Alternative fuels can support shipping’s decarbonisation, but they also introduce safety, operational and environmental considerations that need to be addressed through a company’s Safety Management System (SMS). The Maritime Technologies Forum (MTF), in collaboration with BIMCO and other leading organisations, are developing a series of guidelines to help companies apply the ISM Code framework, industry guidance and developing regulatory requirements to alternative fuels and their specific characteristics.
The guidance is relevant to companies developing new SMS arrangements, strengthening existing systems, preparing for mixed-fuel operations or building organisational awareness of the safety implications of emerging marine fuels.
Regulatory and industry context
The Maritime Technologies Forum (MTF), with support from BIMCO and other industry stakeholders, has developed the Guidelines for developing and implementing a Safety Management System for alternative fuels to help companies integrate alternative fuels into SMS arrangements. The guidance is based on the structure of Part A of the International Safety Management (ISM) Code and is intended to support safe application of alternative fuels across ship and company operations.
Building on this work, MTF subsequently developed dedicated guidance for companies using or preparing to use ammonia as fuel. The ammonia-specific guidelines consider the additional operational, technical and competence requirements arising from ammonia’s particular characteristics and provide practical recommendations for incorporating them into the SMS.
This complements the IMO’s Interim guidelines for the safety of ships using ammonia as fuel (MSC.1/Circ.1687), which provide a goal-based framework for ship design, equipment, operations, bunkering, toxicity mitigation and crew protection.
Using the SMS to manage alternative fuel risks
Alternative fuels may present elevated risks compared with conventional fossil fuels. The risk profile of each fuel depends on its physical and chemical characteristics, the ship and fuel-system design, the equipment installed, the operating environment and the level of experience available within the company and across the wider industry.
Companies should use a structured risk-management approach within the SMS to identify, assess and control risks associated with alternative fuels. This should include arrangements for design and retrofit stages, bunkering, fuel storage and handling, maintenance, emergency preparedness, training, competence, incident reporting and continuous improvement.
In the early stages of alternative fuel deployment, operational experience may be limited. Companies should therefore ensure their SMS can evolve using lessons learned from risk evaluations, pilot projects, non-conformities, accidents, hazardous occurrences, near misses and experience shared by other operators.
Key SMS considerations for alternative fuels
Companies should assess whether their SMS is sufficiently adaptable to manage ships operating with conventional fuels, alternative fuels or a combination of both. This is particularly important during the transition period, when mixed-fuel operations are likely to be common.
Key areas to review include:
- Fuel-specific risk assessments and operating procedures
- Management of change processes for new fuels, equipment and procedures
- Emergency preparedness for fuel-specific hazards
- Competence, training and familiarisation for shipboard and shore-based personnel
- Safe bunkering, storage, handling and maintenance arrangements
- Reporting and investigation of hazardous occurrences, near misses and accidents
- Arrangements for capturing lessons learned and updating the SMS as experience develops.
Additional considerations for ammonia as fuel
Ammonia is regarded as a potential low- or zero-carbon marine fuel, but it presents significant safety challenges. These include toxicity, corrosiveness, potential formation of hazardous atmospheres, material compatibility issues and the need for robust detection, ventilation, containment and emergency-response arrangements.
Companies using or preparing to use ammonia as fuel should ensure ammonia-specific measures are reflected in their SMS. These measures should be proportionate to the ship design, fuel system, operating profile, crew exposure risks and shore-side support arrangements.
Relevant measures may include enhanced risk assessments, ammonia-specific emergency procedures, safe handling and maintenance procedures, training and familiarisation for relevant personnel, management of change controls and arrangements for mixed-fuel operations.
The ammonia guidelines emphasise a risk-based and adaptable approach, recognising that ship designs, equipment and operational profiles may vary. They also encourage industry-wide reporting and learning as operational experience develops.
Training, competence and familiarisation
The human element is critical to the safe introduction of alternative fuels. Companies should assess, for each role and responsibility, covering both shipboard and shore-based personnel, the competence, training, familiarisation and resources needed for the specific fuels used on board their ships.
Training should cover both routine and non-routine operations, including fuel handling, bunkering, maintenance, monitoring, emergency response, personal protection and ship-shore communication. Shore-based personnel should also understand the operational and emergency implications of the fuels used in the fleet.
Continuous improvement
Because experience with many alternative fuels is still developing, the SMS should be reviewed and updated as new operational data, regulatory requirements, industry guidance and lessons learned become available. Companies should also consider how effective incident reporting and shared learning can help identify emerging risks, improve their own arrangements and contribute to the support safer adoption across the wider industry.