IMO2020 VIEWPOINT: Taking a PASS on the PAS (Publicly Available Specification)

by Ananth Srinivasan, Vice President, V-TIC
Tuesday October 15, 2019

The IMO2020 regulations promise to bring about an exciting new change for the industry. The shipping industry and the full suppliers will do their part to help the world address challenges with the environment.

To take on this incredible task, the shipping industry and the fuel suppliers made substantial investments even though there was limited clarity on what is to come. While we understood that given the short timeline, we would not have a new ISO standard for 2020, we hoped that the PAS would fill in the gaps.

The PAS released in September 2019, by the ISO team, highlights several issues with 2020 fuels, but has little by way of solutions. Consider the following statements in the PAS:

  1. Fuel blend formulations are expected to vary widely across the regions.
  2. Due to the expected higher variety in fuels composition post 2020, the risks for incompatibility between fuels might increase.
  3. A conclusion drawn that such fuels might not be compatible may be incorrect and the advice, based on the spot rating, not to commingle the respective fuels not really required.

These statements are simplistic at best and one would expect these statements when written as a summary for an editorial column dedicated to newcomers in an industry. However, given that the suppliers are looking for specific information to help sell their fuels and help shipowners better understand these new fuels, the PAS fell short.

One of our customers, after reading the PAS said, "The PAS is what happens when an industry tries to write guidelines on fuels that are not readily available. The only way to write this document is to have technical experts write something only to have lawyers re-write it to remove any specifics."

The comments seemed harsh and when I pressed this customer further, he further highlighted the word 'not' and negatives in the statement in bullet 3 above to prove his point. Here is an example:

"A conclusion drawn that such fuels might not be compatible may be incorrect and the advice, based on the spot rating, not to commingle the respective fuels not really required."

As a summary, the PAS essentially points out that there will be higher likelihood of incompatibility, more variations in Kinematic Viscosity, fuels with potentially higher wax content, higher catfines than one would expect from a lower Sulfur fuel etc. But, if one is looking for tactics on how to deal with this higher risk, one would not have answers here.

In terms of helping the industry with solutions, consider the following conclusions from the PAS. These are examples that highlight the very limited support to suppliers from the document:

Kinematic Viscosity:

The last line of the Kinematic Viscosity section suggests that the supplier should communicate the Kinematic viscosity of the fuel prior to delivery. The 8217 standard today already requires the viscosity presented as part of the certificate of analysis.

Ignition Characteristics:

The exact wording from the PAS on this topic is, "However, as with the best practices applied today on pre-2020 fuels, attention should be given to each newly sourced fuel put into use, ensuring machinery plant settings are correctly setup and manufacturers operating limits are not exceeded.
If there is so much uncertainty about these new fuels, the PAS could have suggested some ways that suppliers and shipowners can work together to address issues like ignition characteristics. However, instead of focusing on meaningful suggestions, they gave us generalities.


Perhaps the most important part of the document was hidden in Page 9. This was the observation that the TSA test was inconclusive at times, and that TSP should be the best referee method for 2020 fuels. However, as we know the TSP takes 24 hours and given the uncertainty in the next few months, it is fully expected that transactions will be made at the last minute. The 24 hour TSP would not be fast enough for the industry, and the PAS could have given more guidance about techniques like ROFA (S-value) that give results in 2 hours.

On October 8th, Ara Barsamian, CEO of Refinery Automation posted similar views on Ship & Bunker in an article titled: ISO 2020 PAS… To Be or Not To Be? Or Much Ado About Nothing?

In conclusion, while the PAS is a well written document, it falls short of helping an industry when they needed it the most. It is this author's position that the ISO organization, with the enormous talent and knowledge, could have done more.