INTERTANKO’s

Focus on Chemical Tankers

Captain Howard Snaith

Marine & Chemical Director

INTERTANKO

INTERTANKO - The voice of chemical tanker owners

• INTERTANKO has been the voice of the independent tanker owners since 1970, ensuring that the cargoes that keep the world turning are shipped safely, responsibly and competitively.

• Historically INTERTANKO has represented its members’ chemical tanker interests through an open forum within INTERTANKO called the Chemical Tanker Owners’ Advisory Group (CTOAG).

• Over the last few years the number of chemical tankers within INTERTANKO’s membership has been steadily increasing.

• To ensure that INTERTANKO provides optimal support and representation for its chemical tanker owners, it was decided to reconsider the current methods of work within INTERTANKO.

The INTERTANKO Chemical Tanker Committee

• In 2002 the CTOAG, chaired by John Fields of Iverships, was elevated from an open forum to the full status of a committee within INTERTANKO.

• This new committee is called the Chemical Tanker Committee (CTC) and meets twice a year rotating between Europe and the Far East.

•. The aim is to further the interests of independent chemical tanker owners and ensure that chemical tanker owners' interests are best reflected in the chemical industry’s day-to-day trading activities and market developments.

• The appointment of Captain Howard Snaith as Marine and Chemical Director and the recent appointment of Margaret Doyle as Chemical Manager continue to strengthened our presence in this area.

Chemical Tanker Subcommittee (Americas)

• To ensure that the Americas are fully represented, INTERTANKO inaugurated the Chemical Tanker Sub-committee – Americas (CTSCA) in April 2003.

• This is a Sub-committee of the CTC which aims to support the work of the CTC while handling specific regional issues that arise from both North andSouth America.

• Both the CTC and CTSCA provide a forum for INTERTANKO to promote the activities and priorities nationally, regionally and internationally, and report to the INTERTANKO Council.

Representation at IMO

• Because INTERTANKO has observer status at the International Maritime Organization (IMO) chemical tanker interests are represented via participation in all the IMO meetings.

• Participation at the Bulk Liquid Gases Subcommittee (BLG), Marine Environmental Pollution Committee (MEPC),

• Evaluation of Safety Pollution Hazards Working Group (ESPH), Marine Safety Committee (MSC) ensures the chemical tanker owners’ expert input to the IMO forums that stand to affect them.

• The input provided at all of these meetings represented the input of INTERTANKO’s entire chemical tanker membership. All background, reports and meeting documents are made available via the INTERTANKO website and the INTERTANKO Weekly NEWS.

Regulatory Issues and the Chemical Tanker Owner

MARPOL Annex II Revisions

• The re-categorisation of the existing pollution categories within MARPOL Annex II will change the dynamics of the chemical tanker industry. Currently there exist 5 categories A, B, C, D and an Appendix III.

• INTERTANKO believes that a new 3-category system would be a lot simpler for industry, and also a lot simpler for Port State Control to implement. It is in fact a prudent move to reduce the number of categories from 5 to 3.

• It is proposed that the categories in such a new 3-category system wouldbe called X, Y, Z. Importantly, under this new system there would be no Appendix III and therefore no unregulated noxious cargoes.

Existing Pollution Categories Number of products

Recalculated Pollution Categories Number of products

Category A

61 (11.2%) 63 (11.5%)

Category B

90 (16.5%) 116 (21.2%)

Category C

141 (25.8%) 125 (22.9%)

Category D

174 (31.8%) 138 (25.2%)

Category III

81 (14.8%) 69 (12.6%)

Total Number of Products with Insufficient data (So far)

36 (6.6%)

Current 5 category System & Re-evaluated Effects

MARPOL Annex II Revisions

Category X 50 (9.1%) Category Y 353 (64.5%) Category Z 87 (15.9%) Total Number Products with insufficient data

57 (10.4%)

The Effects of a 3 Tier System on Pollution Categories

MARPOL Annex II Revisions

MEPC 49 MEPC 49 Decisions Made at MEPC 49Decisions Made at MEPC 49

3 + 1 Category System 3 + 1 Category System

(X.Y.Z & O.S.) (X.Y.Z & O.S.)

A fourth category of unregulated cargoes, was A fourth category of unregulated cargoes, was accepted, providing that the cargoes in such a accepted, providing that the cargoes in such a category would be only those that can be genuinely category would be only those that can be genuinely shown to pose no threat to the marine environment. shown to pose no threat to the marine environment.

MARPOL Annex II Revisions

Decisions Made at MEPC 49Decisions Made at MEPC 49This fourth category will consist of 8 products: This fourth category will consist of 8 products: 

Apple Juice Apple Juice  Clay slurry Clay slurry  Coal slurryCoal slurry Dextrose solution Dextrose solution Glucose solution Glucose solution Kaolin slurry Kaolin slurry  Molasses Molasses  WaterWater

It was also decided that  if any products evaluated in the future It was also decided that  if any products evaluated in the future can be proven not to exhibit any harmful effects on the marine can be proven not to exhibit any harmful effects on the marine environment, they may be added to this category. environment, they may be added to this category. 

MARPOL Annex II Revisions

Proposed 3+1 Category SystemProposed 3+1 Category System

CategoryCategory New Buildings New Buildings Existing IBC Ships Existing IBC Ships None None Chemical TankersChemical Tankers

XX

Pre-WashPre-Wash 75 litres 75 litres 12 mile, 12 mile, 25m water depth 25m water depth Underwater Underwater 7 knots 7 knots En-route En-route

Pre-WashPre-Wash150 Litres 150 Litres 12 mile, 12 mile, 25m water depth 25m water depth Underwater Underwater 7 knots7 knotsEn-route En-route

No TransportNo Transport

YY

Pre-wash for solidifying or Pre-wash for solidifying or H/V substances H/V substances 75 litres 75 litres 12 mile 12 mile 25m water depth 25m water depth underwater underwater 7 knots 7 knots En-route En-route

Pre-wash for solidifying or Pre-wash for solidifying or H/V substancesH/V substances150 Litres 150 Litres 12 mile, 12 mile, 25m water depth 25m water depth Underwater Underwater 7 knots7 knotsEn-route En-route   

No TransportNo Transport

ZZ

75 litres 75 litres 12 mile 12 mile 25m water Depth 25m water Depth Underwater Underwater 7 knots 7 knots En-route En-route

150 Litres 150 Litres 12 mile, 12 mile, 25m water depth 25m water depth Underwater Underwater 7 knots7 knotsEn-route En-route   

New ShipsNew Ships Strip to 100Litrers Strip to 100Litrers

Existing Ships Existing Ships Strip to maximum ExtentStrip to maximum Extent

  O.S. Other O.S. Other SubstancesSubstances

No Requirements For No Requirements For CarriageCarriage

No Requirements For No Requirements For CarriageCarriage

No Requirements for CarriageNo Requirements for Carriage

MARPOL Annex II Revisions

Available Chemical Tonnage to Absorb the Changes

• There have been some claims that there will be insufficient tonnage available to take into account the regulatory changes proposed within MARPOL Annex II.

• INTERTANKO is currently undertaking a large independent study of available chemical tanker tonnage to determine the facts. Memers will be kept advised accordingly

MARPOL Annex II Revisions

Indian Age Restriction Removed for Chemical Tankers

• In June 2003 the Indian Government issued a circular (SD Circular 7/2003) announcing that in September 2003 tankers over 25 years of age would be banned from Indian ports. The ruling was to have included gas and chemical tankers.

• INTERTANKO submitted a brief to the Indian Directorate General of Shipping. The document submitted stressed the safety record of the worldchemical tanker fleet and the strict international requirements for chemical tankers.

• This submission was followed up by a number of meetings and discussions between INTERTANKO and the Indian Directorate General of Shipping. Soon after these meetings, Circular (SD Circular 8/2003) was issued.

• The circular indicated that SD Circular 7/2003 had been amended to restrictthe ban to oil and product tankers on international voyages to and from Indian ports.

Chemical Tanker Vetting

• Both oil and chemical tankers alike are subject to vetting inspections. The oil companies operate through the OCIMF SIRE system, and the chemical tankers through the Chemical Distribution Institute (CDI).

• INTERTANKO actively supports the use of both these recognised industry inspection systems in order to reduce the number of multiple inspections.

INTERTANKO is represented at the following CDI Committees:-

1. CDI Technical Committee. 2. CDI Executive Board. 3. CDI Inspection Committee.4. CDI Audit Committee.

US Coast Guard High Interest Vessel Boarding

• Following the September 11th attacks, the US Coast Guard was tasked with ensuring the safety and security of the US Marine Transportation System. Immediately after the attacks INTERTANKO staff worked closely with the US Coast Guard and Captain of the Port representatives in the development of a risk assessment system to efficiently control movement of ‘high interest’ traffic in the ports and waterways.

• The focus on high risk vessels such as tankers carrying gas, oil and chemicals resulted in the US Coast Guard High Interest Vessels Boarding Program currently in use.

• The High Interest Vessels Boarding Program and the current matrix being used are continually being modified using industry input. The Program will be discussed at the autumn CTSCA meeting.

US Coast Guard Chemical Transportation Advisory Committee (CTAC)

• INTERTANKO is as a member of the US Coast Guard Chemical Transportation Advisory Committee. - Recent CTAC committee and subcommittee meetings have focused primarily on maritime security relative to hazardous cargo transportation.

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