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Sunday, September 23, 2018

The Round Table of international maritime associations comments on: EU proposals to amend Annex I of MARPOL 73/78

The Round Table of international maritime associations [BIMCO, the International Chamber of Shipping (ICS), INTERTANKO and INTERCARGO] support and actively participate in many of the EU initiatives aimed at improving safety at sea.

The European Union Member States and the European Commission have suggested wide-ranging amendments to Annex I of MARPOL 73/78 to:

  • accelerate the current schedule of phasing out single-hulled tankers
  • expand the Condition Assessment Scheme (CAS) to all Category 2 and 3 oil tankers over 15 years of age
  • ban the transport of heavy grades of oil in single- hulled tankers 

The Round Table of international maritime associations [BIMCO, the International Chamber of Shipping (ICS), INTERTANKO and INTERCARGO]  support and actively participate in many of the EU initiatives aimed at improving safety at sea.  However the Round Table recognises the importance for the international shipping industry of adopting, implementing and enforcing international rules and regulations if they are to be effective, and the need to avoid unilateral and regional regulations, which create confusion and complications and are often counterproductive. The Round Table also believes that any new regulations should be subject to thorough analysis and impact study before introduction.  The Round Table  therefore welcomes the decision of  the European Union (EU) to  put its proposals before the International Maritime Organization (IMO), which is the appropriate international body for consideration of such issues, which provides the forum for discussion and debate of the implications, and which has the ability to fast-track revisions to Conventions when deemed necessary.

The Round Table does however note that it is only two years since the IMO, at the instigation of the European Union members, undertook in record time a revision of MARPOL, including the drawing up of an accelerated scheme for phasing out single hull tankers. The member countries of IMO  at that time prepared a well constructed timetable, taking into account society’s demand for oil, the capacity of shipyards and ship recycling yards, and the need to avoid a tonnage supply crisis.

The Round Table notes, and is particularly concerned, that there are ever more likely prospects that internationally agreed legislation may now be subject to major revision often without compelling reason for change. The shipping industry, and not least those who invest in it, require a degree of predictability and stability in the regulatory environment and the Round Table expresses concern that a lack of predictability may actually be detrimental to, rather than advance, the cause of improving maritime safety and the protection of the marine environment.

As regards the specific proposals, the Round Table:

  • observes that the EU proposed accelerated phase-out schedule of single hull tankers will in particular create an unprecedented ‘peak’ in withdrawals of Category 2  and Category 3 tankers in 2010, which has the potential to destabilise and distort  freight, shipbuilding and ship recycling markets. This would include the premature removal of a large number of young tankers, with many under twenty years of age, and some Category 3 tankers as young as seven years and some Category 2 tankers as young as 14 years.
  • supports the principles of the condition assessment scheme (CAS), and understands the desire to introduce enhanced survey and reporting schemes for oil tankers aged over 15 years. It however draws attention to the apparent inconsistency between this proposal and the EU’s proposed new phase-out scheme, which would dismiss a significant number of Category 2 and 3 oil tankers before they reach 15 years of age and many others before 20 years of age. The Round Table has also identified what it considers to be real problems in ensuring that all tankers over 15 years will be able to complete CAS compliance requirements by the earliest anticipated entry in to force date of a revision to Marpol, namely April 2005. It is additionally noted that CAS was originally developed for Category 1 and Category 2 tankers, and that extension of its application to Category 3 tankers will necessitate revisions to CAS to cater for the difference in size and type of these vessels.
  • supports the underlying idea of the EU proposal to restrict more pollutant products to carriage on vessels which present a lower risk of pollution in the event of an accident. It has, however, noted the concerns of others about:

-        the definition of ‘heavy crude oils’ not representing realistically the pollutant characteristics of these oils,

-        the impact of these proposals on certain oil trades, and

-        the short term availability of sufficient double hull tonnage with cargo heating availability in some size segments, as highlighted by the IMO Expert Group.

Link to INTERTANKO and BIMCO submission to MEPC 49.

For further information, please contact :

BIMCO
Peter Grube pg@bimco.dk
Tel : +45 44 36 6800 Fax : +45 44 36 6868

ICS
Simon Bennett Simon.bennett@marisec.org
Tel : +44 20 7417 2857 Fax : +44 20 7417 8877

INTERCARGO
Rob Lomas rob.lomas@intercargo.org
Tel : +44 20 7638 3989 Fax : +44 20 7638 3943

INTERTANKO
Sally Woulfe sally.woulfe@intertanko.com
Tel : +44 20 7623 4311 Fax : +44 20 7626 7078