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REPUBLIC OF Marine Notice

THE MARSHALL ISLANDS


No. 2-011-51
MARITIME ADMINISTRATOR
Rev. Jul/2022

TO: ALL SHIPOWNERS, OPERATORS, MASTERS AND OFFICERS OF


MERCHANT SHIPS, AND RECOGNIZED ORGANIZATIONS

SUBJECT: International Code of Safety for Ships Using Gases or Other Low-Flashpoint
Fuels (IGF Code)

References: (a) SOLAS, International Convention for the Safety of Life at Sea,
Consolidated Edition 2020
(b) IGF Code, International Code of Safety for Ships Using Gases or Other
Low-Flashpoint Fuels, as amended
(c) STCW Convention, International Convention on Standards of Training,
Certification, and Watchkeeping for Seafarers, 2011 Edition, as amended
(d) STCW Code, Seafarers’ Training, Certification, and Watchkeeping Code,
2011 Edition, as amended
(e) IMO Resolution MSC.396(95), Amendments to the International
Convention on Standards of Training, Certification and Watchkeeping for
Seafarers (STCW), 1978, as amended, adopted 11 June 2015
(f) IMO Resolution MSC.397(95), Amendments to Part A of the Seafarers'
Training, Certification and Watchkeeping (STCW) Code, adopted 11 June
2015
(g) IMO Resolution MSC.475(102), Amendments to the International Code of
Safety for Ships using Gases or other Low-Flashpoint Fuels (IGF Code),
adopted 11 November 2020
(h) RMI (MI-118), Requirements for Seafarer Certification
(i) RMI Marine Notice 7-038-2, Minimum Safe Manning Requirements for
Vessels
(j) RMI Marine Notice 7-041-1, Entering Enclosed Spaces Aboard Ships –
Safety Precautions

PURPOSE

This Notice details the Republic of the Marshall Islands (RMI) Maritime Administrator’s (the
“Administrator”) requirements for operating ships using gases or other low-flashpoint fuels.

This update supersedes Rev. Mar/2017. Section 2.2 has been inserted to reflect a new IGF Code
regulation requiring that fuel preparation rooms with potential ignition sources must have a fixed
fire-extinguishing system complying with SOLAS regulation II-22/10.4.1.1.
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Inquiries concerning the subject of this Notice should be directed to the Republic of the Marshall Islands Maritime Administrator, c/o
Marshall Islands Maritime and Corporate Administrators, Inc., 11495 Commerce Park Drive, Reston, VA 20191-1506 USA. The most
current version of all Republic of the Marshall Islands Marine Notices may be found at www.register-iri.com.
MI-01, Rev. Apr/2016
BACKGROUND

The IGF Code entered into force on 1 January 2017. It establishes goals, functional requirements,
and regulations for the design and operation of ships using gases or other low-flashpoint fuels.
IMO Resolution MSC.392(95) amended the International Convention for the Safety of Life at Sea
(SOLAS) Chapters II-1, II-2, and the Appendix, thereby making the IGF Code mandatory under
SOLAS.

APPLICABILITY

Unless expressly provided otherwise, this Notice applies to ships to which Part G of SOLAS
Chapter II-1 applies; specifically those using low-flashpoint fuels:

• for which the building contract is placed on or after 1 January 2017;

• 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

• the delivery of which is on or after 1 January 2021.

Except for gas carriers:

• a ship, irrespective of the construction date, including one constructed before


1 January 2009, which converts to using low-flashpoint fuels on or after 1 January 2017
will be treated as a ship using low-flashpoint fuels on the date on which such conversion
commenced; and

• a ship using low-flashpoint fuels irrespective of the construction date, including one
constructed before 1 January 2009, which, on or after 1 January 2017, undertakes to use
low-flashpoint fuels different from those which it was originally approved to use before
1 January 2017 will be treated as a ship using low-flashpoint fuels on the date on which
such undertaking commenced.

In accordance with SOLAS Regulation II-1/56.4, the IGF Code does not apply to gas carriers, as
defined in SOLAS regulation VII/11.2:1

• using their cargoes as fuel and complying with requirements of the International Code for
the Construction and Equipment of Ships Carrying Liquid Gases in Bulk (IGC Code); or

• using other low-flashpoint gaseous fuels provided that the fuel storage and distribution
system design and arrangements for these gaseous fuels comply with the requirements of
the IGC Code for gas as cargo.

Bunker vessels supplying liquefied gas fuels are gas carriers and subject to the IGC Code.

1. Gas carrier means a cargo ship constructed or adapted and used for the carriage in bulk of any liquefied gas or
other product listed in chapter 19 of the International Gas Carrier Code.

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REQUIREMENTS

1.0 Design

1.1 Ships to which this Notice applies must be designed in accordance with the
applicable requirements of the IGF Code.

1.2 The design must be approved by a Recognized Organization.

2.0 Construction

2.1 Ships to which this Notice applies must be constructed in accordance with the
applicable IGF Code requirements.

2.2 For ships constructed on or after 01 January 2024, fuel preparation rooms which
contain pumps, compressors, or other potential ignition sources must have a fixed
fire-extinguishing system that complies with SOLAS II-2/10.4.1.1, taking into
account the necessary concentrations/application rate required for extinguishing
gas fires. (See IMO Resolution MSC.475(102)).

2.3 Construction must be approved and supervised by a Recognized Organization.

2.4 On completion of construction, the Recognized Organization must issue either a


Safety Construction Certificate for Passenger Ships or a Safety Construction
Certificate for Cargo Ships, indicating that the ship complies with:

“part G of chapter II-1 of the Convention using Liquified


Natural Gas “LNG” as fuel.”2

3.0 Operating Requirements

3.1 Every ship covered by this Notice must carry a copy of the IGF Code on board (see
§18.2.1 of the IGF Code). Electronic versions are acceptable.

3.2 Maintenance procedures and information for all gas-related installations must be
available on board and must include all areas and systems that may be subject to
gas leaks and their associated hazards. See also §4.0 of this Notice.

3.3 Each ship must be provided with a detailed fuel handling manual, to ensure that
trained personnel can safely operate the fuel bunkering, storage, and transfer
systems. The contents of this fuel handling manual are more fully described in §5.4
of this Notice.

2. Other low flashpoint fuels may be substituted when approved as indicated in the IGF Code.

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3.4 Each ship must be provided with emergency procedures, covering all aspects of the
fuel handling systems. In addition, emergency procedures must be in place to
provide for the emergency shutdown (ESD) of any equipment that has the potential
to become hazardous under certain abnormal conditions.

4.0 Maintenance Requirements

4.1 All maintenance and repair procedures must include considerations for tank
locations and adjacent spaces, considering the safe operation and other hazards that
may be relevant to the ship.

4.2 An inspection or survey plan for the liquefied gas fuel containment system must be
developed and approved by the Administrator, or by the Recognized Organization
acting on its behalf. All in-service survey, maintenance, and testing of the fuel
containment system must be carried out in accordance with that plan. The
inspection or survey plan must:

.1 identify aspects to be examined or validated (or both) during surveys


throughout the life of the liquefied gas fuel containment system;

.2 also identify any necessary in-service survey, maintenance, and testing that
was assumed when selecting liquefied gas fuel containment system design
parameters.

4.3 The procedures and information must include maintenance of installed electrical
equipment in explosion-hazard spaces and must be performed in accordance with a
recognized standard. Refer to IEC 60079 17:2007 Explosive atmospheres – part
17: Electrical installations inspection and maintenance.

5.0 Bunkering Operations

5.1 Before any bunkering operation commences, the Master of the receiving ship or
their designated representative, and the representative of the bunkering source
(Persons in Charge (PIC)) must:

.1 agree in writing to the transfer procedure, including cooling down and (if
necessary) gassing up, the maximum transfer rate at all stages, and volume to
be transferred;

.2 agree in writing the actions to be taken in an emergency; and

.3 complete and sign the bunkering safety checklist3.

3. The International Organization for Standards (ISO) has issued ISO Standard 20519:2021, Ships and marine
technology – Specification for bunkering of gas fueled ships, that includes a complete pro forma bunkering safety
checklist (ISO 20519, Annex A).

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5.2 In accordance with the IGF Code, §6.8.1, the storage tanks for liquefied gas must
not be filled to more than a volume equivalent to 98% full at the reference
temperature during the bunkering operations.

5.3 On completing bunkering operations, the ship’s PIC must receive and sign a Bunker
Delivery Note for the fuel delivered. It must contain at least the information
specified in the Appendix to this Notice and it must be completed and signed by
the bunkering source’s PIC.

5.4 The fuel handling manual required by §3.3 of this Notice must be part of the
vessel’s Safety Management System (SMS)4 and must include, but not be limited
to:

.1 overall operation of the ship from dry-dock to dry-dock, including procedures


for system cool down and warm up, bunker loading and, where appropriate,
discharging, sampling, inerting, and gas freeing;

.2 bunker temperature and pressure control, alarm, and safety systems;

.3 system limitations, cool down rates, and maximum fuel storage tank
temperatures prior to bunkering, including minimum fuel temperatures,
maximum tank pressures, transfer rates, filling limits, and sloshing
limitations;

.4 operation of inert gas systems;

.5 firefighting and emergency procedures, including the operation and


maintenance of firefighting systems, and the use of extinguishing agents;

.6 specific fuel properties and special equipment needed for the safe handling of
the particular fuel;

.7 fixed and portable gas detection operation and maintenance of equipment;

.8 emergency shutdown and emergency release systems, where fitted;

.9 a pro forma bunkering safety checklist, a copy of which is to be reviewed,


completed, and signed during each bunkering operation; and

.10 a description of the procedural actions to be taken in an emergency situation,


such as leakage, fire or potential fuel stratification resulting in rollover.

4. This is a safety requirement of the Administrator to ensure that the fuel handling manual is maintained and updated
throughout the life of the ship.

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5.5 Documentation of successful verification must be indicated by the mutually agreed
and executed bunkering safety checklist signed by both PICs.

5.6 PICs must have direct and immediate communication with all personnel involved
in the bunkering operation, and this communication must be maintained between
both PICs at all times during the bunkering operations.

5.7 Communication devices used in bunkering must comply with recognized standards
for these devices acceptable to the Administrator. The ship shore link (SSL) or
equivalent means to a bunkering source provided for automatic ESD
communications, must be compatible with the receiving ship and the delivering
facility ESD system.

5.8 Hoses, transfer arms, piping, and fittings provided by the delivering facility used
for bunkering must be electrically continuous, suitably insulated, and must provide
a level of safety compliance with recognized standards5.

5.9 Warning signs must be posted at the access points to the bunkering area listing fire
safety precautions during fuel transfer.

5.10 During the transfer operations, personnel in the bunkering manifold area must be
limited to essential staff only. All staff engaged in duties or working in the vicinity
of the operations must wear appropriate personal protective equipment (PPE). A
failure to maintain the required conditions for transfer is cause to stop operations,
and transfer must not be resumed until all required conditions are met.

6.0 Enclosed Space Entry

6.1 Under normal operational circumstances, personnel must not enter fuel tanks, fuel
storage hold spaces, void spaces, tank connection spaces, or other enclosed spaces
where gas or flammable vapors may accumulate. Personnel may enter these
enclosed spaces only if the gas content of the atmosphere is determined by fixed or
portable equipment to ensure enough oxygen and the absence of an explosive
atmosphere.

6.2 Personnel entering any space designated as a hazardous area must not introduce
any potential ignition source into the space unless it has been certified gas-free and
maintained in that condition. See RMI Marine Notice 7-041-1 for additional details.

5. Additionally, ISO Standard 20519 recommends that an insulation flange be installed between the bunker manifold
and the supply source to electrically isolate the vessel. (See ISO 20519, Paragraph 5.5.6.)

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7.0 Inerting and Purging of Fuel Systems

7.1 The primary objective in inerting and purging of fuel systems is to prevent the
formation of a combustible atmosphere in, near, or around fuel system piping,
tanks, equipment, and adjacent spaces.

7.2 Procedures for inerting and purging fuel systems must ensure that air is not
introduced into piping or a tank containing gas atmospheres, and that gas is not
introduced into air contained in enclosures or spaces adjacent to fuel systems.

8.0 Hot Work on or near Fuel Systems

No hot work may be undertaken in the vicinity of fuel tanks, fuel piping, and insulation
systems that may be flammable, contaminated with hydrocarbons, or that may give off
toxic fumes as a product of combustion, until the area has been secured and proven safe
for hot work and all approvals have been obtained.

9.0 Training

9.1 Vessel owners and operators must ensure that seafarers on board ships using gases
or other low-flashpoint fuels to which the IGF Code applies, are adequately
qualified, trained, and experienced. The seafarers must have completed training to
attain the abilities that are appropriate to the capacity to be filled and duties and
responsibilities to be taken up, taking into account the provisions given in the
STCW Convention and Code, as amended by IMO Resolutions MSC.396(95)6 and
MSC.397(95)7 respectively.

9.2 RMI Marine Notice 7-038-2, Minimum Safe Manning Requirements for Vessels,
§2.0, contains the qualifications, special training, and certification required as part
of minimum safe manning. Also see RMI (MI-118). Requirements for Seafarer
Certification, §5.25.

6. IMO Resolution MSC.396(95) amended the STCW Convention by adding new regulation V/3 which sets
mandatory minimum requirements for the training and qualifications of masters, officers, ratings, and other
personnel on ships subject to the IGF Code.
7. IMO Resolution MSC.397(95) establishes in Chapter V, new Section A-V/3, the minimum standards of
competence for seafarers serving on ships subject to the IGF Code.

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APPENDIX

LNG-BUNKER DELIVERY NOTE*


LNG AS FUEL FOR

SHIP NAME: _______________________________ IMO No. ______________________

Date of Delivery: ___________________________

1. LNG – Properties

Methane Number ** -
Lower calorific (heating) value MJ/kg
Higher calorific (heating) value MJ/kg
Wobbe Indices Ws / Wi MJ/m3
Density kg/m3
Pressure MPa (abs)
LNG temperature delivered °C
LNG temperature in storage tank(s) °C
Pressure in storage tank(s) MPa (abs)

2. LNG – Composition

Methane, CH4 % (kg/kg)


Ethane, C2H6 % (kg/kg)
Propane, C3H8 % (kg/kg)
Isobutane, i C4H10 % (kg/kg)
N-Butane, n C4H10 % (kg/kg)
Pentane, C5H12 % (kg/kg)
Hexane, C6H14 % (kg/kg)
Heptane, C7H16 % (kg/kg)
Nitrogen, N2 % (kg/kg)
Sulphur, S % (kg/kg)
Negligible<5ppm hydrogen sulphide, hydrogen, ammonia, chlorine, fluorine, water

3. Net Total delivered: _______________t, __________________MJ ________________m3

Net Liquid delivery: _______________GJ

4. Signature(s):
Supplier Company Name, contact details: _________________________________

Signature: _______________________ Place/Port _______________ Date: ______________

Receiver: _______________________

* The LNG properties and composition allow the operator to act in accordance with the known properties
of the gas and any operational limitations linked to that.
** Preferably above 70 and referring to the used methane number calculation method in DIN EN 16726.
This does not necessarily reflect the methane number that goes into the engine.

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