafarers holding these qualifications shall, at intervals not exceeding 5 years, undertake refresher training or be required to provide evidence of having achieved the required standard of competence within the previous 5 years.

A Certificate of Proficiency (CoP) is issued to seafarers who have completed the necessary training and hold the prerequisite experience to obtain the CoP. Seafarers on board a ship subject to the IGF code must hold a CoP relevant to their job role and responsibilities.

Seafarers responsible for designated safety duties associated with the care of, use of or emergency response to, the fuel on board ships subject to the IGF code must hold a basic CoP. This requires the seafarer to complete the basic training course for the IGF code; there are no specific sea-going experience requirements for the basic CoP.

Masters, engineering officers and all personnel with immediate responsibility for the care and use of fuels and fuel systems on ships subject to the IGF Code must hold an advanced CoP.

For more information, please see the document below (available only to subscribers):

Guidance on Training Requirements for Seafarers Working Onboard Vessels Using Low-flashpoint Fuels Other Than LNG