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Saturday, January 20, 2018

CATEGORISATION OF PRODUCT TANKERS BETWEEN 20,000 DWT AND 29,000 DWT

As reported in our Weekly NEWS over the last few months, IMO has recently adopted new amendments to MARPOL Regulation 13G (the 2001 Amendments) which come into force in September 2002 and will be applicable from 1 January 2003.

According to the 2001 Amendments, single hull oil tankers are categorised in three categories, depending on a combination of deadweight size, cargoes carried, and whether a vessel satisfies the requirements of regulation 1(26) of Annex I of MARPOL (which describes requirements for Protective Location and for Segregated Ballast Tanks, i.e. PL/SBT).

For the cargo criterion, whereas initially MARPOL had made a distinction only between Crude Carriers and Product Tankers (dirty and clean), the cargo categorisation adopted in the 2001 Amendments is Clean Petroleum Products (CPP) and Dirty Petroleum Products (DPP, i.e. fuel oils, heavy diesel oils and lubricating oils). This distinction was first made in the 1999 Amendments to 13G as a result of the MT Nadhodka breaking up in Japan and causing serious pollution. IMO adopted Resolution MEPC.78(43) requiring that tankers between 20,000 and 29,999 dwt carrying DPP cargoes should be subject to 13G (i.e. at the age of 25 years to adopt SBT/PL or HBL). This amendment was supposed to come into force on 1 January 2003, but as the 2001 Amendments to 13G have re-written this regulation it is concluded that the 1999 Amendments will not come into force.

This background is given to clarify the categorization of single hull tankers between 20,000 dwt and 29,999 dwt when transporting DPPs. The definition of category 2 is as follows:

“Category 2 oil tanker” means an oil tanker of 20,000 tons deadweight and above carrying crude oil, fuel oil, heavy diesel oil or lubricating oil as cargo, and of 30,000 tons deadweight and above carrying oil other than the above, which complies with the requirements for new oil tankers as defined in regulation 1(26) of this Annex;”

This definition leads to a potential ambiguity in the interpretation of “compliance with 1(26)” for 20,000 to 29,999 dwt tankers carrying DPP.

A strict interpretation of this definition (which obviously will overrule the 1999 Amendments) is that a new product tanker (as defined by regulation 1(26)) between 20,000 dwt and 29,999 dwt carrying DPPs would not be subject to phase out under current 13G, but after 1 September 2002 would be phased-out as a Category 2 tanker. In this instance, such a tanker does not need to meet PL/SBT requirements under regulation 13E as she is less than 30,000 dwt, but is still a new 1(26) tanker and therefore a Category 2 oil tanker provided she does not continue to carry any crude oil. If she carries crude, then she is a Category 1 tanker. If she carries only CPP (oils other than crude and DPP) then she is a Category 3.

It is obvious that the "intent" of the 1999 Amendments might have been taken away by the 2001 Amendments and IMO might possibly have a second assessment of this particular aspect.

Whether a tanker is a Category 1 or Category 2 tanker when transporting DPP is evident for single hull tankers without PL/SBT that were built in 1982 and after. The phase-out table is available on our web site.

It should be noted that, to date, there are 49 single hull tankers of this size category which were built in or after 1982 and which are entered with INTERTANKO. The aggregate tonnage is 1.43 mill dwt. World-wide (including the INTERTANKO registered tankers) there are some 87 tankers of this category with an aggregate tonnage of some 2.5 mill. dwt.

Contact:

Dragos Rauta for further clarification dragos.rauta@intertanko.com

Please click here to link to the phase-out table: