INTERTANKO LAP 24 th July 2003 Chemical Update Strengthening our Chemical Activities CCA New members to INTERTANKO
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Chemical Tanker Sub-Committee- Americas CTSCA
Further the interests of independent chemical tanker owners trading in the North and South America
Local, national and international regulatory development
Pollution prevention and response issues
Improvement of safety standards on board chemical tankers trading in the region
Security issues specific to chemical tankers trading to the region
Coordinates and supports activities with CTC
- Secretary to the CTSCA
Marpol's Annex II sets out the regulations covering the carriage of 'noxious liquid substances in bulk'. At present there are five categories of noxious liquid substance A, B, C, D and Appendix III. The Appendix III contains products to which the IBC code does not apply and which are therefore unregulated. In the run up to MEPC 49 INTERTANKO issued a press release on this issue in support of a 3 -category system
In strong favour of a 3 category system.
Widely reported in the worlds press on the eve of MEPC
Assisted in moving this issue forward and achieving a proposal that is not only sensible but will be bold enough to protect the environment into the 21st century.
MEPC Culmination - an agreement for a new pollution category system for Annex II.
Three main Options
1. Retaining a 5 category system (albeit it a new 5 system),
2. Reducing the 3 categories but all regulated, with new names X, Y, Z.
3. A third hybrid proposal with reshuffled products into four categories, but again with an unregulated Appendix III category. But reducing environmental protection such derogations in this latter proposal included: -
Relinquishing the 12 mile limit for Category "Z" Products
The continuance of an unregulated Appendix III category
No decrease in the stripping limits for new chemical tankers,
The continuance of special areas
The matter of Veg oil classification in either "Y" or "Z" and in particular pre-wash requirements how it would be applied
With regards to the Veg oil issue IMO has requested toxicity data from the Veg oil industry for several years.
BLG 8 made a specific request for IMO delegates to urge the Veg oil industry to supply this information so as not to delay the revisions of MARPOL Annex II.
The proposal set out and agreed at MEPC is a
3 + 1 Pollution category system utilising text for the 3 category system (X,Y,Z) : -
Other Substances category
This additional category for other substances would be ONLY for those substances that are harmless to the environment by all properties as evaluated by GESAMP/EHS, such products would be:-
Based upon the enhancements the new system would provide to the environment there would be no need for special areas with the exemption of the Antarctic Area
12 Mile Limit
Agreement to keep the 12 mile discharge limit for category "Z" products with a modification for a waiver for domestic trade that would include trade between countries where transport between them stayed within the 12 mile limit of either country provided that no third party would be effected.
High Viscocity/Solidifying substances
Pre-wash for products allocated to category "Y" could be overcome primarily for vegetable oils by allowing an increase in the unloading temperature to ensure that the viscosity parameters fell below the definition of high viscosity or by raising the definition of high viscosity such that big movers would not meet the criteria for Pre-wash
Stripping Limit Retentions
The retention of the proposal for a new stripping limit of 75 litres for new chemical tanker buildings only
Lists products with insufficient data to enable the products to be categorised for pollution and ship typing.
Importantly this includes Vegetable Oils. !!
MEPC agreed that the data for these products should be provided as soon as possible.
However the committee also agreed that if the data was not forthcoming then the products listed in the INF paper would NOT be included in the IBC code.
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.
Chemical Distribution Institute
INTERTANKO is fortunate that its technical expertise meets strict criteria by CDI, such that INTERTANKO is represented at the
CDI Technical Committee
CDI Executive Board Meetings
CDI Inspection Accreditation Committee
CDI Quality Audit Committee
Use of CDI reports by Port State Control
INTERTANKO supports the CDI concept as a positive step towards reducing the number of commercial vetting inspections and promotes recognition of the CDI scheme by PSC authorities to assist in reducing inspections and better targeting sub-standard vessels (Brazil used of SIRE/CDI reports)
Others such as P&I Clubs ?
US Coast Guard Chemical Transportation Advisory Committee (CTAC)
INTERTANKO continues to participate in the CTAC meetings