MARPOL Annex II Revisions MARPOL Annex II Revisions &&

The Associated Revisions of the IBC The Associated Revisions of the IBC CodeCode

INTERTANKOINTERTANKO

31st NPRA International Petrochemical 31st NPRA International Petrochemical ConferenceConference San AntonioSan Antonio

Captain Howard N. Snaith Captain Howard N. Snaith Director, Marine, Ports, Terminal, Environmental & ChemicalDirector, Marine, Ports, Terminal, Environmental & Chemical

AGENDA AGENDA

Annex II Revisions Deadline Remains!Annex II Revisions Deadline Remains! IMO Ship Type Reviewed IMO Ship Type Reviewed Products Still Missing DataProducts Still Missing Data Practical Implications of the Practical Implications of the

Revisions Revisions Biofuels and the RevisionsBiofuels and the Revisions IMO 2006 Schedule IMO 2006 Schedule

Why was Annex II Revised ?Why was Annex II Revised ?The drivers behind the revisions were:The drivers behind the revisions were:

Editorial improvementsEditorial improvements Adaptation to the revised GESAMP Adaptation to the revised GESAMP

procedureprocedure Reduce the number of categoriesReduce the number of categories Simplification of operational Simplification of operational

requirementsrequirements Fewer non-regulated substancesFewer non-regulated substances Reduction of legal dischargesReduction of legal discharges Keeping up with technical developmentKeeping up with technical development Adaptation to the Global Harmonized Adaptation to the Global Harmonized

System (GHSSystem (GHS

MARPOL Annex II MARPOL Annex II RevisionsRevisions

The long-time ongoing revision work The long-time ongoing revision work on MARPOL Annex II and the IBC on MARPOL Annex II and the IBC Chemical Carrier Code concluded Chemical Carrier Code concluded with the adoption of the revised with the adoption of the revised MARPOL Annex II by MEPC 52 (in MARPOL Annex II by MEPC 52 (in October 2004) and the adoption of October 2004) and the adoption of the revised IBC Code by both MEPC the revised IBC Code by both MEPC 52 and MSC 79 (in December 2004). 52 and MSC 79 (in December 2004).

The revised requirements The revised requirements WILLWILL enter into force and take effect from enter into force and take effect from 1 January 2007.1 January 2007.

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

MARPOL Annex II RevisionsMARPOL Annex II Revisions

MARPOL Annex II RevisionsMARPOL Annex II Revisions

The revised system was agreed in 2003 at The revised system was agreed in 2003 at MEPC 49, this revised system is a 3 + 1 MEPC 49, this revised system is a 3 + 1 pollution category system (X,Y,Z + OS). pollution category system (X,Y,Z + OS).

The fourth category (OS or Other The fourth category (OS or Other Substances) includes Apple juice, Clay Substances) includes Apple juice, Clay slurry, Coal slurry, Dextrose solution, slurry, Coal slurry, Dextrose solution, Glucose solution, Kaoline slurry, Molasses, Glucose solution, Kaoline slurry, Molasses, and Waterand Water

Note: Vegetable oils will be specified and Note: Vegetable oils will be specified and are upgraded from Appendix III (of the IBC are upgraded from Appendix III (of the IBC Code) to Pollution Category Y.Code) to Pollution Category Y.

What is an IMO Ship TypeWhat is an IMO Ship Type

The IBC Code The IBC Code provides provides detailed detailed

standards for standards for the construction the construction and equipment and equipment

of three types of of three types of chemical chemical

tankers (Types tankers (Types 1, 2 and 3) 1, 2 and 3)

An IMO Type 1 ship is a chemical tanker intended An IMO Type 1 ship is a chemical tanker intended for the transportation of products considered to for the transportation of products considered to present the greatest overall hazard.present the greatest overall hazard.

IMO Ship Type 2 & 3 are designed for the carriage IMO Ship Type 2 & 3 are designed for the carriage of products with progressively lesser hazardsof products with progressively lesser hazards

(Such requirements include [but is not limited too] (Such requirements include [but is not limited too] extensive damage survival capability requirements of extensive damage survival capability requirements of differing degrees for each ship type).differing degrees for each ship type).

Tank Type Tank Type ConfigurationsConfigurations

Still a Lack of DataStill a Lack of Data All products had to be re-assessed with regards All products had to be re-assessed with regards

to their pollution and safety data, but not all to their pollution and safety data, but not all the data for all the products was available.the data for all the products was available.

December 31, 2005 has come and gone but December 31, 2005 has come and gone but this was the deadline for submission of data to this was the deadline for submission of data to enable these “missing data” products which are enable these “missing data” products which are currently being carried to be re-evaluated by currently being carried to be re-evaluated by GESAMP. GESAMP.

Unless the necessary data is submitted the bulk Unless the necessary data is submitted the bulk transport of these products will likely not be transport of these products will likely not be able to be carried at sea in Bulk after 1/1/2007.able to be carried at sea in Bulk after 1/1/2007.

Still a Lack of DataStill a Lack of Data

One of the solutions being reviewed is to One of the solutions being reviewed is to consider the carriage of these products by consider the carriage of these products by applying the harshest carriage applying the harshest carriage requirements (Pollution Category X & requirements (Pollution Category X & Ship type 1 or 2) until the data is received Ship type 1 or 2) until the data is received for the missing products.for the missing products.

BUT this or any other proposal if made will BUT this or any other proposal if made will have to be made at IMO at BLG 10 or have to be made at IMO at BLG 10 or MEPC 55, both meetings will be held later MEPC 55, both meetings will be held later this year.this year.

Still a Lack of DataStill a Lack of Data

The 42nd session of the GESAMP Working The 42nd session of the GESAMP Working Group on the Evaluation of the Hazards of Group on the Evaluation of the Hazards of Harmful Substances Carried by Ships Harmful Substances Carried by Ships (EHS 42) was held at IMO Headquarters in (EHS 42) was held at IMO Headquarters in London earlier this year.London earlier this year.

The report on this meeting has just The report on this meeting has just recently been released. recently been released. The most recent The most recent meeting report of GESAMP/EHS has meeting report of GESAMP/EHS has indicated that approximately sixty indicated that approximately sixty products remain on the missing data list products remain on the missing data list from an initial list of 120. from an initial list of 120.

Draft List of Products Still Missing Draft List of Products Still Missing Data Data

at February 2006 at February 2006 Alkyl(C8+)amine, Alkenyl (C12+) acid ester mixture Alkyl(C8+)amine, Alkenyl (C12+) acid ester mixture Aluminum chloride (30% or less)/Hydrochloric acid (20% or Aluminum chloride (30% or less)/Hydrochloric acid (20% or

less) solutionless) solution 2-Amino-2-hydroxymethyl-1,3-propanediol solution (40% or 2-Amino-2-hydroxymethyl-1,3-propanediol solution (40% or

less) less) Ammonium bisulphite solution (70% or less) Ammonium bisulphite solution (70% or less) Ammonium thiocyanate (25% or less)/Ammonium Ammonium thiocyanate (25% or less)/Ammonium

thiosulphate (20% or less) solution thiosulphate (20% or less) solution Benzyl chloride Benzyl chloride N,N-bis(2-hydroxyethyl) oleamide N,N-bis(2-hydroxyethyl) oleamide Butyl stearate Butyl stearate Calcium alkyl (C9) phenol sulphide/Polyolefin Calcium alkyl (C9) phenol sulphide/Polyolefin

phosphorosulphide mixture phosphorosulphide mixture Calcium long-chain alkyl phenolic amine (C8-C40)Calcium long-chain alkyl phenolic amine (C8-C40) Camphor oil Camphor oil Caramel solutions Caramel solutions Cashew nut shell oil (untreated) Cashew nut shell oil (untreated) Cobalt naphthenate in solvent naphtha Cobalt naphthenate in solvent naphtha Creosote (coal tar) Creosote (coal tar) Creosote (wood) Creosote (wood)

Draft List of Products Still Missing Draft List of Products Still Missing Data Data

at February 2006 at February 2006 Decyl acetate Decyl acetate 1,3-Dichloropropane 1,3-Dichloropropane Diethylene glycol dibutyl ether Diethylene glycol dibutyl ether 1,4-Dihydro-9,10-dihydroxyanthracene, disodium salt 1,4-Dihydro-9,10-dihydroxyanthracene, disodium salt

solution solution Dodecenylsuccinic acid, dipotassium salt solution Dodecenylsuccinic acid, dipotassium salt solution Ethyl amyl ketone Ethyl amyl ketone N-Ethylbutylamine N-Ethylbutylamine Ethyl butyrate Ethyl butyrate o-Ethylphenol o-Ethylphenol Ethyl propionate Ethyl propionate Ferric hydroxyethylethylenediaminetriacetic acid, trisodium Ferric hydroxyethylethylenediaminetriacetic acid, trisodium

salt solution salt solution Fish solubles (water-based fish meal extract) Fish solubles (water-based fish meal extract) Fumaric adduct of rosin, water dispersion Fumaric adduct of rosin, water dispersion Glycerine (83%), Dioxanedimethanol Glycerine (83%), Dioxanedimethanol Glycerol polyalkoxylate Glycerol polyalkoxylate Icosa(oxypropane-2,3-diyl)s Icosa(oxypropane-2,3-diyl)s Long-chain polyetheramine in alkyl (C2-C4) benzenes Long-chain polyetheramine in alkyl (C2-C4) benzenes Long-chain polyetheramine in aromatic solvent Long-chain polyetheramine in aromatic solvent

Draft List of Products Still Missing Draft List of Products Still Missing Data Data

at February 2006 at February 2006 Methyl heptyl ketone Methyl heptyl ketone 3-Methyl-3-methoxybutyl acetate 3-Methyl-3-methoxybutyl acetate Naphthenic acids Naphthenic acids Nonyl acetate Nonyl acetate Pentaethylenehexamine Pentaethylenehexamine Polyalkylene oxide polyol Polyalkylene oxide polyol Polyglycerol Polyglycerol Polyolefin amide alkeneamine/molybdenum Polyolefin amide alkeneamine/molybdenum

oxysulphide mixture oxysulphide mixture Polyolefin amide alkeneamine polyol Polyolefin amide alkeneamine polyol Poly(tetramethylene ether) glycol (mw 600-Poly(tetramethylene ether) glycol (mw 600-

3000)3000) Potassium salt of polyolefin acid Potassium salt of polyolefin acid n-Propyl chloride n-Propyl chloride Propylene-Butylene copolymerPropylene-Butylene copolymer

Draft List of Products Still Missing Draft List of Products Still Missing Data Data

at February 2006 at February 2006 Propylene dimer Propylene dimer Rosin soap (disproportionated) solution Rosin soap (disproportionated) solution Sodium aluminate solution Sodium aluminate solution Sodium tartrates/Sodium succinates solution Sodium tartrates/Sodium succinates solution Sulpho hydrocarbon long chain (C18+) alkylamine Sulpho hydrocarbon long chain (C18+) alkylamine

mixture mixture Tall oil fatty acid, barium salt Tall oil fatty acid, barium salt Tall oil soap (disproportionated) solution Tall oil soap (disproportionated) solution Trimethylhexamethylenediamine (2,2,4- and 2,4,4-Trimethylhexamethylenediamine (2,2,4- and 2,4,4-

isomers) isomers) Trimethylhexamethylene diisocyanate (2,2,4- and Trimethylhexamethylene diisocyanate (2,2,4- and

2,4,4-isomers) 2,4,4-isomers) Trimethylolpropane polyethoxylate Trimethylolpropane polyethoxylate Trimethyl phosphite Trimethyl phosphite Urea/Ammonium mono- and di-hydrogen Urea/Ammonium mono- and di-hydrogen

phosphate/Potassium,chloride solution phosphate/Potassium,chloride solution Urea formaldehyde resin solution Urea formaldehyde resin solution

Certification of Cargoes Certification of Cargoes

All non-oil cargoes carried in bulk are All non-oil cargoes carried in bulk are classified by the International Maritime classified by the International Maritime Organization (IMO) and/or the vessel’s flag Organization (IMO) and/or the vessel’s flag state.  The carriage requirements for a state.  The carriage requirements for a product are then determined by these product are then determined by these entities using the guidelines set forth by entities using the guidelines set forth by GESAMP and IMO. GESAMP and IMO.

If regulated by the IBC Code those cargoes If regulated by the IBC Code those cargoes must be authorised for carriage on that must be authorised for carriage on that particular ship, and listed on, the ship’s particular ship, and listed on, the ship’s Certificate of Fitness. Certificate of Fitness.

Certification of Cargoes Certification of Cargoes

The bulk carriage of any liquid product The bulk carriage of any liquid product other than those defined as oil (subject to other than those defined as oil (subject to MARPOL Annex I) is prohibited unless the MARPOL Annex I) is prohibited unless the product has been evaluated and categorised product has been evaluated and categorised for inclusion in Chapter 17 or 18 of the IBC for inclusion in Chapter 17 or 18 of the IBC Code (The International Code for the Code (The International Code for the Construction and Equipment of Ships Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk).Carrying Dangerous Chemicals in Bulk).

The MARPOL Annex II Revisions will result The MARPOL Annex II Revisions will result in an amended IBC Code and new in an amended IBC Code and new certification for cargoes and vessels.certification for cargoes and vessels.

Practical Implications of Practical Implications of the Revisions the Revisions

Every chemical tanker is required to Every chemical tanker is required to have a Certificate of Fitness (CoF) – have a Certificate of Fitness (CoF) – indicating that it is certified to carry indicating that it is certified to carry certain products.certain products.

The issuance of a CoF will also require The issuance of a CoF will also require a revised Procedures and a revised Procedures and Arrangements Manual. Arrangements Manual.

Shipping Companies are now Shipping Companies are now therefore starting a process of therefore starting a process of renewal NOW.renewal NOW.

Certificates of FitnessCertificates of Fitness

The new P & A Manuals and the The new P & A Manuals and the new Certificates need to be new Certificates need to be onboard each ship BEFORE the 1 onboard each ship BEFORE the 1 January 2007 deadline. January 2007 deadline.

Class societies and owners are Class societies and owners are working diligently to ensure that working diligently to ensure that in late 2006 in late 2006 both systems will be both systems will be in place.in place.

New Certificates / P & A New Certificates / P & A ManualsManuals

All Certificates of Fitness issued under the All Certificates of Fitness issued under the present requirements will become invalid present requirements will become invalid from 1 January 2007. from 1 January 2007.

This also affects Offshore Support Vessels This also affects Offshore Support Vessels and dry cargo ships with deep tanks certified and dry cargo ships with deep tanks certified for carriage of noxious liquid substances. for carriage of noxious liquid substances.

Cargoes legally loaded before 1 January 2007 Cargoes legally loaded before 1 January 2007 will be allowed to be carried to the scheduled will be allowed to be carried to the scheduled unloading port under the “old” requirements.unloading port under the “old” requirements.

To carry any noxious liquid substance in bulk To carry any noxious liquid substance in bulk from 1 January 2007 all ships will need to from 1 January 2007 all ships will need to hold a Chemical Carrier Code CoF issued hold a Chemical Carrier Code CoF issued under the revised requirements. under the revised requirements.

Two Systems Two Systems

BUT the revised requirements may BUT the revised requirements may not be used not be used before before 1 January 2007. 1 January 2007.

This means that a newbuilding This means that a newbuilding being delivered in December 2006, being delivered in December 2006, will need to be certified under the will need to be certified under the current version of ANNEX II (with current version of ANNEX II (with “old type” P & A Manual and CoF) “old type” P & A Manual and CoF) but also have from 1 January 2007 but also have from 1 January 2007 its “new” P & A Manual and a “new” its “new” P & A Manual and a “new” CoF with revised List of Products.CoF with revised List of Products.

The CoF ListThe CoF List

The List of Products attached to a new The List of Products attached to a new Certificate of Fitness will be calculated based Certificate of Fitness will be calculated based on the revised Pollution Categories and the on the revised Pollution Categories and the ship’s compliance with the revised carriage ship’s compliance with the revised carriage requirements. requirements.

Less sophisticated chemical tankers, Less sophisticated chemical tankers, including those not complying with the including those not complying with the present stripping requirements for the present stripping requirements for the current pollution category B substances, current pollution category B substances, may, under the revised requirements, lose a may, under the revised requirements, lose a very large portion of their current List of very large portion of their current List of Products.Products.

Stripping & Underwater Stripping & Underwater DischargeDischarge

An underwater discharge arrangement for tank An underwater discharge arrangement for tank washing water is required for pollution washing water is required for pollution categories X and Y for ships keel-laid before 1 categories X and Y for ships keel-laid before 1 January 2007. Newer ships will require such for January 2007. Newer ships will require such for all pollution categories X, Y and Z.all pollution categories X, Y and Z.

The waiver possibilities in respect of stripping The waiver possibilities in respect of stripping performance and underwater discharge performance and underwater discharge arrangement for dedicated ships engaged in arrangement for dedicated ships engaged in carriage of products not involving cleaning of carriage of products not involving cleaning of cargo tanks will remain unchanged. cargo tanks will remain unchanged.

The additional requirements for operation The additional requirements for operation within Special Areas (except the Antarctic) within Special Areas (except the Antarctic) have been deleted.have been deleted.

The Veg Oil CompromiseThe Veg Oil Compromise As expected, products defined as "Floaters" and As expected, products defined as "Floaters" and

"Persistent floaters", which include the "Persistent floaters", which include the vegetable oils, will be assigned to Pollution vegetable oils, will be assigned to Pollution Category Y. Under the currently defined ship Category Y. Under the currently defined ship typing criteria this will mean they have to be typing criteria this will mean they have to be carried in IMO Type 2 ship space.carried in IMO Type 2 ship space.

The veg oil industry expressed concern that The veg oil industry expressed concern that there would not be enough Type 2 tonnage to there would not be enough Type 2 tonnage to accommodate the demand post 2007. accommodate the demand post 2007.

At MEPC 52 ( in 2004) a compromise was At MEPC 52 ( in 2004) a compromise was therefore developed by the USA, Netherlands therefore developed by the USA, Netherlands and Panama and accepted by IMO. The and Panama and accepted by IMO. The purpose of the compromise is to alleviate purpose of the compromise is to alleviate concerns regarding a tonnage shortageconcerns regarding a tonnage shortage..

The Veg Oil Compromise The Veg Oil Compromise Accepted at MEPC 52Accepted at MEPC 52

An Administration An Administration maymay exempt ships from the exempt ships from the carriage requirements under Regulation 11 for carriage requirements under Regulation 11 for ships Certified to carry individually identified ships Certified to carry individually identified vegetable oils identified by the relevant footnote vegetable oils identified by the relevant footnote (k) in chapter 17 of the IBC Code, provided the (k) in chapter 17 of the IBC Code, provided the ship complies with the following conditions:ship complies with the following conditions:

1. Subject to this regulation, the NLS tanker shall 1. Subject to this regulation, the NLS tanker shall meet all requirements for ship type 3 as meet all requirements for ship type 3 as identified in the IBC Code except for cargo tank identified in the IBC Code except for cargo tank location; location;

2. Under this regulation, cargo tanks shall be 2. Under this regulation, cargo tanks shall be located at the following distances inboard. The located at the following distances inboard. The entire cargo tank length shall be protected by entire cargo tank length shall be protected by ballast tanks or spaces other than tanks that ballast tanks or spaces other than tanks that carry oil as follows:carry oil as follows:

The Veg Oil Compromise The Veg Oil Compromise Accepted at MEPC 52Accepted at MEPC 52

.1.1 Wing tanks or spaces shall be arranged such Wing tanks or spaces shall be arranged such that cargo tanks are located inboard of the that cargo tanks are located inboard of the moulded line of the side shell plating nowhere moulded line of the side shell plating nowhere less than 760 mm; andless than 760 mm; and

.2 Double bottom tanks or spaces shall be .2 Double bottom tanks or spaces shall be arranged such that the distance between the arranged such that the distance between the bottom of the cargo tanks and the moulded line bottom of the cargo tanks and the moulded line of the bottom shell plating measured at right of the bottom shell plating measured at right angles to the bottom shell plating is not less angles to the bottom shell plating is not less than B/15 (m) or 2.0 m at the centreline, than B/15 (m) or 2.0 m at the centreline, whichever is the lesser. The minimum distance whichever is the lesser. The minimum distance shall be 1.0 metre.shall be 1.0 metre.

The The relevant certificaterelevant certificate shall indicate the exemption shall indicate the exemption granted. granted.

MARPOL Annex II RevisionsMARPOL Annex II Revisions

Despite the rumours Despite the rumours

veg oils veg oils willwill move move As of today, no extensions or delays As of today, no extensions or delays

have been accepted by IMO. have been accepted by IMO. On 1 January 2007 veg oils will On 1 January 2007 veg oils will

have to be carried in IMO Type 2 or have to be carried in IMO Type 2 or 3 space.   3 space.  

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

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. 

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 It will be the guidance used by will be the guidance used by industry and regulators.industry and regulators.INTERTANKO is Chairing this INTERTANKO is Chairing this GroupGroup

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).

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.

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:

1. Palm oil fatty acid methyl ester (currently in the IBC Code)

2. Coconut oil fatty acid methyl ester (currently in the IBC Code)

3. 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.

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.

 

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.

IMO and the 2006 ScheduleIMO 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:

1.BLG – 10 – April 2006 2.MEPC 55 – October 2006

Thank you for your Attention