Report from IMO's Sub-committee on Bulk Liquids and Gases (BLG 15)

The IMO's Sub-committee on Bulk Liquids and Gases (BLG) met this week. INTERTANKO has been participating in the meeting. The following key issues were discussed under the evaluation of safety and pollution hazards (ESPH) of chemicals and preparation of consequential amendments. The ESPH working group met during the meeting and worked on the following issues:

Evaluation of Cleaning Additives

The group reviewed 110 new cleaning additives of which 86 products were approved. Of the products that were rejected, some were rejected for not having any information on their use as a cargo tank cleaner while others were rejected as they either contained Pollution Category X components, which were not readily biodegradable, or they were not intended for cleaning cargo tanks residues but instead were intended for pickling, passivating or removing rust from cargo tanks.

A full list of approved cleaning additives will be published along with the final report of the group and also as part of the MEPC.2/Circ.

Contact: Ajay Gour

The Application of requirements for the carriage of bio-fuels and bio-fuel blends

At its previous meeting, the group had prepared draft guidelines for the carriage and blending of biofuel/petroleum oil mixtures.

In finalising these guidelines, the group reviewed the proposal from Finland to include renewable diesel oils in the group of products identified as biofuels to be used in biofuel/petroleum oil blends.

The group noted that renewable diesel oils were principally referenced by their chemical name of “Alkanes (C10-C26), linear or branched” and agreed that biofuel blends of diesel or gas oil and Alkanes (C10-C26), linear and branched (with appropriate flashpoint specifications) should be incorporated into the proposed guidelines.

The group also noted that, if new biofuels are proposed for inclusion in the guidelines in future, this would necessitate a revised circular being issued following each approval. It was agreed by the group that a new annex for the MEPC.2/Circ should be developed which would record all biofuels approved for biofuel/petroleum oil blends to be covered by the guidelines. This could then be referenced in the guidelines to incorporate new biofuel materials.

The guidelines on the carriage of biofuels and biofuel blends will be proposed to the IMO's Marine Environment Protection Committee (MEPC) for approval and issue as an MEPC Circular and can be accessed here

Contact: Ajay Gour

Prohibition of blending onboard during the sea voyage

The group had, at its previous session, developed a draft regulation for SOLAS Chapter VI to prohibit the blending of bulk liquid cargoes during the sea voyage in line with the recommendations of MSC-MEPC.2/Circ.8.

This draft has been further refined and is proposed to the Maritime Safety Committee for inclusion in SOLAS.

The proposed text can be accessed here

Contact: Ajay Gour

Review of chapters 17 & 18 of the IBC Code

The group considered the options with regard to addressing the inconsistencies in carriage requirements noted for a number of entries in chapters 17 & 18 of the IBC Code.

It noted that currently the products listed in these chapters have been assessed using two approaches:

  • Existing products listed in the Code (pre 2004) were evaluated on the basis of pollution aspects of Annex II of MARPOL. In line with the decision of the MEPC, GESAMP Hazard Profile (GHP) safety criteria were not revisited.
  • New products listed after this time and any specific revisions arising for products in the IBC Code have been fully assessed utilising the complete GHP and the criteria referred to in chapter 21 of the IBC Code, which are based on the IN GHS criteria.

This has resulted in a “dual standard” and in reviewing this matter the group noted that approximately 18% of the products listed may be affected with a ratio of 2:1 for those requiring more stringent carriage requirements compared to those needing less stringent carriage requirements.

In discussing the issue the group noted that the following options were available to the group:

  • Undertake a full review of the carriage requirements using either (a) the current GHP ratings; or (b) updated GHP ratings.
  • Undertake a partial review of carriage requirement assignments based on nominated proposals identifying worst case anomalies.
  • Take no action but maintain the prevailing status which allows individual entries to be proposed for revision by Administrations on a case-by-case basis;
  • Revisit the criteria utilised in chapter 21 of the IBC Code particularly the “Ship-Type” and “Tank-Type” in terms of safety consideration as these are the most problematic areas giving rise to inconsistencies, and assess the validity of applying the existing acute toxicity requirements.

The group agreed that this was an important matter and that further deliberations were required. In doing so delegations were requested to reflect on this issue and provide feedback to the group for its next session.

Contact: Ajay Gour

Issues (Inert Gas) raised by the Fire Protection (FP) Sub-Committee

The Fire Protection (FP) Sub-committee had asked the BLG Sub-committee to comment on the proposed draft SOLAS amendments set out in the Annex to document FP 54/WP.2 and in particular requested the BLG to:

  • consider that the proposed draft SOLAS amendments may impact on chapters 9 & 11 of the IBC Code;
  • evaluate the impacts of applying inert gas to specific cargoes;
  • consider that column 'h' in chapter 17 of the IBC Code indicates which cargoes require inerting under that Code, and that this could cause potential confusion to seafarers, administrations and chemical tanker operators as the criteria for inerting provided in paragraph 21.4.8.1 of the Code are based on environmental considerations including a flashpoint of 23 deg C and are different from the criteria in the proposed draft SOLAS requirements.

In considering the above points and noting the proposed draft text contained in paragraph 16 of document FP 54/WP.2, the group agreed on the following points:

  • The proposed draft SOLAS amendments would not impact on chapter 9 of the IBC Code as the chapter provides definitions and general requirements if environmental controls are required. In chapter 11 the current wording will need to be amended based on the decision as to whether the proposed alternative draft text is to go into SOLAS or the IBC Code.
  • The specification of only nitrogen as an inerting medium is too restrictive and the selection and use of the inerting medium should be left to the shippers to decide.
  • It would be inappropriate to amend column 'h' tank environmental controls to incorporate any future SOLAS IG requirements since the IBC Code applies to all ships carrying chemicals in bulk regardless of their size or date of construction. Therefore the group agreed that this would need to be applied as a separate requirement.

Contact: Ajay Gour

Amendments to SOLAS to mandate enclosed space entry and rescue drills

The IMO's Maritime Safety Committee at its 87th session directed the BLG Sub-committee and the Sub-committee on Dangerous goods, Solid Cargoes and Containers (DSC) to review the proposed SOLAS amendment to mandate enclosed space entry and rescue drills.

It was noted that the objective of such drills is to ensure that seafarers who may be expected to, or decide to, enter enclosed spaces are familiarised with the precautions to be taken prior to entry, and to ensure that effective rescue strategies are available in the event of an accident.

It was also noted that the majority view of the DSC Sub-committee was that the issuance of guidance had not achieved the desired effect with regard to ensuring the proper knowledge, training and understanding of the dangers of entering enclosed spaces and, therefore, the only practical approach to reduce the number of fatalities was to have SOLAS mandated drills.

The view was that the SOLAS Convention was not the appropriate instrument to address this important issue, bearing in mind that such fatalities are a failure of the safety management system. It was proposed by some delegations at the DSC Sub-committee that this matter would be better addressed in the context of the STCW Convention and/or the ISM Code, as appropriate.

In reviewing this proposal the majority of the delegations at the BLG Sub-committee (BLG-15) spoke in favour of the proposed amendments to mandate enclosed space entry and rescue drills.

This will be brought to the attention of the next session of the Sub-committee on Dangerous Goods, Solid Cargoes and Containers (DSC 16).

Contact: Colin Jappy

 

BLG 15 - Revision of the recommendations for entering enclosed spaces aboard ships

A Drafting Group was formed and tasked to prepare draft Guidelines on tank entry for tankers using nitrogen as an inerting medium, and an associated draft MSC circular. The Group was also requested to propose consequential modifications, if appropriate, to section 10.4 of the draft Revised Recommendations for entering enclosed spaces aboard ships (DSC 15/18, Annex 6). The work completed by the Group would be for consideration by the Sub-committee for submission to MSC 89 for approval.

The Group considered the draft Guidelines on tank entry for tankers using nitrogen as an inerting medium, contained in document FP 54/17/1, as modified by document BLG 15/14/1, after an in-depth discussion, and having agreed to the modifications to the draft text, prepared the final text of the draft Guidelines.

Having finalised draft Guidelines on tank entry for tankers using nitrogen as an inerting medium, the Group prepared the consequential modification to section 10.4 of the draft Revised Recommendations for entering enclosed spaces aboard ships (DSC 15/18, Annex 6), by referencing the draft Guidelines as a footnote.

Click here to view the Report of the Drafting Group

These guidelines and the associated draft MSC Circular will be presented to the Maritime Safety Committee at its 89th session (May 2011) for their approval and issuance.

Contact: Colin Jappy