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Thursday, June 21, 2018

Report from IMO Sub-Committee on Bulk Liquids and Gases 8th Session

The IMO Sub-Committee on Bulk Liquids and Gases held its 8th Session (BLG8) met from 24 to 28 March 2003 at IMO, London.  BLG is the IMO technical body dealing exclusively with matters linked to oil tankers, chemical tankers and gas carriers.  INTERTANKO in full attendance with six members of the secretariat actively participated in BLG8. The Association made several submissions and participated in the Review of Annex I of MARPOL 73/78; Application of MARPOL Annex I requirements to FPSOs and FSUs ; Marine Safety data sheets for MARPOL Annex I cargoes and marine fuel oils; Revisions of MARPOL Annex II.

Review of Annex I of MARPOL 73/78

MARPOL Annex I, adopted in 1978, is under a major revision to adapt its regulations to the current state of the tanker fleet and, when possible eliminate outdated rules. This process seems now concluded by BLG and it will be sent to the parent Committee MEPC with the view of a final adoption in 2004.

BLG agreed with most of the INTERTANKO suggestions for the use of the SI System for measurements under Annex I and with our proposed language with respect to the installation of a positive means for the prevention of inadvertent spillages through the sea chest.

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Contact:  Dragos Rauta

Application of MARPOL Annex I requirements to FPSOs and FSUs

This activity is aimed to develop guidelines on the application of MARPOL Annex I requirements to FPSOs and FSUs. BLG 8 developed such guidelines which will be applicable to FPSO and FSU through a modified regulation 21 to MARPOL Annex I. It also adopted Unified Interpretations to the rule and the guidelines which can be summed up as follows:

FPSOs and FSUs are not oil tankers and are not to be used for the transport of oil except that, with the specific agreement by the flag and relevant coastal States on a voyage basis, produced oil may be transported to port in abnormal and rare circumstances...  

Conversion of an oil tanker to an FPSO or FSU or vice versa should not be construed as a major conversion as defined in regulation 1(8)...

There are five categories of discharges that may be associated with the operation of fixed or floating platforms covered by this regulation when engaged in the exploration and exploitation of mineral resources, i.e.:

.1         machinery space drainage;

.2         offshore processing drainage;

.3         production water discharge;  

.4         displacement water discharge; and

.5         contaminated sea water from operational purposes such as produced oil tank cleaning water, produced oil tank hydrostatic testing water, water from ballasting of produced oil tank to carry out inspection by rafting.

Only the discharge of machinery space drainage and contaminated sea water should be subject to MARPOL 73/78

It was agreed to scrap a suggestion for a Form C of the IOPP Certificate for FPSOs and FSUs and that one could use the current form and FPSO and FSU are marked as “a .ship other than above”, annotated with .”FPSO” or ”FSU” and the unit's operating location. 

Finally, the FPSO and FSU will be subject to the Enhanced Survey Program scheme with the only waiver for underwater bottom survey instead of a dry-docking at the scheduled time.

Contact:  Dragos Rauta

Marine Safety data sheets for MARPOL Annex I cargoes and marine fuel oils

INTERTANKO, supported by OCIMF, Norway and ITOPF submitted a paper proposing to:

  • Develop guidelines on safety data sheets for MARPOL Annex I cargoes and marine fuel oils;
  • Prepare an MSC resolution urging States to ensure the supply and carriage of a MSDS for MARPOL Annex I cargoes and marine fuel oils; and
  • Add a new sub-section to SOLAS chapter VII and other appropriate instruments, to require safety data sheets for hazardous liquid substances, 

The outcome was as we sought and a standard form for MSDS together with the required MSC Resolution and the supporting guidelines to the MSDS format was agreed. The issue will be forwarded, as an urgent matter, for approval to MSC 77 due to meet late May this year.

As far as mandatory application of MSDS is concerned, although BLG 8 agreed the drafted justification for MSC 77, it also thought it necessary to first involve other competent organizations such as the WHO, ILO and other IMO sub-committees such as the STW Sub-Committee. So, rather than inviting MSC 77 to approve to expand the work under this item to include the development of mandatory requirements for MSDS for the carriage of MARPOL Annex I cargoes and marine fuel oils, BLG 8 decided to better wait the receipt of input from WHO, ILO and the STW Sub-Committee. They invited Governments to submit comments and proposals on the development of mandatory requirements for MSDS to BLG 9, next year.

Although INTERTANKO wished a more fast track implementation of the MSDS forms as mandatory requirements, we still believe this was a real progress. We may submit to MSC 77 a list of justifications on why MSDS should be a mandatory requirement.

Contact:  Dragos Rauta

Revisions of MARPOL Annex II

The target completion date for the revisions of MARPOL ANNEX II remains 2003 with an implementation date of 2007.  The main issue to be resolved centres around whether the pollution category system should be revised to a new 3-tier pollution system (X,Y,Z) or alternatively a new 5-tier pollution category system (A,B,C,D, plus of course an Appendix III). Currently no consensus has been reached, this remains to be resolved at the next meeting of MEPC in July later this year, (2003).

Text was developed at this session of BLG for the revision of MARPOL Annex II for both a 3 category and 5 category system , pending the final decision at MEPC in 2003.

This session of BLG 8 did not conclude on the decision to recommend which system (5 or 3 category), the main focus of BLG 8 and the ESPH working group was to conclude the work necessary to make definitive recommendations to MEPC 49 where the decisions will be made. So, although this final decision will be sent  to MEPC 49, some concerns were raised, by some delegations regarding the current lack of reception facilities for Animal fats and Veg oils, IMO however requested these delegations submit data to MEPC in this regard for further discussion at that session..

A large portion of work involved in the Annex II Revisions comprises a re-assessment by GHS/GESAMP for the safety and pollution aspects of each Noxious Liquid Substance within MARPOL and the IBC Code. As previously advised to members during earlier reports from BLG & MEPC, approximately 90 percent of products in the IBC Code have been evaluated in accordance with the Globally Harmonised System.  However, Vegetable oils make up most of the last substances to be re-evaluated. This information remains outstanding and a repeated specific call was made by IMO to the Veg oil industry to provide this information to GESAMP in order to allow them to complete their work.

In the BLG 8 report it was noted that the vegetable oil industry had still not provided the data requested. The Subcommittee strongly requested member states to use all means at their disposal to ensure that the data be submitted. 

INTERTANKO, along with other industry associations and various flag states remains committed to a revised 3-tier pollution category system, a revised stripping limitation to new buildings of 75 litres, (which should “NOT” be applied retrospectively to existing vessels). INTERTANKO and its Chemical Tanker Committee, believe that this will ensure that the revised MARPOL Annex II will be robust enough for the future to provide enhanced protection of the marine environment by regulating all noxious substances, whilst at the same time being easier to understand by those using the IBC Code, and easier to implement.

INTERTANKO will be working over the next few months to encourage the vegetable oil industry to submit the necessary information to complete the evaluation. 

Requests were made to industry  and flag states to submit papers to MEPC detailing the impact of both the new 3 category and new 5 category systems on the; -

  • Vegetable oil industry
  • Ships engaged in domestic trade.

Importantly, it is worthy of note that despite previous requests by IMO for such information this data, and data relating to the acute toxicity associated with Vegetable Oils and Fats has not been submitted.

BLG agreed for an intercessional meeting of ESPH ( Evaluation of Safety & Pollution Hazards), working group to meet later this year in September 2003.

Contact:  Howard Snaith  or Margaret Doyle