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MARPOL Annex II Revisions & The Associated Revisions of the IBC Code INTERTANKO

MARPOL Annex II Revisions & The Associated Revisions of the IBC Code INTERTANKO 31st NPRA International Petrochemical Conference San Antonio Captain Howard N. Snaith Director, Marine, Ports, Terminal, Environmental & Chemical. AGENDA Annex II Revisions Deadline Remains!

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MARPOL Annex II Revisions & The Associated Revisions of the IBC Code INTERTANKO

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  1. MARPOL Annex II Revisions & The Associated Revisions of the IBC Code INTERTANKO 31st NPRA International Petrochemical Conference San Antonio Captain Howard N. Snaith Director, Marine, Ports, Terminal, Environmental & Chemical

  2. AGENDA • Annex II Revisions Deadline Remains! • IMO Ship Type Reviewed • Products Still Missing Data • Practical Implications of the Revisions • Biofuels and the Revisions • IMO 2006 Schedule

  3. Why was Annex II Revised ? The drivers behind the revisions were: • Editorial improvements • Adaptation to the revised GESAMP procedure • Reduce the number of categories • Simplification of operational requirements • Fewer non-regulated substances • Reduction of legal discharges • Keeping up with technical development • Adaptation to the Global Harmonized System (GHS

  4. MARPOL Annex II Revisions • The long-time ongoing revision work on MARPOL Annex II and the IBC Chemical Carrier Code concluded with the adoption of the revised MARPOL Annex II by MEPC 52 (in October 2004) and the adoption of the revised IBC Code by both MEPC 52 and MSC 79 (in December 2004). • The revised requirements WILL enter into force and take effect from 1 January 2007.

  5. MARPOL Annex II Revisions • Currently there exist 5 Pollution categories within today's MARPOL Annex II - categories A, B, C, D and an Appendix III. (Appendix III lists products to which the IBC Code does not apply).

  6. MARPOL Annex II Revisions • The revised system was agreed in 2003 at MEPC 49, this revised system is a 3 + 1 pollution category system (X,Y,Z + OS). • The fourth category (OS or Other Substances) includes Apple juice, Clay slurry, Coal slurry, Dextrose solution, Glucose solution, Kaoline slurry, Molasses, and Water • Note: Vegetable oils will be specified and are upgraded from Appendix III (of the IBC Code) to Pollution Category Y.

  7. What is an IMO Ship Type The IBC Code provides detailed standards for the construction and equipment of three types of chemical tankers (Types 1, 2 and 3)

  8. An IMO Type 1 ship is a chemical tanker intended for the transportation of products considered to present the greatest overall hazard. • IMO Ship Type 2 & 3 are designed for the carriage of products with progressively lesser hazards (Such requirements include [but is not limited too] extensive damage survival capability requirements of differing degrees for each ship type).

  9. Tank Type Configurations

  10. Still a Lack of Data • All products had to be re-assessed with regards to their pollution and safety data, but not all the data for all the products was available. • December 31, 2005 has come and gone but this was the deadline for submission of data to enable these “missing data” products which are currently being carried to be re-evaluated by GESAMP. • Unless the necessary data is submitted the bulk transport of these products will likely not be able to be carried at sea in Bulk after 1/1/2007.

  11. Still a Lack of Data • One of the solutions being reviewed is to consider the carriage of these products by applying the harshest carriage requirements (Pollution Category X & Ship type 1 or 2) until the data is received for the missing products. • BUT this or any other proposal if made will have to be made at IMO at BLG 10 or MEPC 55, both meetings will be held later this year.

  12. Still a Lack of Data • The 42nd session of the GESAMP Working Group on the Evaluation of the Hazards of Harmful Substances Carried by Ships (EHS 42) was held at IMO Headquarters in London earlier this year. • The report on this meeting has just recently been released. The most recent meeting report of GESAMP/EHS has indicated that approximately sixty products remain on the missing data list from an initial list of 120.

  13. Draft List of Products Still Missing Data at February 2006 Alkyl(C8+)amine, Alkenyl (C12+) acid ester mixture Aluminum chloride (30% or less)/Hydrochloric acid (20% or less) solution 2-Amino-2-hydroxymethyl-1,3-propanediol solution (40% or less) Ammonium bisulphite solution (70% or less) Ammonium thiocyanate (25% or less)/Ammonium thiosulphate (20% or less) solution Benzyl chloride N,N-bis(2-hydroxyethyl) oleamide Butyl stearate Calcium alkyl (C9) phenol sulphide/Polyolefin phosphorosulphide mixture Calcium long-chain alkyl phenolic amine (C8-C40) Camphor oil Caramel solutions Cashew nut shell oil (untreated) Cobalt naphthenate in solvent naphtha Creosote (coal tar) Creosote (wood)

  14. Draft List of Products Still Missing Data at February 2006 Decyl acetate 1,3-Dichloropropane Diethylene glycol dibutyl ether 1,4-Dihydro-9,10-dihydroxyanthracene, disodium salt solution Dodecenylsuccinic acid, dipotassium salt solution Ethyl amyl ketone N-Ethylbutylamine Ethyl butyrate o-Ethylphenol Ethyl propionate Ferric hydroxyethylethylenediaminetriacetic acid, trisodium salt solution Fish solubles (water-based fish meal extract) Fumaric adduct of rosin, water dispersion Glycerine (83%), Dioxanedimethanol Glycerol polyalkoxylate Icosa(oxypropane-2,3-diyl)s Long-chain polyetheramine in alkyl (C2-C4) benzenes Long-chain polyetheramine in aromatic solvent

  15. Draft List of Products Still Missing Data at February 2006 Methyl heptyl ketone 3-Methyl-3-methoxybutyl acetate Naphthenic acids Nonyl acetate Pentaethylenehexamine Polyalkylene oxide polyol Polyglycerol Polyolefin amide alkeneamine/molybdenum oxysulphide mixture Polyolefin amide alkeneamine polyol Poly(tetramethylene ether) glycol (mw 600-3000) Potassium salt of polyolefin acid n-Propyl chloride Propylene-Butylene copolymer

  16. Draft List of Products Still Missing Data at February 2006 Propylene dimer Rosin soap (disproportionated) solution Sodium aluminate solution Sodium tartrates/Sodium succinates solution Sulpho hydrocarbon long chain (C18+) alkylamine mixture Tall oil fatty acid, barium salt Tall oil soap (disproportionated) solution Trimethylhexamethylenediamine (2,2,4- and 2,4,4-isomers) Trimethylhexamethylene diisocyanate (2,2,4- and 2,4,4-isomers) Trimethylolpropane polyethoxylate Trimethyl phosphite Urea/Ammonium mono- and di-hydrogen phosphate/Potassium,chloride solution Urea formaldehyde resin solution

  17. Certification of Cargoes • All non-oil cargoes carried in bulk are classified by the International Maritime Organization (IMO) and/or the vessel’s flag state.  The carriage requirements for a product are then determined by these entities using the guidelines set forth by GESAMP and IMO. • If regulated by the IBC Code those cargoes must be authorised for carriage on that particular ship, and listed on, the ship’s Certificate of Fitness.

  18. Certification of Cargoes • The bulk carriage of any liquid product other than those defined as oil (subject to MARPOL Annex I) is prohibited unless the product has been evaluated and categorised for inclusion in Chapter 17 or 18 of the IBC Code (The International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk). • The MARPOL Annex II Revisions will result in an amended IBC Code and new certification for cargoes and vessels.

  19. Practical Implications of the Revisions • Every chemical tanker is required to have a Certificate of Fitness (CoF) – indicating that it is certified to carry certain products. • The issuance of a CoF will also require a revised Procedures and Arrangements Manual. • Shipping Companies are now therefore starting a process of renewal NOW.

  20. Certificates of Fitness • The new P & A Manuals and the new Certificates need to be onboard each ship BEFORE the 1 January 2007 deadline. • Class societies and owners are working diligently to ensure that in late 2006 both systems will be in place.

  21. New Certificates / P & A Manuals • All Certificates of Fitness issued under the present requirements will become invalid from 1 January 2007. • This also affects Offshore Support Vessels and dry cargo ships with deep tanks certified for carriage of noxious liquid substances. • Cargoes legally loaded before 1 January 2007 will be allowed to be carried to the scheduled unloading port under the “old” requirements. • To carry any noxious liquid substance in bulk from 1 January 2007 all ships will need to hold a Chemical Carrier Code CoF issued under the revised requirements.

  22. Two Systems • BUT the revised requirements may not be used before 1 January 2007. • This means that a newbuilding being delivered in December 2006, will need to be certified under the current version of ANNEX II (with “old type” P & A Manual and CoF) but also have from 1 January 2007 its “new” P & A Manual and a “new” CoF with revised List of Products.

  23. The CoF List • The List of Products attached to a new Certificate of Fitness will be calculated based on the revised Pollution Categories and the ship’s compliance with the revised carriage requirements. • Less sophisticated chemical tankers, including those not complying with the present stripping requirements for the current pollution category B substances, may, under the revised requirements, lose a very large portion of their current List of Products.

  24. Stripping & Underwater Discharge • An underwater discharge arrangement for tank washing water is required for pollution categories X and Y for ships keel-laid before 1 January 2007. Newer ships will require such for all pollution categories X, Y and Z. • The waiver possibilities in respect of stripping performance and underwater discharge arrangement for dedicated ships engaged in carriage of products not involving cleaning of cargo tanks will remain unchanged. • The additional requirements for operation within Special Areas (except the Antarctic) have been deleted.

  25. The Veg Oil Compromise • As expected, products defined as "Floaters" and "Persistent floaters", which include the vegetable oils, will be assigned to Pollution Category Y. Under the currently defined ship typing criteria this will mean they have to be carried in IMO Type 2 ship space. • The veg oil industry expressed concern that there would not be enough Type 2 tonnage to accommodate the demand post 2007. • At MEPC 52 ( in 2004) a compromise was therefore developed by the USA, Netherlands and Panama and accepted by IMO. The purpose of the compromise is to alleviate concerns regarding a tonnage shortage.

  26. The Veg Oil Compromise Accepted at MEPC 52 An Administration may exempt ships from the carriage requirements under Regulation 11 for ships Certified to carry individually identified vegetable oils identified by the relevant footnote (k) in chapter 17 of the IBC Code, provided the ship complies with the following conditions: 1. Subject to this regulation, the NLS tanker shall meet all requirements for ship type 3 as identified in the IBC Code except for cargo tank location; 2. Under this regulation, cargo tanks shall be located at the following distances inboard. The entire cargo tank length shall be protected by ballast tanks or spaces other than tanks that carry oil as follows:

  27. The Veg Oil Compromise Accepted at MEPC 52 .1 Wing tanks or spaces shall be arranged such that cargo tanks are located inboard of the moulded line of the side shell plating nowhere less than 760 mm; and .2 Double bottom tanks or spaces shall be arranged such that the distance between the bottom of the cargo tanks and the moulded line of the bottom shell plating measured at right angles to the bottom shell plating is not less than B/15 (m) or 2.0 m at the centreline, whichever is the lesser. The minimum distance shall be 1.0 metre. The relevant certificate shall indicate the exemption granted.

  28. MARPOL Annex II Revisions Despite the rumours veg oils will move • As of today, no extensions or delays have been accepted by IMO. • On 1 January 2007 veg oils will have to be carried in IMO Type 2 or 3 space.  

  29. What is Moving Where: There are approximately 150 products from the IBC Code that are moving to Type 2.  Here are just a few in alphabetical order: Ammonia, aqueous Carbon tetrachloride Chlorobenzene Decanoic acid Decyl alcohol Dodecyl alcohol Fatty acid (saturated C13+) Hexane Lauric acid Nonene Octanol Oleic acid Perchloroethylene Propylene tetramer Pyridine Pyrolysis gasoline Turpentine Undecanoic acid Undecyl alcohol

  30. MARPOL Annex II and US Implementation The USCG is initiating a regulatory project to implement the MARPOL Annex II revision. However, these regulations will not be completed in time for their entry into force date of 1 January 2007. The USCG regulations that will be in effect on that date will be the current regulations for the transport of Annex II substances. 

  31. MARPOL Annex II and US Implementation To assist this process the USCG is developing a Navigation and Vessel Inspection Circular (NVIC), a guidance document to industry that will provide the industry with an elective (or alternative) method of complying with the regulations in effect. This elective method will reflect the revised Annex II. It will be the guidance used by industry and regulators. INTERTANKO is Chairing this Group

  32. MARPOL Annex II and the Carriage of Biofuels The term biofuel encompasses a diverse range of products such as bio-gas, biodiesel and bioethanol. Any fuel made from a renewable biological source is considered a biofuel. Biofuels include ethanol, biodiesel, and methanol. Biofuel is derived from recently living organisms or waste streams (agricultural, domestic or municipal).

  33. Carriage of Biofuels Biodiesel is produced from a variety of vegetable oils, including but not limited to palm, rape, canola, soy, linseed, coconut, mustard and cotton oils. It can also be manufactured from tallow oil and yellow grease (used cooking oils). The production process is to modify the oils through esterification to produce glycerin as a useable by-product. These products cannot be shipped under MARPOL Annex II using these trade names.

  34. Carriage of Biofuels Most of the discussion recently regarding the classification of bio-fuels under Annex II has been predominantly about bio-diesel. The majority of biodiesel cargoes are fatty acid methyl esters (FAME) which can have various compositions. There are only three fatty acid methyl esters approved for carriage under the current MARPOL Annex II: Palm oil fatty acid methyl ester (currently in the IBC Code) Coconut oil fatty acid methyl ester (currently in the IBC Code) Rapeseed oil fatty acid methyl ester (currently in list 1 of MEPC.2 Circ) All three of these products are currently Category D and Chapter 18.

  35. Carriage of Biofuels BIODIESEL Any new data that has been submitted on these products will be considered at BLG 10 in April 2006. If approved by BLG 10 they will be included on List 1 of the 2006 edition of the MEPC.2/Circ., most likely as Category Y and Ship Type 2. Regardless of the base oil, FAME products are not “unmodified” oils, and will not be considered applicable under the exemption clause in MARPOL Regulation 4.1.3.

  36. Carriage of Biofuels Proposals A proposal has been made to the IMO that will act as an interim measure in classifying the expanse of biofuels in existence but we need to wait for the conclusions of these discussions.

  37. IMO and the 2006 Schedule There are many loose ends that need to be tended to before December 31, 2006 IMO has three meetings scheduled for 2006 where these matters can be discussed: BLG – 10 – April 2006 MEPC 55 – October 2006

  38. Thank you for your Attention

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