INTERCARGO International Association of Dry Cargo Shipowners

1. INTERCARGO International Association of Dry Cargo Shipowners Joint Technical Seminar Annex V for Dry Bulk 22nd November, 2006 by Roger Holt Secretary General

2. INTERCARGO Annex V and the problems associated with water washing

3. INTERCARGO Agenda: • - Introduction to Intercargo • The Round Table of International • Shipping Associations • - India and Dry Bulk • - The Regulator and Rule Maker • MARPOL Annex V • Port Reception Facilities • Water Washing

4. INTERCARGO Introduction to INTERCARGO

5. INTERCARGO • The International Association of Dry Cargo Shipowners • Representation of Bulk Carrier Owner/Operator interests • Direct entry organisation • Specialising in Bulk Carrier issues • - Promotion of Safety, Quality, Efficiency and Profitability

6. INTERCARGO • 120 Full and Associate Members • 900 bulk carriers over 10,000 dwt • Inclusive of Operators as full members

7. 1 INTERCARGO The Round Table of international shipping associations

8. INTERCARGO Round Table summary: • BIMCO, International Chamber of Shipping, Intertanko and Intercargo • Established 1998 • Probably covers about 90% of the world’s tonnage • Designed to improve efficiency, identify major issues, be more effective with the regulator, prevent surprises, enhance cooperation

9. INTERCARGO • Typical issues: • Tripartite Dialogue – 5th annual meeting in • Seoul in September • Dialogue with the Asia Shipowners Forum • Dialogue on Piracy – Malacca Straits • Industry Code on Recycling • Industry Guidelines on Flag State • Performance • However, recognition that each Association is answerable to its own management

10. 1 INTERCARGO India and Dry Bulk

11. INTERCARGO INDIA & DRY BULK Ownership & Control • 20 Dry Bulk companies trading internationally (10,000dwt+ vessels) • 92 Dry Bulk vessels controlled within India plus another 16 elsewhere • 12th largest ownership concentration globally

12. INTERCARGO DRY BULK OPPORTUNITIES • Average age of Indian fleet – 18.65 years (international average – 14.76 years • World GDP growing at c. 5% p.a : India c. 6% • Management and manning advantages • Clusters – Class; Shipyards; Training Colleges

13. 1 INTERCARGO The Regulator and Rule Maker

14. INTERCARGO • IMO • National Administrations • Regional Administrations • State Legislation • Classification Societies • Flag States • Port States There is conflict between a number of these authorities e.g. EU SSP The Regulation of Shipping

15. IMO Conventions and Protocols INTERCARGO • Safety prime importance – SOLAS, maritime traffic, load lines, carriage of dangerous goods, etc • Pollution – MARPOL 73/78 • Liability conventions • International Mobile Satellite Organization (1970) • Global Maritime Distress and Safety System (1999) • Standards of Training, Certification and Watchkeeping (1978) In total, around 40 Conventions and Protocols have been adopted.

16. INTERCARGO Sample of regulatory topics • IACS/Common Structural Rules • IMO/Goal Based Standards • MARPOL/Annex V • MARPOL/Annex VI • EU/Competition Law

17. INTERCARGO MARPOL Annex V

18. INTERCARGO • Annex V in force December 1988 • Regulation for the prevention of pollution by Garbage • Garbage includes all kinds of food, domestic and operational waste ……. • Amendment to Garbage Record Book in force on 1st August 2005 includes: * Cargo residues * Position of the ship

19. INTERCARGO Procedures to be followed: • - Garbage categories in the GRB must • include cargo residues • Cargo residue disposal must be recorded • giving start and stop lat/long positions • - Disposal prohibited < 12nm to nearest land • In a Special Area, cargo residues cannot be • disposed into the sea • MARPOL requirements are the minimum; • port states may be more stringent

20. INTERCARGO Special Areas • Adopted Entry into force In effect • Mediterranean Sea 02 Nov 1973 31 Dec 1988 - • Baltic Sea 02 Nov 1973 31 Dec 1988 01 Oct 1989 • Black Sea 02 Nov 1973 31 Dec 1988 - • Red Sea 02 Nov 1973 31 Dec 1988 - • ‘Gulfs Area’ 02 Nov 1973 31 Dec 1988 - • North Sea 17 Oct 1989 18 Feb 1991 18 Feb 1991 • Antarctic Area 16 Nov 1990 17 Mar11992 17 Mar 1992 • Caribbean Sea 04 July 1991 04 April 1993 - • + Gulf of Mexico

21. INTERCARGO Special Areas (cont.) • The Special Areas where the requirements have not taken • effect may be due to the following reasons: • Lack of adequate reception facilities; • Lack of ratification of the Convention by Coastal States

22. INTERCARGO A few definitions: Operational Wastes are defined as cargo-associated waste and maintenance waste and cargo residue. Cargo Residues are defined as the remnants of any cargo material on board which cannot be placed in cargo holds plus spillage during loading (spillage) or which remain in cargo holds plus spillage after unloading

23. INTERCARGO Plus: • Cargo residues are expected to be in small • quantities • Cargo material contained in the cargo hold • bilge water is not treated as cargo residue • Such bilge water must be discharged from a • loaded hold through the ship’s fixed piping • bilge drainage system

24. INTERCARGO Port Reception Facilities

25. INTERCARGO Regulation 7 of Annex V states: • Each party to the Convention undertakes to ensure the • provision of reception facilities at ports and terminals • for the reception of garbage :- • 1) Without causing undue delay to ships • 2) According to the needs of the ships using them • Each party to the Convention shall notify the IMO of all • cases where the facilities provided are alleged to be • inadequate

26. INTERCARGO Port Reception Facilities Database (PRFD) • FSI13 instructed the IMO Secretariat to develop the • PRFD as a module of GISIS (Global Integrated • Shipping Information System) • Reports on alleged inadequacy of reception facilities • to be made publicly available on the IMO PRFD • Follow-up response by the port States to be posted • within 3 months after receipt of notification of • inadequacy • PRFD went live 1st March 2006 • Member States enter own port reception facilities • Public access on a view-only basis • Website: http//gisis.imo.org

27. INTERCARGO Port Reception Facility Data (cont.) • Three main tools available to the user in GISIS:- • - Location of reception facility in a port • Search for available reception facilities in a port • Locate information on alleged inadequacies • Plus, there is an industry PRF Forum which:- • Aims to ensure the provision and use of PRF • internationally as per MARPOL; • Focus on technical and operational matters • (avoid political); • Meets twice a year; produces an Action List • -

28. INTERCARGO Cargo Hold Water Wash

29. INTERCARGO Cleaning after Green Delayed Petcoke • Sweep and remove all solids • High pressure water wash all holds with • warm water (50-60deg C) • Footprint/staining will be left behind on hold • coating • Use detergents as prescribed by MEPC • Circular MEPC.2/Circ.8 • Pump out to port reception facility

30. INTERCARGO What happens if the port or terminal will not or cannot accept the Water Wash? • Provided the prescribed detergent has been used, the oily • content or sheen will be emulsifed into a harmless solution. • - Retain the water wash solution on board in a suitable tank. • Pump out the harmless solution into the ocean not less than • 50nm from land as prescribed in Annex I. • - Here we have a joining of bulk carrier and tanker interests.

31. INTERCARGO Warning! • If you do not supply the correct detergent for • cleaning as laid down by MEPC Circular • MEPC.2/Circ.8 your Master will have severe • problems: • Port reception facilities will almost certainly • refuse to take the solution; • - It cannot be pumped out at sea – ANYWHERE.

32. INTERCARGO In Conclusion: • The amendments to the Garbage Record • Book may cause PSC problems • Not all Special Areas have a strict ban • on disposal of cargo residue at sea • Bilge water in loaded hold condition does • not contain cargo residue – by definition • Refer to PRFD on GISIS and report • inadequate facilities • Take care with disposal of hold water wash

33. INTERCARGO Finally …. Do not create problems for your Master and have him branded as a criminal!

34. INTERCARGO INTERNATIONAL ASSOCIATION OF DRY CARGO SHIPOWNERS Thank you www.intercargo.org www.shippingfacts.com http//gisis.imo.org www.themaritimefoundation.com