INTERTANKO • LAP • 24th July 2003 • Chemical Update
Strengthening our Chemical Activities • CCA • New members to INTERTANKO • In addition to representing 70% of the world’s independent oil tanker fleet, INTERTANKO also represents over 576 chemical tankers. Chemical tankers account for close to 30% of the tankers registered in INTERTANKO. • This makes INTERTANKO the world’s largest association representing independent oil and chemical tanker owners.
Chemical Tanker Committee • CTC • Upgraded to Committee Status Approved by Council and now called CTC (Chemical Tanker Committee). • Commercial issues affecting all chemical tankers. • National and international regulatory development. • Pollution prevention and pollution liability issues. • Improvement of safety standards on board chemical tankers • IMO • Meetings East & West Hemisphere • Capt Howard Snaith Marine & Chemical Director • - Remains as Secretary to the CTC
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 Meets Bi-annually Coordinates and supports activities with CTC Margaret Doyle - 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 MARPOL Annex II - Update
INTERTANKO position 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:- Apple Juice Clay Slurry Coal Slurry Dextrose Solution Glucose Solution Kaolin Slurry Molasses Water
Special Areas 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.
Pre-Wash Reductions 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
MEPC INF/23 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.
Other issues 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 (CDI) 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