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Saturday, October 20, 2018

Revision of Annex II of MARPOL 73/78

At the 5th Session of IMO’s Bulk Liquids and Gases Sub-Committee (BLG5) meeting 26-30 June, the schedule of the revision of Annex II of MARPOL 73/78 was discussed in the light of its work schedule to complete the revision by 2002.

Discussion of substantial amendments such as stripping limits, guidelines on categorization, the form of the Cargo Record Book, assessment of residue quantities in cargo tanks pumps and piping, prewash, procedures and ventilation procedures.

Broad Chemical descriptors in the IBC Code

It was agreed to make separate entries in the IBC Code when the carriage conditions for a chemical differ significantly, for example in molten or solution condition. Although some entries in the IBC Code are qualified as a molten or aqueous solution, some ships are only fit to carry the product as an aqueous solution.  Because the Certificate of Fitness lists the product as it appears in the IBC Code, this causes inconsistency.  Account should be taken of the maximum allowable temperature of a cargo that will not cause thermal stress.  As a result it was considered appropriate that future entries should be split in order to take account of the different carriage requirements of a product

Inerting compatible cargoes adjacent to tanks containing Propylene Oxide

It was proposed that there was a need for clarification on special requirements 15.8.18 of the IBC Code, in respect of whether inert gas should be required for the ullage space above compatible cargoes in tanks adjacent to those containing Propylene oxide.  Whilst recognizing the problem the committee was informed that no problems had been encountered with the present regulation, but that it is not clear whether or not there is a limit to the ullage space of the adjacent tank containing compatible cargo.  It was therefore agreed that it should be a requirement that adjacent tanks should be substantially full.

BLG5 agreed that loading of cargoes compatible with Propylene Oxide should be taken to mean that adjacent tanks are substantially full e.g. 80% or to the level which will ensure safety even if leakage of Propylene oxide should occur, and to identify this explanation in a footnote to special requirement 15.8.18 of the IBC Code.

Evaluation of New products

Rape seed oil fatty acid methyl ester

The committee noted that this was a new product which might eventually be included in the generic groupings being developed by the Vegetable and Animal Oils industry, but which meanwhile needs to be classified as a single entity.  This product had been evaluated and the resultant Hazard Profile indicates that the product should be pollution category Appendix III rather than the category D as proposed.  BLG5 was informed that the entry covers a wide range of Rape Seed fatty acid methyl esters and that the name should therefore be in the plural.  It was agreed that the product has no safety hazards and that Rape seed fatty acid methyl esters should be assigned to Chapter 18 of the IBC Code as Appendix III.

Polyalkyl (C10 – C18) methacrylate ethylene propylene-copolymer mixture

It was noted that the GESAMP EHS Group evaluated this product and assigned it to Chapter 18 of the IBC Code as Pollution Category D.

Pyrolysis gasoline

It had been noted that one of the components of Pyrolysis gasoline (Alkyl (C3 – C4) benzenes) had originally been assigned to pollution Category A due to a combination of the tainting potential and acute toxicity.  However, as MEPC had agreed that Tainting should not be used as a criterion for assigning Pollution Categories to new products, the group had anticipated that the highest Pollution Category for Pyrolysis gasoline may only be Category B.

In addition the group agreed that Pyrolysis gasoline should be used as the product name instead of Pygas. The carriage requirements can be obtained from INTERTANKO. It was agreed that the 2 entries for Pyrolysis gasoline in the Index of the IBC Code should be deleted.