Chemical Distribution Institute MARPOL ANNEX II REVISIONS November 12, 2003 Howard Snaith, Director, Marine and Chemical INTERTANKO

MARPOL ANNEX II REVISIONS MARPOL Annex II Revisions (Update)  Background on the Annex II Revisions  INTERTANKO Position  Decisions Made by MEPC 49  Work Accomplished at ESPH 9  Outstanding Cargoes  Adoption Schedule  Entry into Force of MARPOL Annex II Revisions

1. Editorial amendments and simplification of present requirements: 2. Delete requirements that will be outdated at the time the revised Annex is expected to enter into force; 3. Separate hardware requirements from operational requirements and place them into different regulations; 4. Identify which elements of the Standards of Procedures and arrangements for the discharge of noxious liquid substances should be incorporated in Annex II; 5. Redraft regulations 5 (Discharge of Liquid Noxious Substances), 5A (Pumping Piping and unloading arrangements), and 8 (Measures of Control), as necessary, IMO Bulk Liquid Gases – Terms Of Reference MARPOL ANNEX II REVISIONS

Background on the Annex II Revisions  Re-categorisation of the existing pollution categories within MARPOL Annex II has been a longstanding issue at IMO  Currently there exist 5 categories A, B, C, D and an Appendix III. (Appendix III lists products to which the IBC Code does not apply).  Due to the re-evaluation process of the existing MARPOL Annex II products by GESAMP/GHS, existing products will be re-categorised into a new 5-category system also called A, B, C, D and Appendix III, based upon their re-evaluation

Current 5 category System & Re-evaluated Effects

INTERTANKO Position  A new 3-category (X,Y,Z) system will be simpler for industry, and simpler to implement by Port State Control.  INTERTANKO strongly believes that all MARPOL Annex II products should be regulated with regard to tank washing procedures and slop disposal.

INTERTANKO Position Supported by Industry  The chemical tanker industry, strongly supported and represented by INTERTANKO (who is lobbying flag states, PSC and the vegetable oil producing nations on the issue), supports this concept for a new 3-tier pollution categorisation system, as this will assist in protecting the environment.  Such regulations would include stricter controls regarding vegetable oil tank washings.  INTERTANKO strongly supports the view that all products within MARPOL Annex II should be regulated and controlled in order to better protect the marine environment

The Effects of a 3 Tier System on Pollution Categories

MEPC 49 Decisions Made at MEPC Category System (X.Y.Z & O.S.) A fourth category of unregulated cargoes, was accepted, providing that the cargoes in such a category would be only those that can be genuinely shown to pose no threat to the marine environment.

MEPC 49 Decisions Made at MEPC 49 This fourth category will consist of 8 products:  Apple Juice  Clay slurry  Coal slurry  Dextrose solution  Glucose solution  Kaolin slurry  Molasses  Water It was also decided that if any products evaluated in the future can be proven not to exhibit any harmful effects on the marine environment, they may be added to this category.

MEPC 49 Decisions Made at MEPC 49  Products defined as "Floaters" and "Persistent floaters", which include the vegetable oils, will be assigned to Category Y. Under the currently defined ship typing criteria this will mean they have to be carried on chemical tankers.  Concern had been expressed that assigning vegetable oils to Category Y would cause problems, since this could mean certain vegetable oils classed as high viscosity requiring prewash ashore

MEPC 49 Decisions Made at MEPC 49 The requirement for prewash could be negated by either increasing the discharge temperature so that the viscosity falls below the definition of High Viscosity; and/or changing the definition of High Viscosity so that the "big movers " among the vegetable oils no longer fall within the definition

MEPC 49 Decisions Made at MEPC 49 The 12 mile discharge limit for category Z products will be retained, although the waiver for domestic trade that is in the current text of the 3-category system will be modified to include trade between countries where transport between them stays within the 12 mile limit of either country, provided no other country is affected.

MEPC 49 Decisions Made at MEPC 49  The 75 litre stripping limit for Category Z products on new ships will remain. It had been suggested that this should be increased to 150 litres, but it was agreed that there was no reason for new ships not to be built to take advantage of currently available technology.  A revised text, based on the current 3- category version of Annex II, was developed at ESPH 9 forwarded to the MEPC for its consideration in the spring of 2004.

ESPH 9 Work Accomplished at ESPH 9  Review of the Text of the IBC Code as a Result of Changes to the Classification System and Criteria for Assigning Carriage Requirements  Evaluation of Cleaning Additives New Products and Expiring Tripartites  MEPC Resolution Allowing Derogations for the Transport of Vegetable Oils in Deep Tanks of Cargo vessels  Consolidation and Evaluation of Special Chemical Groups (Currently Vegetable Oils and Polyols)

Outstanding Cargoes  Although there was outstanding data, the GESAMP/GHS Working Group had provisionally evaluated the 17 specific vegetable oils identified by the industry as being transported in bulk by sea.  This has allowed the Pollution Category and Ship Type to be determined for these products, but in future any additional vegetable oils will only be evaluated on the basis of the data provided.

Outstanding Cargoes Data submitted for a range of polyols will be evaluated by the GESAMP/EHS Group in April The following three entries will be deleted from the next edition of the IBC Code:  Animal and fish oils, n.o.s.  Cashew nut shell oil  Vegetable oils, n.o.s.

Adoption Schedule  The ongoing work is directed towards the consequential amendments to the IBC Code  Expect the revisions to be adopted in 2005

Proposed 3+1 Category System CategoryNew BuildingsExisting IBC Ships None Chemical Tankers X Pre-Wash 75 litres 12 mile, 25m water depth Underwater 7 knots En-route Pre-Wash 300 Litres 12 mile, 25m water depth Underwater 7 knots En-route No Transport Y Pre-wash for solidifying or H/V substances 75 litres 12 mile 25m water depth underwater 7 knots En-route Pre-wash for solidifying or H/V substances 150 Litres 12 mile, 25m water depth Underwater 7 knots En-route No Transport Z 75 litres 12 mile 25m water Depth Underwater 7 knots En-route 150 Litres 12 mile, 25m water depth Underwater 7 knots En-route New Ships Strip to 100Litrers Existing Ships Strip to maximum Extent O.S. Other Substances No Requirements For Carriage No Requirements for Carriage

Entry into Force Entry into Force Revised Annex II of MARPOL to come into force by 1 January 2007

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