GUIDELINES TO DEVELOPAND IMPLEMENT A
SAFETY MANAGEMENT SYSTEM
FOR ALTERNATIVE FUELSON BOARD SHIPSGUIDELINES TO DEVELOP AND IMPLEMENT A SAFETY MANAGEMENT SYSTEM FOR ALTERNATIVE FUELS ON BOARD SHIPS – MARCH 2024

Abbreviations and Definitions
Abbreviation

Definition

BIMCO

The Baltic and International Maritime Council

DP

Designated Person

ICS

International Chamber of Shipping

IGC Code

The International Code for the Construction and Equipment of Ships Carrying
Liquefied Gases in Bulk

IGF Code

The International Code of Safety for Ship Using Gases or Other Low-flashpoint Fuels

IMO

International Maritime Organization

INTERTANKOInternational Association of Independent Tanker Owners

ISM CodeInternational Safety Management CodeISOInternational Organization for Standardization

LNG

Liquefied Natural Gas

LPG

Liquefied Petroleum Gas

MEPC

IMO’s Marine Environment Protection Committee

MLC

The Maritime Labour Convention, 2006

MOC

Management of Change

MSC

Maritime Safety Committee

MTF

Maritime Technologies ForumOCIMF

Oil Companies International Marine ForumOEM

Original Equipment Manufacturer

PMS

Planned Maintenance System

SEP

Safety and Environmental Protection Policy

SGMF

The Society for Gas as a Marine Fuel

SIGTTOThe Society of International Gas Tanker and Terminal Operators

SMS

Safety Management System

STCW CodeThe International Convention on Standards of Training, Certification andWatchkeeping for Seafarers,1978

2 Maritime Technologies ForumGUIDELINES TO DEVELOP AND IMPLEMENT A SAFETY MANAGEMENT SYSTEM FOR ALTERNATIVE FUELS ON BOARD SHIPS – MARCH 2024

Executive Summary
The Maritime Technologies Forum (MTF) is a group of flag States and classification societies which aims
to bridge the gap between technological progress and regulatory process. MTF’s relevant recent study
identified three potential gaps within the implementation of The international safety management (ISM)
code in relation to the application of alternative fuels on board ships. Consequently, MTF took an initiative
to develop guidelines for use by industry as a first step to close previously identified gaps to contributeaccelerating the maritime industry’s safe decarbonisation.
In these guidelines, MTF members followed a method to assess these gaps by reviewing ISM Code’s
Part A implementation for each section, and identifying areas that may be relevant to alternativefuel implementation on board. Industry stakeholders were consulted during the development of theseguidelines to strengthen the document with their different sector experiences. The list of these industry
stakeholders can be found at the end of this document.
Proposed guidelines can be used to develop new or strengthen existing SMS.
Based on MTF’s review, recommended actions for each section mirroring ISM Code’s Part A can befound within the main body of this document. Companies can use this guideline to develop new SMS
and/or strengthen their existing SMS for alternative fuels on board their fleet. MTF recommends thatthese guidelines may be used in addition to other similar existing and/or upcoming guidelines (of whichsome are already referenced within this document) to ensure a safe application of alternative fuels on
board ships.
Experience from operating with alternative fuels will initially be limited.
MTF recognises that the prospective alternative fuels considered in the maritime industry possess elevatedoperational and environmental risks relative to fossil fuels. The inherent risks of a specific alternative fuelare a function of its characteristics, while additional risks can emerge with the interactions of the fuelwith the operational environment. It should be recognised that the lack of data from the operational
experience of equipment operating with alternative fuels will be a gap that will exist in the initial stagesof deployment of alternative fuels.
SMS should learn from hazardous occurrences and accidents with alternative fuels.
The application of a structured risk management within the SMS would be beneficial to strengthen thesystem in managing anticipated risks including risks from the deployment of alternative fuels. The strengthof the company’s SMS should be in the ability to proactively identify improvements in the SMS throughlearning from non-conformities, accidents, and hazardous occurrences (including near misses) related toalternative fuels and facilitate the closing of the gaps. Furthermore, and until operational experience isgained within each organisation, the SMS can be improved based on learnings from additional sourcesof information, including risk evaluations from the design or retrofit stage, and learnings from othercompanies or pilots.
SMS should be versatile to accommodate mixed fuel operations.
In the initial stages, with the fuel-mix on board still including fossil fuels along with alternative fuels, the SMS
should be versatile enough to meet the fuel scenarios as alternative fuels are progressively scaled andeventually becoming mainstream.
Training and familiarisation are critical to ensure safe operations with alternative fuels.
The safe operations with alternative fuels will require an assessment of the competency, training,familiarisation and resources relevant to the specific alternative fuels. The human element in theoperations associated with the handling, storage and utilisation of alternative fuels is critical, andshould be considered to ensure safe operations.

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Background and Objective
MTF has been established to provide technical and regulatory expertise for the maritime industry. MTF’srole is to publish research based on its members’ expertise and offer unbiased advice to the maritime
industry. The current research focuses on the common challenges that are faced by the maritime industry
such as decarbonisation, alternative fuels and increased levels of automation therefore allowing safe
adoption of new technologies. MTF’s work can be found on our website:www.maritimetechnologiesforum.com.
One relevant recent study identified potential gaps within the implementation of three existing
Conventions/Codes: The international safety management code [Ref 1], The international convention on
standards of training, Certification and Watchkeeping for Seafarers (STCW),1978 [Ref 2] and the maritime
labour convention (MLC), 2006 [Ref 3]; and made suitable recommendations to close these gaps for
future safe use of alternative fuels on board ships. This work on “Operational Management to Accelerate
Safe Maritime Decarbonisation” can be downloaded from the MTF website. After this review, MTF focusedon three gaps from ISM Code’s implementation, and these are:• “Uncertainty related to Safety Management System requirements development and implementation”;• “Uncertainty related to emergency procedure development”; and• “Uncertainty related to maintenance measures”
MTF believed that the development of a guidance document which can be produced by the industry
may help close these gaps. Therefore, MTF members developed these guidelines document toaccelerate the maritime industry’s safe decarbonisation.
In these guidelines, MTF members followed a meticulous approach to assess these gaps by undertaking areview of ISM Code’s Part A implementation for each section, and identifying areas that may be relevant
to alternative fuel implementation onboard. MTF members believe that this approach will help therelevant stakeholders to understand the guidelines easily; and use it within their organisations.
A number of industry stakeholders representing different maritime sectors contributed towards thedevelopment of these guidelines. Their contributions were in the form of workshop discussions anddocument reviews. MTF members believe that their point of views representing different sectors
strengthens these guidelines. MTF is grateful for their contribution and the full list of these industry
stakeholders can be found at the end of this document.
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Introduction to the Guidelines
These guidelines are developed following a review of each section of the ISM Code’s Part A. The section
numbers within these guidelines therefore mirrors the same layout to help the reader. The structure ofthese guidelines can be summarised as follows:
1.

General2.

Safety and Environmental Protection Policy

3.

Company Responsibilities and Authority

4.

Designated Person(s)5.

Master’s Responsibility and Authority

6.

Resources and Personnel

7.

Shipboard Operations

8.

Emergency Preparedness

9.

Reports and Analysis of Non-conformities, Accidents and Hazardous Occurrences

10. Maintenance of the Ship and Equipment
11. Documentation
12. Company Verification, Review and Evaluation
Each section provides assessments and recommendations into SMS implementation when considering
alternative fuels on board ships. The reader should appreciate that some sections provide more detailed
content than others (high level content) due to the relevance of alternative fuel application on board
ships and the size of gap that exists within its implementation via SMS.
While some content within these guidelines may be considered generic and business as usual, MTF
believes that these should still be highlighted and interpreted with a focus on alternative fuels on
board ships.
The format change in the document between Section 1 to 12 is intentional to provide the reader witha clear difference between the guidelines and the document.

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1. General
In an operational environment, it is difficult to achieve a process devoid of risks, especially when dealing
with operations that may have inherent elevated risks due to several uncertainties.
The consideration of prospective alternative fuels in the maritime industry involves addressing safety andenvironmental risks that differ from those associated with fossil fuels, and in general, can be considered
to be more severe due to uncertainties. These risks may be perceived and mitigated when operational
procedures and contingencies are planned, but there may be some adverse outcomes as the systems
become functional on ships. The lack of operational data regarding systems operating with alternative
fuels creates an initial gap in understanding and experience.
The deployment of alternative fuels creates variability in the equipment and operational aspects:• Equipment – The equipment associated with alternative fuels in some cases will bring variability
as they will be novel technologies, and will be tested to go through iterations of improvements.
• Operational – The variability brought in by the alternative fuels to the operational environment iscertain, but the extent and intensity will be dependent on the characteristics of the alternative fuel.
The practical and pragmatic approach of managing risk in an operational environment can be achieved
through risk management i.e. proactive risk assessment, risk mitigation and continual improvement of theoperational processes. The measures that would be beneficial for safe operations with alternative fuels
could include:• Identification of potential safety and environmental risks associated with the use of alternative fuels.
• Development of operational procedures for operations involving alternative fuels based on assessmentof known and anticipated risks.
• Development of contingency plans to deal with unwanted outcomes of operations.
• Proactive risk assessment and appropriate control measures to mitigate the assessed risks prior tooperations.
• Diligent reporting of non-conformities, accidents, and hazardous occurrences (including near-misses)
noted by personnel in the operational procedures.
• Assessment of reported gaps in operational procedures and incorporation of the outcomes in theoperational procedures and contingency plans, as appropriate.
One key objective of the ISM Code [Ref 1] is that all identified risks shall be assessed and mitigated with
control measures put in place. The ISM Code is not applicable at a vessel’s design stage, however, risk
assessment/analysis shall be conducted, including the vessel’s design/retrofit phase. Although design
measures take precedence over operational and procedural measures, the risk and control measures
identified during this phase, should continue to be implemented into its operational phase and it may
be necessary to implement such measures in the SMS.
These assessments and analysis carried out in the design/retrofit phase will accordingly contain valuable
information and should follow the vessel through its lifecycle. These should be made available on board
the ship upon transfer to the operational phase and whenever the ship changes ownership or company.
Based on the review of risks already identified, development of procedures can be started, followedby considering any additional operational risks not addressed at design/retrofit stage. New technology
requires new/changed set of operational criteria as well as changes to mindset and management thereof.
The strength of the company’s SMS shall be in the ability to continuously improve the operational processes
by proactively identifying any gaps through learning from non-conformities, accidents, and hazardous
occurrences (including near-misses). The agility in amending the processes and maintaining a strong safety
culture throughout the organisation would show the strength of the SMS in preventing the recurrence of
unintended outcomes. Until operational experience is gained within each organisation, the SMS can also
consider learnings from additional sources of information, including risk evaluations from the design or
retrofit stage, learnings from other companies or pilots.

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The deployment of alternative fuels is expected on newbuilds as well as existing assets throughsuitable retrofits. The initial stages, in both cases may involve a fuel-mix that may still include fossil fuels
alongside alternative fuels, while the latter is progressively scaled and becoming mainstream. This
understanding is important for the industry in developing and updating the SMS that is responsive toadapt to changes rapidly at all levels of management. The electronic form of document control of
the SMS has been widely accepted and implemented but will be a necessity to proactively manage
the changes that will be required in a company with one or more vessels operating on alternative
fuels.
The International Code of Safety for Ship Using Gases or Other Low-flashpoint Fuels (IGF Code) [Ref 4]in being the guiding standard for alternative fuels provides, the regulation to ensure that operational
procedures for loading, storage, operation, maintenance, and inspection of low-flashpoint fuelsminimise the risk to the ship, personnel and the environment. The IGF Code in its current form specifies
requirements primarily for natural gas fuel.
The International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk
(IGC Code) [Ref 5] primarily intended to provide regulations for ships carrying gas as cargo, also
outlines the rules for using liquefied gas cargo as fuel. The current version of the code applies theseregulations mainly to liquefied natural gas (LNG) and other alternative fuels that are non-toxic andoffer the same level of safety as natural gas.
While methyl/ethyl alcohol is not yet included in the IGF Code, MSC.1/Circ.1621 - Interim guidelines forthe safety of ships using methyl/ethyl alcohol as fuel [Ref 6] and MSC.1/Circ.1666 - Interim guidelines
for the Safety of Ships using LPG fuels [Ref 7] provides the requirements for facilitating the deploymentof methyl/ethyl alcohol and LPG as fuel.
For alternative fuels, other than natural gas, it is necessary to prove compliance with the requirementsof the IGF Code through a separate design approval process outlined in the IMO guideline MSC.1/
Circular.1455 - Guidelines for the Approval of Alternatives and Equivalents [Ref 8]. The approval
process is predicated on demonstrating that the alternative design has operational and procedural
measures that are equivalent in reducing the risk to the levels of the design being substituted.
These measures are required and expected to be included within the SMS as part of the approval
process and can form the base for further development of procedures as new information becomes
available in operation.
As present, the STCW training requirement is not sufficiently covering gases and all low-flashpoint
fuels. As an interim measure the crew may undergo IGF Code training as per the STCW requirements(section V/3) supplemented by fuel specific training.

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2. Safety and Environmental Protection Policy
The Safety and Environmental Protection (SEP) policy embodies the objectives of the ISM Code and isseen as the reflection of the company’s commitment to safety at sea and environmental protection fromthe highest level of management.
The SEP policy sets the tone for the safety and environmental protection culture in the organisation. In
ensuring that the SMS is fit for purpose for the individual company, the SEP policy will need to assimilate
and reflect the commitment to manage the elevated operational risk environment that will be brought
about by alternative fuels.
It is recommended that as a minimum, the SEP policy should include an additional statement whichreflects on the aspects and impacts of the alternative fuels which are considered in mitigating theadverse effects on the safety of life and environment. This will strengthen the company’s commitment
towards continued operational safety.
Recommended actions that may be considered relevant to section 2 of the ISM Code are listed below:
No.

Recommended Actions

1.

The SEP policy should include aspects and impacts of using alternative fuels to ensure
continued operational safety.

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3. Company Responsibilities and Authority
The ISM Code requires that companies develop, implement and maintain an SMS that includes thefunctional requirements listed in section 1.4 of the ISM Code. The company’s shore based senior
management’s involvement in the development, implementation, and maintenance of the SMS isparamount. Given the potentially increased operational risk, senior management has a crucial role toplay in the safe deployment of alternative fuels in the fleet.
The company has the overarching responsibility to ensure that processes and procedures within thesystem are fit for purpose in covering the range of ships and their operations. While maintaining andimplementing the existing SMS, the company should develop appropriate procedures in anticipation of
deployment of alternative fuels. A company should look into the wide-ranging risk potential to the safetyof ship, the crew and the environment by actively engaging in the monitoring and updating of safety
protocols, staying abreast of industry developments and fostering a culture of continuous improvement.
The SMS of the company should be robust to ensure that the processes and procedures are streamlined
to ensure the safe operation of all vessels’ fuel scenarios in the company fleet.
The company should ensure that the SMS has a description of roles and a clear allocation of their
responsibilities to avoid ambiguity in process execution, accountability, authority levels, and interrelations
among personnel.
In deploying alternative fuels to their fleet, the company’s senior management should understand thatmanaging the elevated operational risks through competence, training and awareness of personnel, andvetted processes is essential.
The company should reassess applicable existing requirements (which may not be apparent at firstglance) with the application of alternative fuels. In this particular case, MSC-MEPC.7/Circular.8 [Ref 9]
which provides basic principles for companies in developing and maintaining the SMS to the requirements
outlined in the ISM Code, may be revisited.
Recommended actions that need to be taken by the company to ensure the adequacy of the SMS(under section 3 of the ISM Code) in general and with a focus on alternative fuels are listed below:
No.

Recommended Actions

2.

A fit for purpose SMS should be developed in addressing the elevated operational risk ofalternative fuels.

3.

Adequate resources, which may be more or different with alternative fuels application, should
be provided to ensure safe operations and to execute contingency plans. This may also
include shore-based resources.

4.

The SMS should be reviewed and evaluated in accordance with the procedures established forprocesses involving alternative fuels.

5.

Procedures should be developed to analyse reports of non-conformities, observations,accidents and hazardous occurrences (including near-misses) in operation with alternative
fuels, and implement corrective and preventive actions.

6.

Procedures should be developed for carrying out internal audits ensuring that the audit processcaptures the processes involving alternative fuels adequately.

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4. Designated Person(s)The Designated Person (DP) plays a pivotal role in the facilitation of the development, implementation,
maintenance, and continual improvement of a company’s SMS. Establishing a safety culture throughSMS will be critical in minimising the period of increased operational risk with alternative fuels being novel
technologies with a lack of operational data.
To fulfil the expected outcome from the role of DP, the individual taking on this role should meet certain
suitability criteria in relation to qualification, training and experience. The company should assess thesuitability criteria within the operational context of the company. MSC-MEPC.7/Circ.6 [Ref 10] provides
guidance to industry on the suitability criteria in the appointment of DP under the provision of the ISM
Code. Some of these are summarised below in light of application of alternative fuels on board ships:• Qualifications – It is recommended that the DP meet the minimum criteria to have the ability toeffectively verify and monitor the implementation of the SMS with refreshed focus on alternative fuels
being deployed in their fleet.
• Training – It is recommended that the DP have undergone training relating to the elements of the SMS,
and additionally in aspects that the company finds relevant during the assessment of the alternative
fuels. The training requirements for the DP should be periodicaly assessed considering learnings fromnew experiences with the application of alternative fuels on board their fleet.
• Experience – The experience of the person in the role of DP cannot be understated and with theapplication of alternative fuels, this will be even more significant. This experience when augmented
with the understanding of the anticipated changes in vessel operations, safety and environmental risks
as well as consideration of human element will be the competence that will help the DP to facilitate
the safe transition of the fleet to alternative fuels.
It is recommended that the DP should have the understanding of the risks associated with operations
involving alternative fuels. This may be achieved through practical experience and training as identified
by the company.
Recommended actions that may be considered relevant to section 4 of the ISM Code are listed below:
No.

Recommended Actions

7.

The SMS should establish suitability criteria for the role of DP giving due consideration to
the qualifications, training and experience within the assessed operational context withalternative fuels.

8.

Clear lines of communication to the DP for onboard personnel, and from the DP to the highest
level of management should be developed.

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5. Master’s Responsibility and Authority
The ISM Code clearly sets out the overriding authority and responsibility of the ship’s Master. In addition,
the Master has the responsibility for promoting the safety culture on board; and implementing the policies
and procedures within the company.
STCW Code section B-V/3 defines the term “person with immediate responsibility” as a person being
in a decision-making capacity for handling of fuel addressed by the IGF Code or other fuel-related
operations. It places the responsibility on the Master to ensure that the person with immediate
responsibility for the fuel on board has the appropriate certification and adequate practical experience.
The Master while retaining the overall responsibility of the vessel, delegates the management of thealternative fuels to the role documented in the SMS as the “person with immediate responsibility”.  
The proactive and diligent review of the SMS and reporting of non-conformities, accidents and hazardous
occurrences from the ship-to-shore management with the deployment of alternative fuels will bebeneficial to strengthen the SMS.
Recommended actions that may be considered in re-evaluating the role of the Master within the SMS in
the context of alternative fuels on board are listed below:
No.

Recommended Actions

9.

The SMS should define the role on board the ship assigned as the “person with immediate
responsibility” for the management of alternative fuels.

10.

The SMS should define the responsibility and authority of the Master in relation to the
management of alternative fuels on board.

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6. Resources and Personnel
The fossil fuel grades used on board ships have evolved over the years and the challenge with these fuelgrades was their inter-compatibility and operational compatibility with the equipment on board. Although
the operational processes may have evolved, the human and environmental risks associated with thesefuels have not changed greatly.
In contrast, the alternative fuel candidates possess differing but certainly elevated operational, andenvironmental risk elements associated with them when compared to fossil fuel grades. This change
highlights the increased importance of competence, training, and awareness of ship’s personnel in the
new operational environment. It is the responsibility of the company to ensure that ships in their fleet aremanned with competent and trained personnel commensurate with the responsibility of the individual
roles.
The IGF Code (Part D) and STCW Code (Part A-V/3) complement each other in providing therequirements for personnel using gases and low-flashpoint fuels. While the IGF Code (Part D) outlines
the requirements for companies to ensure that personnel on board using gases or low-flashpoint fuels
are adequately qualified, trained, and experienced; the STCW Code (Part A-V/3) provides mandatory
minimum requirements for the training and qualification of personnel on board subject to the IGF Code.
In the interim and until such regulations are developed for other alternative fuel candidates, thedeployment of these fuels will need to follow alternative and/or equivalency design approval process.
MSC.1/Circular.1455 [Ref 8] as part of the design approval process addresses the requirements for key
personnel involved in the different stages of the alternative and/or equivalent design approval processincluding the ship crew, and will have to adhere to flag requirements, if any.
All ship personnel will need familiarisation specific to the ship and equipment in line with ISM and STCW
requirements. Additionally, all ship’s personnel should have awareness of the risks associated with specificalternative fuel on board. This could be delivered in a way that is suitable for the size and risk associatedwith the fuel as identified by the company.
Considering the novel nature of the technologies that may be involved with deployment of alternative
fuels, the company may consider consulting all relevant stakeholders such as the original equipment
manufacturer (OEM) in providing specific training to personnel.
The ship crew should have the competence, training and familiarisation to:• Understand the nature of operations associated with equipment specific to alternative fuels and thedifferences from traditional fossil fuel-operated equipment.
• Understand the operational risks in terms of damage to equipment and hazards to humans and theenvironment from equipment operated on specific alternative fuels.
• Perform operational tasks, maintenance and inspection of equipment operated on specific alternative
fuels.

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Recommended actions for appropriate resources and planning to safely manage the operations onboard ships with alternative fuels are listed below:
No.

Recommended Actions

11.

List of competencies should be developed in a suitability matrix for personnel based on
certification, training and experience.

12.

Training procedures should be identified and implemented for personnel on hazards and risks
associated with specific alternative fuels, and contingency plans for dealing with hazardous
situations.
Training procedures should be simulated for training of personnel in dealing with anticipatedhazardous situations with specific alternative fuels.
Basic or advanced training certification should be provided based on the role andresponsibilities related to alternative fuels.

13.

Procedures for familiarisation of personnel on risks associated with the relevant alternative fuels
and equipment should be developed.

14.

Assessment should be able to identify any additional personnel that may be needed withalternative fuels operations.
Personal protective equipment appropriate for the hazardous area zones classified as 0, 1 and 2
should be provided.

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7. Shipboard Operations
The shipboard operations that are directly related to alternative fuels will need to have documented
procedures for the transfer, storage, operation, and maintenance to minimise the risk to ship, personnel
and the environment. These procedures will consider the regulations on requirements for the fuel in the
IGF Code, and in the absence of such regulations for that fuel, the procedures will need to be guided by
the requirements in the IMO guideline MSC.1/Circular.1455 [Ref 8]. The approval process in the guidelineis predicated on demonstrating that the alternative design has measures that are equivalent in reducing
the risk to the levels of the design being substituted. These measures are expected to be included within
the SMS as part of the approval process and can form the base for further development of procedures as
new information becomes available.
Being novel fuel technologies, there may be a lack of operational data to develop robust operational
procedures for alternative fuel candidates. Whilst understanding the characteristics of alternative fuels
may help reduce the operational risks, it can be beneficial to be guided by established fuels such as LNG
in developing operational procedures and contingency plans.
Some of the existing standards and industry guidelines in place for handling of chemicals and liquified
gases as fuel or cargo are listed below. These can inform the development of operational procedures forgas and low-flashpoint alternative fuels.
• ISO 20519:2021- Ships and marine technology — Specification for bunkering of liquefied natural gas
fuelled vessels [Ref 11]: The document specifies requirements for LNG bunkering transfer systems andequipment used in LNG-fuelled vessels, which are not covered by the IGC Code.
• ICS -Tanker Safety Guide (Liquefied Gas) 4th Edition [Ref 12]: The guide provides industry guide tosupport gas carrier operators conduct safe and efficient operations.
• SIGTTO - Guidelines for the Alleviation of Excessive Surge Pressures on ESD for Liquefied Gas Transfer
Systems [Ref 13]: This guideline explains the concept of surge pressure and provides practical advice
on its associated hazards and risk management.
• SIGTTO - Ship/Shore Interface for LPG/Chemical Gas Carriers and Terminals [Ref 14]: This publication
describes risk assessment and hazard identification techniques that can be applied by LPG/chemicalgas shipping staff and terminal operators.
• SIGTTO - Recommendations for Liquefied Gas Carrier Manifolds [Ref 15]: This document provides
recommendations on the layout, strength, and fittings for gas carrier manifolds.
• SIGTTO - Liquefied Gas Handling Principles on Ships and in Terminals, (LGHP4) [Ref 16]: This reference
book covers aspects of safe handling of bulk liquid gases (LNG, LPG and chemical gases) on board
ships and at the ship/shore interface at terminals.
• SGMF – Ammonia as a Marine Fuel [Ref 17]: The document provides insights into technicalconsiderations, safety aspects, and personnel training on ships using ammonia as a fuel.
• SGMF – Hydrogen as a Marine Fuel [Ref 18]: The document provides insights into technicalconsiderations, safety aspects, and personnel training on ships using hydrogen as a fuel.
• OCIMF/MSF – The Carriage of Methanol in Bulk Onboard Offshore Vessels [Ref 19]: The document
provides guidance for the safe loading, carriage and discharge of methanol on offshore vessels.

Engineering

While the ISM Code does not specify any specific approach in managing risks on board ships, it is for thecompany to decide on the methods that are most suitable in assessing risks within the context of thecompany. ISO 31000:2019 [Ref 20] can prove beneficial in carrying out a structured identification, analysis
and evaluation of the risks associated with alternative fuels. The standard provides generic guidelines that
can help structure the risk management into the SMS and thereby strengthen the system in managing
anticipated risks including risks from the deployment of alternative fuels on existing assets as well as newbuilds.
The procedures developed for shipboard processes that involve handling, storage and utilisation ofalternative fuels should be ship-specific and set out to manage the assessed risks to a level as low asreasonably practicable.

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The inherent risks of a specific alternative fuel are a function of its characteristics, while additional risks
can emerge with the interactions of the fuel with the operational environment. The identification of
the sources of risk associated with any specific alternative fuel may go beyond those inherent to its
characteristics. The additional sources of risk generated by the interaction of these fuels in the operational
environment could include:• The risks anticipated to develop due to possible mixing of the alternative fuel with other fuels, if
applicable.
• The risks anticipated to develop due to the interaction of the alternative fuel with the specificoperational environment.
Recommended actions that may ensure safe shipboard operations for ships with alternative fuels arelisted below:
No.

Recommended Actions

15.

A ship-specific fuel handling manual should be developed detailing the system layout, fuelcharacteristics, storage conditions, bunkering procedures, checklists, simultaneous operations
and contingency plans.

16.

Management of Change (MOC) should be integral to the development of shipboard
procedures to address changes resulting in the deployment of alternative fuels. The MOC
should be guided by the assessment of the impact on personnel safety, training requirements,
and documentation.

17.

The company should establish procedures for risk assessment of the shipboard operations. Thisshould be carried out by placing the prospective alternative fuels in context, and the process
would include risk identification, risk analysis, and risk evaluation.

18.

The risk identification should be carried out by persons with appropriate knowledge of thealternative fuels and the operational environment.

19.

The analysis of the identified risks should be carried out specifically to the operational
environment in which the alternative fuel is being deployed. In addition, and if applicable theanalysis should consider the effects of the interactions with other fuels that may be part of thefuel mix on board.

20.

The evaluation of the risk should be able to determine the level of risk and the mitigation
measures that will be required to lower the risk to an acceptable level.

To complement the above recommended actions, an analysis of how the deployment of alternative fuels
on board ships can be addressed through the principles of risk management are listed as below:• Risk management creates and protects value: The inherent hazards due to characteristics ofalternative fuels, compounded by the elevated operational risk and a lack of experience leading to
uncertainty, emphasises the importance of robust risk management. Such measures are essential tominimise risk to ship, personnel and the environment.
• Risk management is an integral part of all organisational processes: The integration of risk management
in all processes in an organisation demonstrates the safety culture in an organisation, and theseprocesses will need to be analysed within the context of relevant alternative fuels.
• Risk management is part of decision-making: The operational landscape on board the ship as well as
the ship-shore interface is expected to shift drastically with alternative fuels, and understanding theassociated risks will help the decision makers make informed choices.
• Risk management explicitly addresses uncertainty: When alternative fuels are deployed on board ships,
there is expected to be some degree of uncertainty in the operational environment, and this can be
minimised by well-conceived plans to manage the perceived risks.
• Risk management is systematic, structured, and timely: A risk management process set out in the SMS
that is systematic, structured and that provides the tools to identify risks associated with alternative
fuels, analyse them, and put mitigations in place promptly will ensure that the risks that arise with the
deployment of alternative fuels are addressed at the earliest.

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• Risk management is based on best available information: The management of risks with alternative
fuels initially will be reliant on its characteristics and perceived behaviour in operation, and would bebased on the best information at that time. This information will be augmented by operational data
and will have to be assessed based on the information that will be continually updated once systems
are functional.
• Risk management is tailored: The management of operational risk with alternative fuels within the
SMS will have to be versatile and agile to be tailored to meet different scenarios that may come into
existence.
• Risk management takes human and cultural factors into account: The inclusion of human and cultural
factors in assessing the operational risks with alternative fuels will be paramount can influence theoutcome of the operations.
• Risk management is transparent and inclusive: The safety culture of a company driven from the top
and that provides visibility at all levels is essential for proactiveness in managing the operational risks.
• Risk management is dynamic, iterative, and responsive to change: The process laid out in thecompany SMS towards risk management will need to be adaptive to changes that will be required as
non-conformities, accidents and hazardous occurrences (including near-misses) can be expected tocome fast once alternative fuels are deployed and will need to be addressed promptly within the SMS.
• Risk management facilitates continual improvement of the organisation: The transition of ships on
to alternative fuels is expected to change the operational risk, but proactive risk management thattakes learnings within the fleet and the industry in progressively strengthening the SMS will be the key inreaching a state of safe operational environment.

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8. Emergency Preparedness
The ISM Code requires the company to identify potential emergency shipboard situations and establish
procedures to respond to them. The company SMS should be versatile through its procedures to manage
the risks associated with these fuels. Understanding that certain processes cannot be entirely controlled,either through design or through normal operational procedures, requires emergency preparedness tominimise the damage to the ship, personnel and the environment.
The IGF Code (Part C-1/17) requires gas- related drills and emergency exercises on board to be
conducted at regular intervals and related safety systems to be regularly tested as part of emergency
preparedness. Emergency preparedness planning has two components:• Contingency plans – Development of plans that are conceptualised as the best course of action in an
emergency to protect the ship, personnel and the environment.
• Emergency training – Training of crew on action to be taken in the event of an emergency.
IMO Resolution A.1072(28) [Ref 21] provides guidelines to assist in the preparation of an integrated systemof contingency planning for shipboard emergencies and will be particularly beneficial in integrating theassessed emergency preparedness with alternative fuels with other existing contingency plans.
Recommended actions that may ensure safe emergency preparedness for ships with alternative fuels arelisted below:
No.

Recommended Actions

21.

The company should identify concerns and provide advice on remedial actions by initiating
assistance from flag and coastal states as part of company response plan.

22.

The emergency preparedness of the ship with alternative fuels should implement an integrated
system of contingency planning for shipboard emergencies. This will provide a structured
framework that tailors individual contingency plans to potential emergencies.

To complement the above recommended actions, some elements of emergency preparedness that may
be addressed in the development of contingency plans and emergency training are listed below:• Contingency plans:–procedures to be followed when reporting an emergency,–procedures for identifying, describing, and responding to potential emergency shipboard situations,and–procedures for the maintenance of the system and associated plans.
• Emergency training:–onboard familiarisation of shipboard personnel with the system and plans,–providing training for shipboard personnel about the system and plans,–scheduling of regular drills and exercises,–effective coordination of crew and the company’s actions, and–developing an effective, transparent, and workable feedback system.

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9. Reports and Analysis of Non-conformities, Accidents andHazardous Occurrences
The ISM Code requires the SMS to include procedures ensuring that non-conformities, accidents andhazardous occurrences (including near-misses) are reported to the company and are investigated,
analysed, and corrective actions implemented to prevent recurrence.
The SMS that has been developed through utmost diligence including the operational context ofthe company and further strengthened over a period of time by assimilating the learnings from nonconformities, accidents and hazardous occurrences (including near-misses) is expected to be robust in
managing operational risks.
With the novel nature of the alternative fuels, development of new operational procedures oramendment of existing ones will be based on inherent characteristics of the specific fuel and assessmentof perceived operational risks, but may lack the operational data. The effectiveness of the procedures
within the SMS that provide practical feedback on non-conformities, accidents and hazardous
occurrences (including near-misses) related to alternative fuels is crucial. This can be the differentiatorthat impacts the time span in closing the gaps that may exist and operational processes reach a placethat minimise the risk to the ship, personnel and the environment.
MSC-MEPC.7/Circ.7 [Ref 22] provides guidance on developing the process of reporting of near-misses
within the SMS. The effectiveness of this feedback from the ship to the company will be crucial in the SMS
in achieving an operational excellence with alternative fuels in the last time frame.
Recommended actions that may be considered relevant to section 9 of the ISM Code are listed below:
No.

Recommended Actions

23.

Effective feedback process within the SMS should be included to report and analyse nonconformities, accidents and hazardous occurrences (including near-misses) related toalternative fuels.

24.

Learning from non-conformities, accidents and hazardous occurrences (including near-misses)
should be critical to continuous development of the SMS.

25.

The procedures should be improved once the systems are functional and the operational data
becomes available with the alternative fuels.

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10. Maintenance of the Ship and Equipment
With the adoption of alternative fuels, fundamentally there is no change envisaged with respect tomanagement practices in which the equipment is maintained, however there is expected to be anelevated operational risk due to uncertainties. The effective consideration of the human element in themaintenance of the equipment associated with the handling, storage and utilisation of alternative fuels isthereby highly critical.
The IGF Code (Part C-1/18) provides the regulations to ensure that operational procedures for the transfer,storage, operation, maintenance, and inspection of systems for gas or low-flashpoint fuels minimise the risk
to the ship, personnel and the environment. These requirements should be considered and integrated in
the Planned Maintenance System (PMS).
Recommended actions that may be considered for the maintenance of the ship and equipment withalternative fuels are listed below:
No.

Recommended Actions

26.

Maintenance procedures should be adapted to include specific requirements related to themaintenance of equipment associated with the handling, storage, and utilisation of alternative
fuels. This may involve additional checks and inspections for components that come into directcontact with alternative fuels.

To complement the above recommended actions, aspects that need to be considered in developing
maintenance plans and procedures for equipment associated with alternative fuels are listed below:• Establishment of procedures for the requirements on maintenance and inspection of systems.
• Establishment of procedures in adherence to the OEM’s recommendation on maintenance intervals
and procedures as well as recommendations from industry guidelines.
• Incorporation of the safety procedures related to handling of the alternative fuels within or linked to theestablished maintenance procedure.
• Identification and documentation of critical equipment and systems related to alternative fuels.
• Establishment of levels of competence within the PMS required for carrying out maintenance events onequipment associated with alternative fuels, with senior personnel oversight for critical tasks.

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11. Documentation
A company fleet may have ships operating on alternative fuels and ships operating on fossil fuels. In anyof these scenarios, the company SMS should always have the correct procedures and documentation foreach ship in the fleet to ensure safe operations and to meet regulatory compliance. The importance ofthe control of documents, maintaining updated documents, and removal of obsolete documents fromthe SMS cannot be emphasised enough on ships operating on alternative fuels which have elevatedoperational risk. The granularity of content and volume of documentation may be the differentiator for aship operating on alternative fuel.
Operational Procedures – The company SMS applies to all ships in the fleet, and there have always beensome procedures applicable to all ships while there were others that were applicable to certain shiptypes and even to particular ships. With the introduction of alternative fuels on some of the ships, there
could be updates to existing procedures as well as new procedures included in the SMS. This may leadto further granularity of procedures in the SMS and can get quite complex for the ship crew that has todisseminate the applicability of operational procedures for the individual ship. It is therefore importantthat the operational procedures are streamlined to an extent that leaves no doubt in the interpretation of
their applicability on each ship in the fleet.
Documented Information – Vessel operational data is recorded, and these records are retained as
documented information for performance monitoring and to evidence “duty of care” and to satisfy
compliance obligations. With the introduction of alternative fuels, changes to the documented
information that needs to be retained can be anticipated, the extent of which will depend on thespecific alternative fuels. Ensure that the related and valid documents are available at all relevant
locations on the ship which may include manuals, checklists, and emergency response plans specific toalternative fuels.
Regulatory Documentation – All ships are required to carry documentation and certificates on boardthat are common to all ship types with some ships required to carry additional ship-specific documents.
With the deployment of alternative fuels, it is expected that there will be changes in the current
documentation as well as additional documentation and certificates may be required to be retainedon the ship. The extent of changes in documentation and certificates will depend on the additional
documentation required to meet the approval criteria under which the alternative and/or equivalency
has been granted.
IMO Guidelines “MSC.1/Circular.1455 – Guidelines for the Approval of Alternatives and Equivalents”[Ref 8] in section 7.2 “Onboard documentation requirements” provides the anticipated generic list of
documentation and additional information that is expected to be retained on ships with equipment
approved with alternative and/or equivalency. And, IMO circular “MSC.1/Circular.1646’ [Ref 23]” provides
a list of certificates and documents required to be carried on board ships.
Recommended actions that may be considered in the maintenance of documentation relevant toalternative fuels are listed below:
No.

Recommended Actions

27.

Effective document control and updated information should be available, and obsolete
documents should be removed.

28.

Operational procedures, checklists, etc., related to alternative fuels should be developed in amanner that can be easily disseminated.

29.

Procedures for the effective retention of required operational records should be developed.

30.

Procedures for effective document control due to higher volumes of documents should be
updated regularly.

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12. Company Verification, Review and Evaluation
The adequacy of the SMS in managing the operational processes on board the ship is evaluatedat regular intervals. While the internal audit, evaluation and corrective action process will remain
fundamentally the same with alternative fuels, there may be room for inspection on the company
verification, review and evaluation processes set in the SMS.
The audit process will need to be amended to include aspects relevant to alternative fuels in ensuringthat audits are comprehensive and relevant, and may include:• Verification of the procedures on handling and storage of alternative fuels, and the retention ofrequired records as documented information.
• Verification of competence, training and familarisation of personnel relevant to alternative fuels
documented in the SMS.
The SMS will need to re-evaluate and document the minimum suitability criteria for auditors eligible tocarry out the audits on ships with alternative fuels, and the criteria could include experience on ships withspecific alternative fuels or suitable training in lieu.
Recommendations that can be considered relevant to section 12 of the ISM Code are listed below:
No.

Recommended Actions

31.

Develop the audit process to include aspects relevant to alternative fuels.

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Conclusions
As companies look to deploy a diverse range of alternative fuels ahead of national and international
regulatory requirements being developed, they can use their SMS to provide an effective tool for
managing the associated risks. Identification of hazards and risks for safe operation and management ofalternative fuel systems is essential for the development of SMS procedures and safety culture which may
differ for each company.
MTF believes that these guidelines may be one way of encouraging safe application of alternative
fuels for industry wide application; acceptance; and consistent development and implementation.
Companies can use these guidelines to develop new SMS and/or strengthen their existing SMS for
alternative fuels onboard their fleet.
MTF recommends that these guidelines may be used in addition to other similar existing and/or upcoming
guidelines (some of which are already referenced within this document) to ensure a safe application ofalternative fuels on board ships.
Based on MTF reviews, some highlights may be drawn from the overall review and are listed below:• In the initial stages, with the fuel-mix on board still including fossil fuels along with alternative fuels, the
SMS should be versatile enough to meet the fuel scenarios as alternative fuels are progressively scaled
and becoming mainstream.
• The lack of data from the operational experience of equipment operating with alternative fuels will bea gap that will exist in the initial stages of deployment of alternative fuels.
• The strength of the company’s SMS shall be in the ability to proactively identify improvements in the
SMS through learning from non-conformities, accidents, and hazardous occurrences (including nearmisses) related to alternative fuels, and facilitate the closing of the gaps that would exist initially due tolack of operational data.
• The IGF Code, IGC Code and relevant IMO circulars may be consulted in developing the procedures
related to alternative fuels within the SMS.
• The anticipated changes in the ship operation that are expected to be brought about by alternative
fuels are set to expand the suitability criteria of the person assuming the role of DP.
• The SMS should identify the role defined in STCW Code section B-V/3 as “person with immediate
responsibility” as a person being in a decision-making capacity for handling of fuels addressed by the
IGF Code or other fuel-related operations.
• The integration of a structured risk management within the SMS would be beneficial to strengthen thesystem in managing anticipated risks including risks from the deployment of alternative fuels.
• The effective control of documents within the SMS is important, and this can be emphasised further
with alternative fuels given the associated elevated operational risk.

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References
1.

IMO, “The International Safety Management (ISM) Code”.

2.

IMO, “The International Convention on Standards of Training, Certification and Watchkeeping for
Seafarers (STCW), 1978”.

3.

IMO, “The Maritime Labour Convention (MLC), 2006”

4.

IMO, “International Code of Safety for Ship Using Gases or Other Low-flashpoint Fuels (IGF Code)”.

5.

IMO, “International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in
Bulk (IGC Code)”.

6.

IMO, MSC.1/Circ.1621, “Interim guidelines for the safety of ships using methyl/ethyl alchohol as fuel”

7.

IMO, MSC.1-Circ.1666, “Interim Guidelines For The Safety Of Ships Using LPG Fuels”.  

8.

IMO, “MSC.1/Circ.1455 – Guidelines for the approval of alternatives and equivalents” 2023.

9.

IMO, MSC-MEPC.7/Circular.8, “Revised guidelines for the operational implementation of theinternational safety management (ISM) code by companies”.

10. IMO, “MSC-MEPC.7/Circ.6 – Guidance on the qualifications, training and experience necesary
for undertaking the role of designated person under the provisions of the international safety
management (ISM) Code” 2007.
11. ISO 20519:2021 “Ships and marine technology — Specification for bunkering of liquefied natural gas
fuelled vessels”, 2021
12. ICS, “Tanker Safety Guide (Liquefied Gas), Fourth Edition  Tanker Safety Guide (Chemicals), Fifth
Edition”, 20231
13. SIGTTO, “Guidelines for the Alleviation of Excessive Surge Pressures on ESD for Liquefied Gas Transfer
Systems”,2018
14. SIGTTO, “Ship/Shore Interface for LPG/Chemical Gas Carriers and Terminals”,2018
15. SIGTTO, “Recommendations for Liquefied Gas Carrier Manifolds”,2018
16. SIGTTO, “Liquefied Gas Handling Principles on Ships and in Terminals, (LGHP4)”,
17. SGMF, “Ammonia as a Marine Fuel”,2023
18. SGMF, “Hydrogen as a Marine Fuel”,2023
19. OCIMF, “The Carriage of Methanol in Bulk Onboard Offshore Vessels”,2016
20. ISO 31000:2019 “Risk Management- Principles and guidelines”
21. IMO, Resolution A.1072(28), “Revised guidelines for a strcuture of an integrated system of contingency
planning for shipboard emergiengies.
22. IMO, MSC-MEPC.7/Circ.7, “Guidance on near-miss reporting”.
23. IMO MSC.1/Circular.1646, “List of certificates and documents required to be carried on board ships”,
2022.

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Acknowledgements:
Organization

Name

ABS

Athanasios Rigas
Shugo Kitta

ClassNK

Naoki Saito
Vikrant Sharma
Kjetil Kasamoen

DNV

Wenche M. Lunde
Pierre Sames
Gilmark D MelloLR

Andrew Sillitoe
Yildiz Williams (Project Manager)

MCA

Andrew Clarke
Paras Thukral
Aun Aun Cheah
Yuanhe Loh

MPA

Muhammad Tashriq Sabtu
Hon Leng Tang
Eddie Yeo

MTF wishes to extend their gratitude for the below listed Industry stakeholders that helped to strengthen
these guidelines with their invaluable feedback.
Industry Stakeholders

Name

BIMCO

Jakob Larsen
Sunil Krishnakumar

ICS

Arvind Natrajan
Gregor Stevens

InterManager

Kuba Szymanski

INTERTANKO

Dr. Phillip Belcher

Nautical InstituteJeffrey Parfitt

For any enquires about this report please send a message to:contact@maritimetechnologiesforum.com.

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