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Sunday, July 22, 2018

FOLLOW UP ON IMO REGULATORY WORK FOR ACCELERATED PHASE-OUT OF SINGLE HULL TANKERS

INTERTANKO has received numerous telephone calls for further clarifications on the IMO development and many questions related to when a particular vessel may be phased-out.

Click here for a printable version of this article including tables and graphs.

Members should note that the table produced by IMO (copied below) is not final and contains a number of anomalies. For instance, according to the table, a PL/SBT tanker (Category 2) built in 1978 should be phased-out by 1 January 2004, two years earlier than a pre-MARPOL tanker (Cat. 1) built same year. One reason is that the MEPC 45 agreed that the cut-off age for a PL/SBT tanker should be 25 years, while the phase-out of pre-MARPOL ship is calculated as a function of tonnage supply. These anomalies are due to limited time for in depth assessment at the MEPC meeting.  However due regard will be given during the inter-sessional meeting to take place.

Table 1 proposed phase-out schedule

Category of oil tanker

Date by which ship shall comply with regulation 13F

Category 1

  • 1/01/2003 for ships delivered in 1973 or earlier
  • 1/01/2004 for ships delivered in 1974 & 1975
  • 1/01/2005 for ships delivered in 1976 & 1977
  • 1/01/2006 for ships delivered in 1978, 1979 & 1980
  • 1/01/2007 for ships delivered in 1981 or later

Category 2

  • 1/01/2003 for ships delivered in 1977 and earlier
  • 1/01/2004 for ships delivered in 1978
  • 1/01/2005 for ships delivered in 1979
  • 1/01/2006 for ships delivered in 1980
  • 1/01/2007 for ships delivered in 1981
  • 1/01/2008 for ships delivered in 1982
  • 1/01/2009 for ships delivered in 1983
  • 1/01/2010 for ships delivered in 1984
  • 1/01/2011 for ships delivered in 1985

Alternative A

Alternative B

·         1/01/2012 for ships delivered in 1986 & 1987

·         1/01/2013 for ships delivered in 1988 & 1989

·         1/01/2014 for ships delivered in 1990 and 1991

·         1/01/2015 for ships delivered in 1992 or later

·         1/01/2012 for ships delivered in 1986

·         1/01/2013 for ships delivered in 1987 & 1988

·         1/01/2014 for ships delivered in 1989 & 1990

·         1/01/2015 for ships delivered in 1991 & 1992

·         1/01/2016 for ships delivered in 1993 & 1994

·         1/01/2017 for ships delivered in 1995 & 1996

Category 3

  • 1/01/2003 for ships delivered in 1974 and earlier
  • 1/01/2004 for ships delivered in 1975 & 1976
  • 1/01/2005 for ships delivered in 1977 & 1978
  • 1/01/2006 for ships delivered in 1979 & 1980
  • 1/01/2007 for ships delivered in 1981
  • 1/01/2008 for ships delivered in 1982
  • 1/01/2009 for ships delivered in 1983
  • 1/01/2010 for ships delivered in 1984
  • 1/01/2011 for ships delivered in 1985
  • 1/01/2012 for ships delivered in 1986

Alternative A

Alternative B

·         1/01/2013 for ships delivered in 1987 & 1988

·         1/01/2014 for ships delivered in 1989, 1990 & 1991

·         1/01/2015 for ships delivered in 1992 or later

·         1/01/2013 for ships delivered in 1987

·         1/01/2014 for ships delivered in 1988

·         1/01/2015 for ships delivered in 1989 & 1990

·         1/01/2016 for ships delivered in 1991, 1992 & 1993

·         1/01/2017 for ships delivered in 1994 or later

 

A significant number of inquiries also related to the definition of MARPOL and pre-MARPOL tankers, which are:

MARPOL tanker is a ship with a design which is in compliance with the MARPPOL Convention requirements for Protective Located Segregated Ballast Tanks (PL/SBT). This means that all ballast tanks, ballast piping and ballast pumps are completely segregated from the cargo tanks, cargo piping system and the cargo pumps. Protective location, means that these ballast tanks are located either on the sides or on the bottom of the ship and thus providing protection against collision or grounding accidents. The size, location and arrangement of the PL/SBTs are governed by other requirements, all to be seen in the MARPOL AnnexI, Regulation 13E. (For that matter, Double hulls are also PL/SBT tankers but in the context of this rulemaking development, we consider only Single Hulls PL/SBT). The PL/SBT tankers were built between July 1982 (some even before that date) and June 1996. These tankers are Category 2 in this regulatory development.

pre-MARPOL are those tankers built before the regulations above mentioned were adopted. These tankers use some of the cargo tanks for ballast during the ballast voyage and thus generating the dirty ballast that needs to be delivered to a Reception Facility (in Special Areas) or at sea under controlled conditions. Majority of existing pre-MARPOL are built between 1974 and 1980, some until 1982. These tankers are Category 1 tankers in this regulatory development. However, there is a significant number of tankers initially built as pre-MARPOL but which have been upgraded and converted to PL/SBT design. These are thus considered as Category 2 tankers for this regulatory development.

The Condition Assessment Scheme (CAS) was also an area where more information was requested especially with respect to the application. Although this needs to be finally decided at the MEPC meeting in April 2001, the interpretation of the current text is outlined below:

A Category 1 tanker may be allowed to continue operation beyond [25 years after its date of delivery] or [2005] subject to compliance with CAS. Te two alternatives in square brackets indicate that IMO has to chose between the two alternatives presented. In case the former alternative is chosen, then in practice almost all pre-MARPOL tankers have to have a CSA by 1 January 2003, when these rules may take effect. In case the latter alternative is chosen, then only tankers that could trade beyond 2005 should go through a CSA. Another thought is whether CSA could be a tool to be used by the very date of the phase-out of a tanker and, if the ship passes the assessment, then there would be an extension beyond the limit suggested by the phase-out table.

A Category 2 tanker may be allowed to continue operation 2010 subject to compliance with CSA. The application if this extension of trade is made with the scope to prolonged the life of relative young Single Hulls PL/SBT tankers. The draft text for this category seems clear that it would apply to ships which are due to phase-out after 2010 and only those of a certain quality would be allowed to trade. However, there were questions on whether CAS could apply to the phase-out date of a ship (after 2010) in order to get some extra years for trade.

The INTERTANKO Secretariat has made some illustrations of the first assessment of the impact of the proposed phase-out as it stands now.

Graph 1  presents the deliveries through the 1990s, the order book for 2001 and 2002 and the tonnage to be phase-out as proposed by Alternative A of the draft proposal (Category 3 not included).

Graph 2 illustrates the phase-out Alternative A as per Category 1, 2 & 3 in Dwt. 

Graph 3illustrates the phase-out Alternative A as per Category 1, 2 & 3 in number of tankers. 

The numbers above do not include combination carriers or products/chemical tankers.

Further statistics are available, please contact mailto:jan.svenne@intertanko.com