No 1/2006
November 2006
1. IMO Update
(i) IMO issues Circular Letter 2730 on MARPOL Annex II Revisions
(ii) IMO Reviews List of Reclassified Products
(iii) 12th Session of the IMO Working Group on the Evaluation of Safety and Pollution Hazards (ESPH 12)
2. Regulatory and Legislative Issues
(i) USCG’s Chemical Transportation Advisory Committee (CTAC) Update
(ii) The Hazardous Cargo Transportation (HCTS) Sub-committee
(iii) USCG NVIC Update
3. MARPOL Annex II Update
(i) INTERTANKO to publish MARPOL Annex II Booklet
(ii) INTERTANKO Biofuels Update
4. Safety Updates
(i) Bow Mariner report – USCG reply to INTERTANKO/ICS response
5. Coordination with other Associations
(i) INTERTANKO attends NIOP 2006
(ii) API Chemical Measurement Working Group
6. INTERTANKO Chemical Committee meetings
(i) Joint Chemical Tanker Committee (CTC) and Chemical Tanker Sub-committee (Americas) (CTSCA) meetings held
(ii) Joint Chemical and Vetting Seminar Held
7. CDI – Inspector Appointment Revisions
8. MARPOL Annex II Reception Facilities Survey
1. IMO Update
to now circulate the formal circular from the IMO outlining an
overview of the revisions (see below).
(i) IMO issues Circular Letter No. 2730
on MARPOL Annex II Revisions
The three-page Circular Letter gives a synopsis of the
adoption of the revisions by Resolutions MEPC.119 (52) and
MSC.176 (79). It explains that they were accepted on 1 July
2006 and reiterates that they will enter into force on 1
January 2007. As the Circular Letter states, “The purpose of
this circular letter is to explain the principal points of the
revision and to ensure that all parties are aware of their
obligations as from 1 January 2007”.
On 3 July 2006 the International Maritime Organization (IMO)
issued Circular Letter No. 2730 to all IMO Member States
and all Parties to MARPOL 73/78, the United Nations (the
IMO parent organisation) and its specialised agencies, all
Intergovernmental Organisations and Non-Governmental
Organisations with Consultative Status.
The Circular also explains:
The subject of the Circular Letter is the “Entry into force of
the revised Annex II to MARPOL 73/78 and the amended
IBC Code”. This document mirrors the information contained
in many of the INTERTANKO documents forwarded over the
last three years on this very important issue. We are pleased
G
Why the revisions were considered necessary; the
purpose of the work of the Joint Group of Experts on
the Scientific Aspects of Marine Environmental
Protection (GESAMP) in revising its hazard
evaluation procedure for chemical products carried
by ships to bring it in line with the U.N.’s Globally
Harmonised System of Classification and Labelling of
Chemicals (GHS);
G
The subsequent re-evaluation of all of the products
listed in the current IBC Code and in the relevant
sections of the MEPC.2/Circular as well as the reevaluation of products;
G
The relative development of a new pollution
categorisation system and criteria for assigning
products to these new categories;
G
The revision of stripping requirements and discharge
criteria and why it was necessary to make a number
of amendments to the IBC Code, in particular the
criteria for ship typing from an environmental point of
view;
G
That in the process of re-evaluation of the products it
was revealed that a large number of products in the
IBC Code had incomplete GESAMP hazard profiles
because data related to safety and/or pollution
issues were missing. The subsequent efforts over the
next three years by IMO and industry to provide the
missing data allowed the GESAMP hazard profiles to
be completed.
G
The fate of any of the products omitted from the
amended IBC Code due to missing safety and/or
pollution data: They will appear in List 1 of the
MEPC.2/Circular, which will be issued on 31
December 2006. Products with missing data omitted
from the amended IBC Code that have not yet been
re-evaluated can be carried under a tripartite
agreement but no such agreement should be
established until confirmation has been received by
the Administration that the required data have been
submitted to the GESAMP/EHS Working Group.
G
That BLG.1/Circ.19 was recently issued listing those
products which to date have been classified or reclassified since the adoption of the amended IBC
Code in 2004 (see article in this issue). The purpose
of this circular is to assist national Administrations
and other stakeholders in their preparations for the
entry into force of the revised MARPOL Annex II and
the amended IBC Code.
G
Why regulation 4.1.3 of MARPOL Annex II was
developed, to allow unmodified oils and fats
displaying the footnote (k) in column ‘e’ in Chapter
17 of the amended IBC Code to be carried on ship
Type 3 chemical tankers, on the condition that these
chemical tankers meet all the requirements for ship
Type 3 and are provided with double bottom and
double sides meeting the specifications laid out in
regulation 4.1.3.
This is also a reminder that the vast majority of noxious liquid
substances will now be subject to regulation; and revised
stripping limits will greatly reduce the amount of residues that
vessels will be allowed to discharge into the marine
environment.
The Circular Letter also reiterates that the 24th session of the
IMO Assembly recognised the importance of this provision,
and that the 54th session of the Marine Environment
Protection Committee (MEPC 54) confirmed that when an
Administration agrees on an exemption, regulation 4.1.3 is
the only regulation for existing and new ships to be used for
vegetable oils identified by footnote (k) in column 'e' in
Chapter 17 of the amended IBC Code.
The document also clarifies that regulations 4.1.1 and 4.1.2
were only developed to allow Administrations to submit to the
Organization a relaxation of certain provisions of an
amendment under restricted conditions, for a specified period
and for existing ships only, and that these regulations were
not permitted to be used for the vegetable oils under
footnote (k).
Lastly the Circular Letter reiterates that before 1 January
2007, vessels certified to carry noxious liquid substances
identified in Chapter 17 of the IBC Code will have to be
issued with new Certificates of Fitness and Procedures and
Arrangements (P&A) Manuals reflecting the changes in
categorisation of products, and this should be taken into
account when preparations for entry into force are
undertaken.
The final paragraph of the Circular Letter contains a table
indicating possible scenarios with regard to certification and
the action to be taken in each case.
Type of concern
Action to be taken in relation to existing certificate
certificate under the revised MARPOL Annex II
Action to be taken in relation to
Certificate valid until
after 1 January 2007
N/A
Issue a certificate under the revised MARPOL Annex II
starting as from 1 January 2007 with an identical expiry
date as the existing certificate.
Renewal survey on or
after 1 July 2006
Extend the validity of the existing
certificate to 1 January 2007.
Issue a new certificate under the revised MARPOL
Annex II with an expiry date of 5 years from the survey date.
Change of flag on or
after 1 July 2006
Replace the coversheet of the current certificate R
with an extension of the validity to 1 January 2007.
survey date.
Issue a new certificate under the revised MARPOL
Annex II with an expiry date of 5 years from the renewal
Delivery of a new vessel
(e.g. 1 July 2006)
Issue a short term certificate under the current
MARPOL Annex II valid until 1 January 2007.
Issue a full term certificate alid for 5 years after the
initial survey.
Click here to view the Circular Letter.
(ii) IMO Reviews List of Reclassified
Products
As part of the agenda for MEPC 55, the Committee reviewed
and accepted MEPC 55 WP 8, a working paper developed
by the drafting group tasked to review the amendments to
the IBC Code. MEPC WP 8 contains a listing of the
products that have been classified or re-classified since the
adoption of the amended IBC Code at the 52nd Session of
the IMO’s Marine Environment Protection Committee (MEPC
52) and the 79th Session of the Maritime Safety Committee
(MSC 79) in 2004 and the products to be included (to date)
in the December 2006 issue of the MEPC.2 Circular.
Although the amendments made since the 2004 adoption will
not be officially entered into the Code until 2009, all the
products amended or added since then will be included in
MEPC.2 Circular 12 due out 31 December 2006.
As INTERTANKO has previously reported, the evaluation and
assignment of the carriage requirements of products have
continued through the work of the GESAMP/EHS
(GESAMP Working Group on the Evaluation of the Hazards
of Harmful Substances Carried by Ships) and the ESPH
(Working Group on the Evaluation of Safety and Pollution
Hazards) respectively. The draft amendments to the complete
Chapters 17 and 18 of the IBC Code were submitted to the
MEPC 55 for consideration at MSC later this month and at
MEPC 56 in December 2006.
This document, once approved, will supersede BLG.1/Circ.
published this summer as a way to aid class and flag
administrations with the issuance of certificates.
Members are reminded that as decided at BLG 9, when a
cargo is loaded prior to the entry-into-force date and
unloaded after the entry-into-force date of the revised Annex
II to MARPOL 73/78, the classification of the cargo at the
time of loading should remain valid until it has been unloaded.
(iii) 12th Session of the IMO Working
Group on the Evaluation of Safety
and Pollution Hazards (ESPH 12)
INTERTANKO participated in the 12th Session of the IMO
Working Group on the Evaluation of Safety and Pollution
Hazards (ESPH 12). INTERTANKO Chemicals Manager,
Margaret Doyle, attended the meetings held at the United
Kingdom Maritime and Coast Guard Agency (MCA) in
Southampton, UK from 4-8 September.
ESPH 12 was chaired by Mrs. Marja Tiemens-Idzinga from
the Netherlands. The group included delegations from 15
countries (Belgium, the Cook Islands, Finland, France,
Germany, Japan, Malaysia, Mexico, the Netherlands, Norway,
Panama, Sweden, Thailand, the United Kingdom, and the
United States of America) and five non-governmental
organisations [European Chemical Industry Council (CEFIC),
International Association of Ports and Harbors (IAPH),
International Chamber of Shipping (ICS), INTERTANKO, and
International Parcel Tankers Association (IPTA)]. Agenda
items discussed included:
Outcome of the GESAMP/EHS Working Group
The 42nd and 43rd sessions of the GESAMP Working
Group on the Evaluation of the Hazards of Harmful
Substances Carried by Ships (EHS 42 and 43) were held at
IMO Headquarters, London, in February and June
respectively. Although a number of the issues stemming from
the EHS 42 were discussed at BLG held in April, these
outstanding issues were finished. The report of EHS 43 was
also reviewed by ESPH 12. As a follow-up to these
discussions the group was asked to finalise the draft
MEPC.2/Circ.12 on (Provisional Classification of Liquid
Substances Transported in Bulk), which will be published by
the IMO in December.
Evaluation of New Products
3
Of the 33 products submitted, the following 29 classifications were approved by ESPH 12:
Product
4
Category
Ship Type
Tank Type
Notes
Acetonitrile (low purity grade)
Y
3
2G
Alcohols (C12-C13), primary, linear
and essentially linear
Y
2
2G
>25% C12 to C13 components.
Alcohols (C14-C18), primary, linear
and essentially linear
Y
2
2G
<25% C13 and lower. Synonyms not to
be listed.
Alcohols (C8-C11), primary, linear
and essentially linear
Y
2
2G
<25% C12 to C13 components.
Synonyms not to be listed.
Alkyl Benzene Distillation Bottoms
Y
2
2G
Possible Annex I
Cocoa Butter
Y
2(k)
2G
Synonyms to be included.
Coconut Oil Fatty Acid
Y
2
2G
Synonyms not to be listed.
Fatty Acid Methyl Esters (FAME)
Y
2
2G
Synonyms not to be listed. The current
entries for Coconut, Palm, and Rapeseed
Oil Methyl Esters to be deleted.
Fatty Acids, C12+
Y
3
2G
Synonyms not to be listed.
Fatty Acids, C16+ Fraction
Y
2
2G
Synonyms not to be listed.
Fatty Acids, C8-C10 Fraction
Y
2
2G
Synonyms not to be listed.
Glucitol/Glycerol blend propoxylated
(containing less than 10% amine)
Z
3
2G
Synonyms not to be listed.
Glycerol propoxylated
Z
3
2G
Glycerol propoxylated and ethoxylated
Z
3
2G
Glycerol/Sucrose Blend propoxylated
and ethoxylated
Z
3
2G
Hydrogenated Starch Hydrolysate
OS
NA
NA
Synonyms to be included.
Maltitol Syrup
OS
NA
NA
Synonyms to be included.
Molybdenum Polysulfide Long Chain
Alkyl Dithiocarbamide Complex
Y
2
2G
A lube oil additive.
Non-Edible Industrial Grade Palm Oil
Y
2
2G
Palm Mid Fraction
Y
2(k)
2G
Polypropylene Glycol
Z
3
2G
Shea Butter
Y
2(k)
2G
Tall Oil Fatty Acids (resin acids less than 20%)
Y
2
2G
Tall Oil Pitch
Y
2
2G
Tall Oil, Crude
Y
2
2G
Tall Oil, Distilled
Y
2
2G
Trimethylol Propane propoxylated
Z
3
2G
Vegetable Acid Oils (not otherwise specified)*
Y
2
2G
*From vegetable oils specified in the IBC
Code.
Synonyms not to be listed.
Vegetable Fatty Acid Distillates
(not otherwise specified)*
Y
2
2G
*From vegetable oils specified in the IBC
Code.
Synonyms not to be listed.
Amending IBC Code.
Trade-name synonyms not to be listed.
Trade-name synonyms not to be listed.
Evaluation of Cleaning Additives
(FAME) products. A footnote (m) on this entry will indicate
that the FAME products carried are derived from vegetable
oils already in the IBC Code. The individual FAME products
that have already been evaluated under the new system are
palm oil FAME, rapeseed oil FAME and coconut oil FAME.
From 1 January 2007 FAME derived from any other vegetable
oil already evaluated and classified may be carried under the
generic entry. This
will also mean that blends of FAME products need not be
subject to a mixture calculation.
Of the 44 additives presented, 27 met the MARPOL
requirements for inclusion in Annex 10 of the forthcoming
MEPC.2/Circ.12.
Review of pending MEPC.2/circ.12 – provisional
classifications, etc.
For products subject to tripartite agreements, the revised
Guidelines (MEPC.1/Circ.512) supersede those of
MEPC/Circ.265. The next edition of MEPC.2/Circ.(12) will
be published on 31 December 2006, slightly later than the
usual 17 December of each year. The deadline for new
entries for MEPC.2/Circ.12 Annex 1 - List 1, will be 01
December 2006. Concern still exists regarding the
classification of pollutant only mixtures (information for
mixtures will be listed in MEPC.2/Circ.12 Annex 2 - List 2).
The deadline for submission of information on mixtures is 30
September 2006. All products currently on list 2 of the
MEPC 2 Circ will expire on 31 December 2006. Normally,
Chapters 17 and 18 of the IBC Code take precedence over
List 1 of the annual MEPC.2/Circular; in this exceptional
case the entries in MEPC.2/Circ.12 Annex 1 - List 1, which
apply to all countries and have no expiry date, will supersede
the entries in the IBC Code.
Polypropylene glycol
Although polypropylene glycol is already an entry in Chapter
17 of the adopted IBC Code, a new submission approved by
ESPH will replace it. The new entry does not change in
pollution category or ship type but changes to the carriage
requirements include a high level alarm requirement found in
Chapter 15 of the IBC Code.
Fatty alcohols and fatty acids
In order to facilitate the large number of fatty alcohols and
fatty acids (oleochemicals) submissions, GESAMP
recommended that these products be grouped according to
chain length. As is the case with the FAME products
discussed above, individual entries previously evaluated will
remain in the adopted Code (tallow fatty acid, coconut oil
fatty acid), but other products will be referred to by chain
length. This will hopefully avoid double entries of products.
FAME Products
ESPH approved a generic entry for fatty acid methyl esters
The following classifications were also finalised by ESPH
Product
1,6-Hexanediol distillation overheads
and Palm kernel acid oil
Category
Ship Type
Tank Type
Y
3
2G
Coal Tar Pitch (molten)
X
2
1G
Creosote (coal tar)
X
2
2G
Ethylene-vinyl acetate co-polymer
Y
3
2G
Fluorosilicic acid (20-30%) in water
Y
3
1G
Polyethylene Polyamines
Y
2
2G
Polyethylene Polyamines (greater than 50%
C5-C20 paraffin oil)
Y
2
2G
Vegetable protein solution (hydrolysed)
Z
Notes
Regulations 4.1.1 & 4.1.2 of MARPOL
Annex II may apply.
Changed from Cat. Z to Chapter 18
OS.
The re-evaluation of the following products did not translate
into a change in their existing classifications:
Alkyl (C12+) dimethylamine
Ammonium polyphosphate solution
Cashew nut shell oil (untreated)
1,6-Dichlorohezane
2,4-Dichlorophenoxy acetic acid triisopropanolamine salt
solution
Diethylene glycol diethyl ether
Ethyl acrylate
Pyridine
Vinyl ethyl ether
Alkyl acrylate-vinylpyridine copolymer in toluene
Dimethyl disulphide
Isobutyl methacrylate
Long chain alkaryl polyether (C11-C20)
Pine Oil
2,2,4-trimethyl-1,3-pentanediol-1-isobutyrate
The following products were re-evaluated and changed ship type but some also changed pollution categorisation:
Product
Comment
iso- & cyclo-Alkanes (C10-C11)
Cat. changed from Z to Y.
iso- & cyclo-Alkanes (C12+)
Cat. changed from Z to Y.
n-Alkanes (C10+)
Cat. changed from Z to Y.
Alkyl (C9+) benzenes
Cat. changed from Z to Y.
Alkyldithiothiadiazole (C6-C24)
Cat. changed from Z to Y.
Calcium long chain alkyl (C11-C40) phenate
Cat. changed from Z to Y.
Dodecyl/octadecyl methacrylate mixture
Cat. changed from Z to Y.
Epichlorohydrin
Cat. changed from Z to Y.
Octanoic acid (all isomers)
Cat. changed from Z to Y.
Octyl aldehydes
Ship Type changed from 2 to 3.
Sulphonated polyacrylate solution
Moves to Chap. 18; Ship Type changed to N.A.
Tridecyl acetate
Cat. changed from Z to Y.
Vegetable protein solution (hydrolysed)
Cat. changed from Z to OS; Moves to Chap. 18, Ship
Type changed to N.A.
Lube Oil Additives
The list of Lube Oil Additives, as in the past MEPC.2/Circ.
Annex 11, will be deleted as these substances are all now in the
IBC Code. Annex 11 will therefore be deleted from
MEPC.2/Circ.12.
Agenda items from the full CTAC meeting included a report from
the CTAC Hazardous Cargo Transportation Security (HCTS) and
the Outreach Sub-committee Work Groups. Included under the
umbrella of the Outreach Sub-committee are the Vapour Control
Work Group, the Barge Emissions and Placarding Work Group
and the MARPOL Annex II Work Groups.
Consolidation of the List of Synonyms for Vegetable Oils
The Group developed an extensive list of synonyms for
vegetable oils to be included in Annex 6 to the pending
MEPC.2/Circ.12. It is set out as Annex 6 to the ESPH 12 draft
report. The ESPH report will be made available as soon as it is
submitted to MEPC for review.
2. Regulatory and Legislative Issues
(i) USCG Chemical Transportation
Advisory Committee (CTAC) Report
The second half of 2006 has been a busy a period for the U.S.
Coast Guard (USCG) Chemical Transportation Advisory
Committee (CTAC).. The U.S. Coast Guard (USCG) Chemical
Transportation Advisory Committee (CTAC) held its most recent
meeting in August 2006 in Jeffersonville, IN.
6
(ii) The Hazardous Cargo Transportation
(HCTS) Sub-committee
The Hazardous Cargo Transportation (HCTS) Sub-committee
reported on the issues discussed at the Sub-committee meeting
also held on 22 August 2006. The report to the CTAC included
a detailed review of the Certain Dangerous Cargo (CDC)
requirements currently in place and recommendations made by
the Sub-committee regarding CDCs. The CDC issue came to
light during the Sub-committee’s review of the Federal Register
notice regarding Advance Notice of Arrival (ANOA) Regulations
and the problems encountered when vessels are considered to
have CDC or CDC residue onboard. In the course of a number
of meetings the group has been able to:
G
Examine and determine the practical issues related to
the handling of residues, pumping materials, and
realistically assessing the quantity of cargo left
onboard after discharge.
G
Examine the hazards of CDC cargoes relative to
properties such as vapour pressure, toxicity, and
exposure guidelines. In doing so the group was able to
determine that very few cargo residues pose a sufficient
risk for the vessel to be considered as carrying a CDC.
G
Develop an acceptable definition of "residue".
It is the recommendation of the HCTS Sub-committee that the
following cargoes remain CDCs at all times, even when only
residue quantities remain onboard:
G
Anhydrous Ammonia
G
Chlorine
G
Ethane
G
Ethylene Oxide
G
Methane (LNG)
G
Methyl Bromide
G
Sulphur Dioxide
G
Vinyl Chloride
For all other cargoes the vessel will no longer be classified as a
CDC vessel when only residue quantities remain onboard. All of
these will require a change to regulations 33 CFR 160.24 and
any other regulations affected by changes to the ANOA
requirements. It is expected that these changes will be implemented via a Supplemental Rulemaking some time next year.
Other Outreach Sub-committee Work Groups
Progress reports were also given on the efforts of the Barge
Emissions and Placarding and Vapour Control Work Groups.
Both met on 23 August 2006. The Barge Emissions and
Placarding Work Group has been working closely with industry
and regulators to address barge emissions and proper
placarding issues raised by the Louisiana Department of
Environmental Quality (LDEQ). The Work Group is led by Amy
Husted of Kirby Corporation.
The Vapour Control Work Group was revived in preparation for
the vapour control regulations to examine the recommendations
made by the CTAC at the inception of that regulatory project. An
interim progress report was presented by CTAC member Ed
Shearer of Shearer & Associates. The next meeting of the
USCG CTAC is tentatively scheduled for April/May 2007
possibly in the Boston area.
(iii) USCG NVIC Update
Although the U.S. will become party to these amendments, the
U.S. regulations will not be completed in time for their entry into
force date of 1 January 2007. Therefore, the USCG regulations
that will be in effect on that date will be the current regulations
for the transport of Annex II substances. The U.S. Coast Guard
does not intend to object under the provisions of Article 16 of
the MARPOL Annex II Revisions.
The USCG intends to develop a Navigation and Vessel
Inspection Circular (NVIC) (guidance document to industry) that
will provide the industry with a method of complying with the
regulations in effect. This elective method will reflect the revised
Annex II. The NVIC will reflect the process that the shipowner
should follow if it should choose to use the elective method.
In November 2005, the Chemical Transportation Advisory
Committee (CTAC) voted to approve the formation of the
MARPOL Annex II Work Group, whose primary objectives will
be to develop a framework for the Navigation and Vessel
Inspection Circular (NVIC) that will be used to implement
MARPOL Annex II.
The INTERTANKO representative chairing the MARPOL Annex II
Work Group apprised the Committee of the various meetings
held since its inception in 2005 up to its final meeting on 22
August 2006 and presented the final report of the group. All of
the hard work of the last nine months has culminated in a "draft
guidance" that contains recommendations from CTAC regarding
the development of the Navigation and Vessel Inspection
Circular (NVIC) that will be used to implement MARPOL Annex
II.
The document developed by the MARPOL Annex II Work Group
is in a format similar to that of an NVIC but is not intended to
represent a “draft” of the document that will be ultimately
published and utilised by the U.S. Coast Guard and industry. It
should be noted, however, that this document - regardless of the
positions taken on particular issues - represents work that is
integral to the development of the skeleton that will implement
MARPOL Annex II in the U.S. until the rulemaking process
begins. It was also decided that this Work Group should remain
intact for 2007 in order to address any MARPOL Annex II
implementation issues that may arise.
To view a copy of the final MARPOL Annex II Work Group report
click here.
The final recommendations contained in the draft guidance were
submitted for approval to the full Committee and are now
available on the USCG portal homeport
(http://homeport.uscg.mil).
To view the draft guidance click here.
At the time of this document going to press the USCG NVIC
is in internal clearance within the USCG and has yet to be
released. It will be posted on the NVIC website as soon
as it is approved for release
(http://www.uscg.mil/hq/g-m/nvic/index00.htm) and will be
placed on the INTERTANKO web immediately after.
3. MARPOL Annex II Update
(i) INTERTANKO to Publish MARPOL
Annex II Booklet
Following discussions with a number of members, INTERTANKO
was asked to develop a comprehensive publication, focusing
solely on the MARPOL Annex II Revisions. This booklet, due for
publication in early November, will contain the most up-to-date
list of products found in the Amended IBC Code as well as the
most current MEPC 2 Circular. The publication will also
summarise the exemption for veg oils under Regulation 4.1.3
and will highlight the various INTERTANKO efforts on this.
(ii) INTERTANKO Biofuels Update
The term biofuel encompasses a diverse range of products such
as bio-gas, biodiesel and bioethanol. Any fuel made from a
renewable biological source is considered a biofuel. Biofuels
include ethanol, biodiesel, and methanol. Biofuel is derived from
“biomass” - recently living organisms or their metabolic
byproducts, such as waste streams, (agricultural, domestic or
municipal). It is a renewable energy, unlike other natural
resources such as petroleum, coal and nuclear fuels. From a
global warming perspective, the carbon in biofuels was recently
extracted from atmospheric carbon dioxide by growing plants, so
burning it does not result in a net increase of carbon dioxide in
the earth’s atmosphere. Liquid biofuels are mainly developed as
a vehicle fuel. The major players are biodiesel (methylester of
vegetable oils) and bioethanol.
Biodiesel is produced from a variety of vegetable oils, including
but not limited to palm, rape, canola, soy, linseed, coconut,
mustard and cotton oils. It can also be manufactured from tallow
oil and yellow grease (used cooking oils). The production
process is to modify the oils through esterification to give
glycerine as a useable by-product.
Because of the already existing infrastructure for processing soft
oils such as palm oil, countries in Asia and Latin America are
looking to invest in biodiesel production, resulting in significant
increases in the exports of crude palm oil and fatty acid methyl
esters (FAME). According to expert forecasts, there will be some
100 new biodiesel and bioethanol plants in Europe by the year
2010.
Bioethanol is a readily available, clean fuel that can be utilised in
combustion engines in different ways:
Anhydrous (or dehydrated) ethanol is free of water and at least
99% pure. This ethanol can be blended with conventional fuel in
proportions up to 85% (E85). Blends up to 20% can be used in
modern engines without modification. Traditionally, MTBE
(Methyl Tertiary Butyl Ether) or ethanol has been added as an
oxygenate to gasoline at 6-10% blend for a cleaner burn. As the
use of MTBE has been banned by a growing number of states,
the U.S. ethanol market has grown from 2.3 to 4 billion gallons
in the last three years.
Higher blends require modified engines that run as flexible fuel
vehicles (FFVs). There are currently over a million FFVs on the
road in the U.S. with an increasing number added each year, and
there are a small but growing number of E85 gas stations,
primarily in the Midwest.
Finally, bioethanol is also used to manufacture ETBE (ethyltertiary-butyl-ether), a fuel additive for conventional petrol.
Because ethanol is a great solvent and pulls in water, it is
typically not mixed with gasoline prior to being shipped via
pipeline. In the U.S. most blends are shipped separately; the
gasoline is transported via pipeline and the ethanol is sent by
truck/rail/barge for blending at the distribution point. In the U.S.,
for example in the state of New York, which uses a 10% ethanol
blend, a terminal south of Albany receives 100% ethanol by
barge and mixes it with gasoline from a pipeline.
The U.S. Congress has recently passed a Renewable Fuel
Standard (RFS) that requires a minimum percentage of liquid
fuels from renewable sources. At current gasoline prices there is
an economic incentive to blend more than the required levels of
ethanol. In markets where states have not yet banned MTBE,
distributors are switching to ethanol blends for economic
reasons.
These generic terms “biofuel” and “biodiesel” involve a number of
different products. Because of this, these products cannot be
shipped under MARPOL Annex II using these trade names. Most
of the discussion recently regarding the classification of bio-fuels
has been predominantly about biodiesel. The majority of biodiesel
cargoes are fatty acid methyl esters (FAME), which can have
various compositions. There are only three fatty acid methyl esters
approved for carriage under the current MARPOL Annex II:
Palm oil fatty acid methyl ester (currently in the IBC Code)
Coconut oil fatty acid methyl ester (currently in the IBC Code)
Rapeseed oil fatty acid methyl ester (currently in list 1 of
MEPC.2 Circ)
All three of these products are Category D and Chapter 18.
Tripartites are required for any fatty acid methyl ester other than
those listed above. Soyabean oil fatty acid methyl ester is
currently being tripartited between the United States, the U.K.
and Singapore. (It to will be a Category D and Chapter 18.) Any
new entity looking to transport this cargo must also be listed as
a party to the agreement.
ESPH 12 approved a generic entry for fatty acid methyl esters
(FAME) products. A footnote (m) on this entry will indicate that
the FAME products carried are derived from vegetable oils
already in the IBC Code. The individual FAME products that
have already been evaluated under the new system are palm oil
FAME, rapeseed oil FAME and coconut oil FAME. From 1
January 2007 FAME derived from any other vegetable oil already
evaluated and classified may be carried under the generic entry.
This will also mean that blends of FAME products need not be
subject to a mixture calculation.
Regardless of the base oil, FAME products are not “unmodified”
oils, and will not be considered applicable under the exemption
clause in MARPOL Regulation 4.1.3. (carried in Type 3 space
with Type 2 hull requirements). Right now some charterers are
lobbying to consider biofuels and biodiesel as Annex I cargoes
and not Annex II. There are obviously other stakeholders that
wish to assess each individual product separately under Annex
II, including applicable biofuels, in Chapters 17 and 18 of the
IBC Code.
Most bio-ethanol cargoes (and some biodiesels) containing any
blend containing 85% or more of a mineral diesel oil or gasoline
qualify as an Annex I product. The issue of the carriage of
biofuels will become more prevalent as more of this product is
shipped. Classification of these products needs to be discussed
in greater detail and resolved to ensure the trade can continue
after 1 January 2007.
4. Safety Updates
(i) Bow Mariner report – USCG reply to
INTERTANKO/ICS response
We advised members of the availability of the USCG report into
the loss of the Bow Mariner in our article in Weekly NEWS No.
01/2006 of 6 January 2006. Within the report it was
recommended that the USCG Commandant approach
INTERTANKO and the International Chamber of Shipping (ICS)
with a view to "forming a study group to examine the causes of
all tank vessel explosions in the last five years involving tank
cleaning to search for common factors". ICS and INTERTANKO
formally responded on 26 April 2006 (click here to view our
joint letter).
McCormick, Clipper Wonsild Tankers, Inc. and Richard Sages,
Odin Marine, Inc. INTERTANKO has been invited to participate
in a follow-up session focusing on post 1 January 2007 trends at
the 2007 NIOP Conference tentatively scheduled for March
2007 in Palm Springs California.
(ii) EI/API HM51 Chemical Measurement
Work Group
INTERTANKO continues to participate in the European Institute
(EI)/American Petroleum Institute’s (API) working group tasked
with reviewing the draft of “HM51, Procedure for Bulk Liquid
Chemical Cargo Inspection By Cargo Inspectors". The purpose
of HM51 is to provide systematic cargo measurement
procedures for use primarily by cargo inspectors and to specify
procedures directed at minimising cargo contamination. The goal
of the working group is a review of the complete document with
special consideration given to Chapter 9 (Procedures to Control
Product Quality). The expansion of the Work Group to include
tanker and barge representatives was initiated in early 2006. API
will be working with EI to consolidate the changes prior to the
meeting at the API Denver meeting in late 2006.
6. INTERTANKO Chemical Committee
meetings
(i) Joint Chemical Tanker Committee (CTC)
and Chemical Tanker Sub-committee
(Americas) (CTSCA) meetings held
The INTERTANKO Chemical Tanker Committee (CTC) and
Chemical Tanker Sub-committee (Americas) (CTSCA) held a
joint meeting on 14 March 2006 at the Wyndham Greenspoint
Hotel in Houston, Texas.
5. Coordination with other Associations
Agenda items included an update on the deliberations of the
Inter-Industry Work Group; dialogue on the revisions to
MARPOL Annex II; a review of the products currently in the IBC
Code still missing data (relative to the recent report of the 42nd
GESAMP/EHS Working Group); a report from the USCG
Chemical Transportation Advisory Committee (CTAC) MARPOL
Annex II Work Group; a discussion of classification of tripartites
in the U.S.; and the carriage and classification of biofuels. Lastly,
both the CTC and CTSCA Secretaries gave an update on the
dialogue with other associations including, the National Institute
of Oilseed Products (NIOP), the Federation of Oil, Seeds and
Fat (FOSFA) and the Independent Liquid Terminal Association
(ILTA).
(i) INTERTANKO attends NIOP 2006
Click here to view the minutes of this meeting.
INTERTANKO attended the National Institute of Oilseed
Products 2006 (NIOP) Annual Conference held last March in
Phoenix, TX. The panel discussion entitled “International Maritime
Organization 2007 - Cargo Reclassification and Impact on
Shipping” was held during the “hot topics” portion of the
conference. The panel was moderated by Liam Rogers, Hudson
Tank Terminals; other panellists participating were Mike
The next combined CTC/CTSCA meeting will be held in the
autumn of 2007 in London. The recent CTSCA meeting was
held in Houston, TX, on 17 October 2006.The next CTC
meeting will be held in London on 8 November 2006.
We have now received a response from the USCG confirming
that the joint letter satisfactorily addresses the relevant
recommendation in the Bow Mariner Report
(click here to view the reply).
The CTC meeting will be held in London on 8 November 2006. A
copy of the agenda is available. Click here
9
(ii) Joint Chemical and Vetting Seminar Held
7. CDI – Inspector Appointment Revisions
INTERTANKO also hosted a Joint Chemical and Vetting Seminar
on 15 March 2006 at the Wyndham Greenspoint Hotel in
Houston, Texas. Over 75 people attended the full-day Seminar
comprising the chemical session held in the morning and the
vetting session in the afternoon. The presentations during the
chemical session, chaired by the Chemical Tanker Committee
Chairman Lars Modin, included:
The CDI’s Marine Inspection department (CDI-mid) is governed by
the Statute of the Stichting Chemical Distribution Institute and is
compliant with the Quality Management System in place. The
function of CDI-mid is to respond to ship operators’ and
charterers’ requests for ship inspections and to appoint the
inspector by means of a "mechanical rotation system" (MRS). This
in effect means that the owner is no longer able to select the CDI
inspector to undertake the CDI inspection. Instead the request has
to be sent to CDI-mid, which will appoint the inspector on a strictly
rotational basis.
An Overview of the MARPOL Annex II Revisions, Pre & Post
1/1/2007 (Margaret Doyle, Chemicals Manager, INTERTANKO)
US Coast Guard Houston Sector Port Update and How
Changes to “Sector Houston” Will Affect the Chemical Owner
(CDR Joseph Paitl, Chief,Port Operations, US Coast Guard,
Department of Homeland Security)
Implementation of MARPOL Annex II in the USA *(CDR Bob
Hennessy, Chief, Hazardous Materials Standards Branch, US
Coast Guard, Department of Homeland Security)
The Classification of Biofuels, Maurice Gordon, President,
Maritime Systems Engineering, Inc.
The afternoon vetting session, chaired by Captain Bob Bishop
(Vetting Committee Chairman) agenda included:
Chevron Clearing and Vetting and System, (Tom Pappas,
Clearance Team Leader, Chevron Clearance and Vetting)
Introduction to BP Ship Terminal Feedback Integration with
Intertanko Terminal Vetting Database. (Jim Fortnum, Offshore
Assurance Superintendent, BP)
Port State Control in the USA, CDR Paul D. Thorne,
Commandant (G-PCV-2) Chief Foreign Vessel & Offshore
Activities, US Coast Guard, Department of Homeland Security)
SUNOCO Vetting and Screening, Captain Bill Harkness,
SUNOCO Logistics Partners
A Demonstration of www.Q88.com - A Service of INTERTANKO
(Peter Renehan, Q88.Com)
The meeting was well received and appreciated by members and
non-members alike. Most of these presentations are available in
the chemical section of the INTERTANKO website. The views
expressed by the invited speakers within these presentations are
those of the presenter and not necessarily INTERTANKO's.
Full details of the system can be accessed from the CDI web site
http://www.cdi.org.uk/main.html (download section under CDIMarine Inspection Department). The information includes how the
system works, CDI's obligation, inspection zones, inspection
request and rejection of an appointed inspector.
Note: INTERTANKO was asked by the CDI to review and
comment on these changes. We appreciated this opportunity, and
following a review by the INTERTANKO Vetting Committee and
Chemical Tanker Committee, INTERTANKO has offered its full
support to the CDI for the changes regarding CDI inspector
appointment. This is viewed as an enhancement to the system
8. MARPOL Annex II Waste Reception
Facilities Survey
INTERTANKO members, will be aware that INTERTANKO has
kept them advised of the work being undertaken on reception
facilities, both within the Port Reception Facility Forum and within
the IMO. We recently advised members of the discussion and our
input at IMO during FSI 14 regarding reception facilities pertaining
to Annex II.
Following on from this, the IMO is in the process of further
developing its Global Integrated Shipping Information System
(GISIS) database, which can be accessed at the following link:
http://gisis.imo.org/Public/. The area of interest to chemical owners
is not only the Annex II reception facility information that is available
within the GISIS web site, but also the manner in which the information is presented and the detail of the information - not only at the
current time but especially when the revision to Annex II comes into
force on 1.1.2007 and particularly the additional requirements
regarding pre-wash for certain vegetable oils. INTERTANKO
therefore had the opportunity in its discussions with the IMO
Secretariat to supply its input and feedback on not only what
information is or would be beneficial to you (the users), but also the
format of the way in which the information could be presented.
We undertook a survey of chemical tanker members on this issue.
The replies we received to our survey have now being collated into
a report and submitted to the IMO Secretariat to help and assist
them with regard to the IMO GISIS database work that is being
undertaken. Click here to view this report.