Chemical Tankers:Regulatory Update

Janet Strode

General Manager

International Parcel Tankers Association

• Application of Inert Gas

• Review of requirements for discharge of residues

• Review of IBC Code

• Carriage of Used Cooking Oil

• Tank cleaning products

• Blending on Board

• EU Acceptable List of Immediate Previous Cargoes

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APPLICATION OF INERT GAS TO CHEMICAL TANKERS AND SMALLER OIL

TANKERS

MSC 93 (June 2014) expected to adopt draft amendments to SOLAS:

Application of inert gas

new oil tankers below 20,000

dwt

new chemical tankers

–lower size limit of 8,000 dwt

–vessels of less than 20,000 dwt to be allowed to use shore-supplied inert gas

–chemical tankers to be allowed to apply inert gas on completion of loading but before commencement of discharge

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Oxygen dependent inhibitors

IBC Code Reg 15.13 Cargoes protected by additives

15.13.5 When a product containing an oxygen dependent inhibitor is to be carried in a ship:-

.1 [constructed on or after date of entry into force of the new SOLAS IG requirements], and for which inerting is required as per paragraph 11.1.1 of this Code, the application of inert gas shall not take place before loading or during the voyage, but shall be applied before commencement of unloading.

.2 [constructed before the entry into force of the SOLAS amendments for IG], the product shall be carried without inertion (in tanks of a size not greater than 3,000 m3). Such cargo shall not be carried in a tank requiring inertion under the requirements of SOLAS Chapter II-2

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Amendment to the IBC Code:

15.13 Cargoes protected by additives

…Ships carrying such cargoes shall be provided with a certificate of protection from the manufacturer … specifying:

1. The name and amount of the additive present

2. Whether the additive is oxygen-dependent and if so, the minimum level of oxygen required in the vapourspace of the tank for the inhibitor to be effective"

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REVIEW 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

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

Are the measures triggered appropriate to the hazard identified?

prime triggers for higher ship/tank types are inhalation and dermal toxicity

Is product likely to be inhaled or come into

contact with skin?

If No, why are measures necessary?

If Yes, is a higher ship/tank type the best

way to deal with the hazard?

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the ESPH Group began to examine Saturated Vapour Concentration (SVC) and product behaviour in water

No need for stringent carriage

requirements

low Saturated Vapour

Concentration

likely to dissolve or

evaporate in water

• Revised chapter 21 of IBC Code agreed at PPR1

• Review of implications of revised criteria on products in IBC Code is underway

– Initial indications are:

• 9 products would drop from Type 1 Type 2

• 13 products currently ST 2 will be upgraded to ST1 – 8 moving to 1G tanks

• 36 products would move from ST2 to ST3

• 58 products would move from ST3 to ST2

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• Many of the products in question have data missing from their profiles

– Could affect ship typing

• Intention is therefore to:

– Prepare circular to communicate to industry the proposed changes to cargo carriage requirements• Highlighting products for which there is incomplete data and

requesting industry to provide such data

– Apply any further amendments on the basis of data received

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Review of chapters 17 and 18 of the IBC Code

• ESPH 20 (Oct 2014

• BLG 19 (Feb 2015)

Approval of amendments

• MSC and MEPC 2015

Adoption of Amendments

• MSC and MEPC 2015-2016

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Earliest Entry into Force: 2018

REVIEW OF DISCHARGE REQUIREMENTS UNDER MARPOL ANNEX II

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Revision to MARPOL Annex II

• Entered into force 2007

• More stringent requirements for discharge of residues

• Reduced stripping limits

• Regulation of vegetable oils

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• Ship type 2• Pollution Category Y

Residues can be discharged into sea providing cargo does not meet criteria for high viscosity or solidifying substances at discharge temperature

Poly(4+)isobutylene

PIB

“ RSPB believes the risk of PIB is seriously underestimated and we are calling on the International Maritime Organisation (IMO) to urgently review the hazard classification of PIB, and implement regulations that prevent any further tragic and wholly avoidable incidents like the one just witnessed.”

A serious hazard to seabirds and the marine environment

– UK identifies PIB that caused problems as variety with high molecular weight

– Proposes amendment to carriage requirements

– ESPH 19 agrees to have 2 entries in IBC Code for PIB:

A C D E F G H I ’ I ’ ’ I ’ ’ ’ J K L N O

Polyisobutylene

(MW < 224)Y P 2 2G Open No - - Yes O No A,B No

15.19.6;

16.2.9

Poly(4+)isobutylen

e (MW>224)X P 2 2G Open No - - Yes O No AB No

15.19.6;

16.2.6;

16.2.9

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Submission to PPR 1by Denmark, the Netherlands, Norway, Poland, Sweden and the United Kingdom

• “…… discharge of High-Viscosity and Persistent Floating products and their impact on the environment.”

• approximately 66 recorded incidents of waxes and vegetable oils washing up on beaches since 2010

• “Not classic pollution incidents [but]:

– impairs the recreational and tourism values of beaches and coastlines

– Society bears the expense of the clean-up,

– many seabirds die as a result of becoming coated in the substance”

• twenty tonnes cleaned up from one beach;

• a 27-nautical mile yellow slick trailing behind a vessel;

• two successful prosecutions of vessels making illegal discharges;

• used vegetable oil (declared as Yellow Grease) being discharged; and

• the cost of beach cleaning ranging from several thousands to in excess of 0.5 Million Euros

Possible Fixes

• Amend the definition of “high viscosity” in MARPOL Annex II:

“…a noxious liquid substance in category X or Y with a viscosity equal to or greater than 50 mPa’s at the unloading temperature”

“…50 mPa at 200C”

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• Expand the prewash requirements

– include all products defined as “persistent floaters” in the GESAMP Composite List?

• Over 150 products, including:– Vegetable oils and animal fats

– Waxes

– Acids

– Some alcohols

– Alkylates

– Phthalates

– FAME

– Polyolefins

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• Amend the definition of “en route”

“…underway on a course or courses, including deviation from the shortest direct route, which as far as practicable for navigational purposes, will cause any discharge to be spread over as great an area of the sea as is reasonable and practicable.”

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Need to take into account any potential consequences of any further requirements:

• Reception facilities?

• Additional port time?

• Increased emissions in port areas?

• Characteristics of individual products

– e.g. Effect of applying hot water?

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Used Cooking Oil

• Entry in List 4 of MEPC.2/Circ. (components not assessed)

• “Used Cooking Oil of Vegetable Origin”

• Fuelstreamers S.A

• Valid until December 2015 – only for product shipped by Fuelstreamers

• Data has to be submitted

Generic Tank Cleaning Products

Regulation 13.5.2 of MARPOL Annex II:

“ where detergent products are used for the washing of ships' tanks the product shall contain no pollution category X components, except where they are readily biodegradable and present in a total concentration of less than 10% of the additive.”

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MEPC.2/Circ. – Annex 10

"It should be noted that where products or their solutions that appear in chapter 17 or 18 of the IBC Code or list 1 of the MEPC.2/Circular are used as washing media, their discharge shall be governed by regulation 13.5.1 of MARPOL Annex II and they do not need to be listed here."

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Blending on Board1 The physical blending of bulk liquid cargoes during sea voyages 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.

2 The prohibition in paragraph 1 does not apply to the blending of products for use in the search and exploitation of seabed mineral resources on board ships used to facilitate such operations.

3 Any production process on board a ship during sea voyages is prohibited. Production processes refer to any deliberate operation whereby a chemical reaction between a ship's cargo and any other substance or cargo takes place.

4 The prohibition in paragraph 3 does not apply to the production processes of cargoes for use in the search and exploitation of seabed mineral resources on board ships used to facilitate such operations. ”

ESPH 17

“9.2 The representative from IPTA asked the Working Group for confirmation that recirculation of a cargo within its cargo tank during the voyage for the purposes of maintaining cargo homogeneity is not prohibited under MSC-MEPC.2/Circ.8, including when two or more different products have previously been loaded into the cargo tank within port limits. The Group confirmed that since there was no transfer of cargo between tanks, and no new product created during the voyage, MSC-MEPC.2/Circ.8 would not apply. The Group further confirmed that the circulation of cargo through external heat exchangers was not intended to be prohibited under MSC-MEPC.2/Circ.8.”

EU Acceptable List

• European Food Safety Agency (EFSA) has reviewed all the products in the EU List according to Codex criteria

• Completed November 2012

• Revised EU List of Acceptable Previous Cargoes expected to be issued imminently

ADDED• Ammonium nitrate solution• Calcium nitrate (CN-9) solution and their double salt • NH4NO3.5Ca(NO3)2.10H2O, named "nitric acid, ammonium calcium

salt”• Fatty acid esters —[Now includes all bulk commercial FAME products]• Fructose• Hydrogen peroxide• Iso-butanol (2-methyl-1-propanol)• Kaolin slurry• Unfractionated fatty acid mixture or mixtures of fatty acids from

vegetable oils and fats [from edible sources]• Unfractionated fatty alcohol mixture or mixtures of fatty alcohols from

vegetable oils and fats [from edible sources] • Unfractionated fatty esters or mixtures of fatty esters from vegetable

oils and fats [from edible sources]

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MODIFIED

Previous cargo restriction removed

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• Animal, marine and vegetable and hydrogenated oils and fats according to the MEPC.2/Circ. of the IMO

• Molasses, which has been produced from the conventional sugar processing industry using sugar cane, sugar beet, citrus or sorghum

• Paraffin wax (food grade)

• Potable water • Calcium chloride solution • Potassium hydroxide solution • Sodium hydroxide solution

REMOVED• Beeswax (white and yellow)

– Believed to be no longer carried in bulk

• Calcium lignosulphonate– Better product specification and more data needed

• Candelilla wax – Believed to be no longer carried in bulk

• Carnauba wax - (Brazil wax)– Believed to be no longer carried in bulk

• Montan wax B– Believed to be no longer carried in bulk

• Silicon dioxide (microsilica) – Believed to be no longer carried in bulk

• Wine lees (vinasses, vinaccia, argol, vini, argil, arcilla, weinstein, crude cream of tartare, crude potassium bitartrate) – Better product specification and more data needed

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FOSFA List but not EU List

• Cyclohexanol• Cyclohexanone• Dairy products [allowed as foodstuffs]• Ethyl tertiary butyl ether (ETBE)• Fatty alcohols - synthetic primary alcohols (C9 – C15)• 2,3-butanediol (2,3 butylene glycol)• Lecithin [Allowed as foodstuff]• Methyl acetate• n-Nonane (nonyl hydride)• Urea (carbamide) [Allowed as a food additive]

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Thank you for your attention

25 years serving the chemical tanker industry

www.ipta.org.uk

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