MARPOL Annex II Revisions

INTERTANKO

Latin American Panel Meeting

16th November 2005
Miami Beach, Florida

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 MARPOL Annex II Revisions

 The Revision of MARPOL Annex II and the IMO IBC Code was
a long road and has taken some 12 years to achieve.

 It concluded with the adoption by IMO of the revised

MARPOL Annex II 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 accordingly enter into force

and take effect from 1 January 2007.

 Currently there are 5 categories A, B, C, D and an Appendix

III - Appendix III lists products to which the IBC Code does
not apply.

 In line with the re-evaluation process the aim was to simplify

the existing categorisation system
- Existing products will be re-categorised into a new 3 plus 1
category system.

 BUT - The 3+1 system is in effect a 4 category system

 Because - The 4 category system consists of:

1. The 3 = Pollution categories X, Y and Z

2. The +1 = OS (Other Substances).
= 4 categories

 In the 3 + 1 category system (X,Y,Z + OS), The forth

category holds only 8 harmless products: Apple juice, Clay
slurry, Coal slurry, Dextrose solution, Glucose solution,
Kaoline slurry, Molasses, Water

 Vegetable oils will be individually specified and are upgraded

from Category D and Appendix III (of the IBC Code) to
Category Y and Ship Type 2.

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 IMO Ship Type

What is considered IMO Ship Type Space?

 The IBC Code provides standards for the construction of

three types of chemical tankers (Types 1, 2 and 3)

 A Type 1 ship is a chemical tanker intended for the

transportation of products considered to present the greatest
overall hazard and ship Type 2 and Type 3 for products of
progressively lesser hazards

The revised IBC Code indicates:

Cargo tanks shall be located at the following distances inboard:

 Type 1 ships: from the side shell plating, not less than the
transverse extent of damage specified: (B/5 or 11.5m which
ever is less) and from the moulded line of the bottom shell
plating at centreline, not less than the vertical extent of
damage specified (B/15) and nowhere less than 760 mm
from the shell plating.

 Type 2 ships: from the moulded line of the bottom shell

plating at centreline, not less than the vertical extent of
damage specified (B/15 or 6 m which ever is less and
nowhere less than 760 mm from the shell plating.

 Type 3 ships: no requirement.

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 Tank Type Configurations

Tank Type Configurations

B/5 or 11.5m
which ever is
less, but no
where less
than 760mm

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 Certificates of Fitness

The issuance of a Certificate of Fitness (CoF) reflecting the new

ship type criteria will require a revised Procedures and
Arrangements Manual.

P&A Manuals

 We must draw to your attention for the need to have in place

and onboard each ship a revised P&A Manual before
1/1/2007.

 The process of application for the P&A should therefore be

commenced now.

Certificates of Fitness

 The List of Products attached to a new CoF will be compiled

based on the revised Pollution Categories and the ship’s
compliance with the revised carriage requirements.

 The timely training for ships personnel to these new

requirements and procedures also has to be considered.

New Certificates & P & A Manuals

 All Certificates of Fitness as well as all NLS Certificates

issued under the present requirements will become invalid
from 1 January 2007.

 It is assumed that cargoes legally loaded before 1 January

2007 will be allowed 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 an IBC Code CoF or NLS
Certificate issued under the revised requirements.

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 Stripping Requirements

 Stripping performance requirements apply to all tankers

holding a Chemical Carrier Code CoF.

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. New builds will require such
for all pollution categories X, Y and Z.

 The additional requirements for operation within Special

Areas (except the Antarctic) have been deleted.

 Every ship constructed on or after 1 January 2007 shall be

provided with a pumping and piping arrangement to ensure that
each tank certified for the carriage of substances in Category X, Y or
Z does not retain a quantity of residue in excess of 75 liters in the
tank and its associated piping

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 2007 Deadline

 The revised requirements may not be used before 1 January

2007. This means that a newbuilding being delivered in
December 2006, will have to be certified under the current
requirements (with “old type” P & A Manual and CoF) and
then again from 1 January 2007 with a “new” P & A Manual
and a “new” CoF with List of Products.

MARPOL Annex II Revisions

Why Will Veg Oils Move?

 Products defined as "Floaters" and "Persistent floaters",

which include vegetable oils, will be assigned to Category Y.
Under the currently defined ship typing criteria this will mean
they have to be carried in IMO Type 2 space.
 Oil like substances will not exist (xylene will require an IBC
COF).

The Veg Oil Compromise

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 This revision was proposed to alleviate concerns raised with
regards to a potential tonnage shortage in the vegetable oil trade
resulting from the re-categorization of many vegetable oils into
the revised Annex II.

Vegetable oils listed in Chapter 17 of the IBC Code will be

regulated as Pollution Category Y and ship Type 2, and contain a
limit on free fatty acid content.

 The IMO agreed that the individually identified vegetable oils

should in principle be carried in Ship Type 2.

 However, via regulation 4.1.3 of the revised MARPOL Annex

II, an administration might allow the carriage of these
substances in a ship Type 3 “ONLY” if the ship complies with
all requirements for a ship Type 3, as identified in the IBC
Code, except for cargo tank location.

 The cargo tank location shall be in accordance with

regulation 4.1.3.2 of the revised MARPOL Annex II but these
ships must be constructed with double sides meeting the
requirements for IMO ship Type 2 vessels and double bottom
requirements of B/15 or 2 meters (whichever is the lesser)
and the CoF shall indicate the exemption granted.
 Next to each of these product listings in Chapter 17 will be a
footnote referring to regulation 4.1.3 of the revised MARPOL
Annex II.

Big Movers – Chemicals

Chemicals Current Cat Proposed ST Current Cat Proposed ST

Phenol C Y 2 2
Phosphoric Acid D Z 3 3
Caustic Soda D Y 3 3
Sulphuric acid C Y 3 3
Benzene C Y 3 3
Toulene C Y 3 3
Cumene (Propylbenzene) A Y 3 3
Acetic Acid D Z 3 3
Methanol D Y N/A 3
Ethylene Glycol D Y N/A 3

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 Xylenes C Y 3 2
Acrylonitrile B Y 2 2
MTBE D Z N/A 3
Urea Ammonia Nitrate Soln
(UAN) C Y 3 3
Ethylene Dichloride (EDC) B Y 2 2

Big Movers – Veg Oils & Fats

Vegetable Oils & Fats Current Cat Proposed ST Current Cat Proposed ST

Palm Oil D Y N/A 2

Palm Kernal Oil D Y N/A 2
Soyabean Oil D Y N/A 2
Cottonseed Oil D Y N/A 2
Groundnut Oil D Y N/A 2
Sunflower Oil D Y N/A 2
Rapeseed Oil D Y N/A 2
Corn Oil D Y N/A 2
Coconut Oil D Y N/A 2
Olive Oil D Y N/A 2
Castor Oil D Y N/A 2
Linseed Oil D Y N/A 2
Tallow D Y N/A 2
Lard III Y N/A 2
Fish Oil\ D Y N/A 2

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 Still a Lack of Data

 A large number of products currently classified for carriage

have not been re-evaluated by GESAMP for inclusion in the
revised Annex II because of a lack of data and information,
with the data these products will NOT be listed in the revised
IBC code

 Unless the necessary data are submitted by the end of 2005

the bulk transport of such products is likely to face
substantial problems from 1 January 2007 (because the
required certificate cannot be issued).

 A list of products with missing data has been published by

IMO. Although 60 additional products were recently
evaluated and accepted by IMO about 120 products remain
with missing data

 A revised list has just recently being produced.

What’s INTERTANKO Doing about this?

 Exclusive Press release Lloyds List This week

 Contact with CEFIC, CDI, ACC, ABSA CTAC & regional

chemical Manufacturers

 Requested USCG to include in the Federal Register

 Contacted US & LISCR regarding the possibility of a MEPC

submission.

 A USCG CTAC Work Group has been formed to developing the

MARPOL Annex II NVIC in 2006

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