Regulatory UpdateJanet Strode

General Manager

International Parcel Tankers Association

• Founded 1987

• Attained consultative status at IMO 1997

• Project leader on IMO Workshops worldwide on MARPOL Annex II

• Cooperation with USCG and European Commission

• EQUASIS Editorial Board

• 24 years on FOSFA Oils and Fats and Technical Committees

• Setting up of CDI

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• Application of inert gas to chemical tankers

• Damage Stability for Tankers

• Review of chapters 17 and 18 of the IBC Code

• Carriage of Biofuel Blends

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APPLICATION OF INERT GAS TO CHEMICAL TANKERS AND SMALLER OIL

TANKERS

FP 53 - 2009• “…recognized that the fitting of appropriate inert gas systems

to NEW oil tankers below 20,000 dwt and NEW chemical tankers carrying low-flash cargoes would minimize the risk of fires and explosions”

• “…. benefits of such fitting should outweigh any negative effects of the introduction of IG systems, such as

– increased fuel consumption

– increased CO2 emissions

– increased building costs

– increased complexity of procedures

– possible increase of the risk associated with tank entries”

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FP 54 – April 2010

• Joint ICS/IPTA paper with information on operational issues

• Proposes separate operational requirements for the application of inert gas to chemical tankers

• Sub-Committee agrees that where vessel is carrying IBC Code cargoes, can have option of applying nitrogen either on completion of loading or immediately prior to discharge

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Lower size limit• 8,000 DWT

– Japan, China, Brazil, Singapore, Panama and Turkey

• 500 GRT

– Bahamas, Norway, EU States, Intertanko, OCIMF

• IPTA and ICS: seems that problems occur below 5,000 DWT,

and therefore would not support any thing below 5,000 DWT

• Proponents of 500 grt eventually agree to compromise on

5,000 DWT

• FP 55 to decide on lower size, based on range between 5,000

DWT and 8,000 DWT

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BLG 15• Reminds FP that some cargoes have oxygen-

dependent inhibitors

• Concludes that column h of chapter 17 of the IBC Code not appropriate for incorporating future SOLAS inert gas requirements for new ships,

• Took note that the review of Resolution A864(20) -Recommendations for Entry into Enclosed Spaces Aboard Ships had been completed and finalised a specific footnote addressing entry into cargo spaces on all tankers subject to inerting with nitrogen

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Damage Stability of Tankers

MSC 83 (2007)• Denmark, Finland, Germany, Norway, Sweden, UK and

Intertanko propose new work programme item on damage stability of tankers

• “ Taken in conjunction with the low margins of stability often exhibited by the standard loading conditions in approved stability information for tank vessels, there is a probability that these ships are regularly operating in loading conditions with reduced or zero levels of residual stability, even where these loading conditions appear to be closely related to a standard loading condition”

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SLF 52 - 2010• UK - survey of 73 oil, chemical and gas tankers

entering and leaving UK ports

• non-compliance =

– variation of more than 1% by weight in any cargo or ballast tank from conditions outlined in the stability book

– vessel not verifying that the damage stability requirements were still being complied with

• 23 vessels not compliant

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• “over one third of tank ships regularly sail in conditions of loading significantly different from those in the approved stability information”

• “This poses an unacceptable risk to life at sea and to the environment and enforcement action ……… is justified under the existing instruments which apply to these vessels”

• Sub-Committee concludes that there is some ambiguity in regulations

• Agrees that guidelines should be developed for verification of damage stability at

– initial approval stage

– onboard prior to sailing

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SLF 53 – January 2011agrees that further discussion needed and sets up

Correspondence Group that will report back to SLF 54 in 2012

– Guidance also needed for Port State Control

– clarification of “loaded in accordance with” an approved condition

• Are deviations allowed and, if so, to what extent?

– methods of verification of compliance,

• stability software,

• KG/GM curves

• shore assistance

– clarification of the terms and conditions for use of stability software

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Paris MOU CIC

• 1 September 2010 to 30 November 2010

• 1065 tankers inspected in order to check:

– Vessel loaded in accordance with Stability book?

– If not, have checks been carried out to ensure the loaded condition complies with damage stability regulations?

“A significant number of tankers could pose a risk to the environment”

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• 94 (8.8%) inspections resulted in deficiencies

• 2 oil tankers and 2 chemical tankers detained

• 77 oil tankers, 84 chemical tankers and 12 gas tankers (16.2% of total) could not demonstrate that they were normally loaded in accordance with the Stability Book

• detailed results to be reviewed Port State Control Committee in May and report to be submitted to the IMO

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REVIEW OF CHAPTERS 17 AND 18 OF THE IBC

CODE

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Changes to GESAMP hazard profiles

2007 amendments applied on pollution

grounds only

New criteria for assigning carriage

requirements applied to new products only

Dual standard

product list

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– around 18% of products would be affected

– 17 products moved from chapter 18 to chapter 17

– “significant number” increase in ship type of one level

– “small number” increase in ship type of 2 levels

– A few cases, increase in tank type from 2G to 1G

If all the products in the Code were re-evaluated according to the current criteria:

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Tank type 2G = Integral tank

– forms part of ship’s hull and may be stressed in in same manner and by same forces which stress the ship’s hull structure

Tank type 1G = Independent tank

– “…not contiguous with, or part of , the hull structure. An independent tank is built and installed so as to eliminate whenever possible (or in any event to minimize”) its stressing as a result of stressing or motion of the adjacent hull structure “

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Representative sample of 10 products examined to establish which criteria trigger particular

requirements

Dermal toxicity triggers enhanced ship type and/or

tank type

Inhalation toxicity triggers enhanced standards for

venting, gauging and vapour detection

Long term effects could also trigger similar

requirements

BLG 15

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Possible action:

• Full review of carriage requirements

• Allowing period for updating of data by industry

• Partial review, based on worst case anomalies

• Revisit chapter 21 of the IBC Code

ESPH 17 (October 2011) to consider further

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Carriage of Biofuel Blends

Fatty acid methyl esters (FAME)

Vegetable oil

Bio-ethanol

“Renewable Diesel”

Biofuel

Diesel

Gasoil

Gasoline

Petroleum

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Draft Guidelines for the Carriage of Blends of Biofuel and Petroleum (agreed at BLG 15 in February 2011)

75% or more petroleum oil

• Product subject to MARPOL Annex I

• ODME – to be in compliance with regulation 31 of Annex I of MARPOL and approved for the mixture being transported

• Until 1 January 2016 bio-fuel blends may be carried when the ship's ODME is not approved, provided that tank residues and all tank washings are pumped ashore

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More than 1% but less than 75% petroleum oil

• Product subject to MARPOL Annex II

• Pollution Category X, Ship Type 2

– carriage requirements based on the generic entry defined for the biofuel blend concerned

– Generic carriage requirements will be incorporated into List 1 of the MEPC.2/Circular

1% or less Petroleum oil

• Product to be treated as the Annex II product in the blend

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a c d e f g h i’ i’’ i’’’ j k l n o

Blends of Diesel/gasoil and

FAME

(>25% but<99%)

X S/P 2 2G Cont No - - Yes C T ABC No

15.12,

15.17,

15.19.6

Blends of Diesel/gasoil and

vegetable oil

(>25% but<99%)

X S/P 2 2G Cont No - - Yes C T ABC No

15.12,

15.17,

15.19.6

Blends of Gasoline and

Ethyl alcohol

(>25% but<99%)

X S/P 2 2G Cont No T3 IIA No C F-T ABC No

15.12,

15.17,

15.19.6

Blends of Diesel/gas oil and

Alkanes (C10-C26), linear

and branched with a

flashpoint > 60oC

(>25% but <99% by volume)

X S/P 2 2G Cont No - - Yes C T ABC No 15.12,

15.17,

15.19.6

Blends of Diesel/gas oil and

Alkanes (C10-C26), linear

and branched with a

flashpoint ≤ 60oC

(>25% but <99% by volume)

X S/P 2 2G Cont No T3 IIA No C F-T ABC No 15.12,

15.17,

15.19.6

• Draft Guidelines still to be formally adopted by the Maritime Safety Committee and Marine Environment Protection Committee

• In the meantime the interim guidance has been extended to 1 September this year

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• Blends can be carried under provisions of MARPOL Annex I providing the proportion of biodiesel or bio-alcohol does not exceed 15 % (B15/E15).

• residues and tank washings must be pumped ashore

unless ODME equipment is certified as able to deal

with such blends

• blends containing more than 15% biofuel: tripartite

agreement

Interim Guidance (agreed at BLG 10 in 2006)

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Biofuel Blends in MEPC.2/Circ.16• List 2

• Alcoline (Greenergy)

• Etamax (SEKAB)

• List 3• E85 VSS (Vertical)

• E85 VWS (Vertical)

• E90 (Fuelstreamers)

• E90 (Shell)

NOS 8 • Pollution category Y •Ship Type 3

•Pollution category X•Ship Type 2

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• Blending on board :

– the mixing of two products resulting in one single product

– reflects only physical mixing as distinct from any chemical processing

• Blending operations only to be undertaken within port limits

• Blending on board during a sea voyage to create new products is prohibited (See MSC-MEPC.2/Circ.8)

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Blending at Sea – MSC-MEPC.2/Circ.8The MSC and the MEPC noted that there were concerns that the practice of the physical blending of MARPOL regulated cargoes on board during the sea voyage for the purposes of creating new product blends presents clear hazards for the safety of the ship and protection of the marine environment. Having considered the proposal by the BLG Sub-Committee the Committees agreed that such practices should be prohibited and that mandatory provisions should be developed in that respect under the auspices of both Committees.

Until the matter can be further discussed in detail by the BLG Sub-Committee and approved by the Maritime Safety Committee and the Marine Environment Protection Committee, physical blending refers to the process whereby the ship’s cargo pumps and pipelines are used to internally circulate two or more different cargoes within the ship with the intent to achieve a cargo with a different product designation. This circular does not preclude the master from undertaking cargo transfers for the safety of the ship or protection of the marine environment.

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DRAFT REGULATION 5-2 OF SOLAS CHAPTER VI

PROHIBITION OF THE BLENDING OF BULK LIQUID CARGOES DURING THE SEA VOYAGE

The physical blending of bulk liquid cargoes during the sea voyage is prohibited. Physical blending refers to the process whereby the ship's cargo pumps and pipelines are used to internally circulate two or more different cargoes with the intent to achieve a cargo with a new product designation. This prohibition does not preclude the Master from undertaking cargo transfers for the safety of the ship or protection of the marine environment. The prohibition does not apply to the blending of products for use in the search and exploitation of sea-bed mineral resources on board ships used to facilitate such operations.

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Thank you for your attention

The internationally recognised Non-Governmental Organisation dedicated to serving the needs of the IMO classified chemical

and product tanker fleets

www.ipta.org.uk

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