'"Transportation

The lver Pride is 3. typical edible oillliquid carlo anker.

Proposed revisions to rules for fats andoils transport at sea may add to costs

Ocean-going ships carryingfats and oils have beenallowed to discharge suchcargo into oceans and seas,often when cleaning (stripping)their holds and tanks.However, this practice hasbeen questioned, and proposedrevisions to internationalagreements on shipping couldchange the rules.

By Amanda Kolli,%Inform editor/writer

Volume 12 • October 200 I • Inform

Under MARPOL, the InternationalMaritime Organization's (lMO) con-vention on transoceanic shipments, fatsand oils are considered "non pollu-tams"-meaning that while there arerestrictions on when and where fatsand oils can be discharged, there areno limits as to how much of the prod-uct can be disposed of at sea.

The idea of unlimited discharges ofany product has come under fire inrecent years as a practice that poten-tially could damage marine wildlifeand resources.

A major turning point in reviewing

the way MARPOL categorizes prod-ucts came at the 1992 United Nations(U.N.) Conference on Environmentand Development in Rio de Janeiro,Brazil, when delegates approved a pro-gram calling for global harmonizationof hazard classification and labeling ofchemicals. That required a new look atthe MARPOL agreeemeru.

Soon after the 1992 UN conference,the lMO committee on bulk liquids andgases (BLG) agreed TO review twoamendments, or annexes, to the MAR-POL agreement. The second annex,which has five categories (known as A,

97J

THREE

INDUSTRY

OBSERVERS,

AND.\N IMOREI'Rt:SE!'\.'TATIVE,

WERE ASKED TO

ANSWER QUESTIONS

A80lIT 11-11:

POSSIIIl.E

RECLASSIFICATION.

Robert Reeves, presidentof the Institute of Shorteningand Edible Oils, a U.S. tradeassociation based inWashington, DC, thar repre-sents refiners of edible oilsand fats. Reeves also hasparticipated in activitiesof the National lnsritureof Oilseed Products (NIOP), one of the groupsrepresented on the (MO Industry Working Group.

Liam Rogers. marketingmanager at Hudson TankTerminals of Port Newark,New Jersey, which operatessrorage and loading facilitiesfor international cargoes,including fats and oils. Rogershas been acrive in lOPmeetings as well as the (MOIndustry Working Group.

Stuart Logan, chiefexecutiveof FOSFA International, a tradeassociation founded in 1971through the merger of predecessororganizations. FOSFA, based inLondon, United Kingdom, is aprofessional international contract-issuing and arbitral body concernedwith world trade in otlsccds, oils,and fats. Logan is chairman of theIndustry Working Group.

John Crayford, seniortechnical officer, subdivisionfor pollution prevention,marine environmentdivision, InternationalMaritime Organization(lMO), based in London,United Kingdom. Crayfordhas served as staff liaison ~to the IMO IndustryWorking Group, a committee of trade associationrepresentatives that provides information to IMO.

MARPOL to make them more "user-friendly," led to the revision of the pol-lution categories under MARPOL

B, C, D, and Appendix III-from mostto least restrictive), lists fats and oils incategory D. In 1995, IMO's workinggroup on the Evaluation of Safety andPollution Hazards of Chemicals (ESPH)announced that the existing five-category system could be simplifiedinto a three-category system (Table I).

Many in the fats and oils industry saythat this "simplification" will mean morerestrictions on fats and oils transportation.

Three industry observers, as well asa representative of IMO, were askedby inform to answer some questionsabout the possible reclassification.

Fi1 \Vhy are MARPOL~ annexes being revised?

Ragen: As a result of the 1992 EarthSummit in Rio de Janeiro, theOrganization for EconomicCooperation and Development(OECD) was asked to harmonize con-flicting criteria used for carriage ofdangerous goods via ship, rail, andtruck. All U.N. bodies were to workwith OECD on any revisions of sub-stances carried in bulk. This, in con-junction with a decision made by BLCin 1995 to update Annexes I and II of

Wlllat progress has beenmade regarding revisionof MARPOL annexes?

Reeves: There has apparently beenslow but steady progress on the revi-sions of MARPOL Annexes I and II.Annex I deals with the prevention ofpollution by petroleum oil. Annex IIapplies to noxious liquid substancescarried in bulk at sea and therefore is

Volume 12 • October 200 I • Inform

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'"

ABBREVIATIONS

Many of the organizations involved in trying to reduce pollution ofmarine waters are best known by their abbreviations. Here's a listof some of the key organizations mentioned in these articles:

IMO; Inrernarional Maritime Organization; an arm of the UnitedNations that regulates marine transportation.

HARPOl 7J/7B:The International Convention for Prevention ofPollution from Ships; adopted by IMO in 1973 and revised in1978.

of particular interest to the edible fatsand oils industry.

The criteria by which Annex ll-lisr-ed substances are categorized currentlyare being revised to include physicaland biological properties that maydetermine their safety and environmen-tal fate. The appropriate placement ofthese substances into "pollution cate-gories" has required extensive reviewof all the noxious liquid substancesknown to be transported at sea. Thisprocess has been in progress for severalyears and is expected to be finalized in2003. It is reported that about 65% ofthe chemicals currently listed have beenassigned to a GESAMP hazard profile.GESAMP is IMO's Joint Group ofExperts on the Scientific Aspects ofMarine Pollution-Working Group onthe Evaluation of the Hazards ofHarmful Substances.

HEPC: Marine Environment Protection Committee; one of theIMO committees that must endorse proposed revisions in ship-ping rules before IMO can adopt them.

HSC: Marine Safety Committee-the other IMO committee thatmust endorse proposed revisions before JMO can adopt them.

ESPH: Evaluation of Safety and Pollution Hazards ofChemicals-this working group evaluates safety and pollutionhazards.

BlG: Bulk Liquids and Gases; a subcommittee of MEPC and MSCthat forms a revision proposal based on ESPH recommendations.

GESAHP-EHS: Joint Group of Experts on the Scientific Aspectsof Marine Pollution-Working Group on the Evaluation of theHazards of Harmful Subsrances-a group of volunteer scientistsfrom around the world who will review data submirted frommembers of the industry working group.

IWG: Industry Working Crcup-cccmprised of members of the fatsand oils industry (listed below).

FOSFA: Federation of Oils, Seeds and Fats Associations; FOSFAis secretariat of the IMO/BLG Industry Working Group.

NIOP: National Institute of Oilseed Products; this U.S.-b3sedindustry group has been sharing information with the U.S. CoastGuard, which acts as the U.S. representative to the IMO, andwith the IMOfBLG Industry Working Group.

PORIH: Palm Oil Research Institute of Malaysia (now theMalaysian Palm Oil Board)

UCAP: United Coconut Associations of the Philippines

NIOP: National Institute of Oilseed Products

IFOHA: International Fishrneal and Oil Manufacturers'Association

NRA: National Renderers Association

FEDIOL: European Community Seed Crushers' and OilseedProcessors' Federation

APAG: European Oleochemicals and Allied Products Group

OECO: Organization for Economic Cooperation and Development,an organization of 30 member nations that work to promoteopen-market economies and liberalized trade.

Rogers: An IMO/BLG IndustryWorking Group (IWG) was formedto deal with supplying information toregulators. The IWG consists of theFOSFA lnremarional, Palm OilResearch Institute of Malaysia(PORIM, now the Malaysian PalmOil Board), United CoconutAssociations of the Philippines(UCAr), National Institute of OilseedProducts (NIOP), InternationalFishmeal and Gil Manufacturers'Association (lFOMA), NationalRenderers Association (NRA),European Community Seed Crushers'and Oilseed Processors' Federation(FEDlOL), and the EuropeanOleochemicals and Allied ProductsGroup (APAG).

The work of the IWG is beingadministered by FOSFA, with StuartLogan as its chairman. An inventory offats and oils and oleochemicals wasdeveloped as a starting point from

Volume 12 • October 200 I • Inform

SVSTI"

Maximum allowable dischuge (in liters)Existing ships New ships

None None300 100900 300Unrestricted UnrestrictedUnrestricted Unrestricted

Table ICURIUNT

Catego~

ABCoAppendbc III

PRO,"OSED SYSTEM

'"

Iej:onditlons of dischugeregulated

Not a'n.lh.bley"y"y"No

Catego~XyZ

Maximum allowable dischuge (in liters)None100900

which to begin data collection. TheIWG submitted its data to IMO onApril 24, 200 I.

Crayford: It is anticipated that adecision on the new criteria for assess-ing pollution categories and ship types,based on the revised GE$AMP hazardprofiles, will be made next year. Thiswill allow Annex II to be finalized andso adopted by around 2005.

C£SAMI' developed a newhazard evaluation procedure,which was used by industry tosubmit data. \'(Iould you pleaseexplain this new procedure?How does it differ from the ailepreviously in place?

Crayford: The original five-column(category) hazard profile system usedby GESAMP to convey the propertiesof products transported by sea wasregarded as tOOsimple and inadequateto convey a complete picture of thehazards of the products. For example,a "+" in column A defined a productas having bioaccumulation potential inassociation with other harmful effects,

which were not defined. The revisedsystem separates these properties tomake the picture clearer.

There has also been a greater under-standing of the properties of productsthat may have an effect on the environ-ment. As a result, biodegradation isevaluated in the new system, as well asthose physical properties that couldresult in the product floating on thesurface of the sea long enough to havean adverse effect on such creatures assea birds.

In addition, GESAMP has expandedits evaluation of mammalianTOxicological effects so that they can beused to ensure the safety of ships'crews, as well as protection ofnatural resources (e.g., beaches).

Fi1 What information did industry~ submit using this system?

Logan:The primary vehicle for dataexchange was the BLG product datareporting form. This comprises fivesections under the headings ProductIdentity, Physical Properties, RelevantChemical Properties, MammalianToxiciry, and Marine Pollution.

One of the IWG's problems, andindeed initial concerns, was that theBLG form was devised for chemicals,and various IMO groups have beenrevising and developing the structureand content of the form in parallel tothe vegetable oil industry's task to pro-vide data ahead of submission dead-lines (April 200 I).

Some 14 completed forms coveringthe major oils and fats on an individ-ual basis were submirred to IMO'sSecretariat in April, although theIWG took the initiative to develop ageneric data form covering thetriglyceride oils and fats, C-8 to

C-24. This approach was adapted inorder ro provide GESAMP with con-solidated data, in the belief that ani-mal, vegetable, and marine oils andfats, and their derivatives carried inbulk (exceeding 50 metric tons) byocean carrier could be grouped col-lectively, if the need arose, under anyrevised Annex II categories in chapter18, "List of Chemicals to Which theCode Does Not Apply," wherein veg-crable oils, vegetable acid oils, andderivatives (distillates) are listed asunder category D.

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Volume 12 • October 200 I • Inform

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fi1 \Vhat ioill be done with thisI;;::J i,,(ormatioll?

Reeves: The IMO/GESAMP havetaken the data collected from varioussources and are attempting 10 establisha three- or five-step hazard classifica-tion system using the physical andchemical property data. The resultantpollution category to which a noxiousliquid substance is assigned will dictatehow that substance must be carried atsea and the cleaning procedures neces-sary following its transport.

Rogers: The GESAMP-EHS (evalua-tion of harmful substances) evaluationswill be submitted to to the Evaluationof Safery and Pollution Hazards ofChemicals (ESPH) corurninec. ESPHwill assign any new categories as rec-ommendations to BLG. BLG willdecide whether to include these recom-mendations in its revision of Annex Iand n and submit them to the MarineEnvironment Protection Committee(MEPC; IMO's senior technical body).MEPC will generate any new regula-tions.

\Vhy change the [ioe-categorysystem to a three-categorysystem, as ESPH has indicatedmigbt happen?

Crayford: Almost from the time thefive-category system was developed,ESPH recognized that it was unneces-sarily complex. As a result, considera-tion has been given to simplifying it aspan of the exercise of simplifyingAnnex II as a whole.

In the five-category system, categoryA was regarded as an indication thatthe product was such a severe marinepollutant that the slops resulting fromtank cleaning would need to be put

ashore for proper treatment as theycould not be [discharged] into the sea,even in small amounts. The differencebetween categories Band C wasregarded as tOOsmall to be significantand so it was decided that these couldbe combined into one category.Category D and Appendix III (non pol-lurnnrs] do not have any restrictions onthe amount of product that can be purinto the sea, which, b)' eoday's stan-dards, is regarded as environmentallyirresponsible and therefore unaccept-able.

As a result, the old five-categorysystem may be replaced b)' a simplerthree-category one.

How ioould you respond to tl}cfats and oils industry memberswho say that by defall/t, thethree-category system will bemore restrictive (or them thanthe five-category system, andtherefore more costly?

Crayford: Uncontrolled discharge oflarge quantities of vegetable oils have,allegedly, been responsible for thedeaths of thousands of sea birds, whichis a situation that must be regarded asunacceptable these days.

It is true that many of these prod-UCtSare currently unregulated and sothe new system would impose newrestrictions on them. However, Ibelieve that the new restrictions willonly impose requirements that are inline with good commercial practice.That is, as much of the product as ispracticably possible will have to betransferred from rhe ship to theshore. It is not anticipated that theseproducts will be forced onto chemi-cal tankers, with the associated addi-tional COSTS of transport, as a resultof requiring efficient stripping [clean-

Shippers of palm fatty add distillate usually heat the $Glid In their tankers before reaching port-In liquid form,however, the tankers tend to overilow, releasing the palm oil into the sea. The oil that washes ashore can form a$Gild chunk with sand functioning as an a&lregate. This D::r.mple, found in Wales, United Kingdom, weighed morethan 100 kg (220 Ib) and was approximately four feet long.

ing] techniques to be applied tothem.

Notwithstanding this remark, the[fats and oils] industry is alreadybeing asked to provide the data nec-essary (0 allow the safety and pollu-tion hazards of these products to beproperly evaluated. Whilst recogniz-ing that this does impose some initialfinancial burden and extra work, it isnot unreasonable that products pro-duced in such large quantities shouldbe properly assessed for safety andenvironmental impact.

\VifI the potentialrecategorization of Allllex 1/be all improllement ouer theold system? /s it necessaryi

Logan: Review of Annex II has rbusfar only led to proposals and possibleOutcomes, none of which is necessarilygoing to be adopted, and therefore it ispremature to say whether they are nec-essary. Clearly, the shipping industry,in particular government representa-tives of that industry, feels that theenvironmental and human safety issuesassociated with the carriage of bulkliquids, some of which are hazardousand noxious, merit close examinationof stripping criteria (of tanks) and,where need arises, washing-ashore ofresidues.

The oils and fats industry shouldfeel confident that vegetable oils in themain have not, to date, required spe-cial handling procedures other than in

977

t!

the interest of quality preservation ofthe oil itself.

Reeves: The new categorization sys-tem theoretically should be animprovement over past methods due to

the expanded criteria used to establishthe pollution categories. I doubt therevised system will be more "simple"due to the more extensive and complexdata used for reclassification purposes.I reserve judgment on the final classifi-cation system until I see it in its entire-ty and (can) determine its impact onthe edible fats and oils industry.

Rogers: The new categorization sys-tem is not yet developed and so it isdifficult (0 determine if it is necessary

Volume 12 • October 200 I • Inform

97.

or an improvement. Certainly, we as anindustry have tried to be involved asmuch as possible in the process toensure that the form of any potentialchanges in the regulations are bothnecessary and improvements. The pres-ent regulations are functioning verywell with respect co the oils and fatsbusiness and do nor appear (Q needchange. The IMO holds relatively littletechnical information about our prod-ucrs and wants more. As a responsibleindustry, we should respond, and haveresponded, to their request.

\'(Ihat might be the effect ofa neu/ categorization systemon the fats and oils/shippingindustrlesi

Logan: Clearly the industry wouldhope that animal, vegetable, and marineoils and fats and their derivatives couldbe exempt from regulation (as is cur-rently the case). Alrernarively, if they areto be categorized, then the lowest crite-rion should be applied. Inevitably, anycategorization with more stringentrequirements for handling procedureswill have COStimplications (storage, lay-time, possible specialist handling).

Reeves: If the new pollution cate-gories require stricter handling ofsubstances associated with the fatsand oils industry, the resulting trans-

NetlinksMARPOL,

www.imo.org

Transportation

porrarion COStScan be expected toincrease.

Most substances associated withthe edible fats and oils industry arecurrently listed in "category D" of afive-step categorization system. Thiscategory is the least restrictive of thenoxious liquid substances. Our indus-try is hopeful that these substancesmay continue to be placed in anequivalent category under the newsystem, while being effectively andappropriately controlled during trans-portation at sea.

We would have concerns if these pol-lution categories were created only forthe sake of simplicity, and if fatloil sub-stances were collectively placed in a cate-gory with other substances havinggreater restrictions.

Rogers: If, as postulated, the IMOreduces the number of pollution cate-gories from five to three, then thelikely result would be an increase incost of goods sold through more com-plex handling procedures. Potentially,the new regulations could requirethat ships must wash tanks toonshore reception facilities [disposeof wastewaters to land-based sys-terns].

Presently, the tanks used for veg-etable and animal fats and oils canbe washed at sea. The increased costfor both vessels and ocean terminal

FOSRwww.fosfa.org

facilities would be substantial.If cargoes of concern to our

industry are not appropriately cate-gorized, an increase in COStof goodssold is practically assured. As anindustry, we must be proactive inresponding to regulatory bodies. Theregulations coming out of theseefforts will be implemented aroundthe world. It is important that theybe constructed in such a way as toassure a fair and even implementa-tion in all regions.

How IOllg might shippers haveto compl). with the possiblearuendtnentsi

Rogers: There is no schedule at presentfor the phasing in of any new regulations.In fact, it is not certain there will be newregulations. The only hard date that weknow of is that BLG has to submit itsrevisions, if any, by the end of 2002.

/s there allYthing more that read-ers o(inform shcuid know aboutpotential changes to MARPOU

Logan: Until we hear from IMO'sGESAMP and separately that there is aformal declaration of the rccarcgoriza-rion program (currently uncertaintiesexist), the industry must continue to

monitor developments in the respectivecommittees.

Institute of Shortening and Edible Oils:www.iseo.org/isco

MARJ>OL 73178-The [uture o( AnI/ex II,by John V. Crayford (1999):

http://www.imo.orgllnfoResourccfconrcnrs.asp?topic_id=406&doc_id= I073

Volume 12 • October 200 I • Inform

A =u: configurationis made with a skimmer

and booms to recover thecanola slick; 2000 spill.

How do oiland fat spills

affect the.marineenvironment?

'"

At the heart of the debate over whetherto restrict the discharge of fats and oilsinto the sea is the potential effect ofthese products on marine environments.

Worldwide marine pollution fromships, resulting from routine operations aswell as accidents, has decreased 60%since the 19705 (MAR POL was adoptedin 1973), according to U.S. NationalAcademy of Sciences estimates, as repon-ed by the Business Times of Singapore.This is despite a 70% increase in seabornetrade. However, damage to marine envi-ronments remains a major concern.

Some researchers, such as StephenMudge, senior lecturer in marine chem-istry at the School of Ocean Sciences,Gwynedd, United Kingdom, have saidthat edible oils may have long-lasting,and possibly deleterious, effects onmarine environments. Those in industrytend to argue that although an edible oilspill might cause damage to "ameni-ties," such as beaches or harbors, theoils themselves are not toxic, posing lit-tle danger to wildlife.

"Of course there are environmentaleffects," Liam Rogers, marketing manag-er at Hudson Tank Terminals, said. "Butthe question is, is that effect enough to

cause damage? Pouring fresh water intosalt water can have environmentaleffects, too. It's a matter of figuring outwhere we should draw the line."

Besides, industry members point our,edible oil spills are relatively few and farberween-especially compared to petro-leum oil spills. Since 1995, there havebeen 16 edible oil spills involvingunplanned discharges of at least 10,000gallons (Table 2), according ro data pro-vided by John Kaperick, technical infor-mation specialist nr the Office ofResponse and Restoration, NationalOcean Service, National Oceanic andAtmospheric Administration (NOAA)in Seattle, Washington. NOAA recordslist more than 300 petroleum oil spillsfor the same period.

Research on the effects of these types ofspills and of regular discharges of fats andoils products into the sea is ongoing.However, some data show that such spillsand discharges might harm marinewildlife. As a researcher in this area,Mudge said he has seen three specific neg-ative effects of edible fats and oils spills.

The first is an increase in mortalityrates for wildlife in spill areas.

"The experiments that we've done in

Volume 12 - October 200 I • Inform

98'

the past have demonstrated that [edible]oils can, for reasons that we can't quiteexplain, cause mussels to die," Mudgesaid.

"This was demonstrated with the1991 Kimya sunflower oil spill off thecoast of Wales. With this ship, oil wasslowly released inro the water. Most ofthe oil was released over several monthsand there were mussels dying along theshore," he explained.

The mussels may have died from suf-focation or from starvation, as somewill not open their shells in the presenceof oil. Others will continue to feed andtake on a new farry acid profile, but willnot die, Mudge added.

The second effect is persistence,Mudge said.

"Certain oils are able to polymerizeand call last longer in the environmentthan you might realize. I can still go to

the (Wales) shore and see chunks ofpolymerized oil from the Kirnya spill.

"Different oils polymerize at differ-ent rates. The rate of polymerizationseems to be related to the linoleic acid[content) in the oil. In the case of theKimya spill, sunflower oil is 70%

Transportation

An Environment Canada employee with a canola oil 5ample-the darklayer is canota oil and illustrates that the slic:ks can berelatively thic:k on the water; 1999 spill.

linoleic acid, and polymerizes at a highrare. It's not toxic on beaches, but thereis an amenity issue," Mudge said.

Polymerized oils can also cause a sortof "cap" to form on the water's surface,which can block sunlight, arrestingplant or wildlife development.

The third effect of oil spills isdecreased oxygen supply in the area ofthe spill.

"Oils have a relatively high biochemi-cal oxygen demand. They can trike quite awhile to degrade, depending on whetherbacteria can eat them," Mudge noted.

Regarding IMO's classification offats and oils, Mudge said, "I would sayIMO is not exactly right. I don't thinkthese vegetable oils are relatively benign,and they shouldn't be classified as such,bur it's not really a clear-cur situation."

Table 2Known edible oil spills exceeding 10,000 gallons since 1995

Amount(gallons)

1,000,00010,00044.000265,00029,00014.3001\8,00080,00010.00023,000138,70010,00012,00020,00058.80014,700

Product

Palm oilSoybean oilPalm stearin oilPalm oilCooking oilSoybean oilCanola oilCOCOnutoilSoybean oilVegetable oilPalm and fuel oilSoybean oilSoybean oilVegetable oilCanola oilCanola oil

Location SourceCountry

Port Muhammad Bin QasuuMacon, GeorgiaHamburgEnglish ChannelNazrerGulf of MexicoSouth China SeaColumbus, OhioOwensboro, KentuckyDanville, VirginaVenice, louisianaSidney. OhioWichita, KansasChadds Ford. PennsylvaniaVancou"er, Brirish ColumbiaVancou,-er, British Columbia

PakistanUnited StaresGermanyUnited KingdomEthiopiaUnited StatesHong KongUnited StatesUnited StatesUnited StalesUnited StatesUnited StatesUnited StatesUnited StatesCanadaCanada

Storage lankSlorage lankStorage tankTankerStorage tankTankshipTankerRailcarStorage (',InkRailcarTankerRailcarRailcarRailcarUnknownTerminal

Volume 11 . October 100 I • Inform