ipta regulatory update

8/12/2019 IPTA Regulatory Update

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Regulatory UpdateJanet Strode

General Manager

International Parcel Tankers Association


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Founded 1987

Attained consultative status at IMO 1997 Project leader on IMO Workshops worldwide on MARPOL

Annex II

Cooperation with USCG and European Commission

EQUASIS Editorial Board

24 years on FOSFA Oils and Fats and Technical Committees

Setting up of CDI

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Application of inert gas to chemicaltankers

Damage Stability for Tankers

Review of chapters 17 and 18 of the IBC

Code

Carriage of Biofuel Blends

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APPLICATION

OF INERT GAS

TO CHEMICAL

TANKERS AND

SMALLER OIL

TANKERS


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FP 53 - 2009

recognized that the fitting of appropriate inert gas systemsto NEW oil tankers below 20,000 dwt and NEW chemical

tankers carrying low-flash cargoes would minimize the risk of

fires and explosions

. benefits of such fitting should outweigh any negative

effects of the introduction of IG systems, such as

increased fuel consumption

increased CO2 emissions

increased building costs increased complexity of procedures

possible increase of the risk associated with tank entries

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FP 54 April 2010

Joint ICS/IPTA paper with information onoperational issues

Proposes separate operational requirements for the

application of inert gas to chemical tankers

Sub-Committee agrees that where vessel is carrying

IBC Code cargoes, can have option of applying

nitrogen either on completion of loading orimmediately prior to discharge

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Lower size limit

8,000 DWT

Japan, China, Brazil, Singapore, Panama and Turkey

500 GRT

Bahamas, Norway, EU States, Intertanko, OCIMF

IPTA and ICS: seems that problems occur below 5,000 DWT,

and therefore would not support any thing below 5,000 DWT

Proponents of 500 grt eventually agree to compromise on

5,000 DWT

FP 55 to decide on lower size, based on range between 5,000

DWT and 8,000 DWT

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BLG 15 Reminds FP that some cargoes have oxygen-

dependent inhibitors

Concludes that column h of chapter 17 of the IBC

Code not appropriate for incorporating future SOLAS

inert gas requirements for new ships,

Took note that the review of Resolution A864(20) -

Recommendations for Entry into Enclosed Spaces

Aboard Ships had been completed and finalised aspecific footnote addressing entry into cargo spaces

on all tankers subject to inerting with nitrogen

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Damage Stability ofTankers


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MSC 83 (2007)

Denmark, Finland, Germany, Norway, Sweden, UK andIntertanko propose new work programme item on

damage stability of tankers

Taken in conjunction with the low margins of stability

often exhibited by the standard loading conditions in

approved stability information for tank vessels, there is a

probability that these ships are regularly operating in

loading conditions with reduced or zero levels of residual

stability, even where these loading conditions appear to

be closely related to a standard loading condition

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SLF 52 - 2010

UK - survey of 73 oil, chemical and gas tankersentering and leaving UK ports

non-compliance =

variation of more than 1% by weight in any cargoor ballast tank from conditions outlined in the

stability book

vessel not verifying that the damage stabilityrequirements were still being complied with

23 vessels not compliant

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over one third of tank ships regularly sail in conditions of

loading significantly different from those in the approved

stability information

This poses an unacceptable risk to life at sea and to the

environment and enforcement action is justified under

the existing instruments which apply to these vessels

Sub-Committee concludes that there is some ambiguity in

regulations

Agrees that guidelines should be developed for verification of

damage stability at

initial approval stage

onboard prior to sailing

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SLF 53 January 2011agrees that further discussion needed and sets up

Correspondence Group that will report back to SLF 54 in 2012

Guidance also needed for Port State Control

clarification of loaded in accordance with an approved condition

Are deviations allowed and, if so, to what extent?

methods of verification of compliance,

stability software,

KG/GM curves

shore assistance

clarification of the terms and conditions for use of stability software

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Paris MOU CIC

1 September 2010 to 30 November 2010

1065 tankers inspected in order to check:

Vessel loaded in accordance with Stability book?

If not, have checks been carried out to ensure the loaded

condition complies with damage stability regulations?

A significant number of tankers could pose a

risk to the environment

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94 (8.8%) inspections resulted in deficiencies

2 oil tankers and 2 chemical tankers detained

77 oil tankers, 84 chemical tankers and 12 gas

tankers (16.2% of total) could not demonstrate that

they were normally loaded in accordance with theStability Book

detailed results to be reviewed Port State Control

Committee in May and report to be submitted to the

IMO

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REVIEW OFCHAPTERS

17 AND 18OF THE IBC

CODE

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Changes to GESAMPhazard profiles

2007 amendmentsapplied on pollutiongrounds only

New criteria forassigning carriage

requirements appliedto new products only

Dual

standardproduct list

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Tank type 2G = Integral tank

forms part of ships hull and may be stressed in insame manner and by same forces which stress the

ships hull structure

Tank type 1G = Independent tank

not contiguous with, or part of , the hull structure.

An independent tank is built and installed so as to

eliminate whenever possible (or in any event tominimize) its stressing as a result of stressing or

motion of the adjacent hull structure

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Representative sample of 10

products examined to establishwhich criteria trigger particular

requirements

Dermal toxicity triggersenhanced ship type and/or

tank type

Inhalation toxicity triggers

enhanced standards forventing, gauging and

vapour detection

Long term effects couldalso trigger similar

requirements

BLG 15

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Possible action:

Full review of carriage requirements

Allowing period for updating of data by industry

Partial review, based on worst case anomalies

Revisit chapter 21 of the IBC Code

ESPH 17 (October 2011) to consider further

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Carriage of Biofuel Blends

Fatty acid methylesters (FAME)

Vegetable oil

Bio-ethanol

Renewable Diesel

Biofuel

Diesel

Gasoil

Gasoline

Petroleum

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Draft Guidelines for the Carriage of Blends

of Biofuel and Petroleum

(agreed at BLG 15 in February 2011)

75% or more petroleum oil

Product subject to MARPOL Annex I

ODME to be in compliance with regulation 31 of Annex I of

MARPOL and approved for the mixture being transported

Until 1 January 2016 bio-fuel blends may be carried when theship's ODME is not approved, provided that tank residues and

all tank washings are pumped ashore

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More than 1% but less than 75% petroleum oil

Product subject to MARPOL Annex II

Pollution Category X, Ship Type 2

carriage requirements based on the generic entry

defined for the biofuel blend concerned

Generic carriage requirements will be incorporated

into List 1 of the MEPC.2/Circular

1% or less Petroleum oil

Product to be treated as the Annex II product

in the blend

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a c d e f g h i i i j k l n o

Blends of Diesel/gasoil and

FAME

(>25% but25% but25% but 60oC

(>25% but 25% but


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Draft Guidelines still to be formally adopted

by the Maritime Safety Committee and

Marine Environment Protection Committee

In the meantime the interim guidance has

been extended to 1 September this year

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Biofuel Blends in MEPC.2/Circ.16

List 2 Alcoline (Greenergy)

Etamax (SEKAB)

List 3 E85 VSS (Vertical)

E85 VWS (Vertical)

E90 (Fuelstreamers) E90 (Shell)

NOS 8

Pollution category Y

Ship Type 3

Pollution category X

Ship Type 2

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Blending on board :

the mixing of two products resulting in one singleproduct

reflects only physical mixing as distinct from any

chemical processing

Blending operations only to be undertaken within

port limits

Blending on board during a sea voyage to createnew products is prohibited (See MSC-

MEPC.2/Circ.8)

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Blending at Sea MSC-MEPC.2/Circ.8

The MSC and the MEPC noted that there were concerns that the practice ofthe physical blending of MARPOL regulated cargoes on board during thesea voyage for the purposes of creating new product blends presents clearhazards for the safety of the ship and protection of the marineenvironment. Having considered the proposal by the BLG Sub-Committeethe Committees agreed that such practices should be prohibited and that

mandatory provisions should be developed in that respect under theauspices of both Committees.

Until the matter can be further discussed in detail by the BLG Sub-Committee and approved by the Maritime Safety Committee and theMarine Environment Protection Committee,physical blending refers to theprocess whereby the ships cargo pumps and pipelines are used to internally

circulate two or more different cargoes within the ship with the intent toachieve a cargo with a different product designation. This circular does notpreclude the master from undertaking cargo transfers for the safety of theship or protection of the marine environment.

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DRAFT REGULATION 5-2 OF

SOLAS CHAPTER VI

PROHIBITION OF THE BLENDING OF BULK LIQUIDCARGOES DURING THE SEA VOYAGE

The physical blending of bulk liquid cargoes during the seavoyage is prohibited. Physical blending refers to the process

whereby the ship's cargo pumps and pipelines are used tointernally circulate two or more different cargoes with the intentto achieve a cargo with a new product designation. Thisprohibition does not preclude the Master from undertakingcargo transfers for the safety of the ship or protection of themarine environment. The prohibition does not apply to the

blending of products for use in the search and exploitation ofsea-bed mineral resources on board ships used to facilitate suchoperations.

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Thank you for your attention

The internationally recognised Non-Governmental Organisationdedicated to serving the needs of the IMO classified chemical

and product tanker fleets

www.ipta.org.uk

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http://www.ipta.org.uk/http://www.ipta.org.uk/

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