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Thursday, September 20, 2018


One of the more contested elements in the European Commission's proposal for a revised PSC directive is the proposal to make tank inspections mandatory. At the Council meeting in Oslo recently it was decided that INTERTANKO should voice concern about this particular part of the proposal.

From various contacts with the Commission, INTERTANKO understands that the Commission regards this as an important element of the draft directive and that a proposal to dilute it is likely to be opposed.

Discussions with various Members of the European Parliament (MEPs) also indicate that this will be an uphill battle.  Nevertheless INTERTANKO has decided to work for it and this week a position paper was left with the "rapporteur" of the proposal, MEP Mark Watts, as well as with other influential MEPs of the Parliament's Transport Committee.  

Please find a copy of the text of the INTERTANKO Position below:

Position on the issue of mandatory inspections of ballast tanks in the new draft Directive 95/21 on Port State Control

INTERTANKO is a strong supporter of efficient Port State Control and is therefore in broad agreement with the proposed changes to Directive 95/21.

There is one point, however, where INTERTANKO would strongly advise that the draft directive ought to be changed.  This concerns the amended Annex V B of the Directive where the concept of mandatory tank inspections by port state control is being introduced.  INTERTANKO is of the opinion that this particular part of the proposal could be counterproductive and that it should therefore be deleted.  INTERTANKO also puts forward this proposal on the background that Port State Control resources in Member States are limited (both in terms of qualified personnel and money) and must therefore be prioritised towards the most cost efficient tasks.

Furthermore, the background for INTERTANKO’s proposal is as follows;

  1. PSC does not have qualified persons who know enough about steel, coatings and corrosion to be able to judge what they see.
  2. The opening of ballast tanks is prohibited by the Port Authority in many instances
  3. A tanker would have to move to a separate lay-by berth to perform such jobs. It is unclear who should pay for the shifting and for the time.
  4. Ballast tanks on chemical tankers are regularly purged with nitrogen and cannot be entered.
  5. Owners are responsible for continuously checking all tanks.  The Enhanced Survey Programme  (ESP) also has clear provisions after the first Special Survey (ship's age is 5 years). If the coating of ballast tanks is in a poor condition or the cargo tanks have a pitting density over 20%, these tanks are to be inspected on an annual basis.

INTERTANKO recommends that inspections of ballast tanks be left to Classification Societies, and that any external monitoring should be undertaken by the Classification Societies themselves.