INTERNATIONAL MARITIME ORGANIZATION
E
IMO
SUB-COMMITTEE ON BULK LIQUIDS
AND GASES
13th session
Agenda item 3
BLG 13/3
3 November 2008
Original: ENGLISH
EVALUATION OF SAFETY AND POLLUTION HAZARDS OF CHEMICALS AND
PREPARATION OF CONSEQUENTIAL AMENDMENTS
Report of the fourteenth session of the Working Group on the Evaluation of
Safety and Pollution Hazards of Chemicals
SUMMARY
Executive summary: This document reports on the outcome of the fourteenth session of the
Working Group on the Evaluation of the Safety and Pollution Hazards
of Chemicals (ESPH 14) which was held from 27 to 31 October 2008
Strategic direction:
7.2 and 1.3
High-level action:
7.2.2. and 1.3.3
Planned output:
7.2.2.1 and 1.3.3.1
Action to be taken:
Paragraph 10
Related documents:
None
1
INTRODUCTION
1.1
The Working Group on the Evaluation of Safety and Pollution Hazards
of Chemicals (ESPH) met on 27 to 31 October 2008 under the Chairmanship of
Mr. Iain David MacRae (United Kingdom).
1.2
The meeting was attended by representatives from the following Member Governments:
BELGIUM
CHINA
EGYPT
FINLAND
FRANCE
GERMANY
JAPAN
MALAYSIA
NETHERLANDS
NORWAY
OMAN
SWEDEN
UNITED KINGDOM
UNITED STATES
For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.
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and observers from the following non-governmental organizations in consultative status:
INTERNATIONAL CHAMBER OF SHIPPING (ICS)
INTERNATIONAL ASSOCIATION OF PORTS AND HARBORS (IAPH)
OIL COMPANIES INTERNATIONAL MARINE FORUM (OCIMF)
INTERNATIONAL ASSOCIATION OF INDEPENDENT TANKER OWNERS
(INTERTANKO)
DANGEROUS GOODS ADVISORY COUNCIL (DGAC)
INTERNATIONAL PARCEL TANKERS ASSOCIATION (IPTA)
1.3
Prior to the start of the meeting the Secretariat reminded the Group that the previous
Chairman, Mrs. M.C. Tiemens-Idzinga (Netherlands), after many years of dedicated service was
now no longer able to participate in the Group. Mr. Iain David MacRae (United Kingdom) had
kindly indicated that he was willing to take up this position and this was relayed by the
Secretariat to the Group. Mr. MacRae was accordingly nominated for Chairman by the
delegation of the United States and this was seconded by the delegation of Norway and then
supported unanimously by the Group.
Opening address
1.4
In his opening address, the Chairman welcomed everyone to ESPH 14 and expressed his
thanks to the Group for their support. He acknowledged that maintaining the high standards set
by Mrs. M.C. Tiemens-Idzinga was a formidable challenge but hoped that with the continued
commitment of the Group, it would be possible to sustain the ongoing progress being made with
all agenda items.
Adoption of the agenda
1.5
The adopted agenda of the meeting, with the associated list of documents, are set out in
annex 1. In adopting the agenda, the Chairman drew the attention of the Group to the need to
modify item 6 “Consideration of the application of requirements for the carriage of bio-fuels and
bio-fuel blends, including blending on board” in view of the recent decisions taken at MEPC 58.
1.6
At this session, the Committee deliberated the proposal to expand the terms of reference
of the ESPH Working Group to include blending on board during the sea voyage. Whilst some
delegations had advised that this was an ongoing practice and therefore a concern, others had the
view that insufficient information had been made available to support this point.
1.7
The Committee agreed that a final decision on whether to expand the terms of reference
on this topic should be taken by the BLG Sub-Committee. If a need was demonstrated by the
submission of relevant information and this was agreed by BLG 13, the Intersessional ESPH
Working Group should, on this occasion, then work on this issue during 2009. In view of this
decision, the Committee noted accordingly that only shore-blended material should consequently
be addressed at the ESPH 14 meeting.
2
EVALUATION OF NEW PRODUCTS
2.1
The Group noted that there were seven new products submitted to this session
for evaluation:
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.2
.3
.4
.5
.6
.7
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Dialkyl (C9-C10) phthalates (ESPH 14/2);
Glycerol ethoxylated (ESPH 14/2/1);
Olefin mixtures (C7-C9) (ESPH 14/2/2);
Sodium bromide solution (less than 50%) drilling brines (ESPH 14/2/3);
Sodium bicarbonate solution (less than 10%) drilling brines (ESPH 14/2/4);
Potassium chloride (brines <26%) (ESPH 14/2/5); and
Alcohols, linear (C12+) (ESPH 14/2/6).
2.2
When considering each proposal, the Group recalled that it was important to ensure that
all the appropriate data had been submitted and that the proposed classification and carriage
requirements were commensurate with the data provided.
2.3
With respect to the former point, it was noted that if data are inconsistent or incomplete,
it becomes a difficult task to establish clearly the minimum carriage requirements. In such cases,
it was recalled that the ESPH Working Group had been directed by the BLG Sub-Committee not
to accept such submissions and it was important therefore for Administrations or NGOs to ensure
that all information provided was complete and fully comprehensive.
2.4
With regard to the presentation of data, the Group recalled that submissions should
always be made using the BLG data reporting form and that documents now needed to provide
linkages to the Strategic and High-level Action Plans in line with the operations of the Guidelines
on the Organization and method of work of the Maritime Safety Committee and the Marine
Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.2).
2.5
With respect to the latter point, it was debated whether the entries for Strategic direction,
High-level action and Planned output for new product submissions should utilize respectively
codings of 1.3/1.3.3/1.3.3.1 or 5.2/5.2.3/5.2.3.1. Whilst both routes may be seen to have merit,
the Group decided that the preferred allocation was the latter one (5.2/5.2.3/5.2.3.1) and it was
agreed therefore that for consistency, this coding should be used for all future product evaluation
submissions.
2.6
In assessing this issue, the Group noted that additional clarification for the planned
outputs under the references given above would be beneficial and it was proposed that this
should be considered whenever the High-level Action Plan is updated. Specifically, it was noted
that 1.3.3.1 in relation to the IBC Code refers only to MEPC but should include also MSC and
that 5.2.3.1 should reflect amendments to MARPOL Annexes I and II and the IBC Code rather
than input.
2.7
In considering the products submitted, it was noted that in the accompanying GESAMP
profiles, in some cases entries for parameters D3 (long-term health effects) and E1 (tainting)
were shown as blanks and it was questioned if this meant that the profiles were incomplete.
2.8
The Secretariat advised that it had been past practice to leave D3 empty if none of the
specified effects under this parameter were judged to be relevant by the GESAMP/EHS team and
this could clearly be seen by inspecting the latest GESAMP/EHS composite list. In the current
database design, unless an appropriate code letter is entered, the default action is to leave the
parameter blank. The fact that a profile appears in the composite list means that it is endorsed by
the GESAMP/EHS Group and it is not therefore the case that the profile is incomplete. Should
there have been any doubts at the review stage, either a precautionary approach would be adopted
and the appropriate code letter(s) entered or the product would be rejected pending a request for
further information from the supplier.
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2.9
With respect to parameter E1, it is noted in GESAMP Reports and Studies No.64 that
over recent years, an assessment of tainting properties has been steadily withdrawn as
a regulatory criterion for classifying chemical substances for transport purposes.
In the GESAMP composite list, all existing ratings cited are endorsed by supporting evidence
and on this basis, it was decided to retain column E1 in the profile for information purposes.
In taking this action, it was recognized that ratings on new substances are no longer expected to
be presented in the future.
2.10 For both D3 and E1 properties, it was recognized that the use of blank entries might still
be seen by some as confusing and it was agreed therefore that this should be relayed to the
GESAMP/EHS Group for their consideration.
2.11 In considering the submission on Dialkyl (C9-C10) phthalates (ESPH 14/2), the Group
noted that following a recent review of phthalates by GESAMP/EHS, a number of changes to the
hazard profile had been adopted. This had resulted in two changes to the carriage requirements
established under the tripartite agreement being proposed relating to columns “i'” and “o”.
It was additionally noted that for column “o”, a reference to 15.19.6 was needed as the material
was pollution category Y.
2.12 It was noted that no synonyms had been specified in the submission for this product but
that a number of Index names listed in chapter 19 of the IBC Code in relation to Dialkyl
(C7-C13) phthalates would be applicable in this instance (e.g., Didecyl phthalate, Diisodecyl
phthalate, Diisononyl phthalate and Dinonyl phthalate). It was agreed that the resolution of this
issue should be taken into account during the work to review all chapter 19 Index name entries.
2.13 In considering the submission on Glycerol ethoxylated (ESPH 14/2/1), the Group noted
that compared to the initial tripartite agreement, the Pollution category has now been changed
from Z to OS and carriage requirements related to the former assignment have been withdrawn.
2.14 In debating this product, the Group recalled that when GESAMP ratings are placed in
brackets reflecting that the assignment is not based on an actual test result, this should
nevertheless be interpreted in the same manner as an unbracketed result for the purposes of
assigning carriage conditions (see annex 7 of document BLG 12/3, Decisions with regard to the
categorization and classification of products).
2.15 In reviewing the submission on Olefin mixtures (C7-C9) (ESPH 14/2/2), the Group noted
that in the EHS Composite List there are already existing entries for Heptene (all isomers);
Octene (all isomers) and Nonene (all isomers) and that data had consequently been cross-checked
with the information held for these substances in the course of assigning a profile for the olefin
mixture.
2.16 The Group further noted that although this olefin mixture may be considered to be
covered by the entry for olefin mixtures (C5-C15), there was a clear onus upon shippers to use
specific Product names in preference to more generic descriptions when offering bulk liquid
cargoes for shipment as detailed in BLG.1/Circ.25.
2.17 In the context of the Product name, the Group decided that a more detailed description
was required and it was agreed therefore that the name should be amended to specify additionally
“C8 rich, stabilized”.
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2.18 In comparing this product to other similar olefin substances and mixtures, the Group
observed that there may be some inconsistencies within this product family and accordingly, it
was agreed that GESAMP/EHS should be requested to review these materials. This should
address not only the profiles but also the names used to describe olefin mixtures.
2.19 In view of this action, it was agreed that “Olefin mixtures (C7-C9), C8 rich, stabilized”
should be retained as a tripartite agreement valid for all countries but still retaining its expiry
date, pending the review of the family group as indicated above.
2.20 In considering the submission on Sodium bromide solution (less than 50%) drilling brines
(ESPH 14/2/3), the Group noted that in the original data form, a concentration of 48% had been
specified but in the current Tripartite agreement the entry for this product related to solutions
“less than 50%”. It had been accepted by GESAMP/EHS that the data supplied would support
the latter product and that the higher percentage level limit could therefore be adopted.
2.21 In terms of the Product name, as drilling brines reflected an application or use, it was
agreed to delete this reference.
2.22 The Group noted that in the submission proposal, due to concerns with respect to
reprotoxicity for sodium bromide, requirements in relation to controlled tank vent, closed
gauging, toxic vapour detection and other operational requirements would be triggered.
It was considered by some Member States, however, that only non-hazardous water vapour
should result from this product and accordingly, it was questioned if these controls were really
necessary in this situation.
2.23 Some members of the Group considered that when a toxic solid with a low vapour pressure
is suspended in water, loaded and discharged under closed conditions and carried at ambient
temperature, the requirement of chapter 21.4.7 for controlled Tank vents should not apply.
However, others considered that the full requirements of 21.4.7 for controlled venting should apply.
2.24 The Group was informed that the main use of drilling brines is in the offshore industry
and if controlled venting were applied, Offshore Support Vessels (OSVs) would not be able to
carry this product or another two products currently in List 1, Ammonium chloride solution (less
than 25%) drilling brines and Cesium formate solution (less than 25%) drilling brines.
Currently OSVs do not have controlled vents fitted for practical reasons and would not be able
to comply with the requirements in the IBC Code.
2.25 As a consequence of these discussions, the Group agreed that the existing tripartite
agreement should remain in force pending further deliberations on this issue and invited
interested Member States to submit proposals to BLG 13 for consideration.
2.26 The Group, in evaluating the submission on Sodium bicarbonate solution (less than 10%)
drilling brines (ESPH 14/2/4) observed that in the original data form, a concentration of 7.5%
had been specified but in the current Tripartite agreement the entry for this product related to
brines “less than 10%”. It had been accepted by GESAMP/EHS that the data supplied would
support the latter product and that the higher percentage level limit could therefore be adopted.
2.27 The Group agreed to delete the term drilling brines from the Product name and, agreed
further, to request GESAMP/EHS to consider adding the descriptor “less than 10%” to the entry
in the composite list. It was noted that in the BLG product data form, some of the data presented
for physical properties appeared to be related to the solid material rather than the 10% solution.
It was reiterated that all data should be directly relevant to the product under evaluation.
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2.28 In presenting the submission on Potassium chloride (brines <26%) (ESPH 14/2/5), it was
noted that at the GESAMP/EHS review, it had been observed that in the Composite List entries
already existed for “potassium chloride solution” and “potassium chloride brine”. Accordingly,
it had been agreed to rename the latter entry (qualifying this with a limit of <26%) rather than
introduce a third entry. In consolidating all data, the D2 column (eye irritation) entry for both
products was modified to a rating of 0 (reflecting solution properties rather than the effects
observed for the solid material). This change, in turn, also then resulted in a modification of
the C3 rating for both products from a (1) to (0).
2.29 In considering this product submission, the Group decided that a more appropriate
Product name would be potassium chloride solution (<26%) but that the brine descriptor should
then be noted as a synonym.
2.30 The Group noted that in the case of the submission on Alcohols, linear (C12+)
(ESPH 14/2/6) the carriage requirements proposed were equivalent to those specified for
Alcohols (C12-C13), primary, linear and essentially linear. It was further noted that the existing
entry for Alcohols (C13+) might now also be covered by the new proposal but that, although
carriage requirements set for the two grades had some differences, this was not a problem since
the C13+ product was effectively a subset of the Alcohols, linear (C12+) product.
2.31 Although there was some overlap, as noted previously it was reiterated that use of the
most specific Product name should always be used when offering bulk liquid cargoes for
shipment as detailed in BLG.1/Circ.25.
2.32 For clarification purposes, the Group agreed that the Product name should be expanded to
include the terms “primary, linear” after Alcohols (C12+).
2.33 The Group’s decisions on each of the products reviewed regarding the classification and
assignment of carriage requirements are set out at annex 2.
3
EVALUATION OF CLEANING ADDITIVES
3.1
The Group recalled that MARPOL Annex II, regulation 13, on “Provisions on the control
of discharge of Noxious Liquid Substances” imposes restrictions on the cleaning additives
permitted for use in tank washing operations as follows:
“13.5.2 When small amounts of cleaning additives (detergent products) are added to
water in order to facilitate tank washing, no additives containing Pollution Category X
components shall be used except those components that are readily biodegradable and
present in a total concentration of less than 10% of the cleaning additive. No restrictions
additional to those applicable to the tank due to the previous cargo shall apply.”
3.2
The Group was informed that 49 cleaning additives had been presented to this session for
evaluation through the revised tank cleaning additives guidance note and reporting form as issued
under MEPC.1/Circ.590, which has superseded MEPC/Circ.363. In line with normal practice, in
order to preserve the confidentiality of the composition of such additives, the additives were
evaluated by a sub-group made up of representatives of Administrations only. The delegations of
Belgium, Germany, the Netherlands, Norway and the United States were represented in the sub-group.
3.3
The sub-group reported that compositions of 31 products met the criteria outlined
in MEPC.1/Circ.590. One manufacturer withdrew three products due to errors on their forms.
The other 15 rejected products contained at least one ingredient that had not been evaluated
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by GESAMP/EHS. The absence of a GESAMP/EHS hazard profile for greater than 1% of the
product composition was considered to be inconsistent with the procedures for cleaning additive
assessment. In that regard, the instructions in MEPC.1/Circ.590, paragraph 7.1, indicate that
obtaining a hazard profile for components should be the initial step in obtaining approval for
cleaning additives, and MEPC.1/Circ.512 permits one per cent unknown substances in a mixture.
One cleaning additive lacked a hazard profile for three components. A delegation noted that
obtaining hazard profiles for the components would cost $19,500.00 and that such a sum seemed
quite large for smaller cleaning additive producers. Annex 3 shows the list of cleaning additives
meeting the criteria.
3.4
For one company’s cleaning additives applications, each had an accompanying Material
Safety Data Sheet (MSDS). While not required, the sub-group considered the information
helpful, and the Group strongly recommends that forms be supplied along with MSDSs, which
are also supplied to users of the cleaning additives.
3.5
In regard to usage instructions, all applications proved, at least, adequate.
No applications were rejected because of shortcomings in the recommended usage instructions.
3.6
One cleaning agent contained Nitriloacetic acid, trisodium salt solution (NAT) which is
carcinogenic, mutagenic, and reprotoxic. As was the case previously for Dipentene, concerns
related to occupational health and protection of the marine environment were expressed
regarding the use of NAT as a component in a cleaning additive.
3.7
The Group recalled that Member Governments having submitted cleaning additives for
evaluation according to MEPC.1/Circ.590 are advised to maintain records of information
submitted on approved cleaning additives listed in annex 10 of the MEPC.2/Circular. As no files
will be kept within IMO, any changes in composition, ingredients or instructions for use resulting
in any questioning of the evaluation may be tracked through national files only.
3.8
The Group further recalled that since the Marine Environment Protection Committee, at
its fifty-sixth session, had agreed that cleaning additives in annex 10 of the MEPC.2/Circular,
identified as being evaluated through MEPC/Circ.363, will cease to be valid by 31 July 2010,
re-evaluation of the cleaning additives concerned will be necessary.
3.9
The need to stress the urgency of this work in order to be able to comply with the
timelines for the different phases of activity was reiterated by the Group. It was noted that this
has already been strongly emphasized and reflected in circular BLG.1/Circ.24 (Re-submission of
data for cleaning additives for re-evaluation under the revised MARPOL Annex II).
4
REVIEW OF MEPC.2/CIRCULAR – PROVISIONAL CLASSIFICATION OF
LIQUID SUBSTANCES TRANSPORTED IN BULK AND OTHER RELATED
MATTERS
4.1
The Group recalled that under this agenda item, it was customary to consider those products
that have been subject to tripartite agreements and reported to IMO since the publication of the
latest version of the MEPC.2/Circular (MEPC.2/Circ.13), along with those tripartite agreements
which had passed their expiry date. In the latter case, due to the special provisions made in view
of the revision of MARPOL Annex II and the consequential amendments to the IBC Code, there
were no products in this category to be reviewed at this time. It was noted, however, that starting
from next year (i.e. for listing in MEPC.2/Circ.15), expiry dates may be triggered and that
Administrations and industry should accordingly take action on such cases as appropriate.
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4.2
It was agreed by MEPC that a three-year period was sufficient to carry out the necessary
testing and submit the information for GESAMP/EHS to assess and provide a hazard profile for
the product which was under a tripartite agreement and agreed that tripartite agreements should
not be extended beyond the stipulated three-year period.
4.3
The Group also recalled that regulation 6.3 of the revised MARPOL Annex II requires the
Administration initiating a tripartite agreement for the classification of products to provide IMO
with the appropriate details of the agreed classification within 30 days and Guidelines for the
provisional assessment of liquid substances transported in bulk are presented in MEPC.1/Circ.512.
4.4
It was noted that document ESPH 14/4/3 had been circulated so that Administrations
could check those tripartite agreements for which they have been responsible, in order to ensure
that the entries would be correct when published in December 2008.
4.5
In this context, with the entry into force of the 2007 amendments to the IBC Code taking
effect from 1 January 2009, it was noted that a number of deletions from List 1 have now been
made. These represent those products which are marked up with footnote “n” in chapter 17 or
footnote “a” in chapter 18 of the IBC Code 2007 edition.
4.6
In accordance with the decision taken by the Group at its previous meeting, List 1 entries
to be retained for MEPC.2/Circ.14 accordingly now comprise of the following elements:
-
all tripartite entries still showing an expiry date;
-
entries having “all countries/no expiry date” but which were finalized after adoption
of the amendments to the 2009 IBC Code; and
-
entries included in the amendments of 2009 IBC Code but for which changes have
subsequently been agreed as reflected in their List 1 profiles.
These entries together with any new notifications received throughout the past year hence
form the basis for List 1 in the draft MEPC.2/Circ.14.
4.7
The Group noted that additionally, four products identified from the review of the
GESAMP/EHS report (paragraph 5.12) had been presented with the List 1 entries for review.
In these cases, it was recognized that the carriage requirements currently assigned were not
compatible with the GESAMP hazard profiles for these materials but it was agreed that, in line
with the standard process, a submission for each product with an accompanying BLG data
reporting form was needed in order to formally review the revisions required. These products
will accordingly not be listed in MEPC.2/Circ.14.
4.8
In this context, the Group noted that whenever a GESAMP hazard profile is amended it is
incumbent upon all interested parties (whether Industry or Administrations) to note the changes
made and then to take action as appropriate with respect to any consequent impact on carriage
requirements. If amendments are to be proposed, these should be submitted in the normal
manner for consideration by the ESPH Working Group.
4.9
For clarity in document ESPH 14/4/3, it was noted that in all Product Lists, where any
changes have been made relative to the entries of MEPC.2/Circ.13, these are highlighted for
information purposes.
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4.10 In addition to the List 1 deletions described above, for List 2, it was noted that two
products have been removed (Solvesso 150 and Solvesso 200) following their reassignment to
List 3. Similarly, for List 4, OLOA 49807 was also deleted following reassignment to List 3.
4.11 Amendments needed for the Interesterified Mixed Vegetable Fat products in List 3 prior
to issuing MEPC.2/Circ.14 in December 2008 were advised by the delegation of Malaysia and
these will be adopted accordingly.
4.12 It was noted that any new inputs or corrections should be provided by 1 December 2008
to allow for processing and publication in MEPC.2/Circ.14.
4.13 With respect to products successfully reviewed under agenda item 2, these will be entered
in List 1 to reflect validity for “all countries” with “no expiry” date pending their subsequent
adoption into chapter 17 of the IBC Code.
4.14 The Group also noted that under this agenda item, four trade-named products had been
submitted for evaluation as permanent entries of List 3 ((Trade-named) mixtures containing at
least 99% by weight of components already assessed by IMO, presenting safety hazards):
.1
OLOA 865G (ESPH 14/4)
.2
OLOA 50908 (ESPH 14/4/1)
.3
RBHC (ESPH 14/4/2)
.4
H.B.M. (Volatile Oil) (ESPH 14/4/4)
4.15 In the case of evaluating Trade-named mixtures, it was recognized that in many cases
there was a need to maintain certain confidentiality aspects with respect to formulation details.
In this event, it was agreed that when this was required, it was not appropriate to include
the BLG Data Reporting Form in the document to be placed on IMODOCS due to its then broad
access/availability (encompassing not only Member States but also IGOs and NGOs).
4.16 This approach had been adopted for the two OLOA products and RBHC and the
associated BLG Data Reporting Forms were therefore issued during the meeting to Member State
Representatives only. These forms were retrieved after use in order to maintain control of the
confidential data presented.
4.17 In considering the general principles of how to handle commercially sensitive
composition data for Trade named mixtures with components presenting safety hazards (List 3
entries in the MEPC.2/Circular), the Group concurred that a clear procedure was required.
4.18 It was agreed that the interests of all parties could be served by adopting the following
procedures:
.1
submissions need not incorporate detailed compositional data if a degree of
commercial sensitivity has been identified;
.2
this may be achieved by removing any sensitive data from the BLG Data
Reporting Form accompanying the document;
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.3
the submission document itself should nevertheless clearly identify all
components present which pose a safety hazard and should reflect the safety
concern(s) involved;
.4
the rationale for assigning pollution category and ship type should be provided in
accordance with MEPC.1/Circ.512 but components and percentages need not be
specified;
.5
the “contains name”, however, should be provided with a justification for its
choice based on the latest GESAMP/EHS hazard profile;
.6
when reviewing the product at the ESPH meeting, a complete BLG Data
Reporting Form should be made available to any interested Member States in
order that they may fully assess the mixture in line with MEPC.2/Circ.512; and
.7
upon completion of the review, the data forms should be returned to the reporting
country in order to maintain a control of the commercially sensitive aspects.
4.19 It was stated by the delegations of the Netherlands and Norway that if information from
the BLG form is needed by an Administration for List 3 products having commercial sensitivity,
this should be made available, under confidential terms, upon request.
4.20 In considering the review process itself, it was debated if this should be undertaken in a
closed session (similar to the procedures adopted for dealing with Cleaning Additives) but the
Group decided that this was not required.
4.21 In reviewing document ESPH 14/4 on OLOA 865G, the Group noted that in view of the
properties of some components with respect to inhalation toxicity and sensitization, the mixture
was now considered to present safety hazards and needed therefore to be reviewed accordingly.
4.22 It was noted as a general point that in view of the IBC Code requirement to treat skin
sensitizers as respiratory sensitizers (unless demonstrated otherwise), there could be an
increasing number of cases where special requirement 15.12 (toxic products) would be triggered.
4.23 In evaluating document ESPH 14/4/1 on OLOA 50908, the Group noted that this mixture
was also now considered to present safety hazards and required a revision of its carriage
requirements accordingly. Again, concern was expressed in relation to the need to specify 15.12
(Toxic products) in the specific and operational requirements.
4.24 In reviewing document ESPH 14/4/2 on RBHC, the Group noted that although this
product had been previously carried as “Benzene and mixtures having 10% benzene or more”, as
the composition of RHBC had now changed with the effect of raising the product to pollution
category X, it was necessary to reassess this material and to assign new carriage requirements
accordingly.
4.25 In assessing the product, there was debate as to whether this material was a List 3 mixture
or if it should be considered as a List 1 entry. It was recognized that there was a degree of
ambiguity associated with the term mixture but the issue was: should products generated as
production cuts (as opposed to blended formulations) be assessed on the basis of their
components? Additionally, it was questioned, in this case, if products of this nature should not
be treated as Annex I cargoes?
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4.26 After due consideration, the Group agreed that the product should be retained as an
Annex II material to be placed on List 3 but it was decided that the Trade name needed to be
qualified since Reformate Benzene Heart Cut (RBHC) alone was too generic. Accordingly, the
Trade name was modified to RBHC (Exxon Mobil).
4.27 It was noted that the delegation of the United States expressed concern at the assignment
of this material to List 3 and did not support this course of action.
4.28 In the wider context, it was recognized that this issue of how to handle production run
cuts which are effectively natural mixtures may merit further review, and delegations were
accordingly invited to submit their views to future sessions for consideration.
4.29 In reviewing document ESPH 14/4/4 on H.B.M. (Volatile Oil), it was noted that this
product should not be confused with 1,3-Pentadiene concentrate as reviewed recently at
GESAMP/EHS 45. The current product could thus be processed as a mixture based on the
information already available for the components present in the product. Whilst similar concerns
to those above could be expressed, it was agreed that the product should also be assigned to
List 3 but with the following additional information: Contains name to specify 1,3-Pentadiene,
company name to be Nihon Zeon Co Ltd and specific and operation requirements to
include 16.6.1, 16.6.2 and 16.6.3.
4.30 A summary of the Group’s decisions regarding the classification and assignment of
carriage requirements for products OLOA 865G, OLOA 50908, RBHC, and H.B.M. (Volatile
Oil) is set out at annex 4. These products as noted will be added to the List 3 entries for
MEPC.2/Circ.14 with a validity for “all countries” with “no expiry” date.
4.31 In recognition of the fact that if MEPC.2/Circ.14 is issued on 17 December 2008 there
would be a gap of fifteen days before the new amendments enter into force, as proposed at the
last ESPH meeting and endorsed by MEPC 58, the cover note of MEPC.2/Circ.14 will specify
that MEPC.2/Circ.13 remains valid up to and including 31 December 2008 and that
MEPC.2/Circ.14 becomes effective 1 January 2009.
4.32 It was recognized that in addition to the amendments and new products described above,
there may be additional entries to be included in the lists of MEPC.2/Circ.14 if products are
reported between the date of this review and 1 December 2008.
4.33 In addition to the annual MEPC.2/Circular, the Group recalled that a summary of
notifications received throughout the year is also now maintained on IMO’s public website.
Details of the information provided and the access route to follow are given in BLG.1/Circ.27.
5
CONSIDERATION OF THE OUTCOME OF THE MOST RECENT SESSION OF
GESAMP/EHS
5.1
The Group considered the report of the forty-fifth session of the GESAMP/EHS Working
Group (BLG.1/Circ.26), the purpose of which was not to discuss the scientific content but
to discuss items that have implications for the work of the Group.
5.2
The Group recalled that due to changes in the duties of the Chairman of GESAMP/EHS,
he would no longer participate in this meeting as a member of the delegation of the Netherlands.
The Group felt, however, that it was desirable that the Chairman of GESAMP/EHS should be
present at ESPH during the debate of the GESAMP/EHS report and during the discussions on the
evaluation of new products for inclusion in the IBC Code (since the GESAMP hazard profile
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forms the basis of these evaluations). Accordingly, this matter had been referred to the
BLG Sub-Committee and subsequently to MEPC for consideration and in both cases, clear
support for this view had been expressed and it was agreed that the Chairman of GESAMP/EHS
should attend ESPH Working Group meetings as required. On this occasion, attendance of the
Chairman had not been possible but guidance on the report was provided by the Secretariat
(which also provides the secretarial service to GESAMP/EHS).
5.3
The Group was advised that at the start of the EHS 45 meeting, a number of Matters
arising from both IMO and GESAMP had been considered. This had included relevant items
resulting from recent ESPH, BLG and MEPC meetings such as the review of chapter 19 of the
IBC Code, the re-evaluation of cleaning additives and the introduction of charges for future
GESAMP/EHS evaluation work.
5.4
With regard to the latter item, the Group recalled that a mechanism based on a fixed cost
per application has been put into place. This treats the evaluation of products to be carried in bulk
or those used as a component in a mixture or in cleaning additives in an identical manner with a
fee of US$6,500 being payable in all cases. It was noted that the fixed fee will be charged each
time an evaluation is carried out on a product as this provides a clear incentive to supply the
complete range of data necessary to carry out an evaluation in one submission. Further details of
the new procedures are given in BLG.1/Circ.28. It was noted that the charging regime will
commence with all evaluations undertaken at the EHS 46 meeting to be held next year.
5.5
In relation to the new procedures, it was noted that there was no intention to introduce
charges for ongoing evaluations which are currently being reviewed by GESAMP/EHS but
which were awaiting further data or the clarification of certain issues.
5.6
Additionally, it was noted that since it was a requirement that payment for the evaluation
assessment should be made prior to the start of the review meeting, this essentially sets a second
deadline for future submissions following the initial provision of the technical data.
5.7
In terms of the next GESAMP/EHS meeting scheduled for 20 to 24 April 2009,
it was noted that this means that whilst the submission of data should be made no later than
Friday, 13 March, 2009, the subsequent payment must also be made before 20 April 2009.
5.8
With respect to GESAMP activities, it had been noted that there had been a revitalization
of GESAMP after a long period of re-orientation and review. GESAMP had also established a
formal GESAMP Office at IMO to provide support to all GESAMP activities and to act as an
internal and external contact point. Substantial support to GESAMP had been received from the
Swedish International Development Co-operation Agency (SIDA) for 2006 to 2008, on the
condition that GESAMP:
.1
rebuilds and strengthens its network and structure;
.2
involves scientific experts from developing countries in its activities; and
.3
plays a role in and supports the “UN Regular Process for global reporting and
assessment of the state of the marine environment, including socio-economic
aspects”.
In the context of point 2, it was noted that there was an opportunity for the GESAMP/EHS Group
to develop this objective should any suitable activity or task be identified.
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5.9
The Group was informed that eight new products had been evaluated by GESAMP/EHS
and that for four of these products, documents were submitted under agenda item 2 as new
products for evaluation.
5.10 In general terms, it was reiterated that the submission of data to the GESAMP/EHS
Working Group, through the GESAMP/EHS Product Data Reporting Form, is the first step in the
classification of a product under MARPOL Annex II and the IBC Code. Once the product has a
complete GESAMP hazard profile, it should be submitted to the BLG Sub-Committee for
evaluation by ESPH, through the BLG Product Data Reporting Form, for the request of the
assignment of pollution category, ship type and carriage requirements under MARPOL Annex II
and the IBC Code. The importance of making this two-step approach, each requiring an individual
reporting form, known to the industry was stressed and it was noted that more information on the
complete process can be found at http://www.imo.org: via marine environment: chemical
reporting forms.
5.11 The Group noted that, next to the evaluation of new products, there had been
communications between GESAMP/EHS and industry which, in some cases, had led to
amendments to existing GESAMP hazard profiles. In the case of Di (2-ethylhexyl) phthalate,
this had also led to a comprehensive review of all phthalate products being undertaken.
It was observed that a review of the impact on carriage requirements where amendments to the
GESAMP profile have been introduced may be required for certain products.
5.12 Additionally, following an observation from Japan that in a small number of cases
GESAMP profiles were not in line with current IBC Code entries, a number of profiles had been
checked and confirmed or amended as appropriate. As a consequence of this, it had been noted
that IBC Code entries may need to be re-evaluated for the following products:
.1
Dodecylbenzene
.2
Dodecyl methacrylate
.3
2,2,4-Trimethyl-1,3-pentanediol diisobutyrate
.4
Urea/Ammonium nitrate solution (containing less than 1% free ammonia).
5.13 The Group also noted that some products had been submitted for evaluation which were
substances not intended for shipment but which were to be used as components in cleaning additive
formulations. In this regard, it was recalled that in accordance with MEPC.1/Circ.590 (cleaning
additives guidance note and reporting form) only a shortened hazard profile is required for each
component. From this, the Pollution Category could be determined and consequently, it was
only necessary to provide data for ratings in columns A1 (bioaccumulation), A2 (biodegration),
B1 (acute aquatic toxicity) and D3 (long-term health effects). Notwithstanding that a cleaning
additive producer or component supplier would not be expected to undertake testing for long-term
health effects under column D3, any reports which might assist in the consideration of this rating,
however, should be provided, when available.
5.14 In the cases submitted for reduced GESAMP profiles all products were rejected for
evaluation due to the absence of data for many of the properties required. In view of the
difficulties encountered the Group reiterated that even if only a partial GESAMP profile is required,
it is still imperative that full supporting data are provided for the properties to be reviewed.
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5.15 In recognition of the problems which may be experienced by manufacturers submitting
data for components of cleaning additives, the Group reviewed the key elements to be supplied
when completing the GESAMP form and these items are listed below:
Sections 1-4
-
all relevant information;
Section 5
-
molecular weight and water solubility;
Section 7
-
sensitization and any long-term health effects; and
Section 8
-
acute toxicity data;
bioaccumulation data; and
biodegradation data.
Further guidance on presenting these data are given in the GESAMP Reports and Studies No.64
publication (The Revised GESAMP Hazard Evaluation Procedure for Chemical Substances
carried by Ships) which may be found at the website http://gesamp.imo.org/publicat.htm.
To support all data submissions, the Group emphasized that summaries with full reference details
or complete study reports should always be provided.
5.16 It was noted that GESAMP/EHS had agreed that when only partial GESAMP profiles are
assigned for cleaning additive components, this should be indicated in the database in the
remarks column in order to be able to clearly identify such substances.
5.17 The Group noted that an indication of this status would also be useful in the GESAMP
composite list and it was proposed that this might be accomplished by marking such substances
with an appropriate footnote. It was agreed that this should be proposed to GESAMP/EHS for
their consideration.
5.18 The Group noted that when only a partial profile as required for cleaning additive
components has been established, this cannot be used for mixture calculations as additional
information is needed in these cases as specified in List 5 of the MEPC.2/Circular.
5.19 A further item addressed at GESAMP/EHS 45 was the evaluation of renewable diesel and
its comparison to mineral-based diesel oil. It was concluded that both products have different
origins and their composition is different. As a result of these compositional differences, the
environmental and human health hazards of renewable diesel are relatively mild, while those of
diesel are potentially severe.
5.20 A proposal to prepare a paper for publication reflecting its recent work with the revised
GESAMP hazard evaluation procedure was also discussed by the GESAMP/EHS Group.
An outline of a paper was put forward focussing on a number of novel aspects introduced during
this work and it was agreed that this would now be further developed intersessionally.
6
CONSIDERATION OF THE APPLICATION OF REQUIREMENTS FOR THE
CARRIAGE OF BIO-FUELS AND BIO-FUEL BLENDS
6.1
The Group recalled that, as noted at the opening of the meeting, following the decision
taken at MEPC 58 only shore blended bio-fuel blends should be addressed during ESPH 14.
If a need is demonstrated to BLG 13 to include blending on board during the sea voyage under
this agenda item, further work on this topic will be addressed during 2009.
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6.2
The Group noted that guidance on the issue of shipping bio-fuel blends is still required
for the industry. When bio-fuels are moved as technically pure products, they fall under
MARPOL Annex II and are identified in the IBC Code accordingly but when being shipped as
blends, the issue then arises under which Annex of MARPOL, i.e. I or II, they should be carried.
6.3
The Group recalled that BLG 10 had agreed to interim guidelines to assist industry in the
movement of these mixtures which may be summarized as follows:
.1
when declaring and shipping Bio-fuels, Bio-diesel (source product), Fatty acid
methyl esters (FAME), Ethanol (Ethyl alcohol), the full requirements of
MARPOL Annex II and the IBC Code shall be complied with;
.2
when declaring and shipping bio-fuels blended with base petroleum fuels, the
under-mentioned products can be carried under MARPOL Annex I provided the
following limits are not exceeded:
.1
blended bio-diesel with a maximum
and 85% ordinary diesel, B15; or
limit
of
15%
bio-diesel
.2
blended bio-ethanol with a maximum limit of 15% bio-ethanol
and 85% ordinary gasoline/petrol, E15; or
.3
gasoline/alcohol mixtures with a maximum limit of 15% alcohol
and 85% ordinary gasoline/petrol, E15;
.3
when carrying these products under MARPOL Annex I or II, the shipper of the
cargo is responsible for providing compatibility information to the ship operator
and/or master. The cargo shall be compatible with all materials of construction
such that no damage to the integrity of the materials of construction is incurred; and
.4
if the blended products contain higher percentages of bio-fuels or gasoline/alcohol
mixtures than shown above, then the shipper should contact the Administration
with regard to the carriage of those cargoes.
6.4
In relation to these limits, it was recalled that bio-fuel blends may also consist of
vegetable oils in petroleum oil and that these products also fall under the same interim measures.
Renewable diesel oil, however, was not considered at this session as this product had not been
reviewed beyond the GESAMP/EHS evaluation reported earlier.
6.5
With respect to the interim 15% bio-fuel limit, it was noted that the value has no technical
or scientific basis. The cut-off point was thought to be based on a 15% limit that had been
applied for MTBE in gasoline in the United States.
6.6
The Group recalled that the BLG Sub-Committee had agreed that the interim guidelines
should not extend beyond 1 July 2009.
6.7
The Group noted that at the previous ESPH meeting, a number of key points had been
identified which required further consideration as summarized below:
.1
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there is a need for more data on bio-fuel blends in order to be able to better
understand these products. In the absence of sound technical data it is difficult to
set any cut-off limits and whilst noting that industry is currently operating with the
BLG 13/3
- 16 interim 15% bio-fuel limit in oil, it was recognized that products with higher
limits are now being used in certain applications and that transportation of these
mixtures by sea may be needed in the future;
.2
there is a need to check the impact on operational viability of oil discharge
monitoring equipment (ODME) under MARPOL Annex I when blended products
are used; and
.3
there is a need to recognize that whilst Annex II permits the carriage of Annex I
petroleum oil products in certain situations (i.e. as when used as a component in a
mixture), the reverse is not true and Annex I does not make any direct reference to
the carriage of chemicals. Furthermore, as any operational discharge of oil which
contains chemicals is prohibited under the current Annex I regulations, it was
recognized that this may present a practical boundary condition in terms of
developing bio-fuel blends proposals since the Working Group has no mandate to
redefine the content of Annex I or Annex II.
6.8
With respect to point 6.7.1, the Group had been advised that typical blends currently
being shipped were:
-
95% mineral oil diesel with 5% FAME (rape base)
90% mineral oil diesel with 10% vegetable oil (palm olein)
99% FAME with 1% mineral oil
99% bio-ethanol with 1% gasoline.
Additionally, it was noted that a number of other ethanol/petrol blends (with petrol levels
up to 21%) were also being shipped as List 2 Trade-named mixtures.
6.9
The Group noted that whilst it appeared that overall there was little movement of bio-fuel
blends as Annex I cargoes, it was recognized that gasoline or diesel fuels may often be shipped
without it being overtly specified that they contain a small amount of bio-fuel (when this was in
line with the normal product specification). It was expected that more information in this context
may become available once safety data sheets are introduced for Annex I materials.
6.10 With respect to point 6.7.2, the Netherlands provided an update on the testing being
undertaken by an ODME manufacturer with bio-fuel materials. Initial trials with 100% vegetable
oil had demonstrated that the ODME did not function correctly and it was reported that further
work with an ethanol/gasoline (85/15) mixture had also confirmed this problem. Whilst it had
been intended to carry out additional work with FAME/gas oil (diesel) and Palm olein/gas oil
(diesel), this had not yet been possible as no samples had been provided. Work was ongoing,
however, and it was expected that a FAME/petrol mixture could be tested shortly.
6.11 With respect to point 6.7.3, it was noted that any change activity in this context could
impact not only on bio-fuel blends but on many other product areas and that consequently a
mandate for a different work programme item might be required if this was to be pursued.
6.12 The Group recalled that as an initial thought to trigger further deliberations, it had
considered that three bands for bio-fuel/petroleum blends might possibly be envisaged:
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BLG 13/3
Band 1:
[85%] or more petroleum oil.
Product then treated as Annex I
(recognizing, however, that this would have to be dependent on there
being no negative impact on operational requirements under Annex I);
Band 2:
more than 1% but less than [85%] petroleum oil.
Product treated under Annex II
(as Pollution Category X, ST2 with worst case minimum carriage
requirements being assigned based on analogous products such as pygas,
butylbenzene);
Band 3:
1% or less oil mixed with one product categorized under Annex II.
Cargo treated as the Annex II product contained in the blend.
6.13 With respect to Band 2, the option of processing via tripartite agreement had also been
considered but it was recognized that without the necessary information on oil in place, this was
difficult to implement effectively. Although this approach had been used for the List 2 products
mentioned earlier, this had so far had to rely upon treating petrol or gasoline as mineral oil for the
purposes of mixture calculations even though these components are known to be highly variable
materials.
6.14 The Group debated this approach but concluded that the use of the mineral oil multiplication
factor identified in MEPC.1/Circ.512 was inappropriate for such mixture calculations as this
substance was a highly refined and purified material. It was noted that when using this
multiplication factor, calculations for the current List 2 bio-fuel blend products led to the option
to move cargoes in single hull vessels and this also was considered not to be acceptable.
6.15 The Group recalled that due to the lack of data on oil products, the amendments to
SOLAS regarding the obligation to provide on MSDS for oil and fuel oil will enter into force
on 1 July 2009 and that accordingly, this might assist with a calculation approach for bio-fuel
blends if this was to be pursued.
6.16 Having reviewed all of the information available, the Group decided that the three Bands
approach should be revised with the qualifications indicated below now becoming applicable.
6.17 For Band 1 products, due to the concerns identified in relation to ODME functionality, it
was concluded that there was no justification to take up the principles of the interim guidance
unless it was conditional upon all residues being pumped ashore or new data demonstrating no
impact on ODME efficiency is made available.
6.18 For Band 2 products, these materials should be treated as mixtures having an unassessed
component which shows safety hazards. Following the procedures outlined in MEPC.1/Circ.512,
this then allows the component to be assessed as if it were a pure or technically pure product for
the purposes of establishing a provisional hazard profile. A tripartite agreement may then be
established and the product may be entered in List 3 of the MEPC.2/Circular.
6.19 As the tripartite agreement has a finite lifetime, there is a requirement for the shipper or
producer to subsequently provide data to the GESAMP/EHS Working Group to establish a
GESAMP/EHS hazard profile in order that the blend may then be reviewed by ESPH in order to
become an “all countries/no expiry date” entry on List 3.
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6.20 With respect to the issue of assigning a provisional hazard profile in the context of a
tripartite agreement, the Group noted that whilst data from relevant trade association sources
might be employed, if more specific information on a particular petroleum fuel used was
available, this could be taken up in preference by the Administration undertaking the assessment.
6.21 Once a GESAMP/EHS hazard profile had been established, it was agreed that the
petroleum fuel should only be recorded as a List 5 entry in the MEPC.2/Circular (Substances not
shipped in pure form but as components in mixtures).
6.22 With respect to any existing List 2 product entries which might be affected by the
proposed revisions, Member States were advised to revisit the tripartite agreements in place and
to take action as appropriate, in light of the conclusions made during this meeting.
6.23 For Band 3 products, the Group concluded that no changes were required compared to
those defined previously, other than to specify that this Band is intended only for FAME,
triglyceride and ethanol bio-fuels.
6.24 With respect to blending on board scenarios, the Group noted that two documents relating
to this topic had been submitted as ESPH 14/6 (the Netherlands and the United Kingdom) and
ESPH 14/INF.2 (INTERTANKO) but in line with the recent MEPC 58 decision, these were not
discussed at the meeting.
6.25 In the context of this issue, however, the Group noted that if non shore-blended products
become of interest pending any submissions made to BLG 13, it was expected that the bands and
conditions agreed for shore-blended mixtures with respect to specifying carriage requirements
should also be applicable in such cases.
7
REVIEW OF CHAPTER 19 OF THE IBC CODE
7.1
The Group recalled that chapter 19 of the IBC Code, listing synonyms or related terms
for IBC Code products, had been developed over many years and that it now contained some
anomalies that needed to be rectified in order to avoid any confusion with its use in the future.
7.2
The Group further recalled that the BLG Sub-Committee had fully endorsed that a review
exercise to address this problem should be undertaken with a target completion date for this work
of 2009. In supporting this, the BLG Sub-Committee had urged delegations to make available
the specialized expertise clearly needed for this project.
7.3
To initiate the review process, the Secretariat had carried out a preliminary review of
chapter 19 of the IBC Code and the results of this exercise were presented at ESPH 13 as set out
in document ESPH 13/9.
7.4
To progress the issue further, the delegation of the Netherlands had since undertaken
a detailed assessment of 1,320 entries out of the 2,240 Index names listed in chapter 19 of the
IBC Code. This had identified some editorial amendments but it had also raised a number of
more fundamental questions for consideration.
7.5
With respect to the latter category, these issues were summarized as follows:
.1
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Should synonyms having a commercial status be included in chapter 19 or should
there always be a technical justification for the names used?
- 19 -
7.6
BLG 13/3
.2
Should Product names and proper shipping names be aligned (as UN Nos. relate
to p.s.n.)?
.3
For single materials, is it appropriate to cite a UN No. if this covers a family of
related compounds?
.4
If using a UN No. which specifies that a material is “stabilized”, should this only
be cited if the associated Index name is also stated to be stabilized?
.5
If a UN No. relates to a flammable liquid N.O.S or other N.O.S entry, is it useful
to reference this (given that there is no other specific UN No. for the substance in
question)?
.6
If a UN No. for a substance does not refer to solutions, should this be employed
for a Product name which specifies a percentage solution (and also if percentages
are given but are different)?
.7
In a similar context, if a Product name describes a solution, should the name of a
solid salt be used as a synonym?
.8
Should names of specific compounds be included in the Index in relation to
Product names which cover a wider, more general entry (as strictly, these may not
always be actual synonyms)?
.9
Should Index names which lack a chain length description be linked to a Product
name where this is specified?
.10
For mixture products, should Index names be used if they reference chemical
compounds which are not included in the named elements of the Product name
used for the mixture?
.11
Should the UN No. relate to the Product name only or could it also relate to a
synonym?
.12
If a Product name is known to have a specific UN No. but this is not listed, should
this be added?
.13
Should additional synonyms be added and if so, on what criteria?
In addressing these points, the Group reached the following conclusions:
.1
Synonyms having a commercial justification should be retained as this enhances
the value of the chapter 19 listings.
.2
Product names and proper shipping names (as related to UN numbers and the
IMDG Code) should not be aligned. Moreover, as the cross reference to
UN numbers (intended for packaged goods) can sometimes cause confusion, it
was agreed that UN numbers should be removed from chapter 19 as part of the
review exercise.
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.3
To explain the removal of UN numbers, it was proposed that a statement
explaining their withdrawal should be included in the explanatory text introducing
chapter 19.
.4
Index names where solutions are specified should not refer to higher percentage
levels than those stated in the Product name.
.5
Index names should always only reflect a subset of the main Product name (unless
the Index name is an exact synonym). Where the Index name is not an exact
match, this should be indicated by an appropriate footnote.
.6
Where an Index name lacks a chain length descriptor but this qualification is
included in the Product name, a footnote should be employed to indicate that the
product needs to be a subset and that this condition therefore needs to be checked.
.7
When an Index name describes a mixture product by a number of components,
this should not include any elements which are not also covered in the main
Product name.
.8
Additional synonyms should not be generated as a consequence of the review
exercise. Any new proposals need to be made on a case by case basis with a
submission being presented to ESPH in line with normal procedures (as for
extending vegetable oil synonyms).
7.7
The Group agreed that these guidelines should now be applied to the review items
identified so far and the delegation of the Netherlands kindly offered to generate an updated list
of proposed modifications accordingly. It was proposed that this would be made available for
review during BLG 13 and additionally, it was indicated that work would continue on the second
half of the chapter 19 Index with a view to finalizing this later next year.
7.8
In the context of the ongoing review, it was again emphasized that input from other
members of the Group was welcome and that if there are any comments these should be provided
to Mrs. Joke Herremans (e-mail: [email protected]) for consolidation.
7.9
The Group noted the considerable efforts which had been made on this exercise by the
delegation of the Netherlands and expressed its appreciation for the work undertaken.
7.10 In undertaking this exercise, it was recognized that anomalies may also exist in other
language versions of chapter 19 but it was agreed that this should only be considered later, once
the initial review has been completed.
8
ANY OTHER BUSINESS
8.1
The Group considered document ESPH 14/8 (INTERTANKO), which drew attention to
a concern they had in relation to the carriage of cargoes that require vapour detection equipment
but for which no toxic vapour detection equipment is available in the market.
8.2
Whilst it was recognized that this anomaly is addressed in the IBC Code, it was stated
that obtaining the necessary exemption statement on the International Certificate of Fitness for
the Carriage of Dangerous Chemicals in Bulk can be problematic and time-consuming.
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8.3
The delegation of IPTA, supported by ICS, advised that they had received no reports of
problems being encountered in this regard, and made reference to a footnote (see annex 6) that some
Administrations use on the Certificate of Fitness, tied to every product requiring Toxic vapour
detection equipment, which specifies that in the absence of suitable vapour detection equipment,
the requirements in the IBC Code, item 13.2.3, must be adhered to. Regulation 13.2.3 in turn draws
attention to regulations 14.2.4 and 16.4.2.2, dealing with equipment the ship must be provided
with and the requirements of safe tank entry procedures. It was considered that this provided a
pragmatic way of dealing with this situation.
8.4
INTERTANKO were of the opinion that this did not adequately address their concerns,
however, and since further consideration or action was considered outside the scope of the
Group, it was suggested that INTERTANKO make a formal submission through the appropriate
channels to propose a solution.
9
FUTURE WORK PROGRAMME
9.1
The Group agreed on the future work programme set out in annex 5.
10
ACTION REQUESTED OF THE SUB-COMMITTEE
10.1
The Sub-Committee is invited to approve the report in general and, in particular, to:
.1
agree to the evaluation of new products and consequential inclusion in the
IBC Code (paragraphs 2.11 to 2.33 and annex 2);
.2
concur with the evaluation of cleaning additives (paragraphs 3.1 to 3.8 and annex 3);
.3
endorse the view that additional clarification with regard to the High-level Action
Plan and the Planned outputs is required in relation to elements 1.3.3.1 and 5.2.3.1
(paragraph 2.6);
.4
concur that the (5.2/5.2.3/5.2.3.1) coding for Strategic direction, High-level
Action Plan and Planned outputs should be used for all future product evaluation
submissions (paragraph 2.5);
.5
note that blank entries under D3 and E1 in the GESAMP/EHS composite list do
not indicate missing data since the default in the database is to leave the parameter
blank unless an appropriate code letter is entered and note that GESAMP/EHS
will be requested to consider this issue (paragraphs 2.7 to 2.10);
.6
concur with the view of the Group that GESAMP/EHS should be requested to
review olefin substances and mixtures as there appeared to be inconsistencies
within the product family and that the review should address not only the profiles
but also the names used to describe olefin mixtures (paragraph 2.18);
.7
consider the view that when a toxic solid with a low vapour pressure is suspended
in water, loaded and discharged under closed conditions and carried at ambient
temperature then the requirement for controlled venting may not need to be applied
and to note this issue requires further consideration (paragraphs 2.24 and 2.25);
.8
note that starting from next year (i.e. for listing in MEPC.2/Circ.15) expiry dates
may be triggered and that Administrations and Industry should take action as
appropriate (paragraph 4.1);
I:\BLG\13\3.doc
BLG 13/3
- 22 -
.9
note that GESAMP/EHS carried out a comprehensive review of all phthalate
products in the composite list and as a result some hazard profiles have been
amended which may impact on the carriage requirements for phthalates in the
IBC Code (paragraph 5.11);
.10
concur with the view of the Group that when it is observed that a GESAMP
hazard profile is not in line with the IBC Code entry, a submission needs to be
made to BLG/ESPH to update the carriage requirements (paragraph 5.12);
.11
note the advice from GESAMP/EHS with regards to the key data elements
required when assessing cleaning additive components (paragraph 5.15);
.12
concur with the view of the Group that an appropriate footnote should be included
for cleaning additive component entries in the GESAMP/EHS composite list to
indicate that they cannot be used in mixture calculations (paragraph 5.17);
.13
agree that when submitting Trade-named mixtures containing confidential
formulation details for evaluation as List 3 MEPC.2/Circular entries, the
procedure set out in paragraph 4.18 should be followed (paragraphs 4.15 to 4.18);
.14
agree that due to concerns identified in relation to ODME functionality the
principles set out in the interim guidance established for bio-fuel blends to be
shipped as Annex I cargoes should not be taken up unless it was conditional upon
all residues being pumped ashore or it can be shown that ODME’s function
efficiently with these blends (paragraph 6.17);
.15
agree that mixtures containing more than 1% but less than 85% petroleum oil,
should be assessed in accordance with MEPC.1/Circ.512 following the
procedures for mixtures with unassessed components that show a safety hazard
(paragraphs 6.18 to 6.21);
.16
concur with the view of the Group that bio-fuel blend List 2 products assessed
using the mineral oil multiplication factor should be revisited and re-assessed
in accordance with MEPC.1/Circ.512 (paragraph 6.22);
.17
note that for bio-fuel blends with 1% or less oil, the cargo should be treated as the
Annex II product contained in the blend and to note that this bio-fuel blend band
applies only to FAME, triglyceride and ethanol mixtures (paragraph 6.23);
.18
note the progress made with the review of chapter 19 of the IBC Code and agree
with the decisions proposed relative to the deletion of UN numbers and the
boundaries for appropriate Index names (paragraph 7.6);
.19
note the discussions regarding the carriage of vapour detection equipment
(paragraph 8.4); and
.20
approve the future work programme of ESPH (paragraph 9.1 and annex 5).
***
I:\BLG\13\3.doc
BLG 13/3
ANNEX 1
AGENDA AND LIST OF DOCUMENTS
1
Adoption of the agenda
ESPH 14/1
ESPH 14/1/1
2
3
Secretariat
Secretariat
Provisional Agenda
Documents from other meetings
Evaluation of new products
ESPH 14/2
ESPH 14/2/1
ESPH 14/2/2
ESPH 14/2/3
The Netherlands
The Netherlands
The United Kingdom
The United Kingdom
ESPH 14/2/4
The United Kingdom
ESPH 14/2/5
ESPH 14/2/6
The United Kingdom
Malaysia
Dialkyl (C9-C10) phthalates
Glycerol ethoxylated
Olefin mixtures (C7-C9)
Sodium bromide solution (less
than 50%) drilling brines
Sodium bicarbonate solution (less
than 10%) drilling brines
Potassium chloride (brines<26%)
Alcohols, linear (C12+)
Evaluation of cleaning additives
No documents submitted. Information for evaluation provided to the sub-group during
the meeting.
4
5
Review of MEPC.2/Circular – Provisional classification of liquid substances
transported in bulk and other related matters
ESPH 14/4
ESPH 14/4/1
ESPH 14/4/2
ESPH 14/4/3
France
France
France
Secretariat
ESPH 14/4/4
Japan
List 3 Entry – OLOA 865G
List 3 Entry – OLOA 50908
List 3 Entry – RBHC
List of proposed changes
MEPC.2/Circ.13
H.B.M. (Volatile Oil)
to
Consideration of the outcome of the most recent session of GESAMP/EHS
BLG.1/Circ.26
I:\BLG\13\3.doc
Report of the forty-fifth session of
the GESAMP/EHS Working Group
on the Evaluation of the Hazards
of Harmful Substances Carried
by Ships
BLG 13/3
ANNEX 1
Page 2
6
7
Consideration of the application of requirements for the carriage of bio-fuels and
bio-fuel blends
ESPH 14/6
The Netherlands and the Blending on board
United Kingdom
ESPH 14/INF.2
INTERTANKO
Review of chapter 19 of the IBC Code
ESPH 14/7
8
Guidelines for the carriage and
blending of cargoes on board
The Netherlands
Review of chapter 19 of the
IBC Code
INTERTANKO
A Review of the carriage
requirements of Cargoes with a
“T” Notation under column “k” of
chapter 17 of the IBC Code for
which there are no testing tubes
available
Any other business
ESPH 14/8
***
I:\BLG\13\3.doc
BLG 13/3
ANNEX 2
EVALUATION OF NEW PRODUCTS
1
Dialkyl (C9-C10) phthalates (the Netherlands, ESPH 14/2)
In considering the information provided, the Group agreed that the following carriage
requirements be assigned to the product:
2
a.
Product name:
Dialkyl (C9-C10) phthalates
c.
Pollution category:
Y
d.
Hazards:
S/P
e.
Ship type:
2
f.
Tank type:
2G
g.
Tank vents:
Open
h.
Tank Environmental Control:
No
i.
Electrical equipment:
i'
Class:
-
i''
Group:
-
i'''
Flash point greater than 60°C
Yes
j.
Gauging:
O
k.
Vapour detection:
No
l.
Fire protection:
ABC
n.
Emergency equipment:
No
o.
Specific and operational requirements:
15.19.6, 16.2.6
Glycerol ethoxylated (the Netherlands, ESPH 14/2/1)
In considering the information provided, the Group agreed that the following carriage
requirements be assigned to the product:
a.
Product name:
Glycerol ethoxylated
c.
Pollution category:
OS
e.
Ship type:
NA
I:\BLG\13\3.doc
BLG 13/3
ANNEX 2
Page 2
3
Olefin mixtures (C7-C9) (the United Kingdom, ESPH 14/2/2)
In considering the information provided, the Group agreed that the following carriage
requirements be assigned to the product:
a.
Product name:
Olefin mixtures (C7-C9), C8 rich, stabilized
c.
Pollution category:
X
d.
Hazards:
S/P
e.
Ship type:
2
f.
Tank type:
2G
g.
Tank vents:
Cont
h.
Tank Environmental Control:
No
i.
Electrical equipment:
i'
Class:
T3
i''
Group:
IIB
i'''
Flash point greater than 60°C
No
j.
Gauging:
Restricted
k.
Vapour detection:
F
l.
Fire protection:
ABC
n.
Emergency equipment:
No
o.
Specific and operational requirements: 15.13, 15.19.6
I:\BLG\13\3.doc
BLG 13/3
ANNEX 2
Page 3
4
Sodium bromide solution (less than 50%) drilling brines (the United Kingdom,
ESPH 14/2/3)
In considering the information provided, the Group agreed that the current tripartite
agreement should be maintained with the following carriage requirements:
a. Product name:
Sodium bromide solution (less than 50%)
c. Pollution category:
Z
d. Hazards:
P
e. Ship type:
3
f. Tank type:
2G
g. Tank vents:
Open
h. Tank Environmental Control:
No
i. Electrical equipment:
i'
Class:
-
i'' Group:
-
i''' Flash point greater than 60°C:
Yes
j. Gauging:
Open
k. Vapour detection:
No
l. Fire protection:
ABC
n. Emergency equipment:
No
o. Specific and operational requirements:
5
Sodium bicarbonate solution (less than 10%) drilling brines (the United Kingdom,
ESPH 14/2/4)
In considering the information provided, the Group agreed that the following carriage
requirements be assigned to the product:
a. Product name:
Sodium bicarbonate solution
(less than 10%)
c. Pollution category:
OS
e. Ship type:
NA
I:\BLG\13\3.doc
BLG 13/3
ANNEX 2
Page 4
6
Potassium chloride (brines<26%) (the United Kingdom, ESPH 14/2/5)
In considering the information provided, the Group agreed that the following
amendments to carriage requirements be assigned to the product:
7
a. Product name:
Potassium chloride solution (less than 26%)
c. Pollution category:
OS
e. Ship type:
NA
Alcohols, linear (C12+) (Malaysia, ESPH 14/2/6)
In considering the information provided, the Group agreed that the following carriage
requirements be assigned to the product:
a.
Product name:
Alcohols (C12+), primary, linear
c.
Pollution category:
Y
d.
Hazards:
S/P
e.
Ship type:
2
f.
Tank type:
2G
g.
Tank vents:
Open
h.
Tank Environmental Control:
No
i.
Electrical equipment:
i'
Class:
-
i''
Group:
-
i'''
Flash point greater than 60°C:
Yes
j.
Gauging:
O
k.
Vapour detection:
No
l.
Fire protection:
ABC
n.
Emergency equipment:
No
o.
Specific and operational requirements: 15.19.6, 16.2.6, 16.2.9
***
I:\BLG\13\3.doc
BLG 13/3
ANNEX 3
CLEANING ADDITIVES EVALUATED AND FOUND TO MEET THE REQUIREMENTS OF
REGULATION 13.5.2 OF ANNEX II OF MARPOL 73/78
Name of cleaning additive
Name of manufacturer
Reporting
country
Evaluated in accordance with
MEPC/Circ.363
KT-Solve
KT-Plus
CTC-Cleaner-VLC
Alkleen Buffer
Alkleen Liquid
Metal Brite HD
Sea Clean Plus
Zinc Coat Conditioner
Alkaline (CAUS)
Alkaline (POT)
Buffer
Metal Deruster
Multicleaner
AC Clean 1 JT
Air-O-Gone 1
Liquid 35 NF
Steamer 130 HD
Super Cleaner Y-SP 2
Careclean Alkaline
Careclean Alkaline Extra
Careclean Buffer
Careclean Coaltar
Careclean Degreaser GP
Careclean Degreaser HD
Careclean Degreaser HD Split
Careclean Foro HD
Careclean GP Enviro
∗
CHEMTEC Chemicals GmbH
CHEMTEC Chemicals GmbH
CHEMTEC Chemicals GmbH
Unitor Chemicals AS
Unitor Chemicals AS
Unitor Chemicals AS
Unitor Chemicals AS
Unitor Chemicals AS
Star Marine Chemical BV
Star Marine Chemical BV
Star Marine Chemical BV
Star Marine Chemical BV
Star Marine Chemical BV
Tristar Industries BV
Tristar Industries BV
Tristar Industries BV
Tristar Industries BV
Tristar Industries BV
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
Cleaning additives identified only in this column will cease to be valid on 1 August 2010.
I:\BLG\13\3.doc
DEU
DEU
DEU
NOR
NOR
NOR
NOR
NOR
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
NLD
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
∗
MEPC.1/Circ.590
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
BLG 13/3
ANNEX 3
Page 2
Name of cleaning additive
Name of manufacturer
Reporting
country
Evaluated in accordance with
MEPC/Circ.363
Careclean Rust
Careclean Synclean HD
Careclean Synclean LF
Careclean Voyage (Seaclean)
Marine Care BV
Marine Care BV
Marine Care BV
Marine Care BV
NLD
NLD
NLD
NLD
_______________
∗
Cleaning additives identified only in this column will cease to be valid on 1 August 2010.
***
I:\BLG\13\3.doc
X
∗
MEPC.1/Circ.590
X
X
X
X
BLG 13/3
ANNEX 4
1
OLOA 865G (ESPH 14/4)
Trade name:
OLOA 865G
Contains:
Calcium long-chain alkyl phenate
sulphide (C8-C40)
c. Pollution category:
Y
d. Hazards:
S/P
e. Ship type:
2
f. Tank type:
2G
g. Tank vents:
Cont
h. Tank Environmental Control:
No
i. Electrical equipment:
i' Class:
-
i'' Group:
-
i''' Flash point greater than 60°C:
Yes
j. Gauging:
C
k. Vapour detection:
T
l. Fire protection:
ABC
n. Emergency equipment:
Yes
o. Specific and operational requirements:
15.12, 15.17, 15.19, 16.2.6
Company
Chevron
I:\BLG\13\3.doc
BLG 13/3
ANNEX 4
Page 2
2
OLOA 50908 (ESPH 14/4/1)
Trade name:
OLOA 50908
Contains:
Calcium long-chain alkyl salicylate (C13+)
c. Pollution category:
Y
d. Hazards:
S/P
e. Ship type:
2
f. Tank type:
2G
g. Tank vents:
Cont
h. Tank Environmental Control:
No
i. Electrical equipment:
i' Class:
-
i'' Group:
-
i''' Flash point greater than 60°C:
Yes
j. Gauging:
C
k. Vapour detection:
T
l. Fire protection:
ABC
n. Emergency equipment:
Yes
o. Specific and operational requirements:
15.12, 15.17, 15.19, 16.2.6
Company
Chevron
I:\BLG\13\3.doc
BLG 13/3
ANNEX 4
Page 3
3
RBHC (ESPH 14/4/2)
Trade name:
RBHC (Exxon Mobil)
Contains:
heptane and benzene
c. Pollution category:
X
d. Hazards:
S/P
e. Ship type:
2
f. Tank type:
2G
g. Tank vents:
Cont
h. Tank Environmental Control:
No
i. Electrical equipment:
i' Class:
T3
i'' Group:
IIA
i''' Flash point greater than 60°C:
No
j. Gauging:
C
k. Vapour detection:
F-T
l. Fire protection:
ABC
n. Emergency equipment:
No
o. Specific and operational requirements:
15.12, 15.17, 16.2.6
Company
Exxon Mobil
I:\BLG\13\3.doc
BLG 13/3
ANNEX 4
Page 4
4
H.B.M. (Volatile Oil) (ESPH 14/4/4)
Trade name:
H.B.M. (Volatile Oil)
Contains:
1, 3-Pentadiene
c. Pollution category:
Y
d. Hazards:
S/P
e. Ship type:
2
f. Tank type:
2G
g. Tank vents:
Controlled
h. Tank Environmental Control:
No
i. Electrical equipment:
i' Class:
T3
i'' Group:
IIA
i''' Flash point greater than 60°C:
No
j. Gauging:
R
k. Vapour detection:
F
l. Fire protection:
ABC
n. Emergency equipment:
No
o. Specific and operational requirements:
15.13, 15.19.6, 16.6.1, 16.6.2, 16.6.3
Company
Nihon Zeon Co Ltd
***
I:\BLG\13\3.doc
BLG 13/3
ANNEX 5
PROPOSED FUTURE WORK PROGRAMME FOR THE
ESPH WORKING GROUP
1
Evaluation of new products
2
Cleaning additives
Ongoing
.1
Evaluation of new cleaning additives
Ongoing
.2
Re-evaluation of cleaning additives in annex 10
to the MEPC.2/Circular
2010
3
Review of MEPC.2/Circular – Provisional classification of liquid
substances transported in bulk and other related matters
Ongoing
4
Consideration of the outcome of the most recent session of
GESAMP/EHS
Ongoing
5
Consideration of the application of requirements for the
carriage of bio-fuels and bio-fuel blends
2009
6
Review of chapter 19 of the IBC Code
2009
7
Any other business
***
I:\BLG\13\3.doc
BLG 13/3
ANNEX 6
TOXIC VAPOUR DETECTION EQUIPMENT – FOOTNOTE
The carriage of products marked with “T” in column “k” in chapter17 of the IBC Code requires
toxic vapour detection instruments to be available. When suitable detection probes are not
available in the market, an exemption option is described in the IBC Code item 13.2.3.
Some ships’ List of Products attached to their International Certificate of Fitness use an
appropriate entry covering the above matter, presented as a footnote which is tied to every
product requiring “Toxic vapour detection instruments” and reads:
“When carrying this product it is required that the ship is provided with equipment and
consumables for testing for presence of toxic cargo vapours. In case suitable toxic
vapour detection equipment is not available the requirements in the IBC Code item 13.2.3
must be adhered to.”
This Code item (13.2.3), in turn, draws attention to the Code items 14.2.4 and 16.4.2.2 describing
the equipment each ship is recorded as being provided with and the operational requirements of
safe tank entry procedures.
______________
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