MARPOL Annex II Revisions INTERTANKO Latin American Panel Meeting 16 th November 2005 Miami Beach, Florida

1. MARPOL Annex II Revisions INTERTANKO Latin American Panel Meeting 16th November 2005 Miami Beach, Florida

2. 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.

3. MARPOL Annex II Revisions • 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.

4. MARPOL Annex II Revisions • BUT - The 3+1 system is in effect a 4 category system • Because - The 4 category system consists of: • The 3 = Pollution categories X, Y and Z • The +1 = OS (Other Substances). = 4 categories

5. MARPOL Annex II Revisions • 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.

6. 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

7. IMO Ship Type 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.

8. Tank Type Configurations B/5 or 11.5m which ever is less, but no where less than 760mm

9. Certificates of Fitness The issuance of a Certificates of Fitness (CoF) reflecting the new ship type criteria will require a revised Procedures and Arrangements Manual.

10. 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.

11. 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.

12. 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.

13. Stripping Requirements • Stripping performance requirements apply to all tankers holding a Chemical Carrier Code CoF.

14. 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.

15. Stripping & Underwater Discharge • 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

17. 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 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.

18. 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).

19. The Veg Oil Compromise 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.

20. Vegoil Compromise 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.

21. 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.

22. Big Movers – Chemicals

23. Big Movers – Veg Oils & Fats

24. 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

25. Still a Lack of Data • 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).

26. Still a Lack of Data • 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.

27. 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

28. Thank You